WI0700012_Monitoring (Report)_19941215

EXPLANATION OF QUARTERLY COMPLIANCE MONITORING REPORT DATABASE:
TEXASGULF INC. PHOSPHATE OPERATIONS, AURORA, NC
(BEAUFORT COUNTY)
On the database (EXCEL\TXGFPHOS.MON), the quarterly
compliance monitoring reports results for each year from 1989
through 1995 are presented. Parameters specified in the permit
conditions are listed in the leftmost column. The unit of
measurement (in parentheses) and the regulatory standard
concentration (in italics) are indicated below each parameter.
Data reported for each parameter are entered on successive
columns by quarterly date. Each parameter is reported for four
sampling sites on each date. The following table gives a
description of the monitoring sites at the tank farm.
Supply - represents the Castle Hayne Aquifer from which
injectate is derived.
WLCT - represents the storage tank where condensate is
mixed with the Supply from the Castle Hayne in order to
reduce concentration of certain parameters below the
regulatory limit.
CIW7 - represents fluid from the riser pipes of the
seventh and last injection well in the line and is
considered to represent the injectate.
MWTF-1C represents groundwater from the Croatan
Formation, into which the fluid is injected.
Monitoring of MWFT-1C was begun in 1989. The permit for
injection was effective from January, 1992, but injection and
monitoring of CIW7, Supply, and WLCT did not commence until
October, 1993. Therefore, the sampling requirements and
regulatory standards specified in the conditions apply only to
reports issued from October, 1993 forward. Note that only
monitoring of CIW7 and MWTF-1C is required; monitoring of Supply
and WLCT is not legally required, but is useful in determining
causes of exceedances reported from CIW7. On the database, the
required CIW7 monitoring site is highlighted in yellow and the
data for CIW7 and MWTF-1C which are not in compliance are
highlighted in green. This includes data that is not reported,
is in exceedance of regulatory limits (CIW7 only), or in which
stated detection limits are greater than the regulatory limits.
KAH
December 15, 1994

6
5
4
0 3
F
2
1
0
PCS_PHOS.PLT Chart 4
PCS PHOSPHATE, MWTF-1C
il,
A
1 1 1 1 1 1 1 1 1 1 1
2 3 4 5 6 7 8 9 10 11 12 13
1! 1 1 1 1 1 1 1 1 1 1—F i—H
14 15 16 17 18 19 20 21 22 23 24 25 2
Page 1

7.2
7
6.8
a 6.6
6.4
6.2
6
PCS_PHOS.PLT Chart 2
PCS PHOSPHATE, MWTF-7C
VP
AL. _ ______
I I I I I I I I I I Ia
a 2 3 4 5 6 7 8 9 10 11 12
13
I I I I I I I I I I I I I
14 15 16 17 18 19 20 21 22 23 24 25 2E
ts
age 1

625
600
575
550
525
Fv500
475
450
425
400
375
0
l
CS_PHOS.PLT Chart 3
Q
PCS APHOSPHATE, MWTF-1C
I�
ir
ti 2 3 4 5 6 7 8 9 10 11 12
'
D
1 14 15 16 17 18 19 20 21 22 23 24 25 2
1
Page 1
q`$

PCS_.
Parameter
Well ID
Jan-95
Apr-95
JuI-95
Oct-95
(units)
regulatory std
Field pH
Supply
6.9
7
6.9
6.8
WLCT
6.8
7
7.1
7
CIW7
7
7
7.3
7
pH 6-7
MWTF-1C
6.7
7.1
7.1
7.2
Temperature
Supply
18.5
19
20.5
19
(Centigrade)
WLCT
30
26
52
54
CIW7
18
20
35.5
27.5
<35.5
MWTF-1C
18.5
21.5
26
24
Total coliform
Supply
(cts per 100m1)
WLCT
< 1
< 1
< 1
< 1
CIW7
<1
<1
<1
<1
MWTF-1C
<1
<1
<1
<1
TDS
Supply
656
532
528
564
(mg/I)
WLCT
490
544
396
356
CIW7
614
608
246
396
<475
MWTF-1C
538
576
440
382
TOC
Supply
2
6
6.3
6.8
(mg/I)
WLCT
2
5.6
3.65
4.6
CIW7
1.7
6
2.7
4
<4.3
MWTF-1C
3.3
5.6
4.25
4
Chloride
Supply
94.1
94.8
84.4
92.7
(mg/I)
WLCT
72.2
81.7
57.7
59.8
CIW7
88.9
83.6
33.8
51.4
<55.0
MWTF-1C
84.7
80.8
55.3
43.2
Fluoride
Supply
0.62
0.58
0.59
0.61
(mg/I)
WLCT
0.48
0.5
0.42
0.41
CIW7
0.59
0.51
0.26
0.35
< 1.0
MWTF-1C
0.5
0.46
0.53
0.66
Sulfate
Supply
< 10
< 10
< 10
16.4
(mg/I)
WLCT
< 10
< 10
< 10
< 10
CIW7
<10
<10
<10
<10
<50.0
MWTF-1C
<10
<10
13.9
<10
Total Phosphorus
Supply
0.015
0.016
0.01
0.03
(mg/I)
WLCT
0.014
0.024
0.015
0.017
CIW7
0.014
0.019
0.069
0.115
<0.15
MWTF-1C
0.254
0.234
0.235
0.267
Page 13

PCS_PHOS.MON
Parameter
Well ID
Jan-95
Apr-95
Jul-95
Oct-95
(units)
regulatory std
Cadmium
Supply
(mg/1)
WLCT
<0.001
<0.001
<0.001
<0.001
CIW7
<0.001
<0.001
<0.001
<0.001
_
<0.005
MWTF-1C
< 0.001
< 0.001
< 0.001
< 0.001
Chromium
Supply
(mg/I)
WLCT
< 0.001
< 0.02
< 0.005
< 0.005
CIW7
< 0.001
< 0.02
< 0.005
0.0064
<0.05
MWTF-1C
< 0.001
< 0.02
< 0.005
< 0.005
Manganese
Supply
(mg/I)
WLCT
0.06
<0.01
< 0.005
< 0.005
CIW7
0.05
<0.01
<0.005
<0.005
<0.05
MWTF-1C
0.17
<0.01
0.14
0.07
Page 14

TXGFPHOS.MON
Parameter Well ID
Jan-94
Apr-94
JuI-94
Oct-94
(units)
regulatory std
Field pH
Supply
7.2
7.1
6.8
7.1
WLCT
7.10
CIW7
7
6.9
alii
ea
pH 6-7
MWTF-1C
6.7
6.5
6.8
6.9
Supply
17.5
19
19.5
21.5
(Centigrade)
WLCT
20.5
CIW7
16
19
OW
21.5
<35.5
MWTF-1C
20
21.5
22.5
22
Total coliform
Supply
(cts per 100mI)
WLCT
< 1
CIW7
<1
<1
<1
<1
MWTF-1C
<1
<1
<1
<1
TDS
Supply
562
494
586
560
(mg/I)
WLCT
500
CIW7
MI
384
396
ill
460
<475
MWTF-1C
540
504
534
TOC
Supply
5.5
(mg/I)
WLCT
5.16
CIW7
4.22
3.86
3
OM
<4.3
MWTF-1C
3.81
3.37
4
3.32
Chloride
Supply
84.1
67.6
91.8
95.1
(mg/I)
WLCT
85.7
CIW7
geffi#
54.6
47.7
OM
<55.0
MWTF-1C
79.1
78.2
76.8
66.2
Fluoride
Supply
0.59
0.6
0.57
0.57
(mg/I)
WLCT
0.53
CIW7
0.58
0.48
0.31
0.71
< 1.0
MWTF-1C
0.48
0.53
0.47
0.51
Sulfate
Supply
<10
<10
<10
<10
(mg/I)
WLCT
< 10
CIW7
<10
<10
<10
<10
<50.0
MWTF-1C
<10
<10
<10
10.6
Total Phosphorus
Supply
0.035
0.038
0.034
0.036
(mg/I)
WLCT
0.021
CIW7
0.039
BMW
0.05
0.024
<0.15
MWTF-1C
0.319
0.295
0.231
0.296
Page 11

TXGFPHOS.MON
Parameter
Well ID
Jan-94
Apr-94
JuI-94
Oct-94
(units)
regulatory std
Cadmium
Supply
(mg/I)
WLCT
< .001
CIW7
OM
<OW
moo
<.001
<0.005
MWTF-1C
<0.010
<0.010
0.002
<.001
Chromium
Supply
(mg/I)
WLCT
< .02
CIW7
<0.02
MK
0.002
<.02
<0.05
MWTF-1C
<0.02
0.51
0.004
<.02
Manganese
Supply
(mg/I)
WLCT
< .01
CIW7
<0.01
_<.0001
<.01
<0.05
MWTF-1C
0.12
0.12
<.0001
0.05
Page 12

TXGFPHOS.MON
Parameter
Well ID
Jan-93
Apr-93
Jul-93
Oct-93
(units)
regulatory std
Field pH
Supply
6.9
7.2
6.8
6.9
WLCT
CIW7
6.7
NIP
6.9
pH 6-7
MWTF-1C
6.9
7
6.5
6.9
Temperature
Supply
18
19.5
20.5
19
(Centigrade)
WLCT
CIW7
16.5
22
24.5
<35.5
MWTF-1C
20
21
20.5
20
Total coliform
Supply
< 1
< 1
<1
(cts per 100m1)
WLCT
CIW7
NW
<1
<1
<1
MWTF-1C
>120
<1
<1
TDS
Supply
520
532
574
492
(mg/I)
WLCT
CIW7
IMP
IR
el
OM
<475
MWTF-1C
535
508
520
468
TOC
Supply
3.9
3.92
4
4
(mg/I)
WLCT
CIW7
!
3.41
map
1.04
<4.3
MWTF-1C
3.52
3.09
4.8
1.2
Chloride
Supply
88.1
89.3
90.3
85.8
(mg/I)
WLCT
CIW7
MIN
ME
IN
NM
<55.0
MWTF-1C
82.1
86.3
80.8
80.3
Fluoride
Supply
0.6
0.45
0.53
0.59
(mg/I)
WLCT
CIW7
0.6
0.55
MIN
0.51
< 1.0
MWTF-1C
0.38
0.42
0.41
0.47
Sulfate
Supply
0.5
0.9
<10
<10
(mg/I)
WLCT
CIW7
0.5
0.7
`
< 10
<50.0
MWTF-1C
9.4
1.5
<10
<10
Total Phosphorus
Supply
0.036
0.062
0.022
0.032
(mg/I)
WLCT
CIW7
0.079
0.046
amp
0.038
<0.15
MWTF-1C
0.231
0.26
0.345
0.243
Page 9

TXGFPHOS.MON
Parameter
Well ID
Jan-93
Apr-93
JuI-93
Oct-93
(units)
regulatory std
Cadmium
Supply
<0.010
(mg/I)
WLCT
CIW7
Mir
It
mom
assim
<0.005
MWTF-1C
MIR
OM
NMI/
1111111111
Chromium
Supply
(mg/I)
WLCT
CIW7
iimi
MN
aim
<0.02
<0.05
MWTF-1C
NM
0.06
<0.02
<0.02
Manganese
Supply
(mg/I)
WLCT
CIW7
MIR
0.05
NM
<0.10I/
<0.10
<0.05
MWTF-1C
0.17
0.01
Page 10

TXGFPHOS.MON
Parameter
Well ID
Jan-92
Apr-92
Jul-92
Oct-92
(units)
regulatory std
Cadmium
Supply
(mg/I)
WLCT
CIW7
.A
<0.005
MWTF-1C
BDL
Chromium
Supply
(mg/I)
WLCT
CIW7
UMW
<0.05
MWTF-1C
BDL
Manganese
Supply
(mg/I)
WLCT
CIW7
0.01
<0.05
MWTF-1C
Page 8

TXGFPHOS.MON
Lk-
Gn� Q rEi W c 4. rncrti..i lv,�I
Parameter Well ID
Jan-92
Apr-92
JuI-92
Oct-92
(units)
regulatory std
Field pH
Supply
6.9
_
WLCT
CIW7
6.9
pH 6-7
MWTF-1C
6.7
6.8
6.5
6.7
Temperature
Supply
19
(Centigrade)
WLCT
CIW7
20.5
<35.5
MWTF-1C
19
20
20.5
20.5
Total coliform
Supply
(cts per 100mI)
WLCT
CIW7
IIP
MWTF-1C
BDL
TDS
Supply
540
(mg/I)
WLCT
CIW7
500
<475
MWTF-1C
594
560
540
490
TOC
Supply
6
(mg/I)
WLCT
CIW7
a
<4.3
MWTF-1C
5
3
2
4
Chloride
Supply
77.7
(mg/I)
WLCT
CIW7
Mali
<55.0
MWTF-1C
52.1
49.5
52.1
66.1
Fluoride
Supply
0.58
(mg/I)
WLCT
CIW7
0.58
< 1.0
MWTF-1C
0.301
0.312
0.3
0.35
Sulfate
Supply
1.1
(mg/I)
WLCT
CIW7
< 10
<50.0
MWTF-1C
68
61.8
67.3
9.6
Total Phosphorus
Supply
0.017
(mg/I)
WLCT
CIW7
0.127
<0.15
MWTF-1C
0.284
0.289
0.259
0.196
Page 7

TXGFPHOS.MON
Parameter
Well ID
Jan-91
Apr-91
JuI-91
Oct-91
(units)
regulatory std
Cadmium
Supply
(mg/I)
WLCT
CIW7
<0.005
MWTF-1C
Chromium
Supply
(mg/I)
WLCT
CIW7
<0.05
MWTF-1C
Manganese
Supply
(mg/I)
WLCT
CIW7
<0.05
MWTF-1C
Page 6

TXGFPHOS.MON
Parameter
Well ID
Jan-91
Apr-91
JuI-91
Oct-91
(units)
regulatory std
Field pH
Supply
WLCT
CIW7
pH6-7
MWTF-1C
6.9
6.6
6.8
6.8
Temperature
Supply
(Centigrade)
WLCT
CIW7
<35.5
MWTF-1C
19
19
20
20.5
Total coliform
Supply
(cts per 100ml)
WLCT
CIW7
MWTF-1 C
TDS
Supply
(mg/I)
WLCT
CIW7
MWTF 1C
532
--540
-- —606
— 586
<475
TOC
Supply
(mg/I)
WLCT
CIW7
<4.3
MWTF-1C
4
3.45
5
5
Chloride
Supply
(mg/I)
WLCT
CIW7
<55.0
MWTF-1C
59.9
59.1
60.4
53
Fluoride
Supply
(mg/I)
WLCT
CIW7
< 1.0
MWTF-1C
0.343
0.252
0.469
0.369
Sulfate
Supply
(mg/I)
WLCT
CIW7
<50.0
MWTF-1C
66.9
65.8
69.7
71.4
Total Phosphorus
Supply
(mg/1)
WLCT
CIW7
<0.15
MWTF-1C
0.262
0.279
0.296
0.321
Page 5

TXGFPHOS.MON
Parameter
Well ID
Jan-90
Apr-90
Jul-90
Oct-90
(units)
regulatory std
Cadmium
Supply
(mg/I)
WLCT
CIW7
<0.005
MWTF-1C
Chromium
Supply
(mg/I)
WLCT
CIW7
<0.05
MWTF-1C
Manganese
Supply
(mg/1)
WLCT
CIW7
<0.05
MWTF-1C
Page 4

TXGFPHOS.MON
Parameter
Well ID
Jan-90
Apr-90
JuI-90
Oct-90
(units)
regulatory std
Field pH
Supply
WLCT
CIW7
pH 6-7
MWTF-1C
6.8
6.6
Temperature
Supply
(Centigrade)
WLCT
CIW7
<35.5
MWTF-1C
19
20.5
Total coliform
Supply
(cts per 100m1)
WLCT
CIW7
MWTF-1C
TDS
Supply
(mg/I)
WLCT
CIW7
<475
MWTF 1C
- 560
— —
-- 568
TOC
Supply
(mg/I)
WLCT
CIW7
<4.3
MWTF-1C
4
3
Chloride
Supply
(mg/I)
WLCT
CIW7
<55.0
MWTF-1C
54.5
55.5
Fluoride
Supply
(mg/I)
WLCT
CIW7
< 1.0
MWTF-1C
0.604
0.341
Sulfate
Supply
(mg/I)
WLCT
CIW7
<50.0
MWTF-1C
76.7
70.6
Total Phosphorus
Supply
(mg/I)
WLCT
CIW7
<0.15
1 M WTF-1 C
0.298
0.321
Page 3

TXGFPHOS.MON
Parameter
Well ID
Jan-89
Apr-89
JuI-89
Oct-89
(units)
regulatory std
Cadmium
Supply
(mg/I)
WLCT
CIW7
<0.005
MWTF-1C
Chromium
Supply
(mg/I)
WLCT
CIW7
<0.05
MWTF-1C
Manganese
Supply
(mg/I)
WLCT
CIW7
<0.05
MWTF-1C
Page 2

INNS -rthm-cenr06114.4
TXGFPHOS.MON
Parameter
Well ID
Jan-89
Apr-89
JuI-89
Oct-89
(units)
regulatory std
Field pH
Supply
WLCT
CIW7
pH 6-7
MWTF-1C
6.8
7.2
6.9
7
Temperature
Supply
(Centigrade)
WLCT
CIW7
<35.5
MWTF-1C
19.5
19
21
20
Total coliform
Supply
(cts per 100m1)
WLCT
CIW7
MWTF-1C
TDS
Supply
(mg/I)
WLCT
CIW7
<475 _ -
- - 554
- 526
528
- ---596
MWTF-1C
TOC
Supply
(mg/1)
WLCT
CIW7
<4.3
MWTF-1C
6
3
4
4
Chloride
Supply
(mg/I)
WLCT
CIW7
<55.0
MWTF-1C
56
52
53
53.5
Fluoride
Supply'
(mg/I)
WLCT
CIW7
< 1.0
MWTF-1C
0.61
0.26
0.28
0.31
Sulfate
Supply
(mg/I)
WLCT
CIW7
<50.0
MWTF-1C
292
58.6
58.3
57.2
Total Phosphorus
Supply
(mg/I)
WLCT
CIW7
<0.15
MWTF-1C
0.299
0.131
0.025
0.614
iPx-1
Page 1

-State of North Cr `Hlina
Department of E-..-_,.ronment,
Health and Natural 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
AV:eCWA
IDEHNR
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-W0-0005,
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 Affirmative 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,
a.
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
Division of Environmental Management
Groundwater Section
North Carolina Department of EHNR
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject:
Dear Sirs:
•
Quarterly Monitoring Data
for Tank Farm Remedial Action System
W.A. Schimming
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 (SO4) 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,
,,x/C t /1/10(-1
W. A. Schimming
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 \TF QTRPT . TF W
Pnnrotl on
Recyc$o Papw

Texasgulf inc.
September 15, 1994
Ms. Karen A.Harmon
Division of Environmental Management
Underground Injection Control Program
Groundwater Section
North Carolina Department of EHNR
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Quarterly Monitoring Data
Tank Farm Remedial Action System
Compliance Report Form MWTF1-C
Dear Ms. Harmon:
Please find the attached copy of the Groundwater Quality Monitoring Compliance Report Form
for monitor well MWTF1-C of the Supplemental Tank Farm Remedial Action System. You had
indicated by phone this morning that this form had not been found in Texasgulf's quarterly
monitoring package submission for this remediation system.
I apologize. for any inconvenience this may have caused.
Please contact me if you have any questions regarding this information.
Sincerely,
/41,(4 /PIA -
Timothy F Walls
Environmental Engineer
TFW/re
Attachment
pc: Willie Hardison - DEM, WRO (w/attch)
Phosphate Operations
P.O. Box 48
Aurora, NC 27806
Phone [phone]
elf

COMPUANCE.MONITORING
GROUNDWATER QUALITY MONITORING
LIANCE REPORT FOF" "..
DIYISIONOP ENVIRONMENTAL MANAOEMPNT �.
YO AOX 2953S ..:.
RALEIGIf NC 27626-05331
(419) 733 322I'
Facility Name: TEXASGULF INC. PHOSPHATE OPERATIONS County: BEAUFORT
Address P.O. BOX 48 AURORA, NC 27806
PERMIT NO.: 06-0071— WI-0238
Non —Discharge Tank Farm Remedial System
_Lagoon _Septic Tank/Drab Field
_Spray Field _Subsurface Low —Pressure
Land Appl of Sludge
—
"tar
UV
•
ote:
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE
Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
L 3/ %/f
.....". t,i..-..r- arTTrr rnn n.(ATI'nnt—trn A rare rr
nATr

Ct.M_I..ECTION AND ANALYSIS OF GROUNDWATER SAMPLES
slcould he analyzed a:; ;oor, as possible alter collection. SAMPLES WHICH ARE HOT ANALYSED WITHIN THE HOLDIIIG IIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
,nlyses: 1Ise Starrcl,ud Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!.t
'!r ' !•i:ri:ri samf!Ies must be collected for metals, then field acidified with 5 rnl concentrated nitric acid per liter or sample, and should be submitted I,) HP'
Iat, .ithin 24 Ircurr.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
3 Atl(I. iSES ARE TO BE MADE OF THE MOBILE CONSTITUENTS (DISSOLVED AS WELL AS COLLOIDAL) IN THE
Gf1:.'IJIJDWATEF1, NQT THOSE THAT ARE A PART OF SEDIMENT ASSOCIATED WITH WELL CONSTRUCTION OR SAMPLING PROCEDURES.
CHECK WITH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION AND PRESERVATION.
4. title 15. North Carolina Administrative Code. Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
it it itiIlowing publications, or by other methods approved beforehand by the Director, Division of Environmental
Msur'rgement:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4 79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
rnes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equiprnent must be calibrated in accordance wi:h recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10. The sarnple container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11."Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

Texasgu if Inc.
•
•
an elf aquitaine company
P.O. Box 48
Aurora, North Carolina 27806
August 31, 1994
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. Schimming
Manager
Environmental Affairs
[phone]
Please find enclosed the Supplemental Tank Farm
groundwater monitoring Remedial Action System quarterly
data for your information. These data are from samples
during July, 1994. The sampling collected
required by Permit No. 06-0071-WO-0005nisl also included s of water from the injection well system as
Please note that the accuracy of all Total Organic Carbon (TOC)
are suspect. The TOC analysis values are not consistent with historicalysis l throughoutTOCvaluesthis for t et
subject wells. Recheck analysis were performed by the orig' the
analysis and by Texasgulf. The TOC values obtained from the recheck analysis,
the original lab, were also inconsistent with inai lab who performed these
thelytic i values obtained b cvlperformed by
their own original analytical values. Recheck
were within the historical trends for the respective TOC
s laboratory may be more accurate because the values
value obtained is reported on the respective compliance monitoring report. value for each well. Each analytical
CIW-7 for TOC will be performed and submitted during
P � P rt• A re -sample at well
September.
Also note that the cadmium analysis for well CIW-7 was 0.009 mg/1. It is believed that this
value was obtained because of cadmium contained in the reagent grade J
preservative for this sample. A re -sample of this well to conduct the nitric acid n ly as sa
scheduled for the first week of September. A blank will also beprepared
cadmium analysis is
preserved with nitric acid as is the sample, to determine if camiiuW is present
distilled water,
preservative. These analysis will be submitted to you as soon as they are available. spresent in the
Please contact me or Tim Walls if you have any questions g
reV arding this information.
Sincerely,
WAs:TF,/t£w
Attachments
Recycled Paps

State of North Cara, 1
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
Ater A
ENS 1-1NIFt
GROUNDWATER SECTION
July 13, 1994
Mr. William A. Schimming
Manager Environmental Affairs
Texasgulf, Inc. Phosphate Operations
P.O. Box 48
Aurora, NC 27806
RE: Compliance Monitoring
Permit No. 06-0071-WO-0005
Dear Mr. Schimming,
Review of the Compliance Monitoring Report for April, 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 two
instances of non-compliance_: T -
1) The total phosphorus concentration of the injectate (sampled
from riser pipe of CIW-7) of 0.497 mg/1 exceeds the concentration
limit of 0.15 mg/1 set in the permit conditions (Part II.A.2).
You are requested to sample and analyze the injectate from CIW-7
for total phosphorus again and submit the result to this office.
If the total phosphorus concentration again exceeds the limit,
Texasgulf, Inc. must provide an explanation for this exceedance.
2) The cadmium detection limit of <0.01 mg/1 reported for both
CIW-7 and MWTF1C is greater than the concentration limit of 0.005
mg/1 specified in the permit conditions (Part II.A.2). The
sensitivity of the method used to analyze for cadmium must be
improved so that the detection limit is below the specified
concentration limit of 0.005 mg/1. If sensitivity cannot be
improved for cadmium analysis in the forthcoming July monitoring
report, an explanation must accompany that report.
Sincerely, L �\
r Kaa en Q
A. Harmon
Underground Injection Control Program
Groundwater Section
cc: UIC Files
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

iuvrvlf-unlN,-.F tvlvll I vnuvsa
tE.REPORT ,,,
OPERATIONS County:
AURORA, NC 27806
BEAUFORT
I'CItMITNO.: 06-001
Noe -Discharge link Form RemeJ6
_Lagoa° _SepncT.nk/etaF
_Spay Fleld __Subrud¢e Low -Po
Land Appl of Sludge
_Roney Millburn( comer
Facility Name: TEXASGULF INC. PHOSPHATE
Address P.O. BOX 48
Well Location: Tank Parin
Well I D. Number:
CI W-7 Well Dept 48.00 Well Depth:
Well Diameler
4" Sample (Screened) Inlerval 31.00 P7' to 45.25 FT
Depth
Deplh to Wafer Level
n/a ft. below meas. p .(before sampling) or n/a (MSL
Measuring Point is
3.33 feel above land surface or 13.13 ft. (MS .)
Gallons of wafer pumped/bailed before sampling CON"IINUOUS
Ricci Almlyiis:pN '" -
6.9 Specific Conductance 525 uMho
Temp (9.0 oC Odor
NONE
Dale Sample Collected
04/14/94 Date Lab Sample Analyzed 4/14-4/26
1994 Appearance: CI.EAIL
Laboratory Name
TEXASGULF INC. Certification No. 330 AND 102 ('I'OC ONLY)
SAMPLES FOR METALS WERE COLLEC113D UNFILTERED AND FIELD ACIDIFIED X YES
NO
COD
N/A mg/1
NO2 as N WA mg/I
Ni - Nickel
N/A
mg/I
Coliform: MP Fecal
NIA /1001111
NO3 as N N/A mg/I
I'b - Lead
N/A
mg/I
Colifonn: MF Tolal
<1 /I00inl
I'Iroijshoi ns:;Total as ly' 'tsr3r iTh'Iitzth"0t49T, l nit mg/IIM
Z.n-Zinc
N/A
mg/I
Dissolved Solids: Total
384 mg4
Al - Aln.ninum N/A mg/1
Pesticides/I letbicides (Specify)
pil (when analyzed)
7.3 units
Ida - Ilan unr N/A mg/I
' ng/1
TOC
3.86 mg/I
Ca - Cal. Min N/A mg/I
ng/I
Chloride
54.6 mg/I
Qr1lrkll.Can nlulnr 1M :.;;;VyrYlss sri ,. <Oot.00, .:mg/1.0
ug/I
Arsenic
N/A nng/I
Chromiun: 'Total tr. 0.34 mg/1
Other FLUORIDE
0.48
tug/1
Grease and Oils
N/A ing/I
Co - Copper N/A ing/I
Other MIIUK
N/A
ug/I
Ilardness: Total
N/A mg/I
Pe - Iron N/A mg/I
Other Ag - Silver
N/A
mg/1
Phenol
N/A nrg/I
llg - Mercury N/A ,ng/I
Other Se - Selenium
WA
mg/1
Sulfate
<10 utg/I
K - l'ola::Mtn N/A mg/I
ng/I
Specific Conductance
N/A uMobs
Mg - Ma;;nesiuni N/A mg/I
ug/I
Tolal Anunonin(N114 + N113)
N/A mg/I
Mn — Ma iganese r. 'IT' gra.:z O.letgr' 'mg/I
Nolo: Values should retied lolal concealra lions
TKN as N
WA nrg/I
Na - Sodium N/A nrg/1
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE
Lly
SIGNATURE OF PERMIT} E (OR AUTHORIZED AGENT)
141/764
06AT E
1—WO-0005.
System
old
MI6

GROUNDWATER SECTION
April 18, 1994
MEMORANDUM
To: Bob Cheek
From: Karen Harmon
Subject: Review of Quarterly Monitoring Reports Submitted to UIC
Group by Texasgulf Inc. Phosphate Operations (Beaufort) From
Oct., 1992 to Jan., 1994 to Comply with the Conditions of Permit
No. 06 - 0071 - WO - 0005 for 7 Injection Wells in their Tank
Farm Remedial System.
1) A TDS concentration of >475 mg/1 is characteristic of the
Croatan Aquifer groundwater (sampled from MWTF1C) both before and
after injection. The TDS limit of 475 mg/1 is exceeded in the
supply of Castle Hayne groundwater and in the injectate (from
CIW-7). Steam condensate was to have been mixed with the supply
to bring the TDS concentration in the injectate below 475 mg/1,
but apparently this dilution was not performed. Texasgulf should
be asked to come into compliance (by adding condensate) or to
request a variance on the TDS concentration limit based on the
high TDS concentration ofACroatan Aquifer groundyaater pbs r e t
MWTF1C . 1/94 rn t : #o r'•w► Q,d„"J.' --rt,1'.! a• �%vti.Y 1 t a eto io, [ I w7� 7'0 aLa�wr
U.• .t o atof pin. • So sty ,4-1-,". two bodilyo• X 96.4^ww+ •
2) A chloride concentration of about 55mg/1 is maintained in
the Croatan Aquifer groundwater (MWTF-1C) before injection
begins, but after injection begins, chloride concentration
increases notably in the Croatan groundwater. The chloride limit
of 55 mg/1 is exceeded in both the supply of Castle Hayne
groundwater and in the injectate (CIW-7). It would appear that
injection is elevating the chloride concentration of the Croatan
Aquifer groundwater. Texasgulf should be asked to �cpme into ����-7) f-
compliance. .I y ,,,,, i.: Ruo,�,tt, `r` 0l ha`.' c, '-
u-no.l..# 60,41 +0 5YL 114/1.
3) A sulfate concentration of 60-70 mg/1 characterizes the
Croatan Aquifer groundwater (MWTF-1C) before injection, but
decreases to less than 10 mg/1 after injection begins.
4) Analytical data for Cd, Cr, and Mn are apparently at or
below the detection limits achieved by Texasgulf labs. Texasgulf

5)
should be asked to decrease their detection limits by refining
their methods or by sending the samples, o a, lab with mac re , Cd t 44
sensitive techniques. A.V. fa. (ov st tirii�
Texasgulf's use of —VA aid BDL or required sample
parameters is not acceptable. Texasgulf should be required to
state the numerical value of the detection limit (i.e.,
<0.001mg/1). When a required parameter is reported as "not
analyzed", the sample should be re -analyzed and a second report
submitted for that parameter.
W i y - :—T3-4-..11 e5h ..,o 1pI r-tq x f� - .-�— .�P Lt
1) c;( A- ,., /) p
(tea -coop- c
,h.e,64-„Ac, A;
70-77,4
ctfrt. It (a
+0 6. p - ._-__ -Z_ lti.c4,_ f
M Ar F C. 0 0.0 Sy,. % Lhh)

. • •
4
%-
•)
•

Texasgulf Inc.
File Number 88-089
Texasgulf Project AFE-N-763
Application to Modify Permit No. 06-0071-WI-0238
for Injection Well System
Attachment III
October 29, 1991
Page 4 of 4
Table 1
SUMMARY OF CASTLE HAYNE AQUIFER STEAM CONDENSATE WATER,
CROATAN FORMATION AND INJECTION WELL FLUID WATER QUALITY
Parameter
Injection Water Supplies
. Existing.Croalan
Formation Background
Groundwater at Monitor
Well MWTF-10
Limits on Injection
Well Fluid
Concentration
Class GA
Water Quality
Standard
Castle Hayne
Aquifer*
I
Steam Condensate
Water**
Specific Conductance @mhos/cm)
550
10
782±37
-
ns
pH
7.1
7.1
6.8±0.2
6,5-7.5
6.5-8.5
Calcium, Ca (mg/I) -
78
0.1
140
s90
ns
Magnesium, Mg (mg/I)
32
0.1
7
s40
ns
Sodium, Na (mg/I)
14
0.2
33
<_50
ns
Potassium, K (mg/I)
12
Tr
3
515
ns
Iron, Fe (mg/I)
0.03
0.06
6.4
s0.2
0.3
Chloride, CI (mg/I)
11
0.6
56±3
s75
250
Fluoride, F (mg/I)
0.7
0.03
0.42±0.18
s1
2.0
Sulfate, SO4 (mg/I)
2
Tr
67±7
510
250
Bicarbonate, HCO3 as CaCO3 (mg/I)
324
4
397
5400 •'
ns
Total Kjeldahl Nitrogen, N (mg/I)
2.4
0.42
-
' s3
ns
Ammonia Nitrogen, NH4 as N (mg/I)
1.0
0.12
-
<1
ns
Nitrate, NO3 as N (mg/I)
<0.02
<0.02
<0.02
50.1
10.0
Nitrite, NO, as N (mg/I)
<0.02
<0.02
-
50.05
1.0
Total Phosphorus, P(tng/I)
0.03
0.03
0.29±0.13
<_0.06
ns
Total Dissolved Solids, TDS (mg/I)
430
-5
563±56
s475
500
Total Suspended Solids, TSS (mg/I)
1
0
-
<_1
ns
Total Hardness as CaCO3 (mg/I)
380
-1
378
s390
ns
Total Coliform Bacteria (counts/100 ml)
-
nd
<1
1
* Based upon groundwater samples obtained from Piezometer P-47 on September 24, 1991 and September 26, 1991. Piezomete P-47 has a
collection zone tapping the top of the Castle Hayne aquifer from 160 to 175 feet below land surface. The top of the Castle Hayne aquifer was
encountered at 155 feet below land surface.
** Based upon steam condensate samples obtained on August 12, 1991 and August
13, 1991.
* Mean ± 1 standard deviation based on eleven quarterly sampling events between January 1989 and July 1991. All other data from groundwater
sample obtained on January 10, 1991.
Where: Tr=Trace; nd=Not-Detected; and ns=No Standard

w NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE OPERATION/USE OF A WELL OF WELL OF WELL SYSTEM FOR INJECTION
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
Texasgulf Inc.
FOR THE OPERATION AND USE OF AN INJECTION WELL/WELL SYSTEM located at
Texasgulf Inc., Aurora, North Carolina, in Beaufort County, 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 and Use only, and
sL, not
otwaive
vesany
ny
provisions of the Water Use Act or any other applicable
Regulations. _Operation and use of a well or well system shall be in
compliance with Title 15-North- Carolina Administrative-2C,--nand
other Laws, Rules and Regulations pertaining to well Code
use.
This Permit shall be'effective, unless revoked, from the date of
Decemberits issuance until
s
bj
spec fed cond tions andli9mitationsset96, and shall
forth I nand II hereof.
Permit issued this the 5th day of December, 1991.
Jim Mulligan
CA
Regional Su • rvisor
By Authority of the nvironmental Management Commission.
PERMIT NO. 06-0071-W0-0005

•
PERMIT NO. nrmnsnnrns
PARTI
A. GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this Permit and with the
standards and- criteria specified in 15 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. ThePermittee-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 toperform 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.
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.

PERMIT NO. 06-0071-W0-0005
PART I (continued)
13. Provisions shall be made for
landnu subsequent to leavinsamples of g theeffluent,
treatm t th prior to
es
its entrance to 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 C1W-7 (fluid tom
° monitoring ewelltMWTFo S1Cinjection
well in line) and fr
(groundwater from the ronaltandithereafteraeveoynJanuary,
system becomes opera parameters:
April, July, and October for the following p
Cadmium
TDS Chromium
TOC Manganese
Chloride SO
Fluoride Total Phosphorous
pH
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 ofNCn2ir2onme5taland
Management, P.O. Box 29535, Raleigh,
to the Groundwater Section, Washington Regional Office,
1424 Carolina Avenue, Washington, NC 27889 every
February, May, August, and November.
2. The quality of the injected fluid the willolnot exceed the
given concentrations in mg/1 for
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
closurethe
ofaddresses
indicated in Specific to plugging and
injection well system 30 days prior
abandonment.

PERMIT NO. 06-0071-WO-0005
PART II (continued)
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).

State of North Carolina
Department of Environment, Health and Natural Resources
Northeastem 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. Schimming:
Lorraine G. Shinn
Regional Manager
Jtr-• r5ti,
SEC �2,
GRGL'3'3GE"iriTER SECTEOi�
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 sblids
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/1: If you should have any questions or comments, just give us a
call at 946-6481.
Sincerely,
CR GINAL S!GNE7 77
. JUO MULUEGAN
Jim Mulligan
Regional Supervisor
cc: Rob Turner-
WaRO
P.O. Box 2188, Washington, North Carolina 27889-2188 Telephone [phone] FAX: [phone]
An Equal Opportunity Affirmaive Action Employer

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL FOR
INJECTION
CLASS 5WFTT5
TO: DIRECTOR, NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
DATE: February 28 19 91 (original application) -Permit No. 06-0071-WI-023
October 29 ,1991 (request for modification)
In accordance with the provisions of Article 7, Chapter, 87: Article 21, Chapter 143, and regulations
pursuant thereto, APPLICATION is hereby made for a PERMIT to construct and/or use a i681i)& well system as
described below and in any accompanying data submitted as a part of this APPLICATION.
A. OWNER DATA: Name: Texasqulf Inc.
Address: Post Office Box 48
City: Aurora, North Carolina Zipcode: 27806
County: Beaufort Telephone: [phone]
Ownership: Federal State _ Private X
Public Commercial _
Other (Specify)
B. FACILITY DATA (Fill out-ONLY-if-the-injection-well(s)-is-(are)-for the purpose of-seiving_a_business-or-
industry):
Business/CorporateName: Texasqulf Inc.
Address: Post Office Box 48
City: Aurora, North Carolina Zipcode: 27806
County: Beaufort Telephone: [phone]
C. HEATING CONTRACTOR DATA (For heat pump systems oniy. Please give information for the contractor
that installed or will install your system):
Name: NA - Not a heat pump system
Address:
D.
E.
City: Zipcode: Telephone:
INJECTION PROCEDURE: Briefly describe how the injection weil(s) will be used.
(See Attachment III)
WELL USE: Will the injection well(s) also be used as the suppiy well(s) for either of the following?:
(a) The injection operation?
(b) Your personal consumption?
YES
YES
F. CONSTRUCTION DATA: (check one)
X EXISTING WELL being proposed for use as an injection well.
Construction Record) and furnish (7 & 8) below. If Form GW-1
through (8) below to the best of your knowledge.
(See Attachment IV for the well construction
injection wells)
NO X
NO X
Attach a copy of Form GW-1 (Well
is not available, furnish the data in (1)
records for the seven
GW-57B May. 1989. Replaces GW-57A. and OW-57B (2184)

PROPOSED WELL to be constructed for use as an injection well. Furnish the data in (1) through (8)
below as PROPOSED construction specifications.
NOTE THE WELL DRILLING CONTRACTOR CAN SUPPLY THE DATA FOR EITHER EXISTING
OR PROPOSED WELLS IF THIS INFORMATION IS UNAVAILABLE BY OTHER MEANS.
(1) Well Drilling Contractor's Name:
(2) Date (to be) Constructed Approximate Depth ft.
(3) Well Casing:
(a) Type: Galvanized Steel _ Black Steel _ Plastic _ Other (Specify)
(b) Inside Diameter. inches; Wall thickness (inches) or schedule #
(c) Casing Depth: From to ft (referenced to land surface)
(4) Cement Grout
(a) Around inner or "primary" casing: From to _ ft
(b) Around outer (pit) casing, if present From to ft
(8)
Screen(s): (if applicable)
(a) Type: • Inner Diameter. inches
(b) Depth: From to feet below land surface
Gravel: (if applicable) From: to feet below land surface
N.C. State Regulations (15, 2, 2C, Section .0200) require the permittee to make provisions for
momtonng' wellhead processes. Kfaucet on both —the influent (water from well) and effluent (water
into well) lines is required. Is there a faucet on (a) the influent line YES NA NO _ or (b)
the effluent line YES X NO ?
Attach a diagram showing the details of construction of the existing and/or proposed well(s).
G. PROPOSED OPERATING DATA: (The manufacturer's brochure should include this information.)
(a) Injection Rate:
(b) Injection Volume:
(c) Injection Pressure:
(d) Injection Temperature:
H. INJECTED FLUID DATA:
Average (Daily) 19.3 gallons per minute (gpm)
Average (Daily) 27,792 gallons per day (gpd)
Average (Daily) NA pounds/square inch (psi)
Winter Average (Daily) 64-96 degrees F
Summer Average (Daily) 64-96 degrees F
(1) Fluid Source (From what depth and what type of rock/sediment unit does the fluid to be injected
derive, i.e. granite, limestone, sand, etc.)
Depth: 180± Rock/sediment unit
Castle Hayne Limestone
(2) Chemical Analysis of Source Water. The following chemical characteristics MUST accompany
this application;
pH 7.1 • Total Hardness 380 ppm (parts per million or mg/I); Iron ppm- 0.03
Chloride 11 ppm; Nitrate <0.02 ppm; Coliform bacteria * counts/100 ml
The above chemical characteristics are for the Castle Hayne aquifer based upon sampling at Piezometer P-7 near the
proposed water supply well. See Table 1 in Attachment III for the chemical analysis of the steam condensate water that
will be mixed with the Castle Hayne aquifer groundwater, if needed, to maintain the injection fluid total dissolved solids
concentration equal to or less than 475 mg/I, and proposed limits on injection fluid constituent concentrations.
*The total cordorm bacteria will be measured on the water supply well after installation, and if greater than
1/100 ml lowered to 51/100 ml prior to injection into the Croatan formation.
GW-S/B May,1989, Replaces GW-57A, and GW-57B (7J84)

NOTE: Assistance in obtaining these values may be facilitated by contacting (a) your local or cotmty health
official, (b) a commercial water -testing laboratory, (c) your well drilling contractor, or (d) the Regional
Hydrogeologist, North Carolina Dept. of Natural Resources & Community Development.
NOTE: If injection system is not for a heat pump, then a detailed analysis of both the source water and the
injection fluid may be required.
I. INJECTION -RELATED EQUIPMENT: See Attachment III
Attach a diagram showing the engineering layout of the (1) injection equipment, and (2) exterior
piping/tubing associated with the injection operation.
NOTE: The manufacturer's brochure, if detailed, should satisfy (1) above if the system is a heat pump.
J. LOCATION OFWFIT(S): See Attachment III
Attach a detailnd map showing the orientation of and distances between the proposed well(s), any existing
well(s) that will in any way be involved in the injection opera-tion, and at least two (2) nearby reference
points such as roads, road intersections, streams, etc. The roads should be identified by U.S., N.C. or SR
(county secondary road) numbers, and streams should be named In addition, the diagram should show the
direction and approximate distance to any existing water -supply and/or injection wells within 1,000 feet of
the proposed injection welL
K. CERTIFICATION:
"I hereby certify, under penalty of law, that I have personally examined and am familiar with the
information submitted in this document and all attachments thereto and that, based an my inquiry of those
individuals immerliarnly responsible for obtaining said information, I believe that the information is -true,
accurate and complete. I am aware that there are significant penalties, including the possibility of fines and
imprisonment, for submitting false information. I agree to operate and use the injection well and all related
appurtenances in accordance with the approved specifications and conditions of e Pegiu/
,r
•
v (Signature o • wner or Authorized ent)
William A. Schimming
Manager Environmental Affai
FOR OFFICE USE ONLY:
1. Initial Application: Complete Incomplete
If INCOMPLETE, Daze of Notification and Resubmittal
2. Standard Industrial Code(s) which best reflect the principal products or services provided by this
facility - if applicable.
(a) (b) (c) (d)
3. APPLICATION NO.
natal" v... 1020 D a.... llW_C24 J nva_o,n flask

Texasgulf Inc.
File Number 88-089
Texasgulf Project AFE-N-763
Application to Modify Permit No. 06-0071-WI-0238
for Injection Well System
Attachment III
October 29, 1991
Page 1 of 4
ATTACHMENT III
GENERAL INFORMATION
APPLICATION TO MODIFY PERMIT NO. 06-0071-WI-0238
FOR INJECTION WELL SYSTEM
TANK FARM AREA
REMEDIAL ACTION SYSTEM
TEXASGULF PHOSPHATE OPERATIONS
AURORA, NORTH CAROLINA
(1) General. The original application for a permit to construct seven Croatan formation
injection wells for, the tank farm area, remedial action system was submitted on
February 28, 1991_in_accordance_with.the_Ardamaa &. Associates, Jnc._Remedial Action
System Design Report dated July 31, 1990, and approved by the State of North Carolina
Department of Environment, Health and Natural Resources Division of Environmental
Management - Groundwater Section on November 26, 1990.
Permission to construct the seven injection wells was issued by the Division of
Environmental Management on May 8, 1991 in Permit No. 06-0071-WI-0238. The injection
wells were subsequently installed between May 30 and June 7, 1991, and construction
records for the wells were submitted to the Division of Environmental Management on
August 16, 1991.
Since submitting the original permit application to construct the injection well system, the
Castle Hayne aquifer water supply well, FERT-1, planned as the source of the injection
fluid has been scheduled to be abandoned and will not be available as the source of
injection fluid. Accordingly, this permit modification requests permission to provide an
alternate water supply source for the injection fluid.
(2) Proposed Modification to Permit No. 06-0071-WI-0238. Permit Items E, G and H in the
original application stipulated that the water supply for the injection well system would be
water supply well FERT-1 in the tank farm area tapping the Castle Hayne aquifer. It was
further stipulated that water from this well would be treated with a reverse osmosis system
to lower the total dissolved solids concentration below 475 mg/I prior to injection into the
Croatan formation. As outlined in the August 29, 1991 notice of modification request,
however, the FERT-1 well has been scheduled to be abandoned and will not be available
as the source for the injection fluid as originally planned. This request for modification to
Permit No. 06-0071-WI-0238, therefore, seeks permission to: (i) 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 (ii) allow mixing of steam condensate water with the well water, if needed, to

Texasgulf Inc.
File Number 88-089
Texasgulf Project AFE-N-763
Application to Modify Permit No. 06-0071-WI-0238
for Injection Well System
Attachment III
October 29, 1991
Page 2 of 4
maintain the total dissolved solids concentration of the injection fluid below 475 mg/I in the
event the total dissolved solids concentration of the Castle Hayne aquifer well water rises
above 475 mg/I.
A revised application for permit to construct and/or use a well for injection (Form GW-57B)
is attached with the requested modifications. The modifications are also described in
detail below. For permit items not requiring modifications, the approved permit application
is referenced.
(3) Permit Items A through D. No change from information contained in Permit No.
06-0071-WI-0238.
• (4) Permit Item E Well Use. The injection wells will be used to inject fresh water into the
Croatan formation as described under Permit Item D. The water supply for the injection
well system will be a new well tapping the upper 20 feet of the Castle Hayne aquifer
installed southeast of the tank farm area in the general location depicted in Figure 1. If
needed, steam condensate water will be added to the well water by a mixing system to
maintain the total dissolved solids_concentration.of theinjectionfluid -equal_to_or_less-than-
475 mg/I (see Permit Item H below).
(5)
Permit Item F - Well Construction Data. No change from information contained in Permit
No. 06-0071-WI-0238. The injection wells were installed between May 30 and June 7,1991
in accordance with the drawings and specifications submitted with the original approved
permit application. Construction records for the wells were submitted to the Division of
Environmental Management on August 6, 1991 and are also included in Attached IV.
(6) Permit Item G - Proposed Operating Data.
• Iniection Rate and Volume. No change from information contained in Permit No.
06-0071-WI-0238
• Injection Pressure. No change from information contained in Permit No.
06-0071-WI-0238
• Iniection Temperature. The water supply for the injection wells will be groundwater
from the upper 20 feet of the Castle Hayne aquifer. Groundwater samples
obtained on September 24 and 26, 1991 from a piezometer tapping the upper 20
feet of the Castle Hayne aquifer near the proposed well site (Piezometer P-47 on
Figure 1) displayed a temperature of 18.5°C (65.3°F). Based upon quarterly
sampling at the FERT-1 water supply well in the tank farm, also tapping the Castle
Hayne aquifer, variations in the temperature of the aquifer groundwater are
expected to be minor, with the temperature of the Castle Hayne aquifer
groundwater remaining between about 18°C (64.4°F) and 21°C (69.8°F). The
temperature of groundwater in the Croatan formation based upon eleven quarterly
measurements between January 1989 and July 1991 averaged 19.7±0.7°C at

Texasgulf Inc.
File Number 88-089
Texasgulf Project AFE-N-763
(7)
(8)
(9)
Application to Modify Permit No. 06-0071-WI-0238
for Injection Well System
Attachment III
October 29, 1991
Page 3 of 4
monitor wells MWTF-1 C and MWTF-2C (see Drawing 2 for well locations) and
28.5±0.8°C at MWTF-3C (groundwater in the Croatan formation is warmer at
monitor well MWTF-3C because of the nearby heated sulfur storage tanks).
Accordingly, when the injection fluid is comprised of groundwater from the Castle
Hayne aquifer, the temperature of the injection fluid will remain within ±1 to ±3°C
(±1 to ±4°F) of the Croatan formation groundwater temperature at monitor wells
MWTF-1 C and MWTF-2C, and will be 7 to 11°C (12 to 20°F) less than the Croatan
'formation groundwater temperature at monitor well MWTF-3C.
Steam condensate water, if used to reduce the total dissolved solids concentration
of the injection fluid, can have a maximum temperature of about 82°C (180°F). The
volume of steam condensate water mixed with the Castle Hayne aquifer well water
will be controlled by the mixing system such that the temperature of the injection
fluid does not exceed 35.5°C (96°F), in compliance with the maximum allowable
30°F temperature increase for injection well systems above the background
groundwater temperature (i.e., for a background groundwater temperature of 19°C
(66°F) at monitor wells MWTF-1 C and MWTF-2C a maximum injection fluid
__temperature of 35.5°C (96°F) is allowed).
Permit Item H - Infected Fluid Data. As discussed above under Permit Items E and G, the
injection fluid will be Castle Hayne aquifer groundwater. Steam condensate water will be
added to the Castle Hayne aquifer groundwater by the mixing system to maintain the total
dissolved solids concentration equal to or less than 475 mg/I, if the total dissolved solids
concentration of the well water rises above 475 mg/I. The chemical characteristics of: (i)
groundwater from the Castle Hayne aquifer based .upon sampling piezometer P-47 near
the location of the proposed water supply well; (ii) steam condensate water; and (iii) the
existing groundwater in the Croatan formation near the injection wells at background
monitor well MWTF-1 C are presented in Table 1.
Permit Item I - Injection Related Equipment. Construction of the seven injection wells,
connecting header pipe, water level control tank and the well water/steam condensate
water mixing and control system was completed in early August 1991, and inspected on
August 15, 1991 by the Division of Environmental Management. Drawings of the injection
well system components (i.e., injection wells, withdrawal wells, injection well header pipe
and water level control tank) were submitted with the original approved permit application.
Permit Item J - Location of Wells. The injection wells were installed at the locations shown
on the drawings submitted with the original approved permit application.

Texasgulf Inc.
File Number 88-089
Texasgulf Project AFE-N-763
Application to Modify Permit No. 06-0071-WI-023B
for Injection Well System
Attachment III
October 29, 1991
Page 4 of 4
Table 1
SUMMARY OF CASTLE HAYNE AQUIFER, STEAM CONDENSATE WATER,
CROATAN FORMATION AND INJECTION WELL FLUID WATER QUALITY
Parameter
Injection Water Supplies
Existing Croatan
Formation Background
Limits on Injection
Well Fluid
Concentration
Class GA
Water Quality
Standard
Castle Hayne
Aquifer*
Steam Condensate
Groundwater at Monitor
Well MWTF-1Ct
Water**
Specific Conductance (Nmhos/cm)
550
10
782±37
-
ns
pH
7.1
7.1
6.8±0.2
6.5-7.5
- 6.5-8.5
Calcium, Ca (mgfl)
78 ,
0.1
140
<90
ns
Magnesium, Mg (mg/I)
32
0.1
7
s40
ns
Sodium, Na (mg/I)
14
0.2
33
<_50
ns
Potassium, K (mg/I),
12
Tr
3
515
ns
Iron, Fe (mg/0
0.03
0,06
• 6.4
<0.2
0.3
Chloride, CI (mg/I)
11.
0.6
56±3
<_75
250
Fluoride, F (mg/I)
, 0.7
0.03
0.42±0.18
s1 `_
2.0
Sulfate, SO4 (mg/I) -
2
Tr
67±7
510
250
Bicarbonate, HCO3 as CaCO3 (mg/I)
324
4
397
s400 r
ns
Total Kjeldahl Nitrogen, N (mg/I)
2.4
0.42
-
s3
ns
Ammonia Nitrogen, NH4 as N (mg/I)
1.0
0.12
-
sl
ns
Nitrate, NO3 as N (mg/I)
<0.02
<0.02
<0.02
s0.1
10.0
Nitrite, NO2 as N (mg/I) .
<0.02
<0.02
- -
s0.05
1.0
Total Phosphorus, P (mg/I)
0.03
0.03
0.29±0.13
s0.06
ns
Total Dissolved Solids, TDS (mg/I)
430
-5
563±56
s475
500
Total Suspended Solids, TSS (mg/0
1
0
-
s 1
ns
Total Hardness as CaCO3 (mg/I)
380
-1 i 1
378
<390
ns
Total Coliform Bacteria (counts/100 m1)
-
nd I
-
s1
1
* Based upon groundwater samples obtained from Piezometer P-47 on September 24, 1991 and September 26, 1991. Piezomete P-47 has a
collection zone tapping the top of the Castle Hayne aquifer from 160 to 175 feet below land surface. The top of the Castle Hayne aquifer was
encountered at 155 feet below land surface. J,
** Based upon steam condensate samples obtained on August 12, 1991 and ugust 13, 1991.
t Mean ± 1 standard deviation based on eleven quarterly sampling events between January 1989 and July 1991. All other data from groundwater
sample obtained on January 10, 1991.
Where: Tr=Trace; nd=Not-Detected; and ns=No Standard

41
0 250 500
SCALE 1'=5001
!I
BARGE°
SLIP
COOLING POND NO. 2
LINE OF CROATAN
FORMATION INJECTION WELLS
(WELLS CIW-1 THROUGH CIW-7)
PLANT OUTFALL CANAL
PROPOSED LOCATION OF
INJECTION WELL SYSTEM
CASTLE HAYNE AQUIFER
WATER SUPPLY WELL
LOCATION OF INJECTION WELL SYSTEM
CASTLE HAYNE AQUIFER WATER SUPPLY WELL
Ardaman & Associates, Inc.
Consulting Engineers in Soil Mechanics,
Foundations, and Materials Testing
TANK FARM REMEDIAL ACTION SYSTEM
TE](ASGULF INC.
PHOSPHATE OPERATIONS
AURORA, NORTH CAROLINA
i
DRA
BY:
FILE NO.
88-089
JJN
-CV
CNE CKED BY: DATE: 10/29/91
FIGURE 1

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
January 4, 1995
Mr. William A. Schimming
Manager, Environmental Affairs
Texasgulf, Inc. Phosphate Operations
P.O. Box 48
Aurora, NC 27806
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 Affirmative 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,
C
A. Elizabeth Morey
Manager
Underground Injection Control Program
Groundwater Section
cc: Tim Walls
Willie Hardison, WaRO
C