WI0700012_Correspondence_20170921

1
W PotashCorp
Helping Nature Provide
September 21, 2017
Division of Water Resources — UIC Program
1636 Mail Service Center
Raleigh, North Carolina, 27699-1636
CERTIFIED MAIL
Subject: Permit Renewal Package
WI0700012
Beaufort County
PotashCorp - Aurora
RECEBVEDINCDEQIDWR
SEP 2 9 2017
Water Quality Regional
Operations Section
Please find the permit renewal package for Permit Number WI0700012. The package includes the
following:
• In -Situ Groundwater Remediation Application Rev. 8-28-2017
• Project Interim Evaluation
Please note that this system operates continuously. Quarterly monitoring reports are submitted to North
Carolina Department of Environmental Quality Inactive Hazardous Site Branch.
Please do not hesitate to contact me at [phone] if you have any questions regarding this
information.
Sincerely,
A9
D. Daniel Winstead III
Senior Environmental Engineer
PCS Phosphate
1530 NC Hwy 306 South, Aurora, NC USA 27806 T [phone]
PotashCorp. J www.potashcorp.com

pc: Will Hart—NCDEQ WaRO (w/ attachments)
12-07-00 (w/ attachments)
Two Copies
Division of Water Resources — UIC Program
1636 Mail Service Center
Raleigh, North Carolina, 27699-1636
H:\Tank Farm Remediation System\2017\Permit Renewal\Cover Letter.doc
2

Water Resources
Environmental Quality
October 9, 2017
Mark Johnson
PCS Phosphate Company Inc.
1530 NC Hwy 306S
Aurora, NC 27808
RE: Acknowledgement of Application No. WI0700012
PCS Phosphate Company Inc.
In Situ Groundwater Remediation Well System
Beaufort County
Dear Mr. Johnson:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
The Water Quality Regional Operations Section (WQROS) acknowledges receipt of your
permit application on September 29, 2017. Your application package has been assigned the number
listed above, and the primary reviewer is Shristi Shrestha.
Central and Washington Regional Office staff will perform a detailed review of the
provided application, and may contact you with a request for additional information. To ensure
maximum efficiency in processing permit applications, the Water Quality Regional Operations
Section (WQROS) requests your assistance in providing a timely and complete response to any
additional information requests.
Please note that processing standard review permit applications may take as long as 60 to
90 days after receipt of a complete application. If you have any questions, please contact Shristi
Shrestha at 919-807-6406 or [e-mail].
For Debra J. Watts, Supervisor
Animal Feeding Operations & Groundwater
Protection Branch
Division of Water Resources
cc: Washington Regional Office, WQROS
Permit File WI0700012
-^ Nothing Compares
State of North Carolina I Environmental Quality 1 Division of Water Resources
Water Quality Regional Operations Section
1636 Mail Service Center I Raleigh, North Carolina 27699-1636
919-707-9129

Shrestha, Shristi R
From: Hart, William
Sent: Tuesday, September 12, 2017 10:21 AM
To: Rogers, Michael; Shrestha, Shristi R
Cc: Danny Winstead; May, David
Subject: FW: PCS TFRAS Injection Well (WI0700012-PCS Tank Farm Remediation Plan)
Attachments: TFRAS Injection Well Permit.docx
Good morning, Michael/Shristi, could you help answer Mr. Winstead's questions?
Will Hart
Hydrogeologist
Division of Water Resources
Water Quality Regional Operations Section
Department of Environmental Quality
252 948 3968 office
wi I l i a m. h a rt(il n cd e n r. g ov
943 Washington Square Mall
Washington, North Carolina 27889
%Nothing Compares_
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Danny Winstead[mailto:[e-mail]]
Sent: Tuesday, September 12, 2017 9:40 AM
To: Hart, William <[e-mail]>
Subject: PCS TFRAS Injection Well
Will,
Attached is the letter I sent last time we renewed this permit. We switched from Lotus Notes to Outlook so I haven't
been able to look at the e-mails that were sent. My question is will a letter suffice or should I submit an application
and if an application is required which form. I tried going to the Injection Well Website but the phone number they
instruct you to call is a fax machine. I don't know if Thomas Slusser is still the guy his number is listed as 919-707-
8331. The renewal letter list Michael Rogers at 919-807-6406 the web has a Mike Rogers at 336-776-9685. Do you
know who in Raleigh I should call?
Danny

A7A
MENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor Director Secretary
September 17, 2012
D. Daniel Winstead, III — Environmental Engineer
PCS Phosphate Company, Inc.
1530 Hwy 306 South
Auroro, NC 27806
Subject: Acknowledgement of
Application No. WI0700012
PCS Phosphate Company, Inc.
Injection Other Wells System
Beaufort County
Dear Mr. Winstead:
The Aquifer Protection Section acknowledges receipt of your permit application and supporting
documentation received on September 7, 2012. Your application package has been assigned the number
listed above, and the primary reviewer is Michael Rogers.
Central and Washington Regional Office staff will perform a detailed review of the provided
application, and may contact you with a request for additional information. To ensure maximum
efficiency in processing permit applications, the Aquifer Protection Section requests your assistance in
providing a timely and complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt of a complete application. If you have any questions, please contact
Michael Rogers at [phone] or [e-mail].
Sincerely,
g&a
for De ra J. a
Groundwater Protection Unit Supervisor
cc: Washington Regional Office, Aquifer Protection Section
Permit File WI0700012
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Salisbury St, Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwaterauality.orq
An Equal Opportunity \Affirmative Action Employer
Not-thCarolina
aturallri

�Id
Michael F. Easley; Governor;
William G. Ross Ir., Secretary
North Carolina Department. of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
December 19, 2005
D. Daniel Winstead, III
PCS Phosphate
P.O. Box 48
Aurora, NC 27806
Subject: Address Changes For Submittal of Monitoring Data
Tank Farm Remedial Action System —
Injection Well Permit Number WI0700012
Beaufort County
Dear Mr. Winstead:
On July 1, 2004, the Groundwater Section became the Aquifer Protection Section as part of a reorganization of the
Division bf Water Quality. This reorganized section now includes the Groundwater Protection Unit, the Land Application
Permitting and Compliance Unit, and the Animal Feeding Operations Permitting and Compliance Unit.
The subject permit contains requirements for reporting data to specific Division addresses listed in the permits. A new
Information Processing Unit has been created within DWQ to process information and data submitted in response to
permit requirements. Due to the reorganization, you must now submit monitoring reports to a new address.
Beginning with your January sampling event, please submit two copies of all future monitoring reports (form GW-59,
Groundwater Quality Monitoring: Compliance Report Form, and related information) to:
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699
Attn: Information Management
Continue to submit all other correspondence, including letters, reports of system or well status, and permit renewal
applications, to the address at the bottom of this letter, as you have done previously.
If you have any questions concerning this correspondence, please contact me at [phone] or Thomas Slusser at
[phone].
Sincerely,
tA--
Evan O. Kane
Underground Injection Control Program Manager
cc: DWQ Information Management
file (2)
1V
_ Ane Caroina
/Vatting;
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http'J/h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycledr10% Post Consumer Paper

Michael F. Easley, Governor
4 —
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
October 6, 2004
Mr. D. Daniel Winstead III
PCS Phosphate Company
P.O. Box 48
Aurora, NC 27806
RE: Injection Well PermitWI0700012 / Tank Farm Remedial Action System
Dear Mr. Winstead:
Per our phone conversation this afternoon, the Division of Water Quality Underground Injection Control
Program understands that PCS Phosphate has decided to replace the filtration and UV disinfection
equipment in the subject injection well system and is therefore no longer pursuing amendment of the
subject permit to allow for disinfection with sodium hypochlorite. We also understand that after the new
equipment is received, the injection well system will be offline for several days while the new
equipment is installed. Once the new equipment is installed, please provide details of the new equipment
and of the system shutdown with your next quarterly report.
If you have any questions regarding this letter or your permit, please call me at [phone].
Sincerely,
Evan O. Kane, P.G.
Underground Injection Control Program Manager
cc: Analee Harris, Washington Regional Office
file
Nor Carolina
Natural/y
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer —50% Recycled/10% Post Consumer Paper

PCS
Phosphate
WI! AURORA
PCS PHOSPHATE COMPANY, INC.
P.O. BOX 48, AURORA, NC U.S.A. 27806
May 14, 2004
EVAN O. KANE
GROUND WATER
DENR
1636 MAIL SERVICE CENTER
RALEIGH, NC 27626-1636
CERTIFIED MAIL
Subject: Amendment of Injection Well Permit WI 0700012
Tank Farm Remedial Action System
Beaufort Co.
Dear Evan:
As discussed by phone on May 14, 2004, Part VIII Item 4. of the subject permit states "The injected water
shall consist of depressurization well (DPW) water treated with a multimedia anthracite/sand filter and an
ultraviolet light treatment tube system."
To allow the option to use either UV or sodium hypochlorite treatment, we request that Item 4 be revised to
read "The injected water shall consist of depressurization well (DPW) water treated with a
multimedia anthracite/sand filter and an ultraviolet light treatment tube system or DPW water
treated with sodium hypochlorite."
Enclosed are copies of trihalomethanes data of Castle Hayne source water treated with sodium
hypochlorite. This data is from potable wells located on the Aurora Site. The DPW water that supplies the
Tank Farm Remedial Action System should have similar results when treated with sodium hypochlorite.
Please do not hesitate to contact me at [phone] if you have any questions regarding this
information.
Sincerely,
AO CUVUtal
/ U
/6v.L1/1-71:—
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate

l
Attachments
pc: Willie Hardison — DWQ- GWS, WaRO
R. M. Smith/12-07-00
T. S. Ingra - Ardaman & Associates
W. A. Schimming
E-Mail: M. D. Johnson
J. H. Taylor / R. B. Lee
C:\MyData\Tank Farm Remediation System\Permit Revision Request.doc
l

EunwhQm]EI11 vin L Dec t ®& ©d
4:0-
PO. BOX 7085, 114 OAKMONT DRIVE
NV -
GREEILLE N C�27835 7Q85_. � ®_ '-
TTHM/HAAS - Disinfection Byproduct Analysis
WATER SYSTEM ID#: 0 4- 0 7- 5 5 8
County: BEAUFORT
Name of Water System: PCS PHOSPHATE CO. (CENTRAL MAIN.WELL
Sample Type: [x] Maximum Chlorine Residence
PHONE [phone]
"_FAX [phone]
[ ] Distribution [ ] Special/Non-compliance
Location Where Collected: PHOS. ACID MAINTENANCE (PCS)
Location Code: D08
Collected By: R.B. LEE
Mail Results to (water system representative):
PCS PHOSPHATE CO. (CENTRAL MAIN.WELL
P.O. BOX 48
AURORA,NC 27806
Collection Date Collection Time
07/15/03 12:08 PM
Phone#: [phone]
Fax#: [phone]
LABORATORY ID#: 3 7 7 1 5
I
[ ] SAMPLE UNSATISFACTORY
[ ] RESAMPLE REQUESTED
CONTAM
CODE
CONTAMINANT
METHOD
CODE
REQUIRED
REPORTING
LIMIT (R.R.L.)
NOT DETECTED
QUANTIFIED
RESULTS
ALLOWABLE
ABOVE R.R.L.
(X)
LIMITS
2941
Chloroform
217
0.001 mg/1
0.005 mg/1
0.100 mg/I
2942
Bromoform
217
0.001 mg/1
0.023 mg/1
0.100 mg/1
2943
Bromodichloromethane
217
0.001 mg/1
0.01 mg/1
0.100 mg/1
2944
Chlorodibromomethane
217
0.001 mg/I
0.016 mg/1
0.100 mg/I
2950
Total Trihalomethanes
217
0.001 mg/I
0.054 mg/I
0.100 mg/1
HAAS ANALYSIS
CONTAM
CODE
CONTAMINANT
METHOD
CODE
REQUIRED
REPORTING
LIMIT (R.R.L.)
NOT DETECTED
QUANTIFIED
RESULTS
ALLOWABLE
LIMITS
ABOVE R.R.L.
(X)
2450
Monochloroacetic Acid
253
0.002 mg/1
mg/1
0.060 mg/I
2451
Dichloroacetic Acid
253
0.001 mg/1
mg/1
0.060 mg/1
2452
Trichloroacetic Acid
253
0.001 mg/I
mg/1
0.060 mg/1
2453
Monobromoacetic Acid
253
0.001 mg/1
mg/1
0.060 mg/I
2454
Dibromoacetic Acid
253
0.001 mg/I
mg/1
0.060 mg/I
2456
Total Haloacetic Acids
253
0.002 mg/I
mg/1
0.060 mg/1
DATE:
TIME:
ANALYSES BEGUN:
07/15/03
3:00 PM
ANALYSES COMPLETED:
07/24/03
4:00 PM
Laboratory Log: 8313-071503-D08
COMMENTS:
Certified By: SEJ
8313
Laboratory'Analy-ses _ Environmental Consultants

P.O., BOX 7085, 114 OAKMONT. DRIVE
, GREENVILLE-N:C:,27835 7085 ..: ...___. _:
:PRONE(252) 756762081.
_FAX (252), 756 0633_ _,,.
TTHM/HAA5 - Disinfection Byproduct Analysis
WATER SYSTEM ID#: 04 - 0 7- 5 5 9
County: BEAUFORT
Name of Water System: PCS PHOSPHATE CO. , INC. (FEAT. /SPA )
Sample Type: [x] Maximum Chlorine Residence [ ] Distribution
Location Where Collected: I/E MAINTENANCE SHJOP
Location Code: E07
Collected By: R.B. LEE
Mail Results to (water system representative):
PCS PHOSPHATE CO., INC. (FEAT./SPA )
P.O. BOX 48
AURORA, NC 27806
[ ] Special/Non-compliance
Collection Date Collection Time
07/09/03 11:15 AM
Phone#: [phone]
Fax#: [phone]
LABORATORY ID#: 3 7 7 1 5
[ ] SAMPLE UNSATISFACTORY
[ ] RESAMPLE REQUESTED
+ _
CONTAM
CODE
W ` ✓
CONTAMINANT
METHOD
CODE
REQUIRED
REPORTING
LIMIT (R.R.L.)
NOT DETECTED
QUANTIFIED
RESULTS
ALLOWABLE
LIMITS
ABOVE R.R.L.
(X)
2941
Chloroform
217
0.001 mg/I
0.011 mg/1
0.100 mg/1
2942
Bromoform
217
0.001 mg/1
0.015 mg/1
0.100 mg/1
2943
Bromodichloromethane
217
0.001 mg/1
0.02 mg/I
0.100 mg/1
2944
Chlorodibromomethane
217
0.001 mg/I
0.031 mg/I
0.100 mg/I
2950
Total Trihalomethanes
217
0.001 mg/1
0.077 mg/I
0.100 mg/I
•+CONTAM
CODE
W
CONTAMINANT
METHOD
CODE
REQUIRED
REPORTING
LIMIT (R.R.L.)
NOT DETECTED
QUANTIFIED
RESULTS
ALLOWABLE
LIMITS
ABOVE R.R.L.
(X)
2450
Monochloroacetic Acid
253
0.002 mg/I
mg/1
0.060 mg/I
2451
Dichloroacetic Acid
253
0.001 mg/1
mg/I
0.060 mg/1
2452
Trichloroacetic Acid
253
0.001 mg/1
mg/1
0.060 mg/1
2453
Monobromoacetic Acid
253
0.001 mg/1
mg/1
0.060 mg/1
2454
Dibromoacetic Acid
253
0.001 mg/1
mg/1
0.060 mg/1
2456
Total Haloacetic Acids
253
0.002 mg/I
mg/1
0.060 mg/1
DATE:
TIME:
ANALYSES BEGUN:
07/09/03
3:00 PM
ANALYSES COMPLETED:
07/14/03
4:00 PM
Laboratory Log: 8316-070903-E07
COMMENTS:
Certified By: SEJ
8316 - :`' Laboratory Analyses EnvironmentalConsultants -.

kownnyEging Tli EtrpErg@cfl
•
P.O. 130 7085,114 OAKMONT DRIVE
GRFNVILLE, N.C. 27835:7085 -
TTHM/HAA5 - Disinfection Byproduct Analysis
WATER SYSTEM ID#: 0 4 - 07 - 592
County: BEAUFORT
Name of Water System: PCS PHOSPHATE CO, INC. (PURIFIED ACID
Sample Type: [X] Maximum Chlorine Residence
PHONE „(252) 78628205:i::
'FAX (252):788t0585
[ Distribution [ ] Special/Non-compliance
Location Where Collected: PURIFIED ACID LAB (PCS)
Location Code: GO4
Collected By: R . B. LEE III
Mail Results to (water system representative):
PCS PHOSPHATE CO, INC . (PURIFIED ACID
P . O. BOX 48
AURORA , NC 27806
Collection Date Collection Time
07/15/03 12:18 PM
Phone #: [phone]
Fax #: [phone]
LABORATORY ID#: 3 7 7 1 5
ANALYSIS
[ SAMPLE UNSATISFACTORY
[ ] RESAMPLE REQUESTED
CONTAM
CODE
CONTAMINANT
METHOD
CODE
REQUIRED
REPORTING
LIMIT (R.R.L.)
NOT DETECTED
QUANTIFIED
RESULTS
ALLOWABLE
LIMITS
ABOVE R.R.L.
(X)
2941
Chloroform
217
0.001 mg/I
0 . 0 0 4 mg/1
0.100 mg/1
2942
Bromoform
217
0.001 mg/I
X
mg/1
0.100 mg/1
2943
Bromodiehloromethane
217
0.001 mgfl
0.005 mg/1
0.100 mg/1
2944
Chlorodibromomethane
217
0.001 mg/1
0 . 0 o3 mg/1
0.100 mg/1
2950
Total Trihalomethanes
217
0.001 mg/1
0.012 mg/1
0.100 mg/I
HAAS ANALYSIS
CONTAM
CODE
CONTAMINANT
METHOD
CODE
REQUIRED
REPORTING
LIMIT (R.R.L.)
NOT DETECTED
QUANTIFIED
RESULTS
ALLOWABLE
LIMITS
ABOVE R.R.L.
(X)
2450
Monochloroacetic Acid
253
0.002 mg/I
mg/1
0.060 mg/I
2451
Dichloroacetic Acid
253
0.001 mg/1
mg/1
0.060 mg/1
2452
Trichloroacetic Acid
253
0.001 mg/I
mg/1
0.060 mg/1
2453
Monobromoacetic Acid
253
0.001 mg/I
mg/1
0.060 mg/I
2454
Dibromoacetic Acid
253
0.001 mg/1
mg/I
0.060 mg/I
2456
Total Haloacetic Acids
253
0.002 mg/I
mg/1
0.060 mg/1
DATE:
TIME:
ANALYSES BEGUN:
0 7 /15
/ 0
3
3:00
PM
ANALYSES COMPLETED:
07/23
/ 0
3
4:00
PM
LaboratoryLog: 8076-071503 -G04
COMMENTS:
Certified By: SEJ
8076
Laboratory Analyses Environmental Consultants

Michael F. Easley, Governor,
William G. Ross Jr., Secretary
North Caroling aartment of Environment and Natural Resources•
Alan W. Klimek, P.E. Director
Division of Water Quality
March 19, 2003
Mr. Daniel Winstead
PCS Phosphate
P.O. Box 48
Aurora, NC 27806
RE: Amendment of Injection Well Permit WI0700012
Dear Mr. Winstead:
In accordance with our phone conversations on March 13 and March 18, 2003, we are amending.
Permit number WI0700012. This permit is for the injection of potable water to control the
migration of contaminated groundwater at the Tank Farm site at PCS Phosphate's plant in
Aurora, NC. This amended permit corrects a mistake in the monitoring schedule that was
included in the permit issued on December 19, 2002. Specifically, the monitoring schedule in
Part V, Section B, paragraph 1, has been changed to require sampling for several parameters
from CIW7 and MWTF-1CR in April and October, rather than January and October. Please note
that the quarterly sampling schedule for total coliform organisms is unchanged.
This permit replaces the permit issued on December 19, 2002. The permit shall be effective
from the date of issuance until January 15, 2008, and shall be subject to the conditions and
limitations stated therein. Please read the entire permit to ensure that you are aware of all
compliance requirements of the permit. In order to continue uninterrupted legal use of the
injection facility for the stated purpose, you should submit an application to renew the permit •
three months prior to its expiration date.
If you have any questions regarding your permit please feel free to contact me at [phone].
cc: Washington Regional Office
CO-UIC files
Enclosure
Sincerely,
o
Evan O. Kane, L.G.
Program Manager
Underground Injection Control
N DENAR
N. C. Division of Water Quality
1617 Mail Service Center Raleigh, NC 27699-1617
[phone] Customer Service
1 800 623-7748

Michael F. Easley
Governor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
DIVISION OF WATER QUALITY
Groundwater Section
February 13, 2003
Mr. D. Daniel Winstead III
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, North Carolnia 27806
RE: Groundwater Sampling Frequency Request Addendum
Tank Farm Remedial Action System
Aurora, Beaufort County, North Carolina
Groundwater Incident Number - 3663
Dear Mr. Winstead:
The Washington Regional Office received your request to ammend the approval to nduee
the sampling frequency. Based on a file review, the following wells are approved for semi-annual
sampling:
**CWW-1 through CWW-7 **SWW-1 through SWW-7
**MWTF1A **MWTF1B
* *WLCT
Please note, wells CIW7 and MWTF 1 CR are regulated by injection well permit
WI0700012. This letter supersedes the letter dated February 5, 2003, from this office. These
wells should be sampled as stipulated within Part V, Section B of the permit. We appreciate
your cooperation along with your effort to protect the state's groundwater resources. Should you
have any questions regarding this matter, please don't hesitate to call Michelle Volosin at 252-
946-6481, extension 354.
Sincerely,
Willie Hardison
Groundwater Supervisor
Washington Regional Office
cc: Evan O. Kane- UIC Group
WaRO
V
Customer Service
1 800 623-7748
Division of Water Quality ! Groundwater Section
943 Washington Square Mall Washington, NC 27889
Phone: [phone] Fax: [phone] Internet: http://www.gw.ehnr.state.nc.us

PCS
Phosphate
AURORA
PCS PHOSPHATE COMPANY, INC.
P.O. BOX 48, AURORA, NC U.S.A. 27806
February 12, 2003
WILLIE HARDISON
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
DENR
943 WASHINGTON SQUARE MALL
WASHINGTON, N. C. 27889-3314
Re: Tank Farm Remedial Action System
PCS Phosphate Inc. - Beaufort County
Dear Willie,
In the January 30, 2003 memo requesting reduction in sampling from quarterly to twice
per year, I failed to clearly identify each well we currently sample. To date the followiii
information has been supplied to your office quarterly to monitor the system. rri
w , rn
W ..2G
--41
Q C.7
nC r"
Q r
1. Water Quality Data on the wells / sample locations listed below:
• CIW7
• MWTF1CR
• Fourteen withdrawal wells:
CWW-1 through CWW-7
SWW-1 through SWW-7
• MWTF1A
• MWTF1B
• WLCT
2. Piezometer level monitoring field sheet
3. Summary operational and maintenance report.
The injection well permit issued December 19, 2002 requires that MWTF-1CR and
CIW7 be sampled quarterly for Coliform and twice per year for TDS, TOC, Chloride,
Fluoride, pH, Cadmium, Chromium, Manganese, Sulfate and Total Phosphate.
The Piezometer level monitoring field sheet as well as the summary operational and
maintenance report will continue to be supplied quarterly.
r �!
C:\MyData\State Correspondence12003\b_February\TFRAS Reduction of -Sampling Request.doc

In addition to the changes noted, we propose reducing monitoring from quarterly to twice
per year on fourteen wells CWW-1 through CWW-7 and SWW-1 through SWW-7.
Additionally sampling on the WLCT, MWTF1A and MWTF1B would be discontinued.
Sorry for not specifically identifying all items in which a reduction in sampling was
requested in the original memo.
Please do not hesitate to call me at 252-322-8283 should you have any questions
concerning this.
Sincerely,
ID
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate
Attachment
pc:
E. O. Kane — Program Manager
Underground Injection Control
N. C. Division of Water Quality
1617 Mail Service Center
Raleigh, N. C. 27699-1617
T. L. Baker / 12-07-00
W. A. Schimming
J. A. Hardy
(w/ attachment)
(w/ attachment)
(w/ attachment)
C:1MyData\State Correspondence\2003\b_February\TFRAS Reduction of Sampling Request.doc

Michael F. Easley
Govemor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Ara
DIVISION OF WATER QUALITY
Groundwater Section
February 5, 2003
Mr. D. Daniel Winstead III
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, North Carolnia 27806
RE: Groundwater Sampling Frequency Request
Tank Farm Remedial Action System
Aurora, Beaufort County, North Carolina
Groundwater Incident Number - 3663
Dear Mr. Winstead:
The Washington Regional Office received your request to reduce the sampling frequency
of CWW-lthrough CWW-7 for the above referenced incident from quarterly to semi-annual.
Based on a file review, this office hereby grants your request.
Please note, "No Further Action" status cannot be granted until four consecutive quarterly
monitoring events reveal contaminant levels below the groundwater standards listed in Title 15A
North Carolina Administrative Code, Subchapter 2L (15A NCAC 2L).
We appreciate your cooperation along with your effort to protect the state's groundwater
resources. Should you have any questions regarding this matter, please don't hesitate to call
Michelle Volosin-at 252-946-6481, extension 354.
Sincerely,
Willie Hardison
Groundwater Supervisor
Washington Regional Office
cc: Evan O. Kane- UIC Group
WaRO
Customer Service Division of Water Quality / Groundwater Section
1 800 623-7748 943 Washington Square Mall Washington, NC 27889
Phone: [phone] Fax: [phone] Internet: http://www.gw.ehnr.state.nc.us

Michael F. Easley
Governor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
DIVISION OF WATER QUALITY
Groundwater Section
February 5, 2003
Mr. D. Daniel Winstead III
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, North Carolnia 27806
RE: Groundwater Sampling Frequency Request
Tank Farm Remedial Action System
Aurora, Beaufort County, North Carolina
Groundwater Incident Number - 3663
Dear Mr. Winstead:
L�l :Z Wd L- 83J CO
The Washington Regional Office received your request to reduce the sampling frequency
of CWW-lthrough CWW-7 for the above referenced incident from quarterly to semi-annual.
Based on a file review, this office hereby grants your request.
Please note, "No Further Action" status cannot be granted until four consecutive quarterly
monitoring events reveal contaminant levels below the groundwater standards listed in Title 15A
North Carolina Administrative Code, Subchapter 2L (15A NCAC 2L).
We appreciate your cooperation along with your effort to protect the state's groundwater
resources. Should you have any questions regarding this matter, please don't hesitate to call
Michelle Volosin at 252-946-6481, extension 354.
Sincerely,
Willie Hardison
Groundwater Supervisor
Washington Regional Office
cc: Evan O. Kane- UIC Group
WaRO
:ustomer Service Division of Water Quality / Groundwater Section
1 800 623-7748 943 Washington Square Mall Washington, NC 27889
Phone: [phone] Fax: [phone] Internet: httpi/www.gw,ihnr.atate.nc.us

1
PCS
Phosphatke AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
January 30, 2003
WILLIE HARDISON
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
DENR
943 WASHINGTON SQUARE MALL
WASHINGTON, N. C. 27889-3314
Re: Tank Farm Remedial Action System
PCS Phosphate Inc. - Beaufort County
Dear Willie,
CA)
W
rn
On December 19, 2002 PCS Phosphate received a reissued construction and operation
permit WI0700012 for the injection wells associated with the Tank Farm Remedial
Action System. In preparation for submitting the renewal application A & A
Engineering, Inc. the North Carolina Division of Ardaman & Associates, Inc. was
contracted to review the performance of the system. Enclosed is a copy of the findings of
this review.
The report confirms that the system is operating as designed and should produce the
desired results in the confined sands layer in 10 years. The Croatan Formation
remediation will be complete in 10 to 15 years. A & A Engineering, Inc. recommends a
reduction of groundwater quality sampling from quarterly to twice per year. By copy of
this memo, PCS Phosphate is requesting this recommended reduction of groundwater
sampling. I am available to review with your office the raw data collected to date which
A & A Engineering, Inc. used to generate this system review.
Please do not hesitate to call me at 252-322-8283 should you have any questions
concerning this.
Sincerely,
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate
C:\MyData\State Correspondence\20031.1anuary\TFRAS Reduction of Sampling Request.doc

Attachment
pc:
E. O. Kane — Program Manager
Underground Injection Control
N. C. Division of Water Quality
1617 Mail Service Center
Raleigh, N. C. 27699-1617
T. L. Baker / 12-07-00 (w/ attachment)
E-mail W. A. Schimming
J. A. Hardy
C:\MyData\State Correspondence \2003Uanuary\TFRAS Reduction of Sampling Request.doc

Michael F. Easley, Governor
William G. Ross Jr., Secretary,
North Carolird _ „,,artment of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
-c
December 19, 2002
Mr. Daniel Winstead
PCS Phosphate
P.O. Box 48
Aurora, NC 27806
RE: Re -issuance of Injection Well Permit WI0700012
Dear Mr. Winstead:
In accordance with the renewal application submitted on April 3, 2001, we are forwarding Permit
No. WI0700012. This permit is for the injection of potable water to control the migration of
contaminated groundwater at the Tank Farm site at PCS Phosphate's plant in Aurora, NC.
This permit shall be effective from the date of issuance until January 15, 2008, and shall be
subject to the conditions and limitations stated therein. Please read the entire permit to ensure
that you are aware of all compliance requirements of the permit. In order to continue
uninterrupted legal use of the injection facility for the stated purpose, you should submit an
application to renew the permit three months prior to. its expiration date.
If you have any questions regarding your permit please feel free to contact me at [phone].
Sincerely,
Evan O. Kane, L.G.
Program Manager
Underground Injection Control
cc: Washington Regional Office
CO-UIC files
Enclosure
VA
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

PCS
Phosphate AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
October 8, 2002
WILLIE HARDISON
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
DENR
943 WASHINGTON SQUARE MALL
WASHINGTON, N. C. 27889-3314
Re: Renewal Application for Injection Well Point
WI0700012
PCS Phosphate Inc. - Beaufort County
Dear Willie,
Evan O. Kane, Program Manager, Underground Injection Control requested you be
provided a copy of the enclosed report produced by A & A Engineering, Inc. concerning
the Tank Farm Remedial Action System.
Please do not hesitate to call me at 252-322-8283 should you have any questions
concerning this.
Sincerely,
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate
Attachment
ire
pc: T. L. Baker / 12-06-001-02 (w/o attachment)
E. O. Kane (w/o attachment)
E-mail W. A. Schimming
C:\MyData\State Correspondence \2002\j_October\TFRAS 10-8-02.doc
ry

' #
_
0

PCS
Phosphate AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
October 4, 2002
CERTIFIED MAIL
Evan O. Kane
Program Manager
Underground Injection Control
Groundwater Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, N. C. 27699-1636
Re: Application for Renewal Permit No. WI0700012
PCS Phosphate Inc. - Beaufort County
Dear Mr. Kane:
Enclosed is a report generated by Ardaman and Associates addressing concerns that
developed as a result of the renewal process for Permit No.WI0700012. The report
outlines the history and performance of the system and should eliminate any concerns
your office has concerning contamination migration resulting from the injection well
system.
Please do not hesitate to call me at 252-322-8283 should you have any questions
concerning this.
Sincerely,
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate
C:\MyData\State Correspondence\2002\j_October\TFRAS Reply 10-4-02.doc

pc: File 12-07-00
T. L. Baker
W. A. Schimming
W. T. Cooper
W. K. Thornton
(w/o attachment)
(w/o attachment)
(w/o attachment)
(w/o attachment)
C:\MyData\State Correspondence \2002\j_October\TFRAS Reply 10-4-02.doc

Michael F. Easley, Governor
William G. Ross Jr., Secretary;::;
North llina Department of Environment and Natural Resourcest..
y
r Gregory J. Thorpe—Rh.n., -_-;
, i Acting Director
-C Division of Water Quality
GROUNDWATER SECTION
February 19, 2002
Mr. Daniel Winstead
PCS Phosphate
P.O. Box 48
Aurora, North Carolina 27806
RE: Renewal application for Injection Well Permit WI0700012
Dear Mr. Winstead:
In the process of reviewing your application for renewal of the subject permit, we have developed some
concerns about the injection well system you are operating. In order for us to perform a complete review and
approve your permit application, we will need additional information from you regarding the injection well
system.
Our first concern is that the injection well system may be causing contamination to migrate into previously
uncontaminated portions of the Croatan Formation or other aquifers. A review of information submitted to the
Groundwater Section by PCS and its predecessor, TexasGulf, shows that the full extent of contamination and
the hydraulic impact of the injection and extraction system have never been delineated. In order to determine
whether or not the injection system is compromising other portions of the Croatan Formation or other aquifers,
please provide the following information:
• Horizontal and vertical extent of dissolved solids and sulfate contamination (including overlying
aquifers) to below 2L standards
• Potentiometric surface maps of the Croatan formation showing the full extent of altered groundwater
heads caused by the injection and extraction system.
Second, we are concerned that the injection -extraction system is not achieving the predicted remediation goals.
The Remedial Action Plan submitted in 1989 for this system estimated a clean-up time of 20 years: A review of
extraction well sample results submitted to the Groundwater Section since system start-up in 1991 does not
show any consistent decreases in the level of contamination in the Croatan Formation. In order to clarify the
purpose and effectiveness of this system, please provide an assessment of the current effectiveness of the
system and re -assessment of the length of time required to achieve clean-up of groundwater in the Croatan
Formation.
FA
N. C. Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 [phone]
Groundwater Section
Customer Service
1 800 623-7748

Page 2
Mr. Danny Winstead, PCS Pho lte
We look forward to receiving your response so that we may perform a proper review of your permit application.
If you have any questions regarding this request please contact me at [phone] or [e-mail].
Sincerely,
Evan O. Kane
Program Manager
Underground Injection Control
cc: Willie Hardison, Washington Regional Office
UIC-CO files
N. C. Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 [phone]
Groundwater Section 1 800 623-7748
Customer Service

Michael F. Easley
/ Governor
I i 11 I r �1 r Williams G. Ross Jr., Secretary
—1 Department of Environment and Natural Resources
-c
Kerr T. Stevens
Division of Water Quality
April 11, 2001
Daniel Winstead III, Environmental Engineer
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Winstead:
Your application for a permit to use injection wells for a tank farm remedial action
system at1539 Highway 306 South in Aurora, North Carolina has been received and is -
currently under review. A member of the Groundwater Section's Washington Regional Office
staff may be contacting you to arrange an inspection of the injection well site as part of the
review.
If you have any questions regarding the permit or injection well rules please contact me
at [phone] or Meliktu Fanuel at [phone].
cc: CO-UIC Files
WARO-UIC Files
AA
t4LDENR
Customer Service
1 800 623-7748
Sincerely,
0.12
Mark Pritzl
Hydrogeological Technician II
Underground Injection Control Program
Division of Water Quality / Groundwater Section
1636 Mail Service Center Raleigh, NC 27699-1636
Phone: [phone] Fax: [phone] Internet: http://gw.ehnr.state.nc.us

PCS
Phosphatee AURORA
PCS PHOSPHATE COMPANY, INC.
P.O. BOX 48, AURORA, NC U.S.A. 27806
March 30, 2001
CERTIFIED MAIL
Mark Pritzl
UIC Program
Groundwater Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, N. C. 27699-1636
Re: Application for Renewal Permit No. WI0700012
PCS Phosphate Inc. - Beaufort County
Dear Mark:
Enclosed are two copies of the application package for the renewal of Permit
No. WI0700012.
Please do not hesitate to call me at 252-322-8283 should you have any questions
concerning this.
Sincerely,
ta„„Aa
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate
pc: File 12-01-008-03-002
T. L. Baker
W. A. Schimming
W. T. Cooper
W. K. Thornton
00-24-000
(w/o attachment)
(w/o attachment)
(w/o attachment)
(w/o attachment)
(w/o attachment)
CD

State of North Carolina. Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Leon Montgomery
Environmental Engineer
PCS Phosphate
PO Box 48
Aurora, NC 27806
0 IS l-I N Ft
September 24, 1997
Dear Mr. Montgomery:
In accordance with the requested permit revisions submitted on your behalf by Jeff Welti of
DEHNR's Washington Regional Office, dated September 17, 1997, we are forwarding Permit
No. WI0700012. This permit is a revision of the permit originally issued on September 30, 1996.
This permit shall be effective from the date of issuance until September 30, 2001, and shall be
subject to the conditions and limitations stated therein. In order to continue uninterrupted legal
use of this well for the stated purpose, you should submit an application to renew the permit six
months prior to its expiration date.
If you have any questions regarding your permit please contact me at (919) 715-6.166 or Amy
Axon at [phone].
Sincerely,
Marcus Geist
Underground Injection Control Program
cc: UIC Files
WARO Files
Enclosures
Groundwater Section
P.O. Box 29578, Raleigh, North Carolina 27626-0578
2728 Capital Blvd., Raleigh, North Carolina 27604
Voice 919/733-3221 FAX [phone]
An Equal Opportunity/Affirmative Action Employer
50% recycled/ 10% post -consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
September 17, 1996
Attn: Mr. Leon Montgomery
Environmental Affairs
PCS Phosphate, Inc.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Montgomery:
In accordance with your application dated May 8, 1996 and additional information regarding
startup of the ASF/UV treatment system, received August 28, 1996, we are forwarding Permit No.
WI0700012 for the operation of an injection well system, for the purpose of groundwater
remediation, in Beaufort County.
This permit shall be effective from the date of issuance until September 30, 2001, and shall be
subject to the conditions and limitations stated therein.
If any parts, requirements, or limitations contained in this permit are unacceptable to you, you
have the right to request an adjudicatory hearing upon request within 30 days following receipt of
this permit. This requestmust be in the form of a written petition, conforming to Chapter 150B of
N.C.G.S., and must be filed with the Office of Administrative Hearings, P.O. Drawer 27447, Raleigh,
NC 27611-7447. Unless such demands are made, this permit shall be final and binding.
If you have any questions regarding your permit please feel free to contact me at
(919) 715 - 6165.
cc: UIC Files
WaRO Files
Enclosures
Groundwater Section,
P.O. Box 29578, Raleigh, North Carolina 27626-0578
2728 Capital Blvd., Raleigh, North Carolina 27604
Sincerely,
Pal
Mark R. Milligan
Underground Injection Control Program
NesC
Reduce Reuss Recycle
mrm-clof ce.!xpdocs/5x25pemt/pcsyhos.lm
Voice 919-733-3221 FAX [phone]
An Equal Opportunity/Affirmative Action Employer
50% recycles/10% post -consumer paper

PCS'
Phosphate
AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
August 28,1996
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29578
Raleigh, North Carolina 27626-0578
Attn: Mark Milligan
Subject: Tank Farm Remedial Action System ASF/UV Treatment System Startup
Injection Well Permit #WI07 0u0012
Dear Mark:
Per Specific Condition 7(c) of the above permit, please note that the Aurora Division of the PCS
Phosphate Co., Inc., brought the ASF/UV treatment system on line on Friday, August 23rd,1996, at
1600 hrs (4 pm). The system is functioning properly without interruption.
Please contact me at [phone] if you have any questions regarding this information.
Sincerely,
L. M. Montgomery
Environmental Engineer
lx:
Willie Hardison - DEM, WaRO
W. A. Schimming, Raleigh
S. R. Phillips / 00-19-000
T. L. Baker/T. W. Davis
M. L. Asby / J. A. Hardy
15-03-W3-02
12-01-008-03-002

PCS'
Phosphate
AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
May 8, 1996
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29578
Raleigh, North Carolina 27626-0578
Attn: Mark Milligan
Subject: Renewal Application
Injection Well Permit #WI0700012
PCS Phosphate Tank Farm Remedial Action System
Dear Mark:
•
Please find the enclosed Renewal Application for the subject system. As support information to the
renewal application, I have enclosed a copy of the original application dated November 1, 1991, the
information submitted by PCS Phosphate to obtain a permit modification allowing the use of another
source of supply water to the system, and an updated drawing of the buildings, tanks equipment, etc.
in the injection well / remediation system area.
The original permit was modified January 26, 1996 to reflect a change in the Company name and
included modifications which allow for the use of a different source of injectate supply water.
If there is need for additional support information please contact me @ [phone] or Leon
Montgomery @ [phone].
Sincerely,
S. R. Phillips
Environmental Affairs
SRP:TFW/rc
Attachments
cc: Willie Hardison, DIY, WaRO (w/attacrments)

Sta
De
HDiv'
f North Carolina
ment of Environment,
and Natural Resources
of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., PRE., Director
Mr. Timothy F. Walls
Environmental Affairs
PCS Phosphate, Inc.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Walls:
•
GROUNDWATER SECTION
March 14, 1996
AWA
EHNR
Our records show that the operating permit for the injection wells of the Tank Farm
Remediation System will expire on December 5, 1996. In order to comply with the regulatory
requirements for permitted injection facilities (15 NCAC 2C .0211), it is imperative that you
submit the enclosed Application for Permit to Construct and/or Use a Well for Injection (form
GW-57N). The application should be forwarded to us by July 5, 1996.
If you have any questions regarding your Permit please feel free to contact me at (919)
715-6165.
Sincerely,
ark Milligan G
Manager
Underground Injection Control Program
cc: UIC Files
Enclosures
mrm-c:office \wpdaabamib‘rmemmut.p s
Groundwater Section
P.O. Box 29,578, Raleigh, North Carolina 27626-0578
2728 Capital Blvd., Raleigh, North Carolina 27604
WIC
KeeIuce KeuSC Recycle
Voice 9.19-733-3221 FAX [phone]
An Equal Opportunity Affirmative Acflon Employer
50% recycled/10% post -consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
GROUNDWATER SECTION
January 26, 1996
Mr. Timothy F. Walls
Environmental Affairs
PCS Phosphate, Inc.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Walls:
-. REQUEST
/
y s�
to Iln.filul
Attime
In response to your request dated December 13, 1995 (copy attached) for a change in the
water supply and allowable Total Dissolved Solids (TDS) concentrations, Total Organic Carbon
(TOC) concentrations, and pH range of the injected water we have reviewed the information you
submitted. Our evaluation of that data supports your request. Thus, we are amending Permit No.
WI0700012, which is for the operation of an injection well system, at your Aurora, NC facility in
Beaufort County. Please note that the only changes to the referenced permit, issued December 5,
1991, are as follows:
1. Specific condition 1 has been changed to include the Groundwater Sections Central Office
new address.
2. Specific condition 2 has been modified as follows: The maximum allowable Total Dissolved
Solids (TDS) concentration of the injected water has been increased from 475 mg/1 to 500
mg/1. The allowable pH range of the injected fluid has been expanded from 6.0 - 7.0 to 6.5 -
8.5. The maximum allowable Total Organic Carbon (TOC) concentration of the injected
water has been increased from 4.3 mg/1 to 10 mg/1.
3. Specific condition 6 has been added as follows: The injected fluid shall consist of
depressurization well (DPW) water treated with a multi -media anthracite/sand filter (ASF)
and an ultraviolet (UV) light treatment tube system. The treated DPW water may be diluted
with steam condensate as needed to comply with the regulatory limits established in Specific
Condition 2.
4. Specific condition 7 has been added as follows! The Pemuttee may continue use of the
current injection well water supply system until the new ASF/UV treatment system is put into
operation, with the following stipulations:
a. Condensate shall be generated, when operationally feasible, to dilute the well water
supply to comply with the quality limits established in Specific Condition 2 until the
ASF/UV treatment system is in operation.
b. The installation, start-up, and operation of the ASF/UV treatment system for DPW water
will be completed within seven months of the date of this permit.
c. The permittee must submit notification to the address indicated in Specific Condition 1 of
start-up of the ASF/UV treatment system for DPW water.
Groundwater Section
P.O. Box 29578, Raleigh, North Carolina 27626-0578
2728 Capital Blvd., Raleigh, North Carolina 27604
Nt... Voice 919-733-3221 FAX [phone]
1./ C An Equal Opportunity Affirmative Action Employer
50% recycled/10% post -consumer paper
Krducr Kau
cycle

This permit shall be effective from the date of issuance until December 5, 1996, and shall be
subject to the conditions and limitations stated therein.
In order to continue uninterrupted legal use of this well for the stated purpose, you should
submit an application to renew the permit six months prior to its expiration date.
If you have any question please feel free to contact me at [phone].
Sincerely,
Mark R Milligan
Hydrogeologist I
Underground Injection Control Program
cc: UIC Files
WaRO Files
Enclosures

PCS
Phosphatke AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
December 13, 1995
Attn: Karen Harmon
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29578
Raleigh, North Carolina 27626-0578
Subject: PCS Phosphate Company, Inc.
Pilot Plant Study - Injection Well Water Supply
Tank Farm Remedial Action System
Permit - WI0700012
Dear Karen:
As requested by Elizabeth Morey's letter dated March 17, 1995, PCS Phosphate submits the
attached report to address the information concerning the Tank Farm Remediation System. The
attached report contains the following information:
1) The results of the pilot study,
2) the plan for treating depressurization well (DPW) water prior to injection, and
3) the schedule for construction and operation of the proposed system to replace the well
water supply.
The attached report indicates that use of treated DPW water as a supply to the Tank Farm
remediation system will require a modification of three of the limitation values contained in the
subject permit. If the DEM concurs that treated DPW water is the best alternative to the present
well water supply, PCS Phosphate requests that the pH range of the water supplied to the
injection system be expanded to a range of 6.0 to 8.5, that the TOC limitation value be increased
from 4.3 mg/1 to a value of 8.0 mg/1, and that the TDS limitation value be increased from 475
mg/1 to 500 mg/1.
If there are any further questions about this report please contact me Q [phone].
Sincerely,
Timothy F. Walls
Environmental Engineer
pc: Willie Hardison/ Guy Pierce- DEM WaRO BAP/00-18-000
W. A. Schimming T. L. Baker
15-03-003-02

Tank Farm Remediation System Injection Well Water Replacement
Introduction
A pilot water treatment system was rented in June 1995 to determine if the facility's
depressurization well (DPW) water could be used as a replacement water source for ground
water supply to the Tank Farm remediation system. The pilot system consisted of a multi -media
anthracite/sand filter (ASF) and a ultraviolet (UV) light treatment tube. The purpose of the ASF
was to remove any suspended solids from the DPW water. The ASF was followed by treatment
with UV light to disinfect any bacteria in the water stream.
The pilot system began operation on 07/13/95 and operated until 12/04/95. The pilot system
operated at a flow rate of 4 gallons per minute. The water from the pilot system was disposed
into the plantsite's water management system and not introduced into the remediation system.
Results of the Pilot Study
Attachment 1 summarizes the water quality data taken during the pilot study. As shown, the
ASF/UV system produced a water stream from the DPW that was in compliance with the
limitations of the subject permit with two exceptions - TOC and pH. The TOC values averaged
5.2 mg/1 versus the permitted limitation value of 4.3. pH values ranged from 7.1 to 7.9
throughout the study which were above the 6.0 to 7.0 range required by the permit. It was
expected that the pH range of the DPW water would be above these values because its normal
pH ranges from 6.7 to 8.2 (year-to-date 1995-values). All of the analysis were negative for the
presence of any coliform.bacteria indicating that UV light disinfection was successful.
Proposed Treatment System
Attachment 2 is an illustration of the proposed ASF/UV treatment system, which, if approved,
will operate as a full scale water supply source for the Tank Farm injection well water system.
This system will ASF/UV treat the DPW water to use as injectate water in the remediation
system. The full scale system will have a design flow rate of 16 gallons per minute (the normal
steady state flow rate into the injection system). The ability to use steam condensate as a
supplement to this water source will also remain.
Monitoring Activities
PCS Phosphate proposes to maintain the quarterly sampling schedule and analysis requirements
of CIW-7 outlined in the subject permit. We also propose to sample and analyze the injection
well system Water Level Control Tank (WLCT) and the product water from the SCF/UV
treatment system on a quarterly basis. CIW-7 samples will continue to be analyzed for the
parameters of cadmium, chromium and manganese. The concentrations of these metals remain
constant throughout the system so the WLCT and the SCF/UV will not be sampled for these
parameters.

Tank Farm Remediation System Injection Well Water Replacement Page 2
Implementation Schedule
Upon concurrence of DEM to proceed with this project, PCS Phosphate will begin a
procurement process of an ASF/UV treatment system. Purchase, delivery, installation and start-
up of the treatment system equipment will be completed within seven months of the approval
date by the DEM. Until the new treatment system can be put into operation, PCS Phosphate
requests DEM permission to continue use of the present injection well water supply system as
the remediation system supply.
Permit Modification Request
If treated DPW water is allowed as a water supply to the remediation system, PCS Phosphate
requests that DEM revise the permit conditions to allow for an increased pH range, a higher
TOC value, and a higher TDS limitation. A pH range of 6.0 to 8.5, a limitation for TOC of
8.0 mg/1, and an increase in the TDS limitation to 500 mg/1 are requested.

Attachment 1
PCS Phosphate - Aurora Division
Pilot Plant Study - Injection Well Water Supply
Parameter
08/01/95
08/15/95
09/07/95
09/21/95
10/11/95
11/01/95
11/30/95
Avgs
Limits
Total Phosphorus mg/I
0.027
0.024',
0.024
0.010
0.014
0.025
0.025
0.021
0.150
Fluoride mg/1
0.73
0.69
0.69
0.68
0.70
0.68
0.71
0.70
1.00
Chloride mg/I
10.8
10.7
9.0
10.6
13.0
10.0
11.5
10.8
55.0
Sulfate mg/I
<10
<10
<10
<10
<10
<10
<10
<10
50
TOC mg/I t
4.0
6.0
6.0
4.8
4.2
6.0
5.2
5.2
/
Co 4.3
i
TDS mg/1 ; '
528
412
330
380
496
357
354
408
1°0475
Cadmium mg/I
<0.005
<0.005
<0.005
<0.001
N/A
<0.001
N/A
<0.005
0.005
Chromium mg/I
<0.05
<0.05
<0.005
<0.001
N/A
<0.001
N/A
<0.001
0.05
Manganese mg/I
<0.05
<0.05
<0.05
<0.05
N/A
<0.01
N/A
<0.01
0.05
Total Caliform /100 ml
<1
<1
<1
<1
<1
<1
N/A
<1
<1
pH
7.9 @19 oC
7.4 @26 oC
7.5 @22 oC
7.4 @24 oC
7.1 @21 oC
7.2 @19 oC
7.4
N/A
b-1ti
6.0 - 7.0
`J'o."•o)(v0-U- LJJ 1,6 "V
h
1) foe u, - 5 %•--64
l N iob-i/oo
CA -1,-o
3) OA in G.vtc vt;
L. At t.,' W Q1. Lore,. 4 IOC t elk kH`,k �f.o..d

•
NOTES.
1.) ALL EOU/PMENT SKIP MOUNTED
2.) ALL ELECTRIC AUTOMATED
3.) INS/OE A 18'x 24'x 12' PREFABRICATED BUILDING'
/ DIVING DPW
STI'PLr
2" SCHEDULE 40
D4 D4
CTIMEDIA FTL TER
24 "x 60"
24"x 60"
150 PSI MAX PRESS
MUL RMEO/A FTL TER
24"x 60"
15 GPM
BACKWASH PUMPS (2HP)
50 GPM, 30 PSIg
D4
D4
D4
UV SIERIL/ZER
UV STERILIZER
BACKWASH to
AREA °A MY.IC£>
POLYETHEL)'ENE BACKWASH TANKS
86" D/AM. x 96" TALL
v
La
2. EO DOSING H2O
BLENDING 5>SILL
DRAWN L.M.MONICOMERTY
CHECKED
APPROVED
APPROVED
PCS
Phosphate AURORA DIVISION
DRAYANG TITLE
MECHANICAL FLOW
/NJECAON WA ID? TREATMENT SYSTEM
ENGINEERING
JOB No.
DATE:
1/5/95
SCALE:
NONE
DRAWING No.
H2O/NJSY

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
GROUNDWATER SECTION
December 5, 1995
Mr. Timothy F. Walls
Environmental Affairs
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, NC 27806
RE: Change of mailing address for the NC DEHNR-DEM-Groundwater
Section-UIC Group
Dear Mr. Wall,
Please be advised that as a result of the relocation of the
NC DEHNR-DEM-Groundwater Section in September, 1995, all future
correspondence and all quarterly monitoring reports should be
directed to the address indicated below:
Underground Injection Control Program
Groundwater Section
NC DEHNR-Division of Environmental Management
P.O. Box 29578
Raleigh, NC 27626-0578
If I can be of assistance, please contact me at (919) 715-
6166.
Sincerely,
x O. 7-1-6tAtyv,ti
Karen A. Harmon
Underground Injection Control Program
c:\wpdocs\memos\pcsphosp.chn
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
GROUNDWATER SECTION
December 4, 1995
Mr. Timothy F. Walls
Environmental Affairs
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, NC 27806
RE: Injection Well Permit No. WI0700012
Tank -Farm Remediaton System
Dear Mr. Wall,
In the letter dated March 17, 1995, from Elizabeth Morey,
you were requested to submit 1) a final report on the results of
the pilot study, 2) a detailed plan for treating and monitoring.
the DPW supply prior to injection, and 3) a schedule for
replacing the well water supply with the DPW supply, by December
1, 1995. In response to your request by telephone on November
30, 1995, for postponement of that submission date due to
personnel changes, UIC staff have determined a revised submission
date of December 22, 1995.
If I can be of assistance, please contact me at (919) 715-
6166.
Sincerely,
T a.—,
Karen A. Harmon
Underground Injection Control Program
c:\wpdocs\memos\pcsphosp.d04
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

PCS
Phosphatie AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
November 29, 1995
Attn: Karen Harmon
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Pilot Plant Study - Injection Well Water Supply
PCS Phosphate Company, Inc.
Tank Farm Remedial Action System
Permit - WI0700012
Dear Karen:
In a letter dated March 17, 1995 the Division allowed the Company to explore a replacement
water source for the subject permit. The water quality from the pilot system was checked on
11/01/95. The result of this sampling is shown below.
Parameter Date - 11/01/95
Total Phosphorus 0.025 mg/1
Fluoride 0.68 mg/1
Chloride 10.0 mg/1
Sulfate <10 mg/1
TOC 6.0 mg/1
TDS 356 mg/1
Cadmium <0.001 mg/1
Chromium <0.001 mg/1
Manganese <0.01 mg/1
Total Coliform <1 / 100 ml
pH 7.2 @ 19°C
If you have any questions about these data please contact me (a [phone].
Sincerely,
✓%647 I pc: Willie Hardison/ Guy Pierce- DEM WaRO
( BAP/00 18 000
Timothy F. Walls 12-01-008-03-002
Environmental Engineer
TFW/re
C:1WALLS 11"kt.LTR03. TFW

PCS
Phosphatke AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
November 28, 1995
Attn: Karen Harmon
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Pilot Plant Study - Injection Well Water Supply
PCS Phosphate Company, Inc.
Tank Farm Remedial Action System
Permit - WI0700012
Dear Karen:
In a letter dated March 17, 1995 the Division allowed the Company to explore a replacement
water source for the subject permit. This pilot study is complete and has demonstrated
encouraging results. Per our phone conversation this morning we agreed to a 15 day extension
to complete the follow up report on the subject study. The report will be submitted to you on
or before December 15, 1995.
I appreciate your consideration in this matter. If you have any questions about this request
please contact me as [phone].
Sincerely,
/-a-(4-7 1lviFf
Timothy F. Walls
Env ironmental Engineer
pc: Willie Hardison/ Guy Pierce- DEM WaRO
BAP/00-18-000
12-01-008-03-002
C:\WALLS\TFFRPT.EXT

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
ra-a4-ATFA
11=0EHNR
GROUNDWATER SECTION
October 19, 1995
Mr. Timothy F. Walls
Environmental Affairs
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, NC 27806
RE: Injection Well Permit No. WI0700012
Tank Farm Remediaton System
Dear Mr. Wall,
In your letter dated October 4, 1995, you presented the
analytical results from three samples of the Depressurized
Well Water (DPW) processed by the pilot UV water treatment system
and collected on August 1, 1995, August 15, 1995, and September
7, 1995. The Groundwater Section finds the concentration levels
of the parameters required in the permit conditions to be
acceptable.
Please submit 1) a final report on the results of thepilot
study, 2) a detailed plan for treating and monitoring the DPW
supply prior to injection, and 3) a schedule for replacing the
well water supply with the DPW supply, by December 1, 1995, as
originally specified in the letter dated March 17, 1995, from
Elizabeth Morey.
If I can be of assistance, please contact me at (919) 715-
6166.
Sincerely,
7*?
ren A. Harmon
Underground Injection Control Program
cc : P.CW& 45:05H istivdli CWa le; 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

PCS
Phosphatie AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
October 4, 1995
Attn: Karen Harmon
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Pilot Plant Study - Injection Well Water Supply
PCS Phosphate Company, Inc.
Tank Farm Remedial Action System
Permit - WI0700012
Dear Karen:
In a letter dated March 17, 1995 the Division allowed PCS to explore a replacement water
source for the subject permit. The water quality from the pilot system has been sampled and
analyzed on the following dates. The result of this sampling is shown below.
Parameter Date - 08/01/95 08/15/95 09/07/95
Total Phosphorus 0.027 mg/1 0.024 mg/1 0.024 mg/1
Fluoride 0.73 mg/1 0.69 mg/1 0.69 mg/1
Chloride 10.8 mg/1 10.7 mg/1 9.0 mg/1
Sulfate <10 mg/1 <10 mg/1 <10 mg/1
TOC 4.0 mg/1 6.0 mg/1 6.0 mg/1
TDS 528 mg/1 412 mg/1 330 mg/1
Cadmium <0.05 mg/1 <0.01 mg/1 <0.05 mg/1
Chromium <0.1 mg/1 <0.02 mgll <0.005 mg/1
Manganese <0.05 mg/1 <0.01 mg/1 <0.05 mg/1
Total Coliform < 1 / 100 ml <1 / 100 ml <1 / 100 ml
pH 7.9 @ 19°C 7.4 @ 26°C 7.5 @ 22°C
Based on this analytical data PCS requests DEM's opinion as to the acceptability of this water
as injectate into the Tank Farm Remediation System.
Please contact me @ [phone] to discuss these data at your convenience.
Sincerely,
ic /� pc: Willie Hardison/ Guy Pierce- DEM WaRO
BAP/00-18-000
Timothy F. Walls 12-01-008-03-002
Environmental Engineer
TFW/re C:\WALLS\TFFLTR03.TFW

PCS'
Phosphate
AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
September 11, 1995
Attn: Karen Harmon
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Pilot Plant Study - Injection Well Water Supply
PCS Phosphate Company, Inc.
Tank Farm Remedial Action System
Permit - WI0700012
Dear Karen:
In a letter dated March 17, 1995 the Division allowed the Company to explore a replacement
water source for the subject permit. The water quality from the pilot system was checked on
08/15/95. The result of this sampling is shown below.
Parameter Date - 08/15/95
Total Phosphorus 0.024 mg/1
Fluoride 0.69 mg/1
Chloride 10.7 mg/1 =.
Sulfate <10 mg/1
TOC 6.0 mg/1
TDS 412 mg/1
Cadmium <0.001 mg/1
Chromium <0.02 mg/1
Manganese <0.01 mg/1
Total Coliform <1 / 100 mi
pH 7.4 @ 26°C
Please contact me a [phone] if you have any questions regarding this information.
Sincerely,
Timothy F. Walls
Environmental Engineer
TFW/re
pc: Willie Hardison/Guy Pierce-DEM,WARO
WAS/00-12-000
12-01-008-03-002
C : \WALLS \TFFLTR02. TF W

i
PCS'
Phosphate
AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
August 17, 1995
Attn: Karen Harmon
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Pilot Plant Study - Injection Well Water Supply
PCS Phosphate Company, Inc.
Tank Farm Remedial Action System
Permit - WI0700012
Dear Karen:
7-0
r ;
7,3
Lr)
rn
In a letter dated March 17, 1995 the Division allowed the Company to explore a replacement
water source for the subject permit. On July 13, 1995 I informed you by phone that the pilot
water system was operational.
The water quality from the pilot system was checked on 08/01/95. The result of this sampling
is shown below.
Parameter Date - 08/01/95
Total Phosphorus 0.027 mg/1
Fluoride 0.73 mg/1
Chloride 10.8 mg/1
Sulfate < 10 mg/1
TOC 4.0 mg/1
TDS 528 mg/1
Cadmium <0.05 mg/1
Chromium <0.1 mg/1
Manganese <0.05 mg/1
Total Coliform < 1 / 100 ml
pH 7.9 @ 16°C
The Contract Laboratory did not analyze cadmium and chromium to the lower detection limit
(LDL) of 0.005 mg/1 and 0.05 mg/1 respectively. These components will be analyzed to the
lower LDL amounts on the next water quality data submission.

Ms. Karen Harmon
Page 2
Please contact me @ [phone] if you have any questions regarding this information.
Sincerely,
Seek/ f Ida
Timothy F. Walls
Environmental Engineer
TFW/re
Attachments
pc: Willie Hardison / Guy Pierce - DEM, WARO
WAS/00-12-000
12-01-008-03-002
C:\WALLS\ 1FFLLTER.TFW

State of North C Mina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
il•A
wit
DEHNF=1
GROUNDWATER SECTION
June
Mr. W.A. Schimming
Manager Environmental Affairs
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Schimming,
16,
1995
In accordance with your request dated May 5, 1995 (copy
attached) for a change of permittee name, we are amending Permit
No. WI0700012, which is for the operation of an injection well
system, at your Aurora, NC facility in Beaufort County. Please
note that the only changes to the referenced permit, issued
December 5, 1991, are as follows:
1. The permittee name has been changed from Texasgulf, Inc. to
PCS Phosphate Company, Inc.
2. The permit numbering system has been revised so that the
permit, originally numbered 06-0071-WO-0005, has a new number.
This permit shall be effective from the date of issuance
until December 5, 1996, and shall be subject to the conditions and
limitations stated therein.
In order to continue uninterrupted legal use of this well for
the stated purpose, you should submit an application to renew the
permit six months prior to its expiration date.
If you have any questions regarding your permit please feel
free to contact me at (919) 733 - 3221, ext. 407.
Sincerely,
A. Elizabet-h Morey
Manager
Underground Injection Control Program
cc: UIC Files
WaRO Files
Enclosures
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10%post-consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE OPERATION OF AN INJECTION WELL SYSTEM
In accordance with the provisions of Article 7, Chapter 87;
Article 21, Chapter 143, and other applicable Laws, Rules and
Regulations
PERMISSION IS HEREBY GRANTED TO
PCS Phosphate Company, Inc.
(formerly Texasgulf, Inc.)
FOR THE OPERATION OF AN INJECTION WELL SYSTEM consisting of 7
injection wells for the purpose of injecting water. This well
system is located in the Tank Farm area at PCS Phosphate Company,
Inc., Aurora, North Carolina, in Beaufort County, and will be
operated in accordance with the application dated November 1, 1991,
and in conformity with the specifications and supporting data
submitted, all of which are filed with the Department of
Environment, Health, and Natural Resources and are considered a
part of this permit.
This permit is for Operation only, and does not waive any
provisions of the Water Use Act or any other applicable Laws, Rules
or Regulations. Operation and use of an injection well system
shall be in compliance with Title 15 North Carolina Administrative
Code 2C, .0100 and .0200 and any other Laws, Rules, and
Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from the date
of its issuance until December 5, 1996, and shall be subject to the
conditions and limitations specified in Parts I through VIII
herein.
Permit issued this the
5 �� day
of June,
1995.
Te. L. Bush, Jr., Assistant Chief
Groundwater Section
Division of Environmental Management
By Authority of the Environmental Management Commission.
PERMIT NO. WI0700012

PERMIT NO. WI0700012
A. GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this Permit
and with the standards and criteria specified in 15A NCAC 2C
.0200. Any Permit noncompliance constitutes a violation of
the appropriate Act and is grounds for enforcement action;
for Permit termination, revocation and reissuance or
modification; or for denial of a Permit renewal application.
2. It shall not be a defense for a Permittee in an enforcement
action that it would have been necessary to halt or reduce
the permitted activity in order to maintain compliance with
the conditions of this Permit.
3. The Permittee shall take all reasonable steps to minimize or
correct any adverse impact on the environment resulting from
noncompliance with this Permit.
4. The Permittee shall give advance notice to the Director of
any planned changes in the permitted facility or activity
which may result in noncompliance with the Permit.
5. The Permittee shall report all instances of noncompliance,
not reported under condition 1. of this Part, at the time
monitoring reports are submitted.
6. Where the Permittee becomes aware of a failure to submit any
relevant facts in a permit application, or of any incorrect
information submitted in said application or in any report
to the Director, the relevant and correct facts or
information shall be promptly submitted by the Permittee.
7. The Permittee shall give notice to the Director as soon as
possible of any planned physical alterations or additions to
the permitted facility.
8. In the event that the permitted facilities fail to perform
satisfactorily, the Permittee shall take such immediate
action as may be required by the Director.
9. The injection system shall be effectively maintained and
operated at all times so that there is no contamination of
groundwaters, or other actions or occurrences which renders
them unsatisfactory for normal use. In the event the
facilities fail to perform satisfactorily, including the
creation of nuisance conditions, the Permittee shall take
such immediate corrective action as may be required by the
Director.

c(.
PERMIT NO. WI0700012
PART I (continued)
10. Department representatives shall have reasonable access for
purposes of inspection, observation and sampling associated
with injection and related facility.
11. This Permit is not transferable without prior notice to, and
approval by, the Director.
12. An application for modification, renewal or transfer of this
Permit shall be filed with the Department at least 30 days
prior to the expiration date of this Permit.
13. Provisions shall be made for collecting samples of facility
effluent, both prior to its entrance to treatment devices
and subsequent to leaving the treatment devices but before
entering the injection well.
PART II
A. SPECIFIC CONDITIONS
1. Water quality samples shall be collected from the riser pipe
of C1W7 (fluid to be injected into last injection well in
line) and from monitoring well MWTF-1C(groundwater from the
Croatan formation) as soon as the system becomes operational
and thereafter every January, April, July, and October for
the following parameters:
TDS Cadmium
TOC Chromium
Chloride Manganese
Fluoride SO4
pH Total Phosphorous
Total Coliform Organisms
The results of the sampling and analysis shall be submitted
on Form GW-59 (Compliance Monitoring Report Form) to the
Underground Injection Control Program, Groundwater Section,
N.C. Division of Environmental Management, P.O. Box 29535,
Raleigh, NC 27626-0535 and to the Groundwater Section,
Washington Regional Office, 1424 Carolina Avenue,
Washington, NC 27889 every February, May, August, and
November.

PERMIT NO. WI070•0012
PART II (continued)
2. The quality of the injected fluid will not exceed the given
concentrations in mg\l for the following parameters:
TDS (475.0) Cadmium (0.005)
TOC (4.3) Chromium (0.05)
Chloride (55.0) Manganese (0.05)
Fluoride (1.0) SO4 (50.0)
Total Phosphorous (0.15)
pH (6.0 - 7.0 standard units)
Total Coliform Organisms (1/100m1)
3. The temperature of the injected fluid will not exceed 35.5 C
(96 F) .
4. The Permittee must submit notification to the addresses
indicated in Specific Condition 1 of closure of the
injection well system 30 days prior to plugging and
abandonment.
5. The Permittee must submit to the addresses indicated in
Specific Condition 1 a plugging and abandonment report
within 30 days after abandoning the injection well system.
This report will include certification that the abandonment
was conducted in full compliance with the injection well
abandonment procedures outlined in 15A NCAC 2C .0214 (Well
Construction Standards Applicable to Injection Wells).
ti

State of North C lina
Department of E /ironment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
GROUNDWATER
Mr. W.A. Schimming
Manager Environmental Affairs
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Schimming,
• 4‘5/141
��
OEHNFl
SECTION
In accordance with your request dated May
attached) for a change of permittee name, we are
No. WI0700012, which is for the operation of an
system, at your Aurora, NC facility in Beaufort
note that the only changes to the referenced
December 5, 1991, are as follows:
5, 1995 (copy
amending Permit
injection well
County. Please
permit, issued
1. The permittee name has been changed from Texasgulf, Inc. to
PCS Phosphate Company, Inc.
2. The permit numbering system has been revised so that the
permit, originally numbered 06-0071-WO-0005, has a new number.
This permit shall be effective from the date of issuance
until December 5, 1996, and shall be subject to the conditions and
limitations stated therein.
In order to continue uninterrupted legal use of this well for
the stated purpose, you should submit an application to renew the
permit six' months prior to its expiration date.
If you have any questions regarding your permit please feel
free to contact me at (919) 733 - 3221, ext. 407.
Sincerely,
A. Elizabeth Morey
Manager
Underground Injection Control Program
cc: UIC Files
WaRO Files
Enclosures
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1096 post -consumer paper

thosphate
PCS
AURORA DIVISION
P. O. BOX 48. AURORA, NC 27806
May 5, 1995
Ms. Linda Bray Rimer
Assistant Secretary
Environment Protection
N. C. DEHNR
P. 0. Box 27687
Raleigh, NC 27611-7687
Subject: PCS Phosphate Company, Inc.
Dear Linda,
III
lit 3:
MAY - n .. •
__,��
IPA :(c tCCi :nu
As you are aware, on .April 10, 1995 ownership of Texasgulf Inc. was
transferred from Elf Aquitaine Inc. and The Williams Companies to the Potash
Corporation of Saskatchewan Inc. With this change of ownership, we changed
our Corporate name.
0n April 18, I discussed with Charles Gardner how we could effect the
name change from Texasgulf Inc. to PCS Phosphate Company, Inc. (PCS
Phosphate) on all our North Carolina Department of Environment, Health and
Natural Resources permits. Following his advice, I am now writing you to
request that all DEHNR permits issued in the name of Texasgulf Inc. (or any
predecessor names) for our Aurora and Kinston locations be changed to 'PCS
Phosphate Company, Inc." I am attaching a schedule of these permits listed by
Division.
If there is any additional information I can provide, please call me at
919/322-8239. I appreciate your assistance in this matter.
Sincerely,
William A. Schimming
Manager
Environmental Affairs
WAS/re
Enclosure

PCte
Phosphate ta
AURORA DIVISION
P. O. BOX 48, AURORA, NC 27806
s
Ms. Linda Bray Rimer
Assistant Secretary
Environment Protection
N. C. DEHNR
P. O. Box 27687
Raleigh, NC 27611-7687
May 5, 1995
Subject: PCS Phosphate Company, Inc.
Dear Linda,
•
5s ti
Iqc
MAY In
As you are aware, on .April 10, 1995 ownership of Texasgulf Inc. was
transferred from Elf Aquitaine Inc. and The Williams Companies to the Potash
Corporation of Saskatchewan Inc. With this change of ownership, we changed
our Corporate name.
On April 18, I discussed with Charles Gardner how we could effect the
name change from Texasgulf Inc. to PCS Phosphate Company, Inc. (PCS
Phosphate) on all our North Carolina Department of Environment, Health and
Natural Resources permits. Following his advice, I am now writing you to
request that all DEHNR permits issued in the name of Texasgulf Inc. (or any
predecessor names) for our Aurora and Kinston locations be changed to "PCS
Phosphate Company, Inc." I am attaching a schedule of these permits listed by
Division.
If there is any additional information I can provide, please call me at
919/322-8239. I appreciate your assistance in this matter.
Sincerely,
i
Acil/.
William A. Schimming
Manager
Environmental Affairs
WAS/re
Enclosure

State of North C Aina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P,E., Director
GROUNDWATER SECTION
March 17, 1995
Mr. William A. Schimming
Manager Environmental Affairs
Texasgulf, Inc. Phosphate Operations
P.O. Box 48
Aurora, NC 27806
141,
CI E H NR
RE: Injection Well Permit No. 06-0071-WO-0005
Tank Farm Remediation System
Dear Mr. Schimming,
Your letter describing the failure of the current sources of
the injection water supply for the Tank Farm Remediation System
to consistently meet the operating conditions of injection well
Permit No. 06-0071-WO-0005 was received by this office on
February 7, 1995. Your letter proposes that the current
injection water supply be replaced with Depressurized Well Water
(DPW) generated by mining operations.
Your letter explains that coliform bacteria may be present
in the DPW supply and that you propose to remove any coliform
bacteria from the portion of the DPW supply intended for
injection using a multimedia filter/ UV sterilizer system. The
proposal and quote for rental of a pilot filter/ UV sterilization
unit from Heyward, Inc., which included a description of the
proposed operating conditions for the system, was attached to
your letter for our consideration.
You request in the letter that Texasgulf, Inc. be allowed to
continue injecting the well water supply while conducting a six-
month pilot study to determine the efficacy of the multimedia
filter/ UV sterilization system on the DPW supply. This office
will consider allowing Texasgulf, Inc. to continue current
injection operations during the pilot study, with the following
stipulations:
1) Condensate shall be generated, when operationally
feasible, to dilute the well water supply to comply
with the regulatory limits established in the permit
conditions during the interval set for the pilot study.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

2) This office shall be notified when the pilot study
begins.
3) The results of the pilot study, including concentration
levels of all parameters required in the permit
conditions, should be submitted to this office at the
beginning of each month during the interval set for the
pilot study.
4) The interval allowed for the pilot study should
commence as soon as possible and extend through the
spring, summer, and fall months in order to monitor the
effectiveness of the system during temperature -related
fluctuations in coliform level.
A final report on the results of the pilot study, a detailed
plan for treating and monitoring the DPW supply prior to
injection, and a schedule for replacing the well water supply
with the DPW supply should be submitted to this office by
December 1, 1995.
If I can be of assistance, please contact me at (919) 733-
3221, ext. 407.
Sincerely,
L7
A. Elizabeth More
Manager
Underground InjE
cc: Tim Walls, DuPont
Willie Hardison, WaRO

Texasgulf
an elf aquitaine company
P.O. Box 48
Aurora, North Carolina 27806
January 30, 1995
Underground Injection Control Program
Groundwater Section
NC DEHNR - Division of Environmental Management
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Attn: Ms. Karen Harmon
Subject: Injection Well Permit No. 06-0071-WO-0005
Texasgulf Inc.
Dear Ms. Harmon:
W.A. Schimming
Manager
Environmental Affairs
[phone] a
c.
n c i1
t-. c'
Gir
—1 c
On January 9, 1995 I met with Bob Cheek, Elizabeth Morey and you at
your office in Raleigh to discuss the subject permit. The basis
for the subject of our meeting is documented in the Division's
letter to me dated January 4, 1995.
As the Division is aware, when Texasgulf installed the Tank Farm
Remediation System (TFRS), a new water supply well was installed in
near proximity to the injection water system. The injection well
system is a component of the TFRS system. The supply well,
installed into the Castle-Hayne aquifer, is solely used to supply
water as injectate to the injection well system. This well has now
operated for approximately 2 years. The quality parameters,
Chloride, Total Dissolved Solids and Total Organic Carbon, though
within drinking water standards, occasionally analyze above the
limitation values of the subject permit.
As we discussed at the meeting, Texasgulf is seeking an alternative
water source for the injection well supply. Our agreement during
the meeting was to allow Texasgulf a reasonable amount of time to
determine an alternate water supply for the injection well system.
Presently we have focused our efforts on the use of
Depressurization Well water (DPW), which is readily available near
the injection system.
The quality of the DPW is well within all values of the subject
permit, but there may be a presence of total coliform. To remove
the coliform from this DPW, Texasgulf believes that an Ultraviolet
(UV) light disinfection system incorporated with a filter can be
used successfully. During our meeting the Division expressed a
concern as to the effectiveness of UV light for this purpose.
Because of this I agreed to investigate the possibility of renting
a pilot UV /filtration system to check its effectiveness.

Ms. Karen Harmon
January 30, 1995
Page 2
Attached you will find a quotation that Texasgulf has obtained to
rent a pilot W light / filtration unit. It is our proposal to
install this unit and operate it for approximately 6 months. The
water that is disinfected and filtered through the unit will not be
introduced into the injection system but will be consumed by
Texasgulf's water management system.
Per this letter Texasgulf hereby requests the Division's
concurrence to continue this investigation of use of DPW water for
injection well water supply.
Please contact me or Tim Walls if you have any questions regarding
this information.
Sincerely,
W.LA. S imming
WAS:TFW/tfw
Attachments
pc: Willie Hardison - DEM, WaRO (w/attch)

Heyward
INCORPORATED
January 23, 1995
CONFIRMATION
P.O. BOX 30600
CHARLOTTE, NC 28230
PHONE:
FAX [phone]
-11953
FAX [phone]
Mr. A. L. McMicken
Chemical Maintenance Engineer
Texasgulf
P.O. Box 48
Aurora, NC 27806
Subject: Texasgulf - Aurora, NC
Water Services Proposal 2195
Multimedia Filter & UV Sterilizer System
File 00998
Dear Mr. McMicken:
On behalf of Water Services Corporation, Heyward Incorporated
proposes to furnish one (1) multimedia filter and UV sterilizer
system rated at a maximum of 4 GPM based upon operation of the
system in accordance with Water Services' Operation and
Maintenance Manual and assuming the following continuous
operating conditions:
Flow Rate (design)
Flow Rate (Max)
Backwash Flow
Pressure Drop (design)
Pressure Drop (max)
Feedwater Iron
Feedwater Suspended Solids
Feedwater Suspended Solids
Effluent Suspended Solids
Feedwater Pressure
The above operating conditions are assumed. System performance
assumes that the solids are readily removable without filter
aids. System performance varies with actual operating
conditions. See Standard Warranty and Terms and Conditions.
*EQUIPMENT AND PRICING:
One (1) Water Services Model DMF 12x48 multimedia filter system
per the enclosed specification. The filter is sized to deliver
a nominal 18 GPM of filtered effluent with a 50% reduction of
suspended solids. The filter is designed for sequential
automatic regeneration.
4 GPM
8 GPM
10 GPM
5 PSID
15 PSID
2 mg/1
60 mg/1 Max.
16 mg/1 Ave.
Approx. 50% of Influent
100 PSIG Max.
"SERVING THE SOUTHEAST SINCE 1908"

January 23, 1995
Page 2
one (1) model NPE first single stage centrifugal pump shall be
furnished for filter backwashing. The pump is rated for 10 GPM
at 30 PSIG and is close coupled to a 0.75 HP TEFC motor. The
pump is constructed of 304 stainless steel and furnished
complete with mechanical seal, isolation valves, check valve and
pressure gauge.
One (1) backwash tank shall be furnished to store filtered water -
for backwashing the filters. The tank is 35 inches in diameter
by 63 inches tall. Tank construction is polyethylene. The tank
shall include a 5 inch hand hole and fill valve.
One (1) Ideal Horizons Model LCI-IS ultraviolet sterilizer shall
be furnished to sterilize the multimedia filter effluent. The
UV sterilizer is rated at a nominal 10 GPM with 99+% bacteria
kill. The system includes 304 stainless steel housing rated at
150 PSIG, quartz UV sleeve, manual sleeve wiper, low UV
intensity alarm, high temperature alarm, elapsed time meter,
power indicator light and LED display. The unit is skid
mounted, prepiped, wired and includes inlet, outlet and bypass
valving.
One (1) skid is furnished to mount the twin multimedia filters,
the backwash pump, the backwash tank and the UV sterilizer. The
skid is constructed of structural fiberglass and assembled with
stainless steel hardware. It will have a 4'W x 6'L x 6'H
footprint and weigh 500 lbs. Piping connections will be 3/4".
Skid should be enclosed.
One (1) set of Schedule 80 PVC interconnecting piping and
valves.
The pressure drop across the pilot unit is 5 PSI. The required
supply pressure is between 30 and 100 PSI.
The skid will require 30 AMP, 120 Volt, single phase service.
Total price, FOB factory, is IMOMMIMIper month with a 6 month
minimum rental period.*
* Prices are FOB point of manufacture unless otherwise noted.
Applicable taxes are not included. Buyer shall pay all
applicable sales, customs, use and excise taxes. Freight is
not included.
Service is available at the rate of la per day.
Payment Terms: First and last month's rent with order, balance
NET 30 days billed each month.

January 23, 1995
Page 3
Shipment from the factory can be made 30-60 days after Water
Services acceptance of an order. If drawing approval is
required, shipment is from date Water Services received drawing
approvals.
This proposal is valid for thirty (30) days from date sent and
is subject to acceptance by Water Services and Water Services'
Standard Terms and Conditions and Warranty.
If we are favored with an order, please place the order as
follows:
Water Services Corporation
c/o Heyward Incorporated
P.O. Box 30600
Charlotte, NC 28230-0600
Yours very truly,
HEYWARD INCORPORATED - For
WATER SERVICES CORPORATION
Stephen G. Rea
SGR:ih
Attach. - Terms & Conditions
Specification

WATER SERVICES CORPORATION
1801 Pewaukee Road• Waukesha, WI 53188
1) Agreement
The Proposal. when aocopled by Buyer on the Iwo Noreen or when Buyer Issuoe
its Purchase Order for the System(s) described therein and these standard lbrnne and
shell upon final *vendee ey Water Servicedle Home Office). No prior dealings, oral IeprBeh
tatlo a trade cueom ar usage, or additional or defame term in Buyer's Purohaee
Order, ahal vary me terms hereof without Water SeniCes' written consent. Only en
executive officer of Water Senecas located at Water SeM®a Home Office. Waukesha,
Wisconsin, sham nave authority to bind Water Services.
2) Latter of Credit
h It the Proposal indicates Confirmed Irrevocable Lever al Credit ea the terms of pay -
one any contract meshing Irom this Proposal shall not oblgate water Services to
; oce0e the order or ship the goo= until II has received a Confirmed drevocabte
order of Credit front a prime U.S. bank acceptable to it. and any aporoxlmaleshlpping
dam snail be delayed for a period o1 time equal to the number of days which elapses
Cowmen formation of contract and receipt of the Inavocable Latter of Credit Subject
la variation by Water Santee in gent of me particular Cre mwan:eaaleach!renew:-
ton, an acceptable Confirmed immeshes Lever of Credit will be issued through Fksl
Wisconsin National Bank of MilWeekee as the confirming bank and will be payable
upon preeentallgn of a commercial invaice tar the goods and documents demonstrat-
ingced
delivery of identified goods o find commercial shipper
draft. ,
3) Rated Design Capacity
The GPD (gallons per day) rated design CapaciRy, end/or espadry between regener-
ations of each system and quality of woter produced ere a function or the temperature
end quality of the feedwelec Accordingly, the Syteem(e) =wilted In the proposal Maly
not meet Re/their rated assign conditions B the newel leedwaler differs Iran the
aasumed conditions II is Buyer's obligation b provide Water Services with a valid and
aetnntable leedwaor eneyde. Water Sanlaes' review of Buyer's valid and accent-
able laedwalar anWysla U uamryy may disclose conditions which require additional or
different enurement with reeuhanl Incresaed coat to Buyer.
a) Price
. Water Serviced edaeeda ndindU= sates, Ursa,roc tee Ordiktertaxes pany gosern-
exM charge"port boxing ener. so statsuch am ed. oCo IrhsegqueeIdm)dln a4A0dl m lie pironies lce ssppeedneddhherolnal .
the amount of any present or future sales. use, excise or almller Imes or government
charges applicable to the gala or use of the equipment and System sold hereunder
snag be paid by the Buyer o1, In Ileu thereof, the Buyer shall provide Water Santee
with a DX exemgllon certificate or regale connate acceptable to taxing sumodBoa.
5) Tele to Goods; Risk of Lose
Title to all equipment and goods covered hereby than remain vested In Water Sine
Ices until recoot al payment In full. N0(wllhsten0ing the foregoing, add equipment
and goads shall be et the risk of Buyer upon delivery o1 said equipment and goods
to the first commercial carrier. Buyer snail provide and maintain 'daqus" legume=
for the equipment and goods against loss or damage by any cause during the lime
'erween delivery lo earner and line) payment. In an amount fully protecting Wager
eO%• wines.
/ Time; Force Me)eure
• Shipping dace are apprndmare and are based upon timely receipt of all necessary
LIMITED WARRANTY
' Materiels and Workmanship
Waif Services warrants the equipment n manufactures le be free from defects In material and workmanship, for a period of one ( t ) year from date of shipment. Water
sorvleea' obligation under this warranty will ba limited to repairing or replacing al Its factory any part which, within one (1) year offer she/Menl. In returned le the Iaetary,
shipment caused by defective material. No allowiOn ancey Water Sonless will be made for loocal parr bits or expenees wtout therwritten prior approval al Water assumes no debility
GeMeor cee1uentlal damages or delays
2. Original Equlprntmt Manufacturers
warranty In mbc0and of equipment
qui me for and
conro given Water Services by NoIncorporated
resIn thetive ryyrom but
u not manufactured by water Sarvlws. Water Services extends to Buyer only such
e
iod
w
eng
3) performance
For a period of one (1) year commencing upon statt•Up or m1M (30) days after delivery, whichever occult Net. Water Services further warrants that for dean water appetite
Bone the System will produce Its rated capacity under the aaeumed operating conditions stated in Water Services' proposal In accordance with Weser Services' Terme and
Conditions, provided the equipment is installed and ODOfaM/ In eocordance with the inebucdone of Water Services. The loge required thereunder ere a condition of thee
warranty. Water Services' obligation under MIN warranty shell he limited to modifying or expanding the System at water SeMees' expense to produce be rated capacity, but
In no went shall Water Services be liable for consequential or Incidental damaged Water Canker" assumes no reaponaibTty ror cortodon erobtems which may occur d W
to local conditions.
THIS WARRANTY IS THE ONLY WARRANTY APPLICABLE 1O THE EQUIPMENT, MATERIALS AND SYSTEM COVERED HEREBY AND IS IN UEU OF ANY OTHER
WARRANTIES, EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE WHICH WOULD
FGT LRE ANY EQUIPMENT T E
RSERVICES
HALL IN NO
10 EVENT
BE
LIABLE MR
R CONSEQUENTIAL OR INCIDENTAL DAMAGES OF ANY KIND ARISING OUT OF THE
U
STANDARD TERMS AND CONDITIONS
Information, raw materiels and component 'clubmen try Water Services. Acceptance
of tho goods by Buyer ohall cometute a waiver al a0 claims; for delay. If WWat
SeMCn le 0s1eyed at any time In the pmgmas of Its work by an ea or neglect o1 Buyer.
ar by =armee in the work, ar by any causes beyond the control of Welot Serviced
such as, without limitation, tabor disputes. strikes. natural disasters, weather• riot, war,
civil dislurbencee. acts al God. interruption of raw material or component part supply,
or other unavoidable casualtlen, then Ina shipment timetable shall be amended lot
a period of time equal to the period al any such delays. I/ arty such delays emceed
sixty (90) days, Water Services may Irr ei= for work completed and material ordered.
and Buyer aholl pay same widen tarry (30) days el Invoice data.
7) Cancellellon
Contracts made pursuant to the Proposal are not subject to cancellation coma with
the written consent el Water Services' Home Orrice end upon Norms which will
Indernntfy Water SeMcos against all loss No equipment Or goods may be rewmed
to Water Services without written permission. If permission ire greeted, the hemp
returned are sublect to a minimum restocking charge al twenty peroem (2094) of the
sale price F.O.B. factors
8) Supentolonl Inalalladonl Engineering Submittals
Installation, lob elle supervision, start-yp services I MOlor Iota service mile are not
Included In the quoted purehaee pike unlerm ahead. Such services, 11 eubaequently
requested, will be (Molted el Current faros, and Water Services standard proeedur0e
and conditions will apply. Water Services will provide for the quoted purchase price
me tellowing engineering drMinge where applicable which drawingt shell remain the
property of Water Service. and may net be reproduced or transferred to °therm.
a) A process and Inetrumsntstion diagram relating Me vedette components of the
Syslem(e) wmtahod;
b) Dimensional drawing showing general arrangement of trio components el the
System(e) fumleked:
e) Electrical lichemalo diaerems;
d) Dbnenabnal outline dra inga of major resale accessary Items which are furnished
as received by Water Services.
9) Inspection, Testing
Water Seneca' shalt conduct much testing of its equipment ea it deems appropriate.
Upon Buyer" request, Water Service, shall ponnll Buyer to Inspect such equipment
poor ro shlpptng or wenes0 such tests as may be specified a1 such time and place
and for each additional charge! Water Services may designing provided, however, any
such Inspection or witness testing shall nog interfere with or delay shipment of such
equipment All ouch inspection' end tenting shall be In accordance with Wets`
Services manufacturing aandaea only.
10) Modification
No employee, agent or other representative of Water Sanwa, except en exeCulve
officer, has the authoriy en modify or very any tone hereof or make any agreement
Or repmeentatten net Incorporated herein. and any sum modification must be In
writing signed by such MC11/1v0 officer
11) Applicable Lew
Any convect or PUrohese Order resulting from this Proposal shall be construed and
determined according to the lawn of the See of Wisconsin. It le the Buyer's roeponsh
bility to severe that the Installation of water services equipment meets all applleable
local C000e such es plumbing, electric. building. etc

GENERAL SPECIFICATION
WATER SERVICES DMF SERIES DUAL -MEDIA FILTERS
Water Services DMF Series Dual -Media filters are designed specifically for iron, turbidity, manganese and
suspended solids removal. The DMF Series fitters feature corrosion resistant construction and are ideally
suited for commercial and industrial applications. Standard pre-engineered systems are available with
diameters from 8 to 24 inches with larger systems available on a custom engineered basis. The following
standard equipment is included:
FILTER TANKS
The filter tanks shall be manufactured of wound
fiberglass with polyethylene lining. The inner
shell is constructed of high density polyethylene
(EDPE) which is wound with continuous
fiberglass roving for strength. The tank shall be
rated at 150 psig operating pressure and 120° F
temperature. Each tank is factory tested prior
to shipment The tanks shall meet the
requirements of NSF, In. and WQA.
MEDIA
A dual -media filter bed shall be provided for
efficient iron and suspended solids removal. The
filter bed consists of two layers of media to
reduce filter pressure drop, provide deep bed
filtration and long filter runs. The first layer will
consist of hard coal anthracite with an effective
size of 0.6 to 0.8 min. The second layer consists
of manganese greensand with an effective size of
0.3 to 0.35 min The manganese greensand can
be regenerated with potassium permanganate
and chlorine for efficient iron removaL •
CONTROL VALVE
A fully automatic multiport control valve shall be
provided to cycle the filter through the down
flow service, up flow backwash and down flow
rinse operating modes. The valve shall be
constructed with cast brass valve body and
Teflon coated brass piston. The valve will be
controlled by a single piston that is motor driven
for positive operation. The control system shall
consist of piston motor timer/positioner which
controls the regeneration program and la fully
adjustable. A clock is provided to allow the
system to be regenerated at any time of the day
or night, on any day(e) of the week. An auxiliary
switch shall be provided to allow the filter to be
interlocked with other equipment during the
regeneration cycle. The system shall include an
automatic flow control to regulate the backwash
and rinse flow rates regardless of feedwater
pressure fluctuation between 25 and 120 psig.
The valve shall include an automatic
regeneration by pass to provide an uninterrupted
supply of water during regeneration.
DISTRD3UTOR SYSTEM
Filters with 14 inch diameter and larger tanks
will be equipped with a hub and lateral
distributor system constructed of ABS and PVC.
The laterals will be slotted to prevent media loss.
Tanks 12 Inch diameter and smaller will include
a single non -clogging segmented distributor
constructed of ABS. The distributor shall be
covered with a gravel support bed.
OPTIONS
The following options are available to meet
specific application requirements:
1) PRESSURE GAUGES AND SAMPLE
VALVES. Pressure gauges and sample valves
can be provided as required. The standard
pressure gauges are 2.5 inch diameter liquid
filled with brass wetted parts and stainless steel
case. The sample valves are 1/4 inch PVC.
2) CHEMICAL FEED SYSTEMS. Chemical
feed systems can be furnfebed to regenerate the
manganese greensand for efficient
o ddatfon/liltration of Iron and manganese or to
add coagulants to improve suspended solids
removal
3) CUSTOM SYSTEM. Custom designed
systems with specially engineered tanks, controls
and valving can be furnished when required.
Specifications Subject to Change without notice.
Revised 12/92
no. i'n. f
n9lrlLrhTL 'MU VIII
nen' AMat' aewM_nrunvTT 7h.0 ulna ca_c7_MWP

PUA 414j'1vIL0
IIGRIItl1U-wnicn DLI[V IurJ
JHR-4J-a2 IIUIV a'44
04.
p
riAr41144
THIS DRAWING IS THE PROPERTY OF WATER SERVICES CORPORATION
IT ISCDBIICTIOOMANGE WRHOJJ NOTICE AND 6 NOV TO SC CONED ON USED W ANYWAY DEMIMIMlAl10 ME COMPANY
INLET DRAIN
FROM OPNDNAL
CliEUICAL FEEDER
FH
TO CONTROL
VALVE
DROP
OPTIONAL
CHERSEE NOTVIL FEED
SYSTEM15
(
OUTLET
MODEL DMF SERIES FILTERS
SIZE
SERVICE FLOW ate'
BACKWASH FLOW
FD-FILTER DIAMETER
FH-FILTER HEIGHT
H-HEIGHT
INLET SIZE (NPTM)
OUTLET SIZE (NPTM)
DRAIN SIZE
SHIP WEIGHT
8X44
1.8
3.6
5
8
44
50
1
1
1/2
95
10 X 47 12 X 48 14 X 65 16 X 65
2.8 4.0 5.4 7.0
5.6 8.0 10.6 14.0
7 10 14 1 8
10 12 14 1 6
47 48 65 6 5
53 54 75 T5
1 1 I 1
1 1 1 1
1/2 3/4 1 1/4 1 t/4
140 205 365 495
N0TEs
1. FLOW RATES ARE IN GAL/MIN DIMENSIONS
ARE IN INCHES. WEIGHTS ARE IN POUNDS.
2. FLOW RATES ARE NOMINAL, CONSULT FACTORY FOR
SPECIFIC APPLICATION REQUIREMENTS.
3. PRESSURE GAUGES AND SAMPLE VALVES ARE
OPTIONAL
4. INSTALL INLET, OUTLET, AND DRAIN LINES WITH UNIONS
OR OTHER MEANS TO ALLOW VALVE TO BE REMOVED FROM
THE TOP OF THE TANK.
5. FOR IRON FILTERS. THE OPTIONAL CHEMICAL FEED
SYSTEM MAY BE REQUIRED.
TOaaIIANCnn
M.W+...—.. ro
REVISIONS
WATER SERVICES CORPORATION
WAUKESHA, WISCONSIN
MD Whip
1
.r.CRrNA.
GENERAL ARRANGEMENT -DU1F SERIES
DUAL MEDIA FILTERS
DRARE. RVju
SCALE NIS ANI._JRr 1 .
A,.a
DA" "Am" As.
wNNcr GA-B-1BOt

State of North Cc lina
Department of E. "onment,
Hgalth and Natu,;(\: Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr„ P.E., Director
January 4, 1995
Mr. William A. Schimming
Manager, Environmental Affairs
Texasgulf, Inc. Phosphate Operations
P.O. Box 48
Aurora, NC 27806
�, fir•
CEHNR
RE: Compliance Monitoring - Injection Well Permit No. 06-0071-WO-0005
Dear Mr. Schimming:
Review of the Compliance Monitoring Report for October, 1994, submitted
to the Underground Injection Control Program, Groundwater Section, in
compliance with the conditions of Injection Well Permit No. 06-0071-WO-0005,
indicates three instances of non-compliance:
1) The total dissolved solids (TDS) concentration of the injectate (sampled
from riser pipe of CIW-7) of 528 mg/I exceeds the concentration limit of 475
mg/I set in permit condition Part II (A)(2).
2) The total organic carbon (TOC) concentration of the injectate (sampled from
riser pipe of CIW-7) of 5.05 mg/I exceeds the concentration limit of 4.3 mg/I
set in permit condition Part II (A)(2).
3) The chloride concentration of the injectate (sampled from riser pipe of CIW-
7) of 94.9 mg/I exceeds the concentration limit of 55.0 mg/I set in permit
condition Part II (A)(2).
In a letter, dated November 28, 1994, to the Groundwater Section, you
state that TDS, chloride, and sulfate concentration values in the CIW-7 sampled
are greater than "recommended injectate quality parameters in the subject permit".
Please note that the concentration limits are required, not recommended. Also
note that TOC, not sulfate, concentrations are in exceedance of the limits set by
Permit No. 06-0071-WO-0005, as well as those of TDS and chloride.
• You indicate in the letter that you will propose an alternative injectate water
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmafive Action Employer 50% recycled/ 10% post -consumer paper

supply to attempt to resolve the problem of concentration limit exceedances in the
injectate. The revised water supply system must supply injectate water that
meets the concentration limits set in Part II (A)(2) of the Specific Conditions of
Permit No. 06-0071-WO-0005.
Furthermore, it has been the practice of Texasgulf, Inc. to submit quarterly
monitoring reports and correspondence in reference to the injection well permit to
the Groundwater Section using a general address. Please note that Part II (A)
(1) of the Specific Conditions of Permit No. 06-0071-WO-0005 requires that the
results of sampling and analysis be submitted to the following address:
Underground Injection Control Program
Groundwater Section
NC DEHNR - Division of Environmental Management
PO Box 29535
Raleigh, NC 27626-0535
Thank you for your co-operation. If I can be of assistance, please don't
hesitate to contact me at [phone] extension 407.
Sincerely,
Vi:
A. Elizabeth Morey
Manager
Underground Injection Control Program
Groundwater Section
cc: Tim Walls
WaRO

•
Texasgulf Inc.
an elf aquitaine company
P.O. Box 48
Aurora, North Carolina 27806
November 28, 1994
i-
O:r.0 tar:TE SEC.
� t Lint: n P1 I : 35
Division of Environmental Management
Groundwater Section
North Carolina Department of EHNR
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Quarterly Monitoring Data
for Tank Farm Remedial Action System
Dear Sirs:
W.A. Schlmming
Manager
Environmental Affairs
[phone]
Please find enclosed the Supplemental Tank Farm Remedial Action System quarterly
groundwater monitoring data for your information. These data are from samples collected
during October, 1994. The sampling and analysis of water from the injection well system as
required by Permit No. 06-0071-W0-0005 is also included.
Water that is supplied as injectate to the injection well system comes from a single well, the
injection supply well, which is exclusively used for this purpose. The water from the injection
supply well now displays total dissolved solids (TDS), chloride (C1) and sulfate (304) values
which are above the recommended injectate quality parameters in the subject permit. This is
also reflected in the analytical values for injection well CIW-7. Texasgulf is presently designing
a filtration/disinfection apparatus which will allow for the use of another source of injectate
water for the subject system. This proposal will be completed and submitted to DEM by
February 1, 1995.
Please contact me or Tim Walls if you have any questions regarding this information.
Sincerely,
77CL /1//l/0
W. A. Schinmting
WAS:TFW/tfw
Attachments
pc: Willie Hardison - DEM, WRO (w/attch)
12-01-005-06 (w/o attch)
00-12-000 (w/o attch)
12-01-008-03-002 (w/ attch)
C:\WORD\TFQTRPT.TFW
U: \WALLS\TFQTRPf.TF W
Pruned on
Rogow Papa

State of North Carolina
Department of Environment, Health and Natural Resources
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889-1424
James G. Martin, Governor
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
December 9. 1991
Mr. W.A. Schimming
Manager Environmental Affairs
Texasgulf Inc.
Post Office Box 48
Aurora. North Carolina 27806
Dear Mr. Schinnning:
Lorraine G. Shinn
Regional Manager
Egt5 TITTLY
tiEC
12 mis..
GROUNDWATER SECTION
RALEIGH, NC
The Groundwater Section in the Washington Regional Office in conjunction
and consultation with the Raleigh Central Office has reviewed your request to
modify the above referenced permit. Based upon our review the Groundwater
Section is granting your request for modification of Permit No.
06-0071-WI-0238. The request seeks permission to 1) use a new well tapping
the upper 20 feet of the Castle Hayne aquifer as the water supply source for
the injection well system; and 2) allow mixing of steam condensate water with
the well water, if needed, to maintain the total dissolved solids
concentration of the injection fluid below 475 mg/1 in the event the total
dissolved solids concentration of the Castle Hayne aquifer well water rises
above 475 mg/l. If you should have any questions or comments, just give us a
call at 946-6481.
Sincerely,
ORIGINAL S GNE^
Al MULLIGAN
Jim Mulligan
Regional Supervisor
cc: Rob Turner
WaRO
P.O. Box 2188, Washington, North Carolina 27889-2188 Telephone [phone] FAX: [phone]
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Health
Public Water Supply Section
P.O. Box 29536 • Raleigh, North Carolina 27626-0536
Telephone [phone]
James G. Martin, Governor
William W. Cobey, Jr., Secretary December 10, 1991
MEMORANDUM
TO:
Mr. Robert J. Turner
Permits and Compliance Group
Groundwater Section
Division of Envirgnenta Management
FROM: Richard K. Rowe
SUBJECT: Application for Injection Well Permit
Texasgulf, Incorporated
Aurora, North Carolina
Beaufort County
Richard K. Rowe
Director
We have reviewed the material submitted to this office concerning the above
referenced subject.
Considering the legal matter of endorsing this proposal, we believe we do not
have sufficient information to deny the request due to a threat to the groundwater
source or to the public health.
Our recommendation that an assessment be made of the effects these systems
might have on groundwater remains.
If we can be of further assistance, please
RKR/RWC/mhj
cc: Mike P. Bell, Regional Engineer
let
us know.
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Environment, Health and Natural Resources
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889-1424
James G. Martin, Governor
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
December 5, 1991 '
Mr. Terry Baker
Texasgulf Inc.
Post Office Box 48
Aurora, North Carolina 27806
Dear Mr. Baker:
Lorraine G. Shinn
Regional Manager
In accordance with your application dated November 1, 1991, we are
forwarding herewith Permit No. 06-0071-WO-0005, for the Operation and Use
of a well system, for the purpose of injecting uncontaminated groundwater
from the Castle Hayne formation into the Croatan formation, in Beaufort
County.
This Permit shall be effective from the date of issuance until
December 5, 1996, and shall be subject to the conditions and limitations
stated therein.
In order to continue uninterrupted legal use of this well for the
stated purpose, you should make application for permit renewal at
least 30 days prior to its expiration date.
Sincerely,
C
-4
im Mulligan
Regional Supervisor
Attachment
cc: UIC Files
WaRO File 4
P.O. Box 2188, Washington, North Carolina 27889-2188 Telephone [phone] FAX: [phone]
An Equal Opportunity Affirmative Action Employer

41 Texasgulf Inc.
elf aquitaine group
P.O. Box 48 Aurora, North Carolina 27806
November 1, 1991
Mr. Willie Hardison
Ground Water Section
Division of Environment Management
N.C. Department of EHNR
P.O. Box 1507
Washington, N.C. 27889
W.A. Schlmming
Manager
Environmental Affairs
[phone]
Ploy '7
Subject: Application To Modify Permit Number 06-6071--WI-.�'
For Injection Well System
Tank Farm Area Remedial Action System
Texasgulf Phosphate Operation, Aurora, N.C.
Dear Mr. Hardison:
Enclosed is one (1) copy of the modified application to
construct the injection well system for the Tank Farm Area
Remedial Action System. This request modifies items E, G, and
H of the permit application (Form GW-57B) to reflect the change
in the source of the injection fluid. Two (2) attachments and
two (2) drawings are included in support of the permit
modification. Please note that two (2) copies of the enclosure
have been sent to the Ground Water Section's, Raleigh Central
Office to the attention of Rob Turner for processing of this
application.
Please do not hesitate to contact Terry Baker or myself if you
have any questions concerning this modification request.
Sincerely,
W.A. Schimming
Enclosures
pc: Rob Turner, Raleigh DEM Ground Water Section (2 copies of
encl.)

a
Texasgulf Inc.
elf aquitaine group
P.O. Box 48 Aurora, North Carolina 27806
August 29, 1991
Mr. Willie Hardison
N. C. Department of EHNR
Division of Environmental
Groundwater Section
P. O. Box 1507
Washington, North Carolina
Management
27889-1507
Phosphate 0
[phone]
Subject: Texasgulf Phosphate Operations
Tank Farm Remedial Action Plan
Injection Well System Permit No. 06-0071-WI-0238
Notice of Modification Request
Dear Mr. Hardison:
Pursuant to our telephone conversation on August 26, 1991, this
letter provides Texasgulf's notification of a modification
request for the subject injection well ,system's water source.
A revised application is expected to be issued to your office by
mid -September, 1991 after necessary water analysis are obtained
from an outside laboratory.
This modification is necessary due to unforeseen developments
since the original application was submitted in March, 1991.
The Fert-1 utility well was specified in the original
application as the water source for the injection well system.
This well is over twenty (20) years old and would require costly
water treatment to lower TDS and chloride levels to below the
recorded levels of the Croatan Aquifer background monitor well
(MWTF-3C). Since the issuance of the subject permit to
construct the injection well system, the report for the renewal
of the mine depressurization water withdrawal permit has been
developed which plans for the abandonment of several utility
wells including Fert-1. This will eliminate the Fert-1 well as
a long term, steady source of water for the injection well
system. Another development is the construction progress of the
NPDES Permit - Water Management System's Depressurization Well
(DPW) water piping system in the Tank Farm Area. Water from
this system has been analyzed and is below both the TDS and
chloride levels required. All other parameters analyzed
indicate that the DPW water is high quality and meets all
groundwater standards. This DPW water source is seen as a long
term, steady source of high quality water for the injection well
system. For additional water quality control, a condensate
(demineralized water) source can be mixed with the DPW water
prior to injection to ensure that TDS levels remain below the
V
•

det
requirements.
The modified application with additionalsesails
are
will be issued as soon
s outside total and febalacoliformtory acounts and
lyreceived which will quantify les.
nitrate levels from DPW water same
August 27, 1991, the letter from Mark T.
Purserrulf dated August
too Aug 1991 (attached) which provides DEM
August 20, completion date to
approval of the revised remedial plantially complete and
September 1, 1991. The construction is esse and Brian Wooten on
was inspected by Mark Purser, Rob Turner,
the seven (7) surficial aquifer
August 15, 1991. Additionally, operation removing
withdrawal wells have been in check-out Seven (7) Croatan
Tor proper
aquifernants sriwae wells
August pending the
withdrawal wells have been checy for ked out
initialproperational flow rateermitsand are for the injection well system for the Croatan
operatio P
Aquifer.
Pl
ease do not hesitate to contact me if you have any questions
concerning this information.
Sincerely,
T. L. Baker
Superintendent, Operations Environmental
TLB/re
Attachment
pc: Rob Turner, DEM, Raleigh - GWS (w/attch)

State of North Carolina
Department of Environment, Health and Natural Resources
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889
James G. Martin, Governor
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 20, 1991
Mr. Terry L. Baker
Superintendent, Operations Environmental
Texasgulf Inc.
Post Office Box 48
Aurora, North Carolina 27806
Dear Mr. Baker:
Lorraine G. Shinn
Regional Manager
We are in receipt of your request to extend the remedial plan completion
date to September 1, 1991. We understand that this is necessary due to
unforeseen construction delays. Additionally, there is the necessary lead
time needed for completion of the project and system check out prior to
issuance of the operating permit. We have no problems with your request
and hereby approve of the September 1, 1991 extension for remedial plan
completion.
MTP:ekw
Sincerely,
Mark T. Purser
Hydrogeological Technician
P.O. Box 1507, Washington, North Carolina 27889-1507 Telephone [phone] FAX: [phone]
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Environment, Health and Natural Resources
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889
James G. Martin, Governor
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
June 21. 1991
Mr. Terry Baker
Texasgulf Inc.
Post Office Box 48
Aurora, North Carolina 27806
Re: Well Construction Permit No. 06-0071-WI-0238
Dear Mr. Baker:
Lorraine G. Shinn
Regional Manager
JUN 241991
GROUNDWATER SECTION
RALEIGH, NG
It has come to our attention that the above referenced permit was
issued for the construction and operation of an injection well system.
Please be advised that the referenced permit is for the construction of the
seven injection wells only and not for their operation. Once the wells are
installed, a member of the Groundwater staff in the Washington office will
inspect the wells for compliance. If the wells are in compliance, then an
operation permit should follow. We thank you for your patience and again.
we apologize for the oversight.
MTP:ekw
cc: Rob Turner
Sincerely,
Mark T. Purser
Hydrogeological Technician
P.O. Box 1507, Washington, North Carolina 27889-1507 Telephone [phone] FAX: [phone]
An Equal Opportunity Affirmative Action Employer

4)
Texasgulf Inc.
elf aquitaine group
P.O. Box 48 Aurora, North Carolina 27806
March 7, 1991
Mr. Willie Hardison
Groundwater Section
Division of Environmental
N. C. Department of EHNR
P. O. Box 1507
Washington, North Carolina
Subject:
Management
27889
Application for Permit to Construct
Injection Wells - Tank Farm Area
Remedial Action Plan
Texasgulf Phosphate Operations
Aurora, North Carolina
Dear Mr. Hardison:
7/7,-, 2)
W.A. Schimming
Manager
En
(91
ffairs
MAR ) 3 1991
GRmi"19WATER
SECTION
LEIGH, NC
Enclosed are three copies of the Application to Construct the seven
(7) injection wells for the Tank Farm Area Remedial Action System.
Two attachments and six drawings are included in support of the
application to provide an adequate description of the proposed
system. Please forward the necessary information to the
Groundwater Section's Raleigh Central Office for processing of this
application.
Please do not hesitate to contact Terry Baker or myself if you have
any question concerning this application.
Sincerely,
[4:407W
W. A. Schimming
WAS:TLB/re
Attachments
pc: T.
B.
W.
J.
H.
I.
T.
R.
J.
O.
T.
E.
M.
K.
L.
M.
Regan, Jr.(w/o attch)
Trusty (w/o attch)
Cooper (w/o attch)
Carpenter (w/o attch)
Breza (w/o attch)
Gilmore (w,battch)
Baker (w/o attch)
Thomas (w/attch)
T. S. Ingra-Ardaman (w/o attch)
T. C. Younger (w/o attch)
G. W. House (w/o attch)
00-12-000 (w/o attch)
12-01-005-06 (w/attch)

State of North Carolina
Department of Environment, Health and Natural Resources
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889
James G. Martin, Governor Lorraine G. Shinn
Secretary Regional Manager
DIVISION OF ENVIRONMENTAL MANAGE)
William W.
Cobey, Jr.,
May 8, 1991
Texasgulf Inc.
Post Office Box 48
Aurora. North Carolina 27806
ATTN: Mr. Terry Baker
Dear Mr. Baker:
In accordance with your application dated February 28. 1991, we are
forwarding herewith Permit No. 06-0071-WI-0238, for the construction of a
well system for the purpose of injecting uncontaminated groundwater from
the Castle Havne formation into the Croatan formation in Beaufort County.
This Permit shall be effective from the date of issuance until
May 8. 1996, and shall be subject to the conditions and limitations
stated therein.
In order to continue uninterrupted legal use of this well for the
stated purpose, you should make application for permit renewal at
least 30 days prior to its expiration date.
Sincerely,
fLey-
j5— Jim Mulligan
Regional Supervisor
Attachment
cc: UIC Files
WaRO File
P.O. Box 1507, Washington, North Carolina 27889-1507 Telephone [phone] FAX: [phone]
An Equal Opportunity Affirmative Action Employer

w wu�
on Leofruited
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
November 26, 1990
Mr. W. A. Schimming, Manager
Environmental Affairs
Texasgulf Incorporated
Post Office Box 48
Aurora, North Carolina 27806-0048
RE: Design Report and Specifications
Supplemental Tank Farm Remedial Action Plan
Dated July 31, 1990 File No. 88-089
Dear Mr. Schimming,
A review of the above mentioned report and technical
specifications has been completed by the Groundwater Section.
The Section has no objections to proceeding with the plan.
There are some points to be considered, however:
1. The injection/withdrawal system requires a federal permit
for the construction and operation of the wells. This
permit is implemented by the Groundwater Section as part
of the federal EPA Underground Injection Control Program.
Enclosed, please find the forms necessary to apply for
this permit. The permit requires no application fee, but
is prepared in the Section's Raleigh Central Office. The
application should contain enough facts, diagrams, and
figures to adequately describe the system, the quality of
the source water, and the ultimate disposal of the
recovered waters.

Mr. W. A. Schimming
Texasgulf Incorporated
November 26, 1990
Page Two
2. The amounts of water injected and withdrawn from the
corrective action system must be reported as' part of the
Water Use Permit that Texasgulf currently holds. These
amounts may also need to be integrated into the recycle
lake water budget.
This letter constitutes approval of the design specifications
and as such, the timetable outlined in the Ardaman and
Associates letter of March 6, 1990 indicates that start of
construction should begin within 90 days of DEM approval.
Please verify the construction start/complete dates as soon
as possible. If you have any questions, or require further
information, please contact either Willie Hardison or Richard
Powers.
enclosures
cc: Willie Hardison.
Richard Powers
Roger Thorpe
Sincerely,
Jim Mulligan
gional Supervisor
1

7-7017'/
a
•
Texasguiflnc.
elf aquitalne group
P.O. Box 48 Aurora, North Carolina 27806
August 2, 1990
W.A. Schimming
Manager
Environmental Affairs
[phone]
Mr. Jim Mulligan
Regional Supervisor
North Carolina Department of EHNR
Division of Environmental Management
Washington Regional Office
P. O. Box 1507
Washington, N. C. 27889
Subject: Design Report and Specifications
Supplemental Tank Farm Remedial Action Plan
Texasgulf, Inc.
Beaufort County
Dear Mr. Mulligan:
As required by the approved Supplemental Tank Farm Remedial
Action Plan, enclosed please find a copy of the project
construction Design Report with specifications. The Division's
approval of the enclosed design package is requested prior to
the start of construction.
Please do not hesitate to contact me or Terry Baker should you
have any questions regarding this information.
Sincerely,
W. A. Schimming
WAS:TLB\kls
Enclosure
pc: Perry Nelson - DEM, Raleigh (w/2 - enclosure)
Willie Hardison - DEM, WRO (w/enclosure)
T. J. Regan, Jr./ G. W. Whitaker, Jr. (w/enclosure)
T. C. Younger, Jr./ P. R. Wilson (w/enclosure)
B. O. Trusty (w/enclosure)
R. M. Thomas ( " )
J. E. Carpenter ( " )
T. L. Baker ( " )
G. W. House ( " )
12-01-005-06 ( " )
00-15-000 (w/o enclosure)
00-12-000 ( " )

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 19, 1990
Mr. W.A. Schimming
Environmental Affairs Manager
Texasgulf Inc.
Post Office Box 48
Aurora, North Carolina 27806
Re: Tank Farm Supplemental Remedial Action Plan
Dear Mr. Schimming:
This office has reviewed -the above referenced report from your consultant,
Ardaman and Associates. The meeting held in January and this report have
adequately addressed the concerns of the Division. As such, this office
approves the conceptual plan for the remediation of impacted groundwaters in the
tank farm area.
Please remember that the Croatan Formation injection wells will require a
special construction/operating permit as their intended use falls under the
Underground Injection Control Program (U.I.C.) The U.I.C. program is the
Division implementation of a Federal EPA program to control the injection of
wastes into aquifers. As such, the injection wells construction/operating
permit will take approximately 45 to 60 days to be approved and issued. The
piezometer/monitoring wells will need to be permitted as per the usual process.

Ir. W.A. Schimming
Page 2
March 19, 1990
Please contact me for any further information.
Sincerely,
Richard R. Powers
Hydrogeologist
RRP:ekw
cc: Bob Cheek, Permits and Compliance Branch, Raleigh
Ann Borden, Pollution Control Branch, Raleigh
Jim Mulligan, DEM Supervisor, Washington
Roger Thorpe, DEM Water Quality Section, Washington
File, Incident No. 3663/5155 ✓

7- io 23
Texasgulf Inc.
elf aquitaine group
P0. Box 48 Aurora, North Carolina 27806
March 9, 1990
�� I Togi oFPicz
�N.16 1990
0. E. M.
Mr. Richard Powers
N. C. Department of EHNR
Division of Environmental Management
Washington Regional Office
P. O. Box 1507
Washington, NC 27889
W.A. Schimming
Manager
Environmental Affairs
[phone]
SUBJECT: Texasgulf Inc.
Tank Farm Supplemental Remedial Action Plan
Response to Deficiencies Noted by the DEM
Dear Mr. Powers:
Attached is a copy of the subject report from Ardaman &
Associates. This includes responses to your December 8, 1989
letter and the proposed revised remedial action plan.
Please do not hesitate to contact Terry Baker or myself should
you have any questions regarding this matter.
Sincerely,
i I // i (/
if y I• [ G ,,
W. A. Schimming
WAS:TLB/re
Attachment
pc:
Jim Mulligan - DEM, Washington
Perry Nelson - DEM, Raleigh
Bill Reid - DEM, Raleigh
T. J. Regan, Jr./G. W. Whitaker, Jr./A. J. Kubicek
B. 0. Trusty
T. C. Younger, Jr.
P. R. Wilson
G. W. House
T. L. Baker
00-12-000
12-01-005-06

Ardaman & Associates, Inc.
March 6, 1990
File Number 88-089
Consultants in Soils, Hydrogeology,
Foundations and Materials Testing
Texasgulf Inc.
Post Office Box 48
Aurora, North Carolina 27806
Attention: Mr. William A. Schimming, Manager
Environmental Affairs
Subject: Response to Deficiencies Noted by the DEM Concerning the Tank Farm
Supplemental Remedial Action Plan and Proposed Revised Remedial Action
Plan, Texasgulf Phosphate Operations, Aurora, North Carolina
Gentlemen:
As requested, we have reviewed the deficiencies noted by the Groundwater Section of the
Division of Environmental Management (DEM) in their letter of December 8, 1989 concerning
the tank farm Supplemental Remedial Action Plan. Responses to the four technical issues,
and the eight suggested recommendations for incorporation in the final Supplemental Remedial
Action Plan are presented below. These responses were briefly discussed with the DEM during
a meeting in their Washington, North Carolina regional office on January 18, 1990.
Responses to Deficiencies in Supplemental Remedial Action Plan
Item 1.
The proposed Remedial Action Plan conceptually is designed to contain and restore
contaminated groundwaters in the surficial and confined sand layers and prevent
migration into the surface waters of the barge slip. The contaminants in the
Croatan formation are not addressed in this Supplemental Remedial Action Plan.
The Croatan formation test results clearly indicate unacceptable levels of phosphorus
(34.3 mg/1), sulfate (874 mg/1), total dissolved solids (2337 mg/1), and total organic
carbon (13 mg/1). Background levels for these parameters have already been
established as 0.1, 0.0, 349, and 4.11 met, respectively. It is requested that
Texasgulf provide further defense, as outlined in NCAC 2L .0113 Variance, of the
proposal to implement a passive remediation or no action approach to restore
groundwater gpality in the Croatan formation. The Washington office will not
recommend granting such a variance. It is most likely that the Director would not
sign a variance request. Otherwise, please include provisions in the final remedial
action plans for restoration of the Croatan formation.
Active remedial measures to restore the quality of groundwater in the Croatan formation were
not proposed in the Supplemental Remedial Action Plan. The no action approach for the
formation was proposed because: (i) the contaminants are isolated below the northern portion
of the tank farm in a formation that is not used as an aquifer; (ii) due to the south -
southeastward direction of flow in the formation the contaminants are not entering the surface
waters of the barge slip; and (iii) the underlying Yorktown-Pungo River aquitard minimizes the
8008 S. Orange Avenue. P.O. Box 593003. Orlando. Florida 32859-3003 [phone] FAX [phone]
Offices in: Avon Park. Bartow. Bradenton. Cocoa. Fort Myers, Miami. Orlando. Port Charlotte, Pori St, Lucie. Sarasota. Tallahassee. Tampa. W =:,m Beacn

r
Texasgulf Inc.
File Number 88-089 -2-
further vertical migration of contaminants toward the Castle Hayne aquifer. Restoration of
groundwaters within the overlying soils, as proposed in the Supplemental Remedial Actin
Plan, would have resulted in the improvement of groundwater quality in the Croatan formation
as the sources of contaminants (i.e., contaminants seeping downward from the overlying soils)
were removed.
To eliminate the concerns of the DEM regarding restoration of groundwater in the Croatan
formation, a series of injection and withdrawal wells will be installed in -the Croatan formation
to remove existing contaminants. It is expected that two series of 7 injection wells on about
100-foot centers fully penetrating the Croatan formation will be installed on the north and south
sides of the tank farm area as conceptually depicted in the attached Figure 1 and Figure 2.
Groundwater from the Castle Hayne aquifer with a total dissolved solids concentration on the
order of 500 mg/t will be injected into each of these wells at a rate of about 0.5 gal/min/well*.
A series of 7 withdrawal wells on about 100-foot centers fully penetrating the Croatan formation
will be installed along the north side of the main east -to -west piperack (Figure 1).
Contaminated groundwater will be withdrawn from these wells at a rate of about
1.0 gal/min/well. Groundwater removed from the wells will be pumped to either Cooling Pond
No. 1 or Cooling Pond No. 2. Piezometers will be installed at the locations depicted in
Figure 1 to verify that the injection/withdrawal well system is altering the piezometric water
levels in the Croatan formation as projected.
The injection/withdrawal well system will be operated as long as needed to restore groundwater
quality to the level of the NCAC Subchapter 2L.0202 water quality standards for Class GA
groundwater. Accordingly, the injection/withdrawal well system will be operated until target
clean-up values for total dissolved solids and sulfate of 500 mg/1 and 250 mg/l, respectively, are
achieved. Groundwater chloride and fluoride concentrations in the Croatan formation do not
exceed Subchapter 2L.0202 standards and therefore do not require restoration. Groundwater
standards for total organic carbon and total phosphorus are not specified in Subchapter 2L.0202.
Based upon existing water quality data for the Croatan formation, however, the concentrations
of these constituents would be expected to improve to about 4 mg/l and less than 1 mg/1,
respectively, when the total dissolved solids target clean-up concentration of 500 mg/1 is
achieved.
Item 2. Please provide information as to the discharge point of the existing drainage ditch
along the north side of the tank farm area. What are the characteristics of the
discharged water (as it appears to be a relief point for the contaminated surficial
sand unit)?
The discharge point for the drainage ditch along the north side of the tank farm, as permitted `s
under the existing NPDES permit, is at a monitored sump/culvert structure at its east end near
the railroad tracks about 400 feet east of sulfur tank No. 3 (Figure 1). Water contained in the') Lc 1
Nie-07
* Groundwater in the Castle Hayne aquifer at many of the utility wells in the tank farm area
displays a total dissolved solids concentration of 750 to 950 mg/1 due to elevated sodium and
chloride concentrations resulting from upconing of saline groundwater from the underlying
Beaufort formation. Groundwater used in the injection wells, therefore, will be obtained
from other Castle Hayne aquifer sources with lower total dissolved solids concentrations.

State of North Carolina
Department of Environment, Health and Natural Resources
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889
James G. Martin, Governor
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
December 8, 1989
Mr. i; . A. Schimming, Manager
Environmental Affairs
Texasgulf Inc.
Post Office Box 48
Aurora. North Carolina 27806
Re: Supplemental Remedial Action Plan
Tank Farm Area
Dear Mr. Schinnning:
Lorraine G. Shinn
Regional Manager
A review of the November 3, 1989 Supplemental Remedial Action Plan for the
Tank Farm Area has been completed. The results of the installation and testing
of the monitor well clusters and wellpoint site provided further definition of
the extent of contamination in the surficial and confined sands and the Croatan
Formation.
The proposed Remedial Action Plan conceptually is designed to contain and
restore contaminated groundwaters in the surficial and confined sand layers and
prevent migration into the surface waters of the barge slip. The contaminants
in the Croatan Formation are not addressed in this Supplemental Remedial Action
Plan. The Croatan Formation test results clearly indicate unacceptable levels
of phosphorus (34.3 mg/L), sulfates (874 mg/L), total dissolved solids (2337
mg/L), and total organic content (13 mglL). Background levels for these
parameters have already been established as 0.1, 0.0, 349, and 4.11 mg/L,
respectively. It is requested that Texasgulf provide further defense, as
outlined in NCAC 2L .0113 Variance, of the proposal to implement a passive
remediation or no action approach to restore groundwater quality in the Croatan
Formation. The Washington office will not recommend granting such a variance.
It is most likely that the Director would not sign a variance request.
Otherwise, please include provisions in the final remedial action plans for <<
restoration of the Croatan Formation. n tiyf� !
P.O. Box 1507, Washington, North Carolina 27889-1507 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Environment, Health and Natural Resources
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Division of Environmental Management
Groundwater Section
November 30, 1989
Mr. Terry Baker
Texasgulf Incorporated
Post Office Box 48
Aurora, North Carolina
RE: Quarterly Monitoring at Tank Farm / SPA Area
Dear Mr. Baker,
Lorraine G. Shinn
Regional Manager
The Division requests that sampling of the three monitor
well clusters and FERT-1 continue on a quarterly basis, as
proposed in the October, 1988 Remedial Action Plan. The
November 3, 1989 Supplemental Remedial Action Plan is
currently under review and a response to TG should be made by
December 8th. As is typical in a pollution incident, any and
all results of sampling on a site is requested by the
Division to aid in interpreting conditions and reviewing
plans. Therefore, please submit previous data from these
wells that is not contained in the Supplemental Remedial
Action Plan.
Sincerely,
Hydrogeological Technician II
P.O. Box 1507, Washington, North Carolina 27889-1507 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Natural Resources and Community Development
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889
James G. Martin, Governor Lorraine G. Shinn
William W. Cobey, Jr., Secretary Regional Manager
CERTIFIED MAIL DIVISION OF ENVIRONMENTAL MANAGEMENT
RETURN RECEIPT REQUESTED September 1, 1989
Mr. W.A. Schimming, Manager
Environmental Affairs
Texasgulf Incorporated
Post office Box 48
Aurora, North Carolina 27806
RE:
Notice of Violation
15 North Carolina Administrative Code 2L
Groundwater Classifications and Standards
Return Transfer Pipe Leak
Texasgulf Mine Site
Aurora, North Carolina
Beaufort County
Dear Mr. Schimming:
North Carolina General Statutes, Chapter 143, authorizes and
directs the Environmental Management Commission of the Department
of Natural Resources and Community Development to protect and
preserve the water and groundwater resources of the state. The
Division of Environmental Management has the delegated authority
to enforce adopted pollution control rules and regulations.
Based upon a field investigation of your facility located
off NC 306, north of Aurora, North Carolina, by the Groundwater
Section of the Washington Regional Office, on June 7, 1989, the
Division has reason to believe that Texasgulf Incorporated, is
responsible for activities resulting in noncompliance with North
Carolina law.
P.O. Box 1507, Washington, North Carolina 27889-1507 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

CERTIFIED MAIL
Mr. W.A. Schimming
Texasgulf Incorporated
Page 2
September 1, 1989
On June 5, 1989, the Division was informed that a ldak of in
excess of 5,000 pounds of phosphoric acid had been discovered in
an underground transfer 'line. Upon investigation, Texasgulf
reported to a staff member that samples indicated the leaked
solution had a pH of 2.2, a fluoride content of 1,660 parts per
million, and a phosphorous content of 4,900 parts per million.
These contaminant levels are sufficient to cause the Division to
suspect groundwater contamination. Such contamination is a
violation of NCAC 2L Groundwater Quality Standards and the Oil
Pollution and Hazardous Substance Control Act of 1978.
The specific violations noted are as follows:
1. 15 NCAC 2L .0103(d) No person shall conduct or cause to be
conducted, any activity which causes the concentration of
any substance to exceed that specified in Rule .0202 of this
Subchapter, except as authorized by the rules of this
Subchapter.
Your company is responsible for this violation because its
operation of the transfer pipe allowed discharges of
hazardous substances to occur. As property owner, you
should undertake efforts to abate the source of
contamination, assess environmental impacts, and any
subsequent remedial action should begin immediately.
Specifically, to correct the above violations, you must
perform the following:
1. The groundwater assessment and monitoring data gathered in
the matter of the Tank #008 leak is sufficient to
characterize impacts from the transfer pipe leak due to its
close proximity. The Division has concluded that the
combination of this new incident and the impacts from the
Tank #008 incident are sufficient cause to require
development of an active remedial action effort to abate
groundwater contamination from both sources. You are
required to submit to the Department for review and approval
a Remedial Action Plan (R.A.P.). The R.A.P. must address
treatment and disposal of contaminants to include all soil,
liquid, and dissolved fractions. The plan should also
include methodologies, construction and operational details,
show the location of any disposal site(s), and should
provide a timetable for each job phase.

CERTIFIED -MAIL
Mr. W.A. Schimming
Texasgulf Incorporated
Page 3
September 1, 1989
Action plans submitted to our office for review must be
accompanied by all documentation, maps, letters of agreement
(for example, disposal site agreement), etc. All analyses,
methodologies, monitoring plans, and procedures to be
encountered during remediation must be addressed in the
R.A.P. To aid you in preparing the R.A.P., please find
attached a guide entitled, "Outline for Evaluation of Site
Characterization Data and Remedial Action Plans for
Groundwater Restoration." Items 8-10 of the outline should
be addressed.
Your Remedial Action Plan must be submitted for reviewo,/ay
within thirty (30) days of receipt of this letter.
2. The Remedial Action System must be implemented within _ tip,
thirty (30) days of the receipt of the approval of the g!ft"i_y n
Remedial Action Plan by the Division. �z�EPU.010
3. The Remedial Action System must be completed and in cc'
operation within sixty (60) days of the approval of the ,-'XE!
Remedial Action Plan by the Division. ygc
Failure to to respond within the time specified and to
voluntarily achieve compliance may result in issuance of a civil
penalty assessment under authority of G.S. 143-216.6(a) of not
more than $10,000.00 per day for as long as the violation(s)
continues, the issuance of a special order against the company
under the authority of G.S. 143-215.2; or a request to the
Attorney General to institute an action for injunctive relief.
It is the policy of the Department to enter into a Special
Order by Consent (SOC) with the responsible party. This
agreement between the responsible party and the Division of
Environmental Management establishes specific schedules and
guidelines for achieving compliance with the standards. Entering
into a consent order with the Division may result in the
suspension of Enforcement Action during compliance with the
agreement. in the future, we will be sending you a draft Soc for
your review and comment. In the interim, you must take the
necessary action to comply with this Notice.

CERTIFIED MAIL
Mr. W.A. Schimming
Texasgulf Incorporated
Page 4
September 1, 1989
You should contact us immediately of your intention to
comply. Your response and/or questions should be directed to the
or to Rudy Smithwick, Regional Hydrogeologist, at the
Northeastern Regional Office at [phone].
Sincerely,
Regional Supervisor
Enclosures
cc: Thomas Hilliard, Office of Legal Affairs
Bill Jeter, Incident Management Unit
Roger Thorpe, Water Quality Section, WaRO
WaRO File

Iv 17 /<
35�2- Z
POLLUTION INCIDENT/U.S.T. LEAK REPCnKTING FORM
1. Incident #
2.Tabulate only
TYPE OF ACTION
Division of Environmental Management
GROUNDWATER SECTION
A
1. Emergency Response
2. Compliance Investigation 4. Routine Inventory
3. Complaint Investigation 5. U.S.T. Leak
®Other:
POTENTIAL HAZARDS:Qoxic Chemicals 2. Radioactivity 31Alr Emmisslons 4. Explosives 5. Fire
INCIDENT DESCRIPTION
t3
Incident
6L/�F- //UC RE uit1
t f�
Location/Name 7 43
7R4,5 f-R PIPE I-e'A,4K
Address
Pa BOX q8
fll
City/Town u R 0 R A
County
1
j2 ffAu t -o Rr
Region koters iuGiv N
Briefly Describe Incident A. l-EAK IA) r . Pot 0 ✓/WJf rEQ R C /URN L-//tJL
iit1R5 DIscoirprD WHEN /; CA11)TL/ elPEA)ED 1IU HE
GRouND,
Date Incident r If L.U.S.T.. How leak
Occurred or Leak I Was Detected
Detected
ot4S '
/� / I
lam' /c / 3c 1
( ((
1. Tank Gauging 5. Interstitial
2. Vapor Monitoring 6. Tank
3. GW Monitoring � 7. Tightness
4. Contractor who tightness tested.
detection system.
Monitoring 8. Othef
Removal
Test
removed tank. or Installed leak
PERSON REPORTING INCIDENT
Name
56HlMM I11J6
Company/Agency r ey [a 1 NC r
Date j _5_8G I iim(// :LiS
REPORTED BY: 1. Tank owner/operator 2. Government agency 3. Private (3rd) party'
Docility owner (Non-L.U.S.T.) 5. Other:
Telephone 519,y 22 jot
RECOMMENDED ACTION
D
ULTIPLE CHOICES POSSIBLE)
vestigation
7. Confirm leak
® Monitoring plan
complete / 311nftiate/.,.i pI F cleanup 5. Drilling support
2. Continue Investigation ®'Long-term remedial action r• ue NOV
Comments
cure em L
THE SITE IS CLOSE TV THE TmUk # oo & Lbi4K
RETW-Di4L 4CT/al) 4T #00e Gt1/LL P130 Fix-rik
LiAJDER ftsSEssrnaN o 4/J
1. esponsible Party
CLEANUP LEAD
2. State
Site Priority
Ranking
D.E.M. Regional Cobtact
•2lcNAR.3 Pt evwEps
Signature
kaamaa RI aufrema
Date
c-g-e7
L2Wk
GW-61 Revised 5/89 -

E
PG__JTION INCIDENT/U.S.T. LEAK REP - JING FORM
POLLUTANTS INVOLVED
• MATERIALS INVOLVED AMOUNT STORED 6R AMOUNT LOST AMOUNT RECOVERED
�AAN
CODL!A16 WATER
307,000,00o Mk00LLral fJO$JE
IMPACT ON SURFACE WATERS
F
WATERS AFFECTED
1. Yes
M 3. Potentially
Distance to Stream(ft)
'f" ! 750 .
Fish Kill
1.Yes
.No
Name of Stream
FAfvIL/Go P/oEf
Stream /loss
IMPACT ON DRINKING WATER SUPPLIES
G
WELLS AFFECTED 1. Yes 2. No 3. P tentlally
No. of Wells
Affected ,..---1
..--•2
No. of Weirs
Potentially Affecrad
M) 'b;TR/P`
Population Served
By Affected Wells
Estimated Population Served By
Potentially Affected Wells O
Aquifer(s) Being Us-
1. Water Table 2. Confined 3. Bedrock
POTENTIAL SOURCE OF POLLUTION
H
PRIMARY SOURCE OF
PRIMARY POI I IJTANT TYPE
LOCATION
$ET1INQ
1. Residential
2. Industrial
3. Urban
GRurol
POTENTIAL POLLUTION (Select one)
(Select one)
1. Pesticide/herbicide
2. Radioactive waste
3. Gasoline/diesel
4. Heating oil
5. Other petroleum prod.
6. Sewage/septage
7. Fertilizers
8. Sludge
9. Solid waste leachate
10. Metals
m)Sther InorganicsA
12. Other organics
1. Intentional dump 13. Well
2. Pit, pond, lagcon 14. Dredge spoil
' Leak -underground 15. Nonpoint source
4. Spray Irrigation
5. Land application
6. Animal feedlot
7. Source unknown
8. Septic tank
9. Sewer line
10. Stockpile
11. Landfill
12. Spill -surface
@acility
2. Railroad
3. Waterway
4. Pipeline
5. Dumpsite
6. Highway
7. Residence
8. Other
Confirmed Violation of:
1. 15 NCAC 2V
•l,, Yes No
2. Article 21XPart I
Yes No
3. Article 21Apart II
X No
If other sources. list corresponding No's..
' OO9 LMK
I Ncl 'p/r No, 366.3 TANK
If multiple pollutant types. Ilst corresponding No's.
4. Federal/State U.S.T. rules
Yes an No
If PIPE prevlously submitted for Nonprimary Sources. fist Incident No's.

s
POLLUTION CIDENT/U.S.T. LEAK REPORTING --'RM
POTENTIAL SOURCE OWNER -OPERATOR
1
Potential Source Owner -Operator
Telephone
/_ 322-wil
Company
i S6aLF l jc,,
Street Address P0B�X 1 43
Ciiy�r,kO,Cf
/
County. fJE�•ttr Fe i�`(�
State tJ C.
Dip Code 2,�g06
U.S.T. REGISTERED
SOURCE/U.S.T.
PERMIT TYPF
OWNERSHIP
OPERATION TYPF
1. YES
2. NO
IN USE
1. N/A
0. N/A
0. N/A
O. N/A
FACILffY ID#
2. YES
3. NO
la. !on -discharge
1. Municipal
1. Public Service
SOURCE PERMITTED
FEDERAL U.S.T.
DESIGNATION IVA
1. Yes
2.No
2. Oil terminal
3. Landfill
2. Military
ry
3. Unknown
2. Agriculirural
1. Regulated
2. Non -Regulated
PERMIT NUMBER
0 ring
4. rivate
3. Residential
4. Educational/Religious
STATE U.S.T.
DESIGNATION r�/R-
SOURCE ON
ERRIS LIST
1. Yes
2. No
PDES
6. RCRA
5. Federal
6. County
I `b. )ndushlal
6. Commercial
1. Commercial
2. Non -Commercial
ERRIS NUMBER
7. State
alining
FASON FOR INCIDENT
U.S.T. LEAK PREVENTION MEASURES
Was tank retrofitted with overfill protection?
2.
1No . Yes �/�
When and by whom?
1. Transportation
a echanlcal failure
Was tank retrofitted with interior lining?
1. Yes
2
2. No NAq
When and by whom?
3. Facility
4. Inventory only
Was tank retrofitted with cathodic protection?
1.Yes
2.No N fir6.
When and by whom?
5. Human error
Vandalism
7. Unknown
ACTIONS TAKEN
J
Investigation, Containment, Cleanup. etc.
(12 5wivr- DOWAf FL-0LV3
REPAIRED PI Pe3E'CT /LN ,
WTNIT0k 1/NcjbEfJ7-# 3663-774 NR #00C3 1-mey
0Aloft)
2EMEN - Acr/0Al rT IA)cl DeiUr # 3663 51-tOutb
8E EFPFc7',VF IN RK-MEMATIA16 13115 S/TF.
Circle Appropriate Responses
Lob Samples Taken By: 1. D.E.M. 2. D.H.S. 33. esponsible Party 4. None
Samples Taken Include
groundwater 2. Soil 3. Surface Water
-• • rauuKe-•C' :. •._ ... _.

1/U.J. I. Ltf\IS I<tYVI<IIIVh
LOCATION OF INCIDENT
K
7 1/2 Min. Quad Name Q n r
: Deg : Min : Sec : 3 S` 22 ' Y6 "
LQop.' Deg : Min : Sec : 0 in 0 4716 ASS "
Five Min. Quad Number
Draw Sketch of AreQ
•
I E
PETIAL C WEP
Sketch Should Identify The Following:
1. Pollutant Source(s) 2. Impacted and Threatened Water Supplies
3. Direction of Overland flow 4. Significant Recharge and Discharge Features 5. Relative Physical Structures (roads.
buildings. etc.)
6. North Arrow 7. Scale
�• 7ur'0r-moar=:�.

I4(100 r.
Durham 1933
/0
I3
x
(AURORA)
5654 IV SE
SCALE 1:24 000
0
1 MILE
1000 2000 3000 ' 4000 5000 6000 7000 FEET
0
1 KILOMETER
CONTOUR INTERVAL 5 FEET
P'n*TIONAL GEODETIC VERTICAL DATUM OF 1929
;TtID SOUNDINGS IN FEET —DATUM IS MEAN LOW WATER
.,;: NSHIP BETWEEN THE TWO DATUMS IS VARIABLE
v(0:_0 ESENTSS•THEI APPROKIMATF•N1NF. OF'ME?.N HIGH WATER
NC d7)
/4
339.
X9
4
11 p
11
n /.1..
p4'
R
• INTERIOR —GEOLOGICAL SORVCV., RESTON. VIRGINIA—l003
• 3401wmm.E
ROAD CLASSIFICATION
Heavy-duty..._4LANEp6LANE Light -duty
Medium -duty LANE1G LANE Unimproved dirt aoeRRee
1._ 3 U. S. Route v State Route

9;
t.z
,N
•
03 ... O
tl

State of North Carolina
Department of Natural Resources and Community Development
Northeastern Region
1424 Carolina Avenue, Washington, North Carolina 27889
James G. Martin, Governor
S. Thomas Rhodes, Secretary
Wet&a
Lorraine G. Shinn
Regional Manager
CERTIFIED MAIL DIVISION OF ENVIRONMENTAL MANAGEMENT
RETURN RECEIPT REQUESTED August 8, 1988
Mr. William A. Schimming
Texasgulf, Incorporated
Post Office Box 48
Aurora, North Carolina 27806
RE: Notice of Noncompliance
North Carolina Administrative Code Title 15 Subchapter 2L
Classification and Water Quality Standards Applicable to
Groundwater of North Carolina
Texasgulf, Incorporated
Aurora, North Carolina - Beaufort County
Dear Mr. Schimming:
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
authority to enforce adopted pollution control rules and
regulations.
Based upon an investigation of your acid -fertilizer complex
at your facility located off N.C. 306 north of Aurora, N.C., and,
known as the Lee Creek Mine, the Division has reason to believe
that activities have occurred resulting in noncompliance with
North Carolina law. The inspection conducted by staff of the
Groundwater Section in the Washington Regional Office revealed
that an above -ground tank (referred to as *008) used to process
phosphoric acid had leaked, resulting in the discharge of an
undetermined quantity of acid. Shallow excavations constructed
beneath the tank floor revealed accumulation of phosphoric acid.
P.O. Box 1507, Washington, North Carolina 27889-1507 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

CERTIFIED MAIL
Mr. William A. Schimming
Texasgulf, Incorporated
August 8, 1988
Page 2
Specific violations noted are as follows:
1) NCAC 2L .0103(b) No person shall cause the
concentration of any toxic or deleterious substance
to exceed that specified in Rule .0202 of this sub-
chapter, except in accordance with a compliance
schedule authorized by the Director.
2) NCAC 2L .0202(d) Class GB waters - No increase above
the naturally occurring concentration of any toxic or
deleterious substance unless it can be shown, upon
request, to the satisfaction of the Director that the
increase:
a) will not cause or contribute to the contravention
of water quality standards in adjoining waters of
a different class;
b) will not accumulate in a manner such that unusual or
different hydrological conditions may cause a threat
to public health or the environment; and
c) will not cause an existing or potential water supply
to become unsafe or unsuitable for its current use.
The responsibility for complying rests with Texasgulf, Inc.
Efforts to abate the source of contamination and to perform
subsequent remedial actions should commence immediately. You are
requested to submit a written response to this Notice describing
your plans to achieve compliance with the above cited laws or
regulations within 10 days from receipt of this letter.
Specifically, to correct the above violations, you must
perform the following:
1. Submit an assessment report characterizing groundwater
conditions in the area of the tank(s) to identify the
vertical and horizontal extent of contamination resulting
from the unauthorized phosphoric acid discharge(s).
Enclosed for your benefit is a guideline
ment of the assessment. Items 1, 2, 3d,
in the outline should be addressed.
The assessment must be submitted to this
days of receipt of this notice.
for the develop-
4, 5, 6, and 7
office within 30

CERTIFIED MAIL
Mr. William A. Schimming
Texasgulf, Incorporated
August 8, 1988
Page 3
2. Submit a Remedial Action Plan (RAP) outlining the
proposed corrective actions to be undertaken. The
RAP should include all designs, methods, techniques,
and systems to be employed during remediation. Items
8, 9, and 10 of the outline should be addressed. A
timetable for the implementation of all remedial actions
must accompany the plan.
The Remedial Action Plan must be submitted to this office
within 60 days of receipt of this notice.
Failure to respond within the above specifications may result
in issuance of a proposed penalty assessment by the Director under
authority of G.S. 143-215.6 which provides that a civil penalty of
not more than $10,000 may be assessed against any person who violates
any classification, standard, limitation, or management practice
established pursuant to G.S. 143-214.1 or 143-215. If any action or
failure to act is continuous, each day may be considered a separate
violation.
Your response and/or questions should be directed to me or
to Rudy Smithwick, Regional Hydrogeologist, at the Washington
Regional Office, at [phone].
lK�
kR/ekw
Sincerely,
ORIGINAL " BY
JIM ML
Jim Mulligan
Regional Supervisor
cc: Office of Legal Affairs
Bill Jeter, Incident Management Supervisor
WaRO File✓
bc: LORRAr$JE 54101

POLLUTI,fl�J INCIDENT REPOLL__ING FORM
1. Incident IP
2. Tabulate only
TYPE OF ACTION
Division of Environmental Management
GROUNDWATER SECTION
A
°Emergency response
3. Complaint invpstigation
2. Compliance investigation 4. Routine Inventory
5. Re-evaluation :
6. Other •
POTENTIAL HAZARDS GToxie chemicals 2. Radioactivity 3. Air emissons 4. Explosives 5.Fire
INCIDENT
B
Incident Name
.-XASEGU LF co. - TANK #Oo g L-E14K
Address
Po Box wg
City/Town
AUPU RA, Nc z>aot,
Cory._
AG(FOPT
Region
kil4Si-l/NGm,J
DEM Regional Contact
RIGHRRP Poi ERS
PERSON REPORTING INCIDENT
C
Name Date
lif)/ iA/!^ scHiMlviiMG 5-3i- 68
Time
15-,15
1
Company/Agency
1 SXASGULP , Cc;,
Telephone y/9
3zz—q1///
Briefly Describe Incident
T/4/JK
OOR,
Du to I rNG REPp-hk / PIRrittr�/v.ticff . er #
1T
WA5 C)15COV REO THERE k) RE HCLES iN rpmK
E,O7+OM P1-t-nulitic, 1.066 Of PN LIAIPErg' RM/ivEih
Amow&i vs= S`i% PH0.P:f0Ric pc,ppj Q&' R AN
UIIDOTERMuNEb LENGTH OF Tlms-,
REPORTED BY: 0 Responsible party 2. Government agency 3. Private party
RECOMMENDED ACTION
*ABOVEGROONP TANS
p
1. Investigation complete ©Initiate/complete cleanup 5. Technical support 7. Enforcement action
0 Continue Investigation Long-term remedial action 6. Drill crew 8. Monitoring plan
Comments
(DGCSE OF TANK Pf6Cot Tl&UEdj C29 CoM5tw-r4AJT TV
Pr55ESS 0 REPPIRS TO $E /YJADE IAiatJbE 1N5779G-
1./47-7 D N O F NEW l-I QvER
LAB SAMPLES: 1. Yes &No
pna re
r �%I e9.we- Q
Date
Fee
GW-61 Revised 11/85
North Carolina Department of Natural -Resources e}itCommunity Development

Inc iilent-4%
s:.
Co6nty; PE.AGFURT_
OLL_ ,ION INCIDENT REPORTING IRM
POLLUTANTS INVOLVED
E
MATERIALS INVOLVED AMOUNT STORED
SN9c PNosPNo c ALI & 3SO,OOD6I3L,
AMOUNT LOST
1,{Ai1CAIOU Al
AMOUNT RECOVERED
IMPACT ON SURFACE WATERS
WATERS EFFECTED 1. Yes 0 No No 3. Potentially
FISH KILL: 1. Yes No
Distance to Stream (ft)
Name of Stream
PAMLICO PrvgR
RISK ASSESSMENT
Amount in Water (gal)
NoAJE
Stream Class
Use these Codes:
High= 3 Moderate=2
Low=1 None=0
Resource Threat
Vertical Migration of Contaminant
Horizontal Migration of Contaminant
Areal Extent of Contamination
Probability of Violations
Remedial Action Priority
Potential Hazard of Substance
Threat to Drinking Water
Seriousness of Threat
Overall Regional Concern
GROUNDWATER
2
2
3
2-
2-
2_
z
Amount Infiltrating Land
SURFACE WATER
AIR
Please Circle the Appropriate Response(s):
1. This -incident poses additional threat to human health by: (1) inhalation (2) absorption (3) ingestion
2. This incident poses additional threat to the environment by potential adverse effects on :
(1) sensitive areas (2) wildlife (3) fish
POTENTIAL SOURCE OF POLLUTION
SOURCE OF POTENTIAL POLLUTION
1. Intentional dump 9. Sewer line
2. Pit. pond, lagoon 10. Stockpile
3. Leak --underground 1), Landfill
4. Spray Irrigation
5. Land application
6. Animal feedlot
7. Source unknown
B. Septic tank
TANK LEAX
Spill --surface
13. Well
14. Dredge Spoil
15.Nonpoint source
TYPE OF POLLUTANT
1. Pesticide/herbicide
2. Radioactive waste
3. Gasoline/diesel
4. Other petroleum prod.
�
5. Sewage/septage
(I 6, Fertilizers
7. Sludge
B. Solid waste leachate
9. Metals
10. Other Inorganics
11.Other organics
MULTIPLE SOURCES AT SITE:
10 Yes 2. No
LOCATION
1&. Facility
2. Railroad
3. Waterway
4. Pipeline
5. Dumpsite
6. Highway
7. Residence
8. Other
SETTING
1. Residential
702 Industrial
/3/Urban
`4. Rural
POLLUTION CONFIRMED
Yee 2. No
2

POLLUT' 4 INCIDENT REPORTING FORM
Responsible Party/Names
ugoRA
REASON FOR INCIDENT
1. Transportation Accident
Mechanical failure
3. Facility design
4. Inventory only
5. Human error
6. Vandalism
7. Unknown
RESPONSIBLE PARTY
SOURCE IN USE
o N/A
Yes
2. No
SOURCPERMITTED
t Yes
2. No
PERMIT NUMBER
SOURCE ON
ERRIS LIST
1. Yes
2, No _
ERRIS NUMBER
PERMIT TYPE
0. N/A
ondlscharge
2. Oil terminal
3. Landfill
0 Mining
NPDES
6. RCRA
7. Air
ACTIONS TAKEN
State
G
OWNERSHIP
0. N/A
1. Municipal
2. Military
3. Unknown
V Private
5. Federal
6. County
7. State
Telephone /?
3ZZ dill
Zip Code
271306
OPERATION TYPE
0. N/A
1. Public Service
2. Agricultural
3. Other Source
4. Educational
5. Industrial
Commercial
Mining
Containment, Cleanup, etc. Tr , K,. ^ 2C E`�. IrCP To 2
.501L UM ON 6YPsuM P/t-E-
--ET, SPOIL TD 6E P/.fKE
50 Pig h5 r/ To N E U TRA L I LE i-Du) , 79 0r
SOIL fEMAIAJ/NG ML)hEA. T7}NK Borronv
3 TA°)K To A 5TR/'PEP Gt-EAA) A,uD NEu>
t t P U DBE R" L/ N E R /&6ThLLEP
a f ROPMPAJ r 1}ssooprgs TQ f9-6se65 i MlI°14C-73
r Tk&K LEA Diu 6-'ouuPooAi 'S
" K 008 350K 6A1L0415
Nearest Populated Buildings --Type and Distance
Preclpltion/Weather Data
PRrva coivsuLrior
CLEAR , Nor, L-16Hr W1194
3

POW' •Nr)N INCIDENT REPORTING 1:ThiM
LOCATION OF INCIDENT
Street Address, Road
PLAWr sl-rr ore Nit 30e
Time Incicipnt Occurred
Date incident Occurred
N/A-
_
City/Town
AURORA
7 1/2 Quad Name
gkrH
Draw Sketch of Area
6 E-4- IITTAci-MIE/v73
County
BEAWFOR7
Lat. : Deg: Min: Sec:
as-° 72- lig-
Long• : Deg: Min: Sec:
0175° Yr 3o
ATTACH PHOTOCOPY OF MAP SHOWING: 1. Pollutant source 2. Threatened Water Supplies
3. Direction of thieilirid:FlOW

POLLUTION INCIDENT REF-:' .;,:TING FORM
SOIL TYPES
COASTAL PLAIN REGION PIEDMONT SOIL REGION
1. Middle Coastal Plain 10. Felsic Crystalline
2. Upper Coastal Plain/Piedmont 11. Carolina Slate Belt
-
3. Sandhills 12. Triassic Basin
,r4. Lower Coastal/Wicomlco. Talbot 13. Mixed Felsic and Mafic
�/ 5./ Lower Coastal Plain/Pamlico
l./ MOUNTAIN SOIL REGION
6. Organic Soil
7. Brackish and Freshwater Marsh 14. Low and Intermediate Mountain
8. Outer Banks 15. Basins/Terraces/Flood Plain
9. Large River Valleys/Flood Plain 16. High Mountain
LANDFORM
1. River/coastal terrace
QCoastal (flat) plain
3. Mountain range
4. Sandhills
5.'Swamp
6. Linear (valley) slope
7. Head slope (concave)
8. Nose slope (convex)
9. Foot slope
10. Barrier island
11. Barrier system
12. Beach ridge
13. Tidal marsh
14. Floodplain
15. Upland: 0-5% slope
(Interstream divide)
OBSERVED
To nearest
Water
To
Stream
AVERAGE GRADIENTS ESTIMATED
water supply: '" ' Y To uppermost
To
DEPTHS
confining bed: .- ft
table gradient- G� Z %
water table• ft.
nearest stream' 0- %
To bedrock: ?-' ft
gradient 0-.2 %
ESTIMATE HYDRAULIC CONDUCTIVITIES
AQUIFER USE
1. Little or no use
Moderate uses
01.
3. Heavily used
Soli
high
ID medium
3. low
4. unknown
Unsaturated zone
1. high
0 medium
3. low
4. unknown
Water Table
1. high
o2 medium
3. low
4. unknown
Upper confined aquifer
1. high
@medium
3. low
4. unknown
DISTANCE TO NEAREST WATER
SUPPLY: 2101)0
ft
DISTANCE TO NEAREST
BUILDING: 00 ft
Describe peneral lithology of soil and unsaturated zone
0- 3 FILL
3' Ile GRAY-BRowN sagCLAY
/2'-/7s' GLAYEy PooK S?NP GR4Y f ARowiW N %ELc°mi
I75'-22' PARK GRPY , jNF smut
22- z7' GRAY p/Nt 3AAt)b
PRom ARP4/Y14Av BORING L.o6 F-012 P1W 2-1
Provide map showing: 1. Pollutant source 2. Threatened water supplies 3. Direction of overland flow

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WOWS 4/ X
6000
7000 FEET
1 KILOMETER
khr,WATER
;inkATER
1N DAR DS'i: •
11:X
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R-‘2EST. 2 • 5,
337 47'30' 338
1 MILE
QUADRANGLE LOCATION
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Gum Point
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• INTERIOR —GEOLOGICAL SURVEY. RESTON. VIRGINIA...19M
ROAD CLASSIFICATION
4 LANE 16 LANE Heavy-duty_ Light -duty
• LANE 6 LANE Medium -duty Unimproved dirt
0 U. S. Route 0 State Route
.--12--
BATH, N. C.
35076-D7-TF-024
1951 .
PHOTOREVISED 1 E
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MONITOR WELL
CLUSTR MW2-t 1
FERTILIZER
COMPLEX
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TAMS (1965)
ABORING Bx5
A
.4 TAMS (1965)
1BORING Bx4
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Site Investigation Report:
Texasgulf Company/Tank 0008 Leak
Aurora, North Carolina
Beaufort County
On June 1, 1988, I went to the Texasgulf Company mine site aL Lhe request
of Rudy Smithwick, the Washington Regional Office Hydrogeologic Supervisor. At
3:45 P.M., on May 31, 1988, Mr. Bill Schinming, Environmental Affairs Manager,
•called Ruddy to inform him of a leak of 54% phosphoric acid from an above -ground
tank at the fertilizer complex.
During the course of my visit, I learned the following:
1. The tank in question is identified as tank 4008. IL is a robber
lined, above -ground steel tank of approximately 350,000 gallons
capacity (45'x36') and is about 20 years old. It is an unpressurized
Lank that is used as a clarifier, with an open side at the top. As
acid fills Lite Lank, solids (primarily gypsum) settle to the bottom
and the supernatant flows out of the side (at the top), iut0 a sluice
Lo the next Lank.
2. -\ small weep was discovered during the third shift an May 12. L988.
The Lank is surrounded by a rubber or ceramic brick ring trough that
directs any spills, overflows. or above -ground Leakage into a sump
for recovery, so the leak was noted, but not immediately repaired.
On or about May 31. 1988. the tank was drained down.. the bottom sludge
removed to the gypsum pile, and the rubber liner removed from the area
neat the weep to allow :access to repair the weep.
As the Lank bottom was cleared, blisters in the rubber liner indicated
the potential for holes in the tank bottom. The liner was then removed
from the lower portion of Lhe Lank sides, the steel bottom was cut up
and removed. A small scoop was dug near the weep Lo allow access to
repair iL. Liquid filled the weep. A check of the pH of the liquid
indicated that it was acid. A further composite sample was Laken to
::•ri fy the pH of 1.
At this point in time. DEM was notified by Texasgulf (3:45 F.9.-5/31/38).
After looking the site over, a meeting with Bill Schimmiug. Barry Winn.
Dun Franklin, David Lancaster, and others. and myself was held at. the Fertilizer
Complex office. I informed them that work could proceed in repairing the lank
if the following was done:
1. Establish four points located on north -south and east -west axes, half
way between the Lank center and the outer edge.
2. Take soil samples aL the surface of each point. then every sis inches
in depth to a point about Lwo to Lhree feet deep and run a pH on each.
This is to provide a soil pH profile under the tank bottom.

Site Investigation Report-Texasgulf
June 2, 1988
Page 2
3. Have Ardaman and Associates (private consultants for TG) perform
an assessment of conditions of the soil and groundwater around
tank 0008. This assessment should have at least three points Or
borings to determine flow. IL is recognized that Ardaman hill
develop the assessment procedures after they arrive on.si:Le and
can have a chance to review the situation. Tltey are to seek DEM
:approval, though.
4. The repair process is to remove about a foot of soil from corder
the Lank bottom, place soda ash in the hole Lo neutralize the acid,
fill part of the hole in with clean sand fill. lay plastic street
in, and then finish filling the liole. A new steel bottom can then
he installed without touching acidic soil. I have reyuesi eel that.
Lhe soil be slug out to a deeper depth based on the pH values found
in 2 (above). The deepest_ extent of soi.1 removal would not go
below the base of Lite ring trough, outside the Lank. IL is about
Lo S 1/2 feet_ in depth.
Richard R. Powers
Hydrogeological Technician
June 2, 1988
SAMPLES: 1. Yes (;J ��N_
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