NC0089109_NOV-2021-SS-0015 Response_20211014

NEXSEN
Austin
Charleston
Charlotte
Columbia
Greensboro
Greenville
Bluffton / Hilton Head
Myrtle Beach
Raleigh
1230 Main Street
Suite 700 (29201)
PO BOX 2426
Columbia, SC 29202
www.nexsenpruet.com
PRUET
Joan W. Hartley
Special Counsel
Admitted in SC, NC
September 14, 2021
Via Electronic Mail (landon.davidsonAncdenr.gov) and U.S. Mail
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
North Carolina Department of Environment
and Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Notice of Violation/Notice of Intent to Enforce
NOV-2021-SS-0015 (BIMS Inc. #202101792)
Permit No. NC0089109
Rutherford County
Dear Mr. Davidson:
Our firm represents American Zinc Product, LLC (AZP) on environmental matters
related to the operation of its Mooresboro facility. On August 24, 2021, AZP
received the above -referenced Notice of Violation/Notice of Intent to Enforce (NOV)
related to the company's notification of a potential release from the facility's raffinate
solution pond which was discovered during the replacement of the liner system in this
process pond. On behalf of AZP, we are responding to the alleged violations in the
NOV and providing the currently available requested information regarding the
company's initial response to the release, the current status of its remedial
investigation into the cause and extent of the release, and the framework for the
development of a plan and proposed schedule to address migration of the released
material.
As discussed more fully below, this response provides an interim report on the actions
taken by AZP and will be supplemented with additional information in a formal
report and proposed plan once AZP's remedial investigation has been concluded.
Additionally, the summaries of the sampling activities and results provided in this
response were previously provided to the Department. The company and its
T [phone]
F 803.727.1471
E [e-mail]
Nexsen Pruet, LLC
Attorneys and Counselors at Law

G. Landon Davidson, P.G.
September 14, 2021
Page 2
consultant, EnSafe, are working to develop plans for assessment and mitigation of the
release, and therefore, will continue to provide your Office with this information as it
is received by the company.
As you know, AZP discovered the potential release to soils under its raffinate solution
process pond during the replacement of the pond's liner system. Following removal
of the lowermost layer of the liner system on July 28, 2021, the underlying substrate
surface, consisting of sand which was observed to be dry, but discoloration of the
visible (sand) surface suggested the possibility that a release may have occurred. Soil
samples were collected at two locations beneath the liner from native soils below the
sand layer. Upon receipt of the preliminary analytical results of these soil samples
from AZP's on -site laboratory on July 29, 2021, AZP notified the National Response
Center (NRC), the Asheville Regional Office, and the EPA. AZP made the call to the
NRC even though the company and its consultant did not have information necessary
to determine whether a reportable quantity of any constituent of the raffinate solution
had been released. Moreover, AZP's consultant could not determine when the release
had occurred or the duration of such release. Additionally, this initial sampling data
was insufficient to conclude whether there were impacts to the groundwater or
surface waters which would trigger an obligation to report the release to NCDEQ
under state law. However, out of an abundance of caution and recognizing the need
for regulatory guidance from the agencies, AZP immediately notified the NRC, the
NCDEQ Regional Office, and EPA. AZP has continued to provide information to
NCDEQ and EPA upon request and has consulted with NCDEQ and EPA regularly
on the company's initial response action and the ongoing remedial investigation.
With respect to the alleged violations in the NOV, AZP disputes the alleged
violations as identified in the NOV and further contends that the company's initial
and ongoing response to the release complies with the requirements of 15A N.C.A.C.
Subchapter 2L ("2L Rules"). Based on the preliminary phase of the remedial
investigation conducted by EnSafe, it would appear that any impacts to the surface
waters adjacent to the raffinate pond area are likely the result of migration of
groundwater containing raffinate constituents from the release. Therefore, as
discussed more fully below, the allegations of a discharge to an unnamed tributary of
the Broad River without a permit (Violations 1 and 2) are inconsistent with the recent
United States Supreme Court ruling in County of Maui v. Hawaii Wildlife Fund, 140
S. Ct. 1462 (2020), and the EPA guidance issued to clarify permitting required under
Maui. Similarly, the allegation of an unlawful discharge under the Oil Pollution and
Hazardous Substances Control Act (OPHSCA) appears to the based on AZP's
notification to the NRC, which as noted above, was made without a determination
that a reportable quantity of any regulated substance had been released. Moreover,
AZP does not yet have information sufficient to make that determination. Indeed, the
NOV acknowledges that information regarding the timing and rate of the release

G. Landon Davidson, P.G.
September 14, 2021
Page 3
remains "unclear." Therefore, the allegation of an unlawful discharge under the
OPHSCA is not supported by the currently available data regarding the release.
While AZP disputes the violations alleged in the NOV, AZP recognizes its regulatory
responsibility to address the release from the raffinate pond under the 2L Rules. The
company has and continues to respond to the release in accordance with the
requirement of these Rules.
A. The release is not a discharge requiring a permit.
As noted above, based on the currently available information and sampling data, any
impacts to the surface waters adjacent to the raffinate pond area appear to be the
result of migration of groundwater containing raffinate constituents from the release.
While the NOV cites to N.C.G.S. 143.215.1 for the unlawful discharges in 'Violations
1 and 2, any such violation for AZP Mooresboro facility would clearly be evaluated
in the context of NCDEQ's delegated authority under Section 402 of the Clean Water
Act (33 U.S.C. § 1342). Indeed, the facility's NPDES Permit N00089109 (identified
in the reference line of the NOV) cites to N.C.G.S. 143.215.1 and the Federal Water
Pollution Control Act for permitting authority on the cover page of the Permit. As
such, the allegations of an unlawful discharge without a permit under N.C.G.S.
143.215.1 must be evaluated as allegations of a discharge of pollutants from a point
source under Section 402 of the Clean Water Act. The U.S. Supreme Court decision
in Maui and the EPA guidance issued in response to Maui do not support such
allegations.
In Maui, the Supreme Court held that that a release of pollutants from a point source
to groundwater before reaching the waters of the United States may require an
NPDES permit, but only if the release is the "functional equivalent of a direct
discharge." Id. at 1476. While the Court did not decide whether the particular
discharge at issue in Maui was the functional equivalent of a direct discharge, the
Court did identify "some of the factors that may prove relevant" to making that
determination. Id. at 1476-77. On January 14, 2021, the EPA issued a guidance
memorandum "to the regulated community and permitting authorities" on the
application of the Supreme Court decision in Maui. (See Guidance Memorandum,
Applying the Supreme Court's County of Maui v. Hawaii Wildlife Fund Decision in
the Clean Water Act Section 402 National Pollutant Discharge Elimination System
Permit Program from Anna Wildeman, Acting Assistant Administrator, United States
Environmental Protection Agency, Office of Water). The EPA Guidance
Memorandum identifies two threshold conditions that must be meet for a discharge
which travels through groundwater before reaching waters of the United States to be
the "functional equivalent of a direct discharge"—(1) an actual discharge to surface
water from (2) a point source. The release from the raffinate solution process pond

G. Landon Davidson, P.G.
September 14, 2021
Page 4
cannot be the "functional equivalent of a direct discharge" because the raffinate
solution process pond is not a "point source" under the EPA Guidance Memorandum.
The EPA Guidance Memorandum discusses each of the potentially relevant factors
identified by the Supreme Court in Maui. With respect to the "point source"
determination under Maui, the EPA identifies an additional factor relevant to this
determination. The Clean Water defines "point source" as any discernible, confined
and discrete conveyance, including but not limited to any pipe, ditch, channel, tunnel,
conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding
operation, or vessel or other floating craft, from which pollutants are or may be
discharged." 33 U.S.C.A. § 1362(14). The EPA Guidance Memorandum focuses on
the design and performance of a system as a key component of the "functional
equivalent" analysis. That is, the more a system's design and performance is
engineered to slow pollutant transit time, increase distance traveled, alter the
chemical composition of pollutants, and/or create diffuse rather than discrete and
confined discharges, the less likely it is that such a discharge through groundwater
will be deemed the "functional equivalent" of a direct discharge requiring an NPDES
permit. Under this EPA guidance, it is clear that the raffinate solution process pond is
not a "point source" under the Maui decision —even if the release from the process
pond to the soil traveled to the groundwater and ultimately reached the surface water
to the west of the process pond. The raffinate solution pond is a process pond
designed to briefly contain raffinate solution prior to returning the solution to the
process and is not intended to ever discharge or release material. Accordingly, the
release from the raffinate solution pond is not a discharge of pollutants without a
permit.
B. The release is not an unlawful discharge under OPHSCA.
With respect to the allegation of an unlawful discharge in violation of G.S. 143-
215.83, the currently available data regarding the release does not support this
allegation. This provision of the OPHSCA provides that it is unlawful "for any
person to discharge, or cause to be discharged, oil or other hazardous substances into
or upon any waters, tidal flats, beaches, or lands within this State, or into any sewer,
surface water drain or other waters that drain into the waters of this State." N.C.G.S.
143-215.83(a). The OPHSCA defines "discharge" in relevant part as follows:
"Discharge" shall mean, but shall not be limited to, any emission,
spillage, leakage, pumping, pouring, emptying, or dumping of oil or
other hazardous substances into waters of the State or into waters
outside the territorial limits of the State which affect lands, waters or
uses related thereto within the territorial limits of the State, or upon
land in such proximity to waters that oil or other hazardous substances

G. Landon Davidson, P.G.
September 14, 2021
Page 5
is reasonably likely to reach the waters, but shall not include amounts
less than quantities which may be harmful to the public health or
welfare as determined pursuant to G.S. 143-215.77A;
G.S. 143-215.77(4) (emphasis added). Section 143-215.77A provides that "[s]uch
quantities of hazardous substances as may be harmful as determined as of June 1,
1980, by the Administrator of the United States Environmental Protection Agency
under 33 U.S.C. 1321(b)(4) are quantities which may be harmful for purposes of this
Article." N.C.G.S. § 143-215.77A(b). The EPA has designated hazardous substances
as required by 33 U.S.C.1321 at 40 C.F.R. § 116.4. For the purposes of establishing
the "quantities which may be harmful," the EPA regulations provides that
"[deportable quantities means quantities that may be harmful as set forth in § 117.3."
40 C.F.R. § 117.1(a). The reportable quantity for sulfuric acid in 40 C.F.R. § 117.3 is
1,000 pounds.
As noted above, despite the call to the NRC on July 29, 2021, AZP's consultant does
not have information sufficient to estimate the quantity of raffinate solution which
was released from the raffinate solution process pond and therefore cannot estimate
the quantity of any sulfuric acid release. Moreover, the results of the pH sampling
conducted by the Department are not indicative of a release of a reportable quantity of
sulfuric acid. Indeed, the NOV clearly states that the allegation is based solely on the
pH analysis of the surface water sampling in the unnamed tributary to the Broad
River. There is simply no basis for the allegation that the regulatory quantity for a
"discharge" under G.S. 143-215.77 in violation of the OPHSCA has occurred.
C. AZP has responded to the release in accordance with the 2L Rules
Although AZP disputes the specific alleged violations in the NOV, AZP
acknowledges its responsibility to investigate and mitigate the impacts of the release
from the raffinate solution process pond under the 2L Rules. The 2L Rules clearly
establish the actions to be undertaken by "[a]ny person conducting or controlling an
activity that results in the discharge of waste or hazardous substances or oil to the
groundwaters of the State." 15A N.C.A.C. 2L .0106(b). Pursuant to the 2L Rules,
an "initial response" to a discharge to groundwater is required to be conducted "prior
to or concurrent with the assessment" required under the Rules. 15A N.C.A.C. 2L
.0106(b). As discussed above, the soil beneath the process pond liner was sampled on
July 28, 2021. Upon receipt of the preliminary sampling results of these soil samples
from AZP's on -site laboratory on July 29, 2021, AZP notified the National Response
Center (NRC), the Asheville Regional Office, and the EPA. In an email to NCDEQ
on July 30, 2021, AZP provided a detailed explanation of the circumstances which
lead to the discovery of the release and a summary of the initial plans for an
investigation of the extent of the release. (See July 30, 2021 email at Attachment A).

G. Landon Davidson, P.G.
September 14, 2021
Page 6
In accordance with the requirements of the 2L Rules, AZP implemented an initial
response to the release by taking the raffinate solution process pond out of service.
Specifically, AZP installed above -ground storage tanks for the raffinate solution and
depleted solution. These tanks were installed above the liners in these process ponds
and elevated in a manner to facilitate the inspection of the tanks and to identify any
potential leaks from the tanks. As such, the lined ponds serve a secondary
containment for the tanks. Additionally, AZP is currently taking the maintenance
pond out of service and installing two above -ground tanks above the liners in the
maintenance. Accordingly, AZP has removed the primary pollutant source for the
raffinate solution release as required for an initial response pursuant to 15A N.C.A.C.
2L .0106(f). AZP has exceeded the requirements of the 2L Rules by proactively
taking the depleted solution and maintenance ponds out of service due to concerns
regarding the similar construction of these ponds.
Additionally, upon discovery of the release from the raffinate solution process pond,
AZP immediately initiated the assessment activities required under 15A N.C.A.C. 2L
.0106(g). Throughout the week of August 1, 2021, AZP conducted the initial
sampling plan proposed in the July 30, 2021 email to the Department. During this
week, EnSafe worked diligently to develop a more comprehensive sampling plan. In
support of that effort, EnSafe also developed a preliminary Site Conceptual Model
(CSM) to understand the relationship of soil, groundwater, and surface water was
immediately initiated by EnSafe and included:
• Assessment of the underlying lithology by reference to geotechnical
borings implemented at the time of plant construction;
• A site survey to identify locations where released liquids may exchange
to surface water conveyances; and
o Sampling of surface water to assess potential impacts from the release.
The findings from these activities have been conveyed to NCDEQ on an ongoing
basis as developed. On August 9, 2021, AZP and EnSafe presented the preliminary
CSM and a comprehensive sampling plan for the assessment of the release on a
conference call with NCDEQ, EPA, and the Department of Justice (DOJ). AZP's
Sampling and Analysis Plan was provided to NCDEQ and EPA on August 9, 2021.
(See Sampling and Analysis Plan at Attachment B). During the August 9, 2021
conference call, AZP also provided the agencies with information regarding the
modification of its process which allowed the raffinate solution process pond and
adjoining depleted solution process pond to be taken out of service as described
above.

G. Landon Davidson, P.G.
September 14, 2021
Page 7
Based on these preliminary activities and to the extent that the release has impacted
surface water in the unnamed tributary to the Broad River, AZP's consultant has
identified the potential for migration of the raffinate solution from the pond area
through the soil to as a potential threat to groundwater as a likely. migration pathway
for such impacts. Accordingly, AZP asserts that its actions are governed by the initial
response and assessment requirements in the 2L Rules. AZP has clearly complied
with the regulatory obligations of an initial response and is conducting that initial
response concurrently with the required assessment of the release from the raffinate
solution process pond. AZP continues to coordinate with the Regional Office to
conduct the assessment outlined in the Sampling and Analysis Plan, and as discussed
below, has provided the Regional Office with sampling results as received by the
company.
D. Report assessing the cause, significance, and extent of the release
In an email to NCDEQ on July 30, 2021, AZP provided a detailed explanation of the
liner system in raffinate solution process pond and the circumstances which lead to
the discovery of the release. This email also provided a summary of the initial plans
for installation of the new liner system and an investigation of the extent of the
release. (See July 30, 2021 email at Attachment A). On August 4, 2021, AZP
provided additional information regarding the discovery of the release, including the
following documents: the material safety data sheet and chemical composition of the
raffinate solution, the August 4, 2021 laboratory analysis report for the samples
collected from beneath the process pond on July 28, 2021, and locations for surface
water sampling from the stream west of the raffinate solution process pond. (See
August 4, 2021 email at Attachment C). By email on August 16, 2021, AZP
provided NCDEQ with surface water sampling results, including results of a water
sample collected from an adjacent stream at the confluence of the Broad River on
August 4, 2021. (See August 16, 2021 email at Attachment D). By email on
September 7, 2021, AZP provided NCDEQ with a summary of the results of soil
sampling, surface water sampling, and sediment sampling conducted pursuant to
Sampling and Analysis Plan. The September 7, 2021 email also included a
modification of the Sampling and Analysis Plan. (See September 7, 2021 email at
Attachment E).
By way of further explanation, the raffinate process water pond contained a total of
four synthetic liners, which included two separate liner systems each consisting of
two liners. The uppermost liner system was installed in 2019 as part of facility -wide
renovation work undertaken during the shutdown from early 2016 through mid -year
2020. More recently, AZP's contractor made limited repairs to the uppermost liner
by installing patches over small areas on the upper liner and the connection of the
liner to the concrete wall of the pump structure. Following consultations with the

G. Landon Davidson, P.G.
September 14, 2021
Page 8
contractor who installed the liner system, AZP initiated a project to replace the liner
system in the process pond. This project was scheduled to be completed during a
planned facility shutdown the week of July 29, 2021. In order to implement the
project, the raffinate solution process pond was modified with the installation of a
barrier wall across the center of the pond to divide the pond into two sections, north
and south. By dividing the pond into two sections, the liners in the pond could be
removed and replaced with a new liner system in two phases, shortening the length of
time required for the plant to be shut down.
Once the overlying liners were removed from the northern area, the lowermost liner
was exposed and inspected. The liner was observed to be intact, and no apparent
breaches were identified. Following removal of the lowermost liner on July 28, 2021,
the underlying upper substrate surface consisting of imported compacted sand, was
observed to be dry; however, there was visible discoloration of the sand surface
which suggested the possibility that a release may have occurred. Soil and liquid
samples were collected at two locations beneath the pond at various depths down to
approximately 2-1/2 feet. During installation of hand borings to collect soil samples,
liquid was encountered in one of the borings. Soil samples were analyzed by AZP's
on -site laboratory and also sent to a certified third -party laboratory. The on -site
laboratory's analysis was concluded the next day (July 29, 2021) and the results
identified elevated lead and cadmium concentrations suggesting a release of the
raffinate solution from the pond likely occurred. As noted above, AZP immediately
notified the NRC, NCDEQ, and EPA.
Summarized below is a timeline of the notifications to the agencies and subsequent
communications and submittals related to the release:
July 29, 2021
July 30, 2021
August 3, 2021
Notification to NRC, EPA and NCDEQ by
telephone with follow-up email to NCDEQ
Emails and telephone calls to EPA and NCDEQ;
NCDEQ on site to collect pH data for water in
the surface water stream west of the raffinate
solution process pond
NCDEQ on site with EnSafe personnel to collect
surface water samples from the western stream;
email to NCDEQ with information on planned
additional downstream samples to be collected on
August 4, 2021

G. Landon Davidson, P.G.
September 14, 2021
Page 9
August 4, 2021
Email to NCDEQ and EPA with additional
information on regarding the discovery of the
apparent release of raffinate solution, including
the following documents: the material safety data
sheet and chemical composition of the raffinate
solution, the August 4, 2021 laboratory analysis
report for the samples collected from beneath the
process pond on July 28, 2021, and a map
slowing locations that surface water sampling
from the stream west of the raffinate solution
process pond
August 6, 2021
Email from EnSafe to EPA and NCDEQ advising
the agencies that a conceptual sampling and
analysis plan had been developed and would be
presented during a scheduled conference call on
August 9, 2021
August 9, 2021
Conference call with EPA, Department of Justice,
and NCDEQ providing information on sampling
conducted to date, the plan for the remedial
investigation, and the installation of above-
ground tanks for the raffinate solution and
depleted solution
August 10, 2021
Email to NCDEQ regarding soil sampling to be
conducted on August 11, 2021
August 11, 2021
EnSafe on . site with NCDEQ to sample soils
beneath the raffinate solution process pond and
the depleted solution process pond
August 16, 2021
Email to NCDEQ regarding August 11, 2021 soil
sampling
August 17, 2021
Email notifying NCDEQ of surface water
samples to be collected on August 18, 2021
August 18, 2021
EnSafe on site with NCDEQ to collect surface
water samples
September 7, 2021
Email to NCDEQ with summary of results of soil
sampling beneath raffinate solution process pond
and the depleted solution process pond and
surface water and sediment samples collected
pursuant to Sampling and Analysis Plan
September 8, 2021
Telephone call to Jeff Menzel regarding samples
from beneath the liner in the maintenance pond

G. Landon Davidson, P.G.
September 14, 2021
Page 10
With respect to the cause, AZP management is working with the facility engineer and
its contractors in an effort to determine the cause of the release. Based on the
condition of the liner system at the time of removal and the preliminary evaluation of
potential causes, a failure at or near the connection of the liner to the concrete pump
structure is believed to a possible source of the release from the raffinate solution
process pond. However, while there was no visible damage to the liner systems itself,
a breach of the liners has not been ruled out since visual observation of the integrity
of the liners at the weld seam is less reliable. AZP is continuing its investigation of
the cause of the release. As part of that investigation, AZP's engineer has taken
samples of the gasket system used by the liner system contractor to seal the liner to
the pump well structure. The gasket material is being sent to a materials specialist to
confirm suitability of the material in the application. Additionally, when the liner
system was removed on July 28, 2021, AZP discovered that the secondary
containment at the concrete pump structure may have been inadequately installed
such that secondary containment was not present at the concrete pump well to include
the area beneath the point where the liner was attached to the concrete. The results of
this investigation will be included with the final report to be prepared at the
conclusion of the remediation investigation conducted by EnSafe.
As noted above, EnSafe is conducting a remedial investigation of the release of
raffinate solution from the raffinate process pond pursuant to the Sampling and
Analysis Plan provided to the Department on August 9, 2021. (See Sampling and
Analysis Plan at Attachment B). This Plan also includes sampling to be conducted
at the two process ponds located adjacent to the raffinate pond, the depleted solution
pond and the maintenance pond. The liner system for the raffinate solution process
pond is described in detail above. The depleted solution process pond and the
maintenance process pond were constructed with the same double -liner system
whereby the lower liner serves as secondary containment.
The facility also operates two stormwater management ponds one on the eastern
side of the facility and the other on the western side of the site as well as an off -
specification effluent pond which is located on the eastern side of the facility. These
three ponds also incorporate a liner system similar to that of the raffinate solution,
depleted solution, and maintenance ponds. However, the nature of the material
managed in the effluent pond differs significantly from those materials managed in
the process ponds on the western side of the facility. Upon the completion of the
investigation of the cause of the release from the raffinate solution process pond, AZP
will conduct the appropriate evaluation to determine whether similar conditions could
be affecting the integrity of the effluent pond liner system. The stormwater ponds,
which capture stormwater associated with industrial activities at the facility, are
managed pursuant to the NPDES Permit NCS000562 and the plans submitted to the
Department with the application for the Permit.

G. Landon Davidson, P.G.
September 14, 2021
Page 1
The liner systems for all of these ponds are described in the table below:
Pond
Number of Liners
Liner Material
Effluent Process Pond
4
(2) XR-5
(1) 60-mil HDPE
(1) 100-mil HDPE
Depleted Solution
Process Pond
2
(2) XR-5
Raffinate Solution
Process Pond (current
liner system)
North Side: 2 layers,
South End: 4 liners
North:
• (1) 60-mil HDPE
• (1) 80-mil HDPE
South:
• (2) XR-5
• (2) 60-mil HDPE
Maintenance Process
Pond
4
(2) XR-5
(1) 60-mil HDPE
(1) 100-mil HDPE
Eastern Stormwater
Pond
2
(1) 60-mil HDPE
(1) 100-mil HDPE
Western Stormwater
Pond
3
(2) XR-5,
(1) 80-mil HDPE
As provided with the September 7, 2021 email to the Department, the Sampling and
Analysis Plan has been amended to address conditions in the field and may be
amended and/or expanded based on the results of the initial sampling events. Upon
the completion of the remedial investigation, EnSafe will prepared a final report with
the sampling results and a delineation of the impacts from the release.
E. Plan to prevent future releases
As detailed in the August 9, 2021 conference call with NCDEQ, EPA, and DOJ, AZP
installed above -ground storage tanks for the raffinate solution and depleted solution.
These tanks were installed above the liners in these process ponds and elevated in a
manner to facilitate the inspection of the tanks and to identify any potential leaks in
the tanks. The lined areas (former ponds) currently serve a secondary containment
for the tanks. (A summary of these process modifications are provided as
Attachment F). These process modifications were undertaken as part of the initial
response to the release. AZP is also preparing to install two 36,000 gallon above-
ground tanks for collection of the material currently held in the maintenance pond.
These modifications to the raffinate solution, depleted solution, and maintenance

G. Landon Davidson, P.G.
September 14, 2021
Page 12
were implemented as part of the initial response to the release discovered beneath the
raffinate solution pond. These above -ground tanks will be managed consistent with
the maintenance and inspection procedures for other process tanks and secondary
containment structures at the facility. AZP continues to evaluate options for the long-
term management of these materials. The selected option will be provided to
NCDEQ along with the EnSafe report at the conclusion of the remedial investigation.
AZP appreciates the opportunity to respond to the alleged violations and remains
committed to compliance with all applicable regulatory requirements for addressing
the release from the raffinate solution process pond. Based upon the foregoing, AZP
believes the allegations in the NOV are premature insofar as AZP's response is
governed by the 2L Rules. AZP has clearly performed the initial response required
under the 2L Rules and began the assessment of the release required under the 2L
Rules within five days of discovering the release. Additionally, and significantly,
AZP presented the Sampling and Analysis Plan to EPA, DOJ, and NCDEQ on
August 9, 2021—less than two weeks following the discovery of the release. AZP is
continuing to implement the Sampling and Analysis Plan on an expedited schedule.
Once the assessment under the Sampling and Analysis Plan has been completed, AZP
requests the opportunity to meet with DEQ to present the findings and proposed plans
for further actions required to address the impacts to the groundwater under the 2L
Rules.
Sincerely,
ttachments: Attachment A
Attachment B
Attachment C
Attachment D
Attachment E —
Attachment F —
— July 30, 2021 Email
— August 9, 2021 Sampling and Analysis Plan
— August 4, 2021 Email
— August 16, 2021 Email
September 7, 2021 Email
Process Modification Summary
cc (via email only): T. Hill Davis, III, NCDOJ ([e-mail])

Attachment A
July 30, 2021 Email

From: Charles G. Howell
To: [e-mail]
Cc: Timothy Basilone; Kobus de Wet; Menzel, Jeff
Bcc: [e-mail]
Subject: AZP Raffinate Pond
Date: Friday, July 30, 2021 2:05:00 PM
Attachments: image001.pnq
Mr. Burch,
I am providing this letter in follow up to our conversation yesterday regarding circumstances related
to the raffinate pond located at the American Zinc Products (AZP) facility in Mooresboro, North
Carolina. As discussed with you during our phone call, while in the process of replacing the liner
system at the raffinate pond, it was determined from analysis of soil samples collected below pond
liner that raffinate solution appears to have entered soil beneath the footprint of the pond.
After becoming aware of the analytical results of soil samples collected beneath the liner, a call was
made to the National Response Center, after which we discussed this matter with you and in
subsequent discussions with Jeff Menzel and Rick Jardine of the USEPA emergency response
section. We currently have a call in to John Johnston at USEPA to discuss this matter further in
regard to pending work under the 3013 Administrative Order for the AZP facility.
The raffinate pond contained four synthetic liners, which included two separate liner systems each
consisting of two liners. The uppermost liner system was installed on top of the underlying liner
system in 2019, as part of renovation work completed at the facility during the shutdown preceding
the facility re -start in 2020. More recently, repairs were made by our contractors to the uppermost
liner to install patches over small areas where the upper liner had been breached. In addition,
repairs have been made at the concrete pump structure where the synthetic liner is joined to the
concrete walls of the structure.
Based on the advice of the contractor who installed the liner system, a project to remove and
replace all the liners in the pond with one new liner system was planned and initiated during a
facility shut down scheduled to occur this past week. In advance of the project, the pond was
modified for this project by installing a barrier wall across the center of the pond to divide the pond
into two sections. By dividing the pond into two sections, the liners in the pond could be removed
and replaced with a new liner system in two phases, while shortening the length of time for the
plant to be shut down.
Once overlying liners were removed from the northern area, the lowermost liner was exposed and
inspected. The liner was observed to be intact, and no apparent breaches were identified.
Following removal of the lowermost liner the underlying substrate surface, consisting of sand, was
observed to be dry; however, there were variations in the appearance of the sand surface which
suggested a potential release. Soil samples were taken in two locations in the base of the pond at
various depths down to approximately 2-1/2 feet. During installation of hand borings to collect soil
samples, some liquid was encountered in one of the borings. Soil samples were analyzed by our on -
site laboratory and sent to a certified third -party laboratory. The results from our on -site laboratory
identified elevated lead and cadmium concentrations which are indicative of a release of the
raffinate solution. Following collection of the soil samples, our contractor proceeded with

installation of the new liner system in the northern portion of the raffinate pond, as planned.
Based on the currently available information, we are unable to determine the source or amount of
the potential release; however, based on our observations of the integrity of the bottom liner, it
appears that a breach at the connection of the liner at the concrete pump structure is the most likely
source of any release. Therefore, a leak detection system is being installed in the vicinity of the
pump structure to enable monitoring for potential leakage. Once liner installation work in the
northern portion of the raffinate pond is completed along with installation of the leak detection
system, the pond will be placed in service and plant operation will commence.
As reported to you, AZP is in the process of developing a plan for investigating the subsurface in the
vicinity of the raffinate pond. Soil borings will be installed to determine the general geology beneath
the pond, the nature of underlying soil, and to determine if a groundwater aquifer is present above
bedrock. If a groundwater aquifer is present above auger refusal, monitoring wells will be installed
in the area. Soil samples will also be collected and analyzed to determine the extent of lead,
cadmium, and zinc in subsurface soil. A copy of the investigation plan will be provided to you in
advance of commencement of field activities. The plan will be implemented as soon as possible
after all arrangements are finalized with a drilling contractor.
AZP with working with its contractor to develop a new design plan for upgrading the raffinate pond.
Based on our current discussions with the contractor, we expect this upgrade project to be
scheduled during the upcoming year. The current objective of the upgrade project is to eliminate
the pump structure and complete installation of two ponds within the current footprint of the
raffinate pond. Operating two ponds in the area will enable future maintenance work to be
scheduled on each of the ponds individually while the facility is operating.
Until the upgrade project is implemented, the raffinate pond will be operated using only the
northern portion of the former pond area. The pond will be operated with raffinate solution in the
pond being kept to the minimum operable level. The leak detection system will be used to monitor
for leakage to the subsurface.
As discussed with you, when completed we will provide to you a copy of our plan for investigating
the subsurface area in the vicinity of the raffinate pond. We hope to have the plan completed next
week and will begin planning with drilling contractors to implement the plan as soon as possible.
The investigation plan will include details on sample analytical result and other information
describing the raffinate pond. In addition, we will work with USEPA and John Johnstone to modify
existing plans to incorporate information on the raffinate pond, and to include findings from the
investigation into the 3013-work plan and report.
In summary, our plans consist of the following two objectives:
• Complete installation of new liners with a leak detection system in the northern portion of the
raffinate pond and commence operation of the pond as described above, and
• Perform an investigation of subsurface soil conditions, including delineation of the extent of
elevated zinc, lead and cadmium concentrations; and assess potential groundwater impact
beneath the raffinate pond. Groundwater wells will be installed in the uppermost
groundwater aquifer, if present above bedrock. Investigation work will be performed on the
soil zone down to auger refusal or bedrock.

As we discussed, the raffinate pond is critical to plant operation and functions to continuously
circulate raffinate solution to the zinc production process. Raffinate is a sulfuric acid solution
containing dissolved metals, including primarily zinc, lead and cadmium. The pond must be in
service during plant operations. Without the availability of the pond, the plant cannot operate. To
enable work for replacement of the raffinate pond liners, the plant was shut down.
We will keep you informed of any changes or new information that becomes available as we prepare
our investigation plan. Please feel free to contact me if you have any questions in the meantime.
Regards,
Charles Howell
Environmental Manager
American Zinc Products, LLC
484 Hicks Grove Rd.
Mooresboro, NC 28114
0. [phone]
C: [phone]
cghowell®azr.com
AZP
AMERICAN
ZINC PRODUCTS
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Attachment B
August 9, 2021 Sampling and Analysis Plan

EIIISAFE
creative thinking. custom solutions.
August 9, 2021
American Zinc Products LLC
Attention: Mr. Timothy R. Basilone
Vice President, Environmental Affairs
484 Hicks Grove Road
Mooresboro, North Carolina 28114
Re: Sampling and Analysis Plan — Process Ponds
American Zinc Products
484 Hicks Grove Road
Mooresboro, North Carolina 28114
BACKGROUND
The American Zinc Products facility is approximately 196 acres in size and is located at 484 Hicks
Grove Road in Mooresboro, North Carolina. A Site Layout Map has been included as Figure 1A.
Primary operations at American Zinc Products (AZP), consist of zinc metal production via solvent
extraction and electrowinning.
During the week of July 25, 2021, the plant initiated a program to replace the liners within a
process pond called the Raffinate Pond which is located on the west side of the facility.
AZP engaged EnSafe Inc. to observe the surface beneath the liner system and conduct sampling
as warranted to determine whether there had been a release from the pond. Upon removal of
the liner system, EnSafe Inc. personnel installed shallow, hand -augured borings at two locations.
Soil samples from these borings, conducted at intervals from 6 inches to 3 feet, were submitted
to an independent laboratory for analysis; however, to provide more rapid data, split samples were
also submitted to the in -plant QA/QC laboratory for analysis. Results of the in -plant analysis
showed soils with low pH. Further, cadmium, lead, and zinc, which are constituents of the
Raffinate process were also detected.
It could not be determined whether the release was the result of a recent failure of the liner system
or from historical operations. However, AZP personnel provided release notification to the
National Response Center, United States Environmental Protection Agency (U.S. EPA) and to the
North Carolina Department of Environmental Quality (NCDEQ) on Thursday, July 29, 2021.
The facility initiated the development of a response plan immediately. This work plan is being
submitted as part of that response plan. The Raffinate Pond which was the subject of testing is
one of three process ponds that are generally co -located on the western side of the plant.
AZP has determined that the other two process ponds should be included in the following response
plan as they are similarly designed and operated.
ENGINEERING I ENVIRONMENT I HEALTH & SAFETY I TECHNOLOGY
5724 Summer Trees Drive I Memphis, Tennessee 38134 I P 901-372-7962 I F 901-372-2454 I www.ensafe.com

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 2
Physiographic and Topographic Setting
The Site is located within the Southern Outer Piedmont physiographic province of North Carolina,
which is characterized by low rounded hills and ridges, and low to moderate gradient streams.
Rainfall amounts in this region vary from 40 to 50 inches per year. The predominant rock type in
the vicinity of the Site consists of Cambrian to Late Proterozoic age schist, mica schist, and biotite
gneiss. Soil types consist primarily of fine, kaolinitic, thermic Typic Kanhapludults (Cecil, Appling,
and/or Madison series). Soil pH levels associated with the Cecil, Appling, and Madison series range
from moderately acidic to very strongly acidic (Omernik & Griffith 2008). Elevations at the Site
range from approximately 880 feet above mean sea level (amsl) along the eastern property
boundary, to approximately 680 feet amsl near the northern property boundary (USGS 2014).
Pre -Construction Geotechnical Evaluation
Geotechnical investigations were performed at the Site in 2011 and 2012, prior to the construction
of the active facility. Results of the investigations were presented in the Subsurface Exploration,
and Subsurface Exploration — Addendum 1 reports submitted by S&ME, Inc. in July, and
December 2011, respectively. A subsequent geotechnical investigation was performed in 2012
along the railyard at the facility, as reported in the Geotechnical Exp/oration Report — Horsehead
Facility — Retaining Wall at Rai/yard (S&ME 2012). Four geotechnical borings were completed in
the vicinity of the west ponds. These borings were identified as follows, in the abovementioned
reports: B-2, B-4, B-6, and B-16. A map depicting the location of historical geotechnical borings
overlaid on the current site configuration has been included as Figure 2.
Boring logs for geotechnical borings completed in the vicinity of the west ponds show that partially
weathered rock, which was encountered in three of the four of the borings in the area, was
reported at depths ranging from 0 to 28 feet below the surface.
Constituents of Potential Concern
The constituents of potential concern (COPCs) associated with the Raffinate solution consist
primarily of the following: sulfuric acid, cadmium, chromium [total], lead, and zinc.
Initial Investigative Measures
On July 28, 2021, two hand auger locations were advanced to a depth of 2.92 feet in HA1 and
1.75 feet at location HA2. Hand auger locations from the initial investigative measures can be
found as Figure 3. It was noted that immediately beneath the lower liner system was a layer of
sand/gravel ranging from 0.8 foot to 2.0 feet thick. Below the sand/gravel layer was a red brown
clay that contained traces of sand and mica along with frequent gravel sized rocks. Liquid was
encountered within the hand auger boring at HA1 around 15-inches below the surface. The
analysis of samples by the onsite laboratory was completed on July 29, 2021 and indicated impacts
to the soil and water below the north side of the Raffinate Pond; however, it does not appear that
the water sampled is true groundwater; it is more likely to be interflow stored in the sand/gravel
layer.
ENSAFE

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 3
Mitigative Measures Implemented
Following confirmation of the Raffinate Pond release, AZP implemented the following response
actions:
• Installed a new double layer liner system
• All connections of the liner to the pump well were sealed
• Began development of an alternative process plan to enable access to the process ponds
for investigation and remediation, if required.
• Conducted a surface water survey downgradient of the ponds and collected samples in two
locations in the nearest ravine to the process pond area.
Process Modification to Accommodate Response Plan
As described below, AZP has temporarily converted the Raffinate Pond (FE-211) and Depleted
Solution Pond (FE-212) to storage tanks with the liner system serving as secondary containment
in order to provide access to the ponds for soil assessment.
This interim configuration consists of a fiberglass reinforced plastic (FRP) storage and pump tanks,
with a high -density polyethylene (HDPE) piping connection between the two tanks. The proposed
modification from the original (as -built) configuration to the proposed interim configuration is
shown in Figure 1B.
From depletion
To gypsum precio
T T
T T TT T T/
— 4
- Depleted soln pond
Raffinate to leach SX
Raffinate from SX
\TTTIT TTTTTTT`
Raffinate pond
— 4
1 1 1 1 1 1 1 1 1 1\
Original configuration. Double liner serve as primary and secondary containment
Automatic shut off valve
From depletion To gypsum precip.
Depleted buffer tank
Raffinate to leach SX
Automatic shut off valve
Raffinate from SX
TTTTTTTT T
Raffinate buffer tank
1 1 1 1 1 1 1
Planned interim configuration. Ponds serve as lined secondary containment.
f
—4
Figure 1B. Original configuration (top) and proposed interim configuration (bottom).
EJVSAFE

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 4
Key features of the proposed interim configuration for the two ponds are as follows:
• Process solution will flow under gravity from the SX circuit, directly into the horizontal
buffer tank, which is connected to a vertical pump tank, placed inside the existing pump
wet well. The solution will be pumped from the vertical pump tank to the next process
stage.
• The pump speed will be controlled to maintain the level in the tanks at a constant value.
• An automatic shut off valve will also be installed in the pipe feeding the buffer tank, to limit
the risk of overflowing the tank.
• In this configuration, the lined ponds will serve only as secondary containments, receiving
rainwater, falling on the footprint of the pond. Any liquid in the pond will be pumped back
into the tanks, or to the metals removal circuit, which is common practice with all secondary
containments onsite.
• The system will provide good access for visual inspection of the integrity of the tanks,
piping connection and pond liner, eliminating the reliance on tell -tale pipes.
Preliminary Conceptual Site Model Summary
Based on analysis of available information summarized above and from the initial site investigation,
it appears that the primary pathway for liquid migration beneath pond liner exists within the
underlying sand/gravel layer. This unconsolidated sand/gravel layer, which underlies the footprint
of the Raffinate Pond and is assumed to be under the other ponds, is the likely geologic unit
providing storage for any released liquids from the ponds.
Other pathways into the subsurface have not yet been identified.
Preliminary Summary of Environmental Receptors
The Conceptual Site Model Preliminary analysis of environmental receptors, should a release have
occurred, include release to interflow and/or groundwater, release to offsite drainage in
intermittent drainage regimes, potential exposure to biota through surface water and sediment,
and potential human dermal and ingestion exposure through surface water and groundwater.
Each of these pathways will be evaluated as data is available as to whether the pathways are
complete and further evaluation is warranted.
ENSAFE

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 5
The potential for exposure to humans through the groundwater pathway is being actively
researched: Research conducted for the Initial Site Review (ISR) report includes an environmental
database search, which identified only one well proximal to the Site. This well is reportedly a
public water supply well located near the southwest corner of the parking area of the primary
administrative building and has a designation as NC0181485. According to the NCDEQ, this well
was constructed in 1977 and permitted for Hicks Grove Methodist Church to serve less than
101 people; the well is listed as closed. Currently, all water used for potable or production
purposes by AZP is obtained from the town of Forest City, and not from onsite wells. Interviews
with Site personnel during EnSafe's February 2020 Site visit indicate there may be one private well
located in the general site area, but details of its location, use (likely lawn irrigation as city water
is readily available), well depth, and or well construction were not known. EnSafe has requested
well records for public and private wells in the area from NCDEQ and the Rutherford County
Health Department but has not received a response.
DATA OBJECTIVES
The principal source of potential concern, which is the subject of this investigation, includes the
presence of free liquid migrating through the surrounding strata and into surface water features.
The primary data gathering objective is to determine if the Raffinate has impacted the area
surrounding the ponds via groundwater or interflow and consequently to surface water/sediment.
This Sampling Plan precedes a broader investigation to be completed under the RCRA 3013 Order
following the U.S. EPA's review of the ISR. In addition to gathering the information intended to
satisfy the questions above, additional information as to the subsurface layers including the
compacted fill unit and the elevation of the groundwater of the nearby area will be gathered.
The purpose for collecting soil information is to determine the presence of potential residual metals
concentrations and the vertical extent of elevated concentrations. Furthermore, soil sample
information will be used to determine if potential metals may have entered the uppermost water
bearing zone, which may be intermittent.
FIELD SAMPLING AND ANALYSIS
Field activities and data validation will be performed in general conformance
with United States Environmental Protection Agency Region 4, Science and Ecosystem
Support Division Field Branches Quality System, and Technical Procedures available at
http://www.epa.gov/region4/sesd/fbgstp/index.html. Additionally, field sampling will be
performed in accordance with a site -specific Health and Safety Plan to ensure that onsite
EnSafe employees are properly trained in accordance with Occupational Safety and Health
Administration 29 CFR 1910.120. The Health and Safety Plan will include operating procedures to
address site -specific hazards and will make recommendations on appropriate personal protective
equipment and associated action levels.
ENSAFE

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 6
Field activities will be performed in a phased approach, in order to adequately assess impacts to
the environment.
Phase 1A — Sub -liner Hand Auger Sampling
In order to assess the subsurface soils below the Depleted Pond, southern end of the Raffinate
Pond, and the Maintenance Pond hand auger borings will be advanced to an estimated depth of
3 feet into soil or refusal, whichever is shallowest. Previous investigations in the northern end of
the Raffinate Pond revealed a sand/gravel layer just below the pond liners. This sand layer will
be removed via a two -person gas powered auger prior to commencement of the hand auger
sampling. If needed temporary polyvinyl chloride (PVC) casing will be installed to prevent hole
collapse. Sample intervals for the hand auger sampling will be 0.0 to 0.5 feet and 2.5 to 3.0 feet
into the soil underlying the sand/gravel layer. One location from each pond will be advanced until
refusal or hand augering becomes impractical. Proposed hand auger locations can be found in
Figure 4.
Sampling of the Depleted Solutions Pond and the Raffinate Pond are planned for week of
August 9, 2021. Sampling of the Maintenance Pond will be implemented after the plant has
drained the pond which may be the following week.
Phase 1B — Subsurface Soil and Groundwater Investigation
Near Pond Borings
Soil borings will be advanced via direct push technology to refusal which is expected at depths
from approximately 10 to 60 feet below ground surface at 11 locations near the operating
Raffinate, Depleted, Maintenance, and Storm Water Ponds. Soil boring locations near the pond
will be placed as to assist in determination the vertical and horizontal extent of contamination (if
present) and in areas accessible by a drill rig. At least five of these soil borings will be converted
into 2-inch monitoring wells for groundwater sampling.
Near pond soil boring sampling will consist of screening continuously collected soil samples with a
hand-held XRF machine to identify potential sampling intervals within the soil. If this becomes
impractical or the samples are moist, sample intervals may be submitted to the onsite laboratory
for screening analysis to determine which intervals are submitted to the third -party offsite
laboratory.
Upgradient Groundwater Wells
Two groundwater monitoring wells will be installed to the southeast and east of the pond area.
Wells will be installed to cross the vadose zone and will provide information on the site wide
groundwater elevations.
ENSAFE

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 7
Proposed soil boring and monitoring well locations can be found in Figure 5.
Methodology: Soil sample intervals will be composited in plastic bags and placed in an
appropriate container. If encountered, groundwater samples will be collected via a peristaltic
pump and Teflon tubing using low -flow techniques. Sample water will be placed into the
appropriate containers and will be unfiltered and acidified (with several drops of ultrapure
nitric acid).
Monitoring wells will be constructed of 2-inch diameter PVC casing coupled to 10 feet of 0.01-inch
slotted PVC casing. The annular space around the slotted casing and 2 feet above the slotted
casing will be filled with 20/30 silica sand, topped with a 2-foot bentonite seal to 1-foot below the
ground surface. Neat cement grout will not be used as to reduce the likelihood of effecting the
pH of the water within the well. The wells will be completed with a 3-foot by 3-foot square
concrete pads and stick up well casings or a 2-foot by 2-foot square concrete pad with flush mount
surface casing, whichever is practical for the well location. Each stickup well will contain at least
three protective bollards painted safety yellow.
Lab Analysis: Soil will be analyzed for the 8 RCRA metals and Zinc using U.S. EPA Method 6020
along with pH using method U.S. EPA Method 9045D. Groundwater will also be analyzed for the
8 RCRA metals and Zinc however field screening of groundwater at each location will be performed
using a multi -parameter water quality meter to measure pH and specific conductance. Other
parameters such as temperature, oxidation-reduction potential, and dissolved oxygen will also be
collected during groundwater sampling.
QA/QC: Sample duplicates will be collected at a frequency of 1:20.
Contingencies: Soil sampling will cease once groundwater or interflow is encountered to prevent
possible contamination of the underlying lithology.
Sampling Frequency: Groundwater sampling will be conducted quarterly to determine seasonal
variations in the underlying aquifer. Groundwater would be sampled quarterly for the first year,
at which time the data will be evaluated to determine if more or less frequency is needed
Boring Abandonment
Upon completion of sampling, all boreholes will be abandoned using a bentonite slurry, installed
via tremie pipe, to the native soil surface below the gravel layer, in accordance with North Carolina
Administrative Code, Title 15A, Subchapter 2C, Section .0113 (NCDENR 2009). The annular space
in the PVC casing will be filled with high strength concrete to maintain the integrity of the
surrounding gravel layer, and ground surface will be restored to its original form (to the
extent feasible).
ENSAFE

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 8
Phase 2 — Surface Sediment and Water Sampling
The approach will include an initial recon of the full traces of Ravines 4, 5, and 6; sample locations
will be flagged and revisited to collect samples as part of the sampling activities. The planned
approach is a systematic evaluation of surface water and sediment in the Ravine 4; and
establishment of conditions in unimpacted Ravines 5 and 6. This systematic approach will consist
of sequential sample collection beginning at lowest end of Ravines 4 and 5 and progressively
moving upstream to avoid disturbance to surface water and sediment in each channel. Ravine 6
will be sampled prior to the confluence with Ravine 5. In the case of Ravine 4, sequential sampling
will begin at the discharge point area at Broad River and continue up the channel until it reaches
the headwall at the head of the ravine. Proposed sample locations can be found in Figure 6.
Activity: Sampling activities will consist of collection of nine paired surface water/sediment
locations along the central trace of Ravine 4, beginning at the discharge point to Broad River, and
continuing to the ravine headwall, two along the central trace of Ravine 5, and one along the
central trace of Ravine 6 prior to the confluence with Ravine 5.
Methodology: Surface water samples will be collected as unfiltered acidified (preserved with
several drops of ultrapure nitric acid) by submerging the sample container in pooled water. The
surface water sample will be collected first to minimize turbidity in the sample. Sediment samples
will be collected from pool bottoms using a stainless -steel scoop and placed in an appropriate
container.
Lab Analysis: Surface water and sediment samples will be analyzed for RCRA Metals + Zinc.
Field screening of surface water at each location will be performed using a multi -parameter
(temperature, pH, specific conductivity, oxidation-reduction potential, and dissolved oxygen) water
quality meter.
QA/QC: Sample duplicates will be collected at a frequency of 1:10.
Contingencies: In the event the presence of surface water is determined to be truly intermittent,
sampling will be preferentially scheduled following a wet weather event. Ravine 1 typically has a
perennial stream flow — this will used as a gauge to make a decision that the other ravines may
be flowing. A rain gauge will be will also be installed onsite to determine site -specific rainfall
amounts.
Seasonal variation: Sampling will be conducted during a dry season and a wet season,
beginning immediately as summer is considered a wet season.
Additional: The chemical signature of the process ponds on the northwest side of the plant is
known; however, the bulk chemistry and leachability of indigenous residuum and weathered
bedrock is not. If reasonable exposures of each are found during recon of Ravines 5 and 6,
ENSAFE

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 9
samples will be collected of each media and submitted for bulk chemistry analysis, and
Synthetic Precipitation Leaching Procedures to quantify leachability.
Global Positioning System
To the extent feasible, sample locations will be recorded via a handheld global positioning system
instrument. Such coordinates will be used to produce site maps and summary figures.
Investigation Derived Waste
Potential investigation derived wastes (IDW) include decontamination water, soil cuttings, and
foundation debris. IDW will be placed in 55-gallon steel drums and temporarily staged at a
designated location onsite. Following receipt of laboratory samples collected during the
investigation, IDW will be transported and disposed of at a licensed disposal facility.
Data Review
Following receipt of analytical data, EnSafe will prepare a brief letter report to summarize field
activities, present analytical data, and to summarize findings of the investigation. The letter report
will include data summary tables and figures displaying sample locations. Analytical data
associated with soil samples will be screened against site -specific background values, as
determined during previous field investigations performed at the Site in 2015, and as reported in
EnSafe's Investigation Summary Report, dated July 2015, along with the NCDEQ Preliminary Soil
Remediation Goals. Background for surface water and sediment will be determined by the sample
results from Ravines 5 and 6.
COMPREHENSIVE DATA EVALUATION
Following completion of the investigation, EnSafe will update the ISR report and will develop an
investigation summary report, which will include summary tables, figures, laboratory reports, etc.,
and will present a summary of findings.
REFERENCES
EnSafe Inc. Initial Site Review Report. 5724 Summer Trees Drive, Memphis, Tennessee.
June 2020.
Investigation Summary Report. 313 Wingo Way, Mount Pleasant, South Carolina.
July 2015.
North Carolina Department of Environmental and Natural Resources, Division of Water Quality.
Well Construction Standards. October 2009.
Classifications and Water Quality Standards Applicable to the Groundwaters of
North Carolina. April 2013.
ENSAFE

Sampling and Analysis Plan — Raffinate Pond Release
American Zinc Products; Mooresboro, North Carolina
August 9, 2021
Page 10
Omernik, J., & Griffith, G. Ecoregions of North Carolina and South Carolina (EPA). 2008. Retrieved
from http://www.eoearth.org/view/article/152148
S&ME, Inc. Subsurface Exploration, Horsehead Corporation, Reid Property. 301 Zima Park Drive,
Spartanburg, South Carolina. July 2011.
Subsurface Exploration — Addendum 1, Reid Property. 281 Fairforest Way,
Greenville, South Carolina. December 2011.
Geotechnical Exploration Report, Horsehead Facility — Retaining Wall at Ra//yard.
301 Zima Park Drive, Spartanburg, South Carolina. July 2012.
United States Environmental Protection Agency Region 4, Science and Ecosystem Support Division.
Field Branches Quality System and Technical Procedures. 2013. Retrieved from:
http://www.epa.gov/region4/sesd/fbqstp/index.html
United States Geological Survey. Chesnee quadrangle, North Carolina [map]. Photo revised 2014.
1:24,000. 7.5 Minute Series. Reston, VA: United States Department of the Interior,
USGS, 2014.
Respectfully submitted,
EnSafe Inc.
By: Phillip . Coop, CHMM
Senior Project Manager
Attachments:
Figures
Figure 1A
Figure 1B
Figure 2 —
Figure 3 —
Figure 4 —
Figure 5 —
Figure 6 —
Tables
Table 1 —
— Site Layout Map
— Interim Configuration for Raffinate and Depleted Solutions Ponds
Historical Geotechnical Boring Location Map
Initial Investigation Hand Auger Location Map
Proposed Sub -liner Hand Auger Sampling Location Map
Proposed Soil Boring and Monitoring Well Location Map
Proposed Surface Sediment and Water Sampling Location Map
Background Soil Sample Summary
ENSAFE

Attachment
Figures

X:\AZP\SiteMapV2.m xd
STORM
BROAD
WATER
RIVER
pPruck
WATER
ADJACENT
APPROXIMATELY
LEACHING
PLINT
TRUCK
L4W
FILTER
PONDS
LOADING
LEACHING
r
WOX\WASHING
4
WATER
PONDS
\ I.
MELTING/CLING/HALLO PING AREA..
iis,_ J
FIGURE 1A
SITE LAYOUT MAP
AMERICAN ZINC PRODUCTS
AZP MOORESBORO FACILITY
LEGEND
AREA 100 - LEACHING AREA 300 - BLEED TREATMENT =I AREA 500/900 - CASTING AREA 700 - WOX UNLOADING
AREA 200 - SX (SOLVENT EXTRACTION) =I AREA 400 - ELECTROWINNING Q AREA 600 - PLINT Q AREA 1100 - WAREHOUSE
WOX WASHING
NAD 1983 STATE PLANE
NORTH CAROLINA FEET
0 100 200
SCALE IN FEET
REQUESTED BY:
DRAWN BY:
RK EJIISAFE
DATE:
8/9/2021
PROJECT:
0888824799
Creative thinking.Custom solutions.
800.5 88.7962 www.ensafe.com
Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS
, USDA, USGS, Ae oGRID, IGN, and the GIS User Communit

LEGEND
O EXISTING HAND AUGER LOCATION n RAFFINATE POND
PROPOSED HAND AUGER LOCATION
n DEPLETED POND
NAD 1983 STATE PLANE
NORTH CAROLINA FEET
0 150 300
SCALE IN FEET
FIGURE 2
RAFFINATE POND INVESTIGATION
HISTORICAL BORING LOCATIONS MAP
AMERICAN ZINC PRODUCTS
484 HICKS GROVE ROAD
MOORESBORO, NC 28114
REQUESTED BY: AW
DRAWN BY:
MS
DATE: 8/9/2021
PROJECT: 0888824799
EJVSAFE
Creative thinking.Custom solutions.
800.5 88.7962 I www.ensafe.com
Sourc : Google Earth Pro Imagery - 01/28/2021

LEGEND
HAND AUGER LOCATION
BERM
NAD 1983 STATE PLANE
NORTH CAROLINA FEET
0 20 40
SCALE IN FEET
FIGURE 3
RAFFINATE POND INVESTIGATION
HAND AUGER LOCATION MAP
AMERICAN ZINC PRODUCTS
484 HICKS GROVE ROAD
MOORESBORO, NC 28114
REQUESTED BY:
AW
DRAWN BY:
MS
DATE:
8/9/2021
EJVSAFE
Creative thinking.Custom solutions.
800.588.7962 I www.ensafe.com
PROJECT:
0888824799
Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS Us r Community. Imagery date - 02/01/2019.

LEGEND
• PROPOSED HAND AUGER LOCATION
BERM
NAD 1983 STATE PLANE
NORTH CAROLINA FEET
0 25 50
SCALE IN FEET
FIGURE 4
AZP POND INVESTIGATION
PROPOSED HAND AUGER LOCATION MAP
AMERICAN ZINC PRODUCTS
484 HICKS GROVE ROAD
MOORESBORO, NC 28114
REQUESTED BY:
AW
DRAWN BY:
MS
DATE:
8/9/2021
EJVSAFE
Creative thinking.Custom solutions.
800.5 88.7962 I www.ensafe.com
PROJECT:
0888824799
Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS Us r Community. Imagery date - 02/01/2019.

\AZP\AZP_PropSBGW Map.mxd
STORMWATER
LEGEND
9 PROPOSED GROUNDWATER WELL LOCATION
• PROPOSED SOIL BORING LOCATION
RAVINE
0
NAD 1983 STATE PLANE
TENNESSEE FEET
110 220
SCALE IN FEET
FIGURE 5
AZP POND INVESTIGATION
PROPOSED BORING AND GROUNDWATER
MONITORING WELL LOCATIONS MAP
AMERICAN ZINC PRODUCTS
484 HICKS GROVE ROAD
MOORESBORO, NC 28114
REQUESTED BY:
AW
DRAWN BY:
MS
DATE: 8/9/2021
PROJECT: 0888824799
ENSAFE
Creative thinking.Custom solutions.
800.588.7962 I www.ensafe.com
Source: Esri, Maxar, GeoEye, Earthstar Geog aphics, CNES/Airbus DS, USDA, USGS, Ae oGRID, IGN, and the GIS User Community

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APPROXIMATE SUBJECT PROPERTY BOUNDARY
SURFACE WATER DRAINAGE PATHWAY
ONSITE
RAVINE 3
FIGURE 6
SCHEMATIC OF AREA HYDROLOGY
AMERICAN ZINC PRODUCTS
MOORESBORO, NORTH CAROLINA
1-
NAD 1983 STATE PLANE REQUESTED BY: AW
NORTH CAROLINA FEET
0 200 400
DRAWN BY: CC
DATE: 8/09/2021
SCALE IN FEET PROJECT: 0888824799
Source
ENSAFE
Creative thinking. Custom solutions.
800.588.7962 I www.ensafe.com
Google Earth Pro Imagery Date: 06/03/2018

Attachment
Table 1 Background Soil Sample Summary

Table 1
Background Soil Sample Summary
Horsehead Metal Products, Inc.
Mooresboro, North Carolina
Sample Location: SB-27 SB-28 SB-28 SB-29 SB-30
Sample Date: 05/08/2015 05/08/2015 05/08/2015 05/08/2015 05/08/2015
Sample Type: B FD B B B
Matrix: Soil Soil Soil Soil Soil
Sample Depth (inches bgs): 0- 6 0- 6 0- 6 0- 6 0- 6
Analyte Units
Aluminum mg/kg 21000 22000 22000 20000 21000
Antimony mg/kg ND ND ND ND ND
Arsenic mg/kg 2.6 4 3.3 2.3 3.7
Barium mg/kg 110 51 52 74 37
Beryllium mg/kg 0.59 0.54 0.48 0.6 0.39
Cadmium mg/kg ND ND ND ND ND
Calcium mg/kg 160 J 68 J 68 J 180 J 60 J
Chromium, Total mg/kg 11 87 J 26 J 7.8 22
Cobalt mg/kg 3.1 8.6 J 8.8 J 2.2 8.8
Copper mg/kg 6.2 26 23 3.5 17
Iron mg/kg 9500 43000 J 22000 J 8400 26000
Lead mg/kg 15 17 15 13 18
Magnesium mg/kg 580 1700 1800 510 360
Manganese mg/kg 200 95 84 140 120
Nickel mg/kg 5.1 10 J 9.2 3.7 12
Potassium mg/kg 1800 2600 2400 570 720
Selenium mg/kg 0.86 J 1.5 1 J 0.63 J 1 J
Silver mg/kg ND ND ND ND ND
Sodium mg/kg ND ND ND ND ND
Thallium mg/kg ND ND ND ND ND
Vanadium mg/kg 18 66 45 15 40
Zinc mg/kg 24 47 45 22 16
Mercury mg/kg 0.024 J 0.026 J 0.027 J 0.014 J 0.0069 J
Notes:
B = background sample
FD = field duplicate sample
bgs = below ground surface
mg/kg = milligrams per kilogram
ND = analyte not detected above method detection limit
J = estimated concentration

Attachment C
August 4, 2021 Email

From: Charles G. Howell
To: Burch. Brent; Menzel. Jeff
Cc: Timothy Basilone; Kobus de Wet; Morris, Sean; Johnston.John; Garcia, Javier; Woosley, Julie
Subject: RE: [External] AZP Raffinate Pond
Date: Wednesday, August 4, 2021 5:21:00 PM
Attachments: 2021-8-3 Pace Lab Analytical Results.pdf
image001.pnq
imaae002.onq
Sampling Locations.docx
Zinc Raffinate Tech. Data Sheet.pdf
Raffinate Composition.xlsx
Brent, Jeff,
This is a follow-up to your conversation with Tim Basilone earlier this afternoon and your site
visit yesterday as well as a response to previous emails from each of you received on Friday
July 30, 2021.
First, as we just discussed and as a follow-up to our call on Thursday advising you of our
preliminary, uncertified results from soil sample during our liner replacement project, we now
have the Pace Analytical results from those soil samples which are generally comparable to
the results from our plant lab we previously reported to you. Please see the Pace results
attached.
Further, as you requested during your site visit yesterday, we pulled two surface water
samples at the locations you identified from the stream west of the raffinate basin which were
also sent to Pace. Later in the evening we collected additional samples of the two previous
locations and one further downstream for preliminary analysis by the plant lab. The
approximate locations of each are marked on the attached drawing. As discussed with Jeff
today, we are disappointed to learn that the preliminary results from our plant lab detected
cadmium in the sample locations B and C on the attached drawings. We intend to collect
additional samples from location "C" as well as another sample "D" as this stream enters the
river, and those samples will be sent to a certified lab.
In response to DEQ's email questions received July 30, 2021, we offer the following:
Question: When were the variations in appearance of the sand surface first observed
and when were the soil samples taken?
EnSafe personnel were on site to observe the liners being removed from the
raffinate pond. While the lowermost liner was being removed on Wednesday,
July 28, 2021, some discoloration of the underlying sand was noted. It was not
clear whether this discoloration was related to a release or was lithologic.
Therefore, the decision was made to collect samples prior to resuming work.
We received the preliminary results from our plant lab on the morning of the
29th, at which time we contacted you, EPA, and NRC.

Question: Provide analytical results from samples taken under the raffinate pond liner:
As previously explained, soil samples collected from under the pond liner were
split for analysis between our plant lab which is not certified and Pace
Analytical. Attached are the analytical results for soil and liquid samples
collected from hand borings in soil beneath the liner obtained from Pace
Analytical yesterday evening, August 3, 2021.
Please note that the values for some metals, especially cadmium and lead, are
lower in the Pace lab report than were reported to the NRC using in -plant
data.
Question: Raffinate Solution Profile:
Attached are two files, including a Technical Data Sheet and analytical results
providing maximum concentrations of constituents contained in Raffinate.
Question: Surface Water Samples:
As discussed above, as requested by you, surface water samples were collected
on August 4, 2021, from the drainage channel located west of the raffinate
pond. These samples were sent to Pace Analytical for expedited analysis for
total RCRA metals and zinc. Conductivity and pH were measured in the field.
Jeff Menzel was present to observe the collection of these samples. We
anticipate results for these analyses will be received from Pace by the end of
the week at which time we will provide these results to you.
Question: You requested TCLP analysis for soil samples.
We have not obtained this information since the TCLP is for waste
characterization purposes for waste disposal. Our results are being compared
to applicable soil and surface water standards and action levels.
We are working diligently with EnSafe to develop a draft work plan to respond to the apparent
failure of the pond liner. We hope to provide the proposed work plan to DEQ and EPA no later
than Friday.
In the meantime, we are also evaluating means by which we might resume limited operations
while also allowing our response actions to continue concurrently.
Please advise me if you have any questions or require additional information.
Respectfully submitted,

Charles Howell
Environmental Manager
American Zinc Products, LLC
484 Hicks Grove Rd.
Mooresboro, NC 28114
0: [phone]
C: [phone]
[e-mail]
AZP
AMERICAN
ZINC PRODUCTS
Ail AP CWW+`r
From: Burch, Brent <[e-mail]>
Sent: Friday, July 30, 2021 2:56 PM
To: Charles G. Howell <[e-mail]>
Cc: Timothy Basilone <[e-mail]>; Kobus de Wet <[e-mail]>; Menzel, Jeff
<[e-mail]>; Morris, Sean <[e-mail]>; Johnston.John
<[e-mail]>; Garcia, Javier <[e-mail]>; Woosley, Julie
<[e-mail]>
Subject: RE: [External] AZP Raffinate Pond
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Thank you for the email response, Mr. Howell. At first glance, I do have some questions that I would
appreciate clarity on.
1. Can you provide a date for when the variations in the appearance of the sand surface were
first observed?
2. Can you provide a date for when the soil samples below the liner system were taken?
As indicated in the information below, installation of the new liner system was implemented prior to
receipt of sample results. Please be advised that installing liners and starting operations prior to a
complete evaluation of the incident is doing so at your own risk. Once additional information is
gathered, the Hazardous Waste Section will advise if any further actions that must be taken...Brent
Brent G. Burch
Compliance Branch Head, Hazardous Waste Section
Division of Waste Management
N.C. Department of Environmental Quality
P.O. Box 1427
Andrews, NC 28901
Direct Telephone: [phone]
Cel I phone: [phone]
Email Address: [e-mail]

�G EQ�
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Charles G. Howell [mailto:CGHowelI( azr.com]
Sent: Friday, July 30, 2021 2:05 PM
To: Burch, Brent <brent.burchlancdenr.gov>
Cc: Timothy Basilone <[e-mail]>; Kobus de Wet <[e-mail]>; Menzel, Jeff
<[e-mail]>
Subject: [External] AZP Raffinate Pond
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Mr. Burch,
I am providing this letter in follow up to our conversation yesterday regarding circumstances related
to the raffinate pond located at the American Zinc Products (AZP) facility in Mooresboro, North
Carolina. As discussed with you during our phone call, while in the process of replacing the liner
system at the raffinate pond, it was determined from analysis of soil samples collected below pond
liner that raffinate solution appears to have entered soil beneath the footprint of the pond.
After becoming aware of the analytical results of soil samples collected beneath the liner, a call was
made to the National Response Center, after which we discussed this matter with you and in
subsequent discussions with Jeff Menzel and Rick Jardine of the USEPA emergency response
section. We currently have a call in to John Johnston at USEPA to discuss this matter further in
regard to pending work under the 3013 Administrative Order for the AZP facility.
The raffinate pond contained four synthetic liners, which included two separate liner systems each
consisting of two liners. The uppermost liner system was installed on top of the underlying liner
system in 2019, as part of renovation work completed at the facility during the shutdown preceding
the facility re -start in 2020. More recently, repairs were made by our contractors to the uppermost
liner to install patches over small areas where the upper liner had been breached. In addition,
repairs have been made at the concrete pump structure where the synthetic liner is joined to the
concrete walls of the structure.
Based on the advice of the contractor who installed the liner system, a project to remove and
replace all the liners in the pond with one new liner system was planned and initiated during a
facility shut down scheduled to occur this past week. In advance of the project, the pond was
modified for this project by installing a barrier wall across the center of the pond to divide the pond
into two sections. By dividing the pond into two sections, the liners in the pond could be removed
and replaced with a new liner system in two phases, while shortening the length of time for the
plant to be shut down.

Once overlying liners were removed from the northern area, the lowermost liner was exposed and
inspected. The liner was observed to be intact, and no apparent breaches were identified.
Following removal of the lowermost liner the underlying substrate surface, consisting of sand, was
observed to be dry; however, there were variations in the appearance of the sand surface which
suggested a potential release. Soil samples were taken in two locations in the base of the pond at
various depths down to approximately 2-1/2 feet. During installation of hand borings to collect soil
samples, some liquid was encountered in one of the borings. Soil samples were analyzed by our on -
site laboratory and sent to a certified third -party laboratory. The results from our on -site laboratory
identified elevated lead and cadmium concentrations which are indicative of a release of the
raffinate solution. Following collection of the soil samples, our contractor proceeded with
installation of the new liner system in the northern portion of the raffinate pond, as planned.
Based on the currently available information, we are unable to determine the source or amount of
the potential release; however, based on our observations of the integrity of the bottom liner, it
appears that a breach at the connection of the liner at the concrete pump structure is the most likely
source of any release. Therefore, a leak detection system is being installed in the vicinity of the
pump structure to enable monitoring for potential leakage. Once liner installation work in the
northern portion of the raffinate pond is completed along with installation of the leak detection
system, the pond will be placed in service and plant operation will commence.
As reported to you, AZP is in the process of developing a plan for investigating the subsurface in the
vicinity of the raffinate pond. Soil borings will be installed to determine the general geology beneath
the pond, the nature of underlying soil, and to determine if a groundwater aquifer is present above
bedrock. If a groundwater aquifer is present above auger refusal, monitoring wells will be installed
in the area. Soil samples will also be collected and analyzed to determine the extent of lead,
cadmium, and zinc in subsurface soil. A copy of the investigation plan will be provided to you in
advance of commencement of field activities. The plan will be implemented as soon as possible
after all arrangements are finalized with a drilling contractor.
AZP with working with its contractor to develop a new design plan for upgrading the raffinate pond.
Based on our current discussions with the contractor, we expect this upgrade project to be
scheduled during the upcoming year. The current objective of the upgrade project is to eliminate
the pump structure and complete installation of two ponds within the current footprint of the
raffinate pond. Operating two ponds in the area will enable future maintenance work to be
scheduled on each of the ponds individually while the facility is operating.
Until the upgrade project is implemented, the raffinate pond will be operated using only the
northern portion of the former pond area. The pond will be operated with raffinate solution in the
pond being kept to the minimum operable level. The leak detection system will be used to monitor
for leakage to the subsurface.
As discussed with you, when completed we will provide to you a copy of our plan for investigating
the subsurface area in the vicinity of the raffinate pond. We hope to have the plan completed next
week and will begin planning with drilling contractors to implement the plan as soon as possible.

The investigation plan will include details on sample analytical result and other information
describing the raffinate pond. In addition, we will work with USEPA and John Johnstone to modify
existing plans to incorporate information on the raffinate pond, and to include findings from the
investigation into the 3013-work plan and report.
In summary, our plans consist of the following two objectives:
• Complete installation of new liners with a leak detection system in the northern portion of the
raffinate pond and commence operation of the pond as described above, and
• Perform an investigation of subsurface soil conditions, including delineation of the extent of
elevated zinc, lead and cadmium concentrations; and assess potential groundwater impact
beneath the raffinate pond. Groundwater wells will be installed in the uppermost
groundwater aquifer, if present above bedrock. Investigation work will be performed on the
soil zone down to auger refusal or bedrock.
As we discussed, the raffinate pond is critical to plant operation and functions to continuously
circulate raffinate solution to the zinc production process. Raffinate is a sulfuric acid solution
containing dissolved metals, including primarily zinc, lead and cadmium. The pond must be in
service during plant operations. Without the availability of the pond, the plant cannot operate. To
enable work for replacement of the raffinate pond liners, the plant was shut down.
We will keep you informed of any changes or new information that becomes available as we prepare
our investigation plan. Please feel free to contact me if you have any questions in the meantime.
Regards,
Charles Howell
Environmental Manager
American Zinc Products, LLC
484 Hicks Grove Rd.
Mooresboro, NC 28114
0: [phone]
C: [phone]
cghowell®azr.com
AZP
AMERICAN
ZINC PRODUCTS
uRcon ii

Raffinate Chemical Composition
Since May 1, 2021
Maximum
Constituent Units
Concentration
Al mg/L (ppm) 281.2
Ca mg/L (ppm) 887.9
Cd mg/L (ppm) 466.5
Fe mg/L (ppm) 115.3
K mg/L (ppm) 4,159
Mg mg/L (ppm) 939.6
Mn mg/L (ppm) 1,752
Na mg/L (ppm) 2,878
Zn mg/L (ppm) 22,169
As mg/L (ppm) 0.065
Co mg/L (ppm) 0.633
Cr mg/L (ppm) 1.089
Cu mg/L (ppm) 340.8
Ge mg/L (ppm) 0.906
Ni mg/L (ppm) 5.222
SX Organic mg/L (ppm) 92.7
Sb mg/L (ppm) 0.424
Sn mg/L (ppm) 1.051
Pb mg/L (ppm) 40.7
Sr mg/L (ppm) 0.003
Ti mg/L (ppm) 0.054
SO4 2 mg/L (ppm) 99,000
Cl- mg/L (ppm) 12,600
F- mg/L (ppm) 81

AZP
AMERICAN
ZINC PRODUCTS
An AZR Company
484 Hicks Grove Road
Mooresboro, NC 28114
Phone: [phone]
Fax: [phone]
www.azr.com
Zinc Raff i n ate
DESCRIPTION
During the hydrometallurgical production of zinc, PLS (pregnant leach solution) is treated through a
solvent extraction process in which zinc is removed. As the zinc content decreases, the sulfuric acid
content increases. The resulting aqueous solution is called zinc raffinate. Zinc raffinate contains water,
zinc, chloride, sulfate, trace SX organic (see SX Organic technical data sheet), sulfuric acid, and other
metals in low concentrations.
TECHNICAL DATA
Physical Properties Chemical Properties
Specific Gravity 1.1 H2O % 90-93%
pH <1.0 Zinc Sulfate % 2-3%
Chloride, % 0.8%
SX Organic <10 ppm
Sulfuric Acid 2-3%
Cu, Cd, Cr, Na and other metals,% trace-0.2%
The information hereon has been compiled from sources which we believe to be reliable, but we assume no responsibility
or liability for its accuracy or for the result of any application made of any information contained herein, nor do we assume
any liability for infringement of any patent which may result from the application of such information.
Revised 8/2/2021
AMERICAN ZINC PRODUCTS: ZINC RAFFINATE

(LeAnaIYticaI
Report of Analysis
EnSafe
5724 Summer Trees Drive
Memphis, TN 38134
Attention: Adam Wanta
Project Name: RUSH AZP Raffinate Pond Soil Sampling
Project Number: 0888824799
Lot Number:WG29012
Date Completed:08/03/2021
08/04/2021 8:25 AM
Approved and released by:
Project Manager II: Marcia K. McGinnity
ANSI National Accreditation Board
ACCREDITED
TESTING LABORATORY
The electronic signature above is the equivalent of a handwritten signature.
This report shall not be reproduced, except in its entirety, without the written approval of Pace Analytical Services, LLC.
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172
Tel: [phone] Fax: [phone] www.pacelabs.com
Page 1 of 42

PACE ANALYTICAL SERVICES, LLC
SC DHEC No: 32010001 NELAC No: E87653
NC DENR No: 329 NC Field Parameters No: 5639
Case Narrative
EnSafe
Lot Number: WG29012
This Report of Analysis contains the analytical result(s) for the sample(s) listed on the Sample Summary
following this Case Narrative. The sample receiving date is documented in the header information
associated with each sample.
All results listed in this report relate only to the samples that are contained within this report.
Sample receipt, sample analysis, and data review have been performed in accordance with the most
current approved The NELAC Institute (TNI) standards, the Pace Analytical Services, LLC ("Pace")
Laboratory Quality Manual, standard operating procedures (SOPs), and Pace policies. Any exceptions to
the TNI standards, the Laboratory Quality Manual, SOPs or policies are qualified on the results page or
discussed below.
Where applicable, all soil sample results (including LOQ and DL if requested) are corrected for dry weight
unless flagged with a "W" qualifier.
If you have any questions regarding this report please contact the Pace Project Manager listed on the
cover page.
The laboratory pH analyses associated with the samples in this report were performed after the method
recommended 15 minute holding time.
Narrative Comments:
Metals:
• Samples WG29012-006 (HA1), WG29012-008 (HA2-0.5-1.0) and WG29012-009 (HA2-1.0-1.75)
were diluted due to the nature of the sample matrix. The LOQs have been elevated to reflect the
dilution.
• Recoveries and/or relative percent differences for cadmium and zinc exceeded limits in the matrix
spike/matrix spike duplicate (MS/MSD) performed on sample WG29012-009 (HA2-1.0-1.75).
Associated results are qualified "S".
Inorganic Non -Metals:
• No issues identified.
Pace Analytical Services, LLC (formerly Shealy Environmetal Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 2 of 42

PACE ANALYTICAL SERVICES, LLC
Sample Summary
EnSafe
Lot Number: WG29012
Sample Number Sample ID
Matrix Date Sampled Date Received
001 HA1-0-0.5 Solid 07/28/20211537 07/29/2021
002 HA1-0.5-1.0 Solid 07/28/20211545 07/29/2021
003 HA1-1.75-2.0 Solid 07/28/20211552 07/29/2021
004 HA1-2.0-2.92 Solid 07/28/2021 1557 07/29/2021
005 HA1D-2.0-2.92 Solid 07/28/2021 1557 07/29/2021
006 HA1 Aqueous 07/28/20211635 07/29/2021
007 HA2-0-0.5 Solid 07/28/20211755 07/29/2021
008 HA2-0.5-1.0 Solid 07/28/20211810 07/29/2021
009 HA2-1.0-1.75 Solid 07/28/20211820 07/29/2021
(9 samples)
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 3 of 42

PACE ANALYTICAL SERVICES, LLC
Detection Summary
EnSafe
Lot Number: WG29012
Sample Sample ID Matrix Parameter Method Result Q Units Page
001 HA1-0-0.5 Solid Barium 6010D 33 mg/kg 7
001 HA1-0-0.5 Solid Cadmium 6010D 36 mg/kg 7
001 HA1-0-0.5 Solid Chromium 6010D 1.1 mg/kg 7
001 HA1-0-0.5 Solid Lead 6010D 110 mg/kg 7
001 HA1-0-0.5 Solid Silver 6010D 0.30 J mg/kg 7
001 HA1-0-0.5 Solid Zinc 6010D 2200 mg/kg 7
002 HA1-0.5-1.0 Solid Barium 6010D 32 mg/kg 9
002 HA1-0.5-1.0 Solid Cadmium 6010D 31 mg/kg 9
002 HA1-0.5-1.0 Solid Chromium 6010D 2.5 mg/kg 9
002 HA1-0.5-1.0 Solid Lead 6010D 100 mg/kg 9
002 HA1-0.5-1.0 Solid Silver 6010D 0.15 J mg/kg 9
002 HA1-0.5-1.0 Solid Zinc 6010D 2000 mg/kg 9
003 HA1-1.75-2.0 Solid Arsenic 6010D 3.8 mg/kg 11
003 HA1-1.75-2.0 Solid Barium 6010D 35 mg/kg 11
003 HA1-1.75-2.0 Solid Cadmium 6010D 80 mg/kg 11
003 HA1-1.75-2.0 Solid Chromium 6010D 6.7 mg/kg 11
003 HA1-1.75-2.0 Solid Lead 6010D 130 mg/kg 11
003 HA1-1.75-2.0 Solid Selenium 6010D 1.2 mg/kg 11
003 HA1-1.75-2.0 Solid Silver 6010D 0.93 mg/kg 11
003 HA1-1.75-2.0 Solid Zinc 6010D 5300 mg/kg 11
004 HA1-2.0-2.92 Solid Arsenic 6010D 1.2 mg/kg 13
004 HA1-2.0-2.92 Solid Barium 6010D 18 mg/kg 13
004 HA1-2.0-2.92 Solid Cadmium 6010D 57 mg/kg 13
004 HA1-2.0-2.92 Solid Chromium 6010D 2.5 mg/kg 13
004 HA1-2.0-2.92 Solid Lead 6010D 41 mg/kg 13
004 HA1-2.0-2.92 Solid Mercury 7471B 0.036 J mg/kg 13
004 HA1-2.0-2.92 Solid Silver 6010D 2.1 mg/kg 13
004 HA1-2.0-2.92 Solid Zinc 6010D 4200 mg/kg 13
005 HA1D-2.0-2.92 Solid Arsenic 6010D 1.0 mg/kg 15
005 HA1D-2.0-2.92 Solid Barium 6010D 16 mg/kg 15
005 HA1D-2.0-2.92 Solid Cadmium 6010D 42 mg/kg 15
005 HA1D-2.0-2.92 Solid Chromium 6010D 2.5 mg/kg 15
005 HA1D-2.0-2.92 Solid Lead 6010D 43 mg/kg 15
005 HA1D-2.0-2.92 Solid Silver 6010D 1.3 mg/kg 15
005 HA1D-2.0-2.92 Solid Zinc 6010D 2600 mg/kg 15
006 HA1 Aqueous Arsenic 6010D 0.38 J mg/L 17
006 HA1 Aqueous Barium 6010D 4.6 mg/L 17
006 HA1 Aqueous Cadmium 6010D 240 mg/L 17
006 HA1 Aqueous Chromium 6010D 2.9 mg/L 17
006 HA1 Aqueous Lead 6010D 20 mg/L 17
006 HA1 Aqueous Mercury 7470A 0.00061 mg/L 17
006 HA1 Aqueous Selenium 6010D 1.2 mg/L 17
006 HA1 Aqueous Silver 6010D 0.80 mg/L 17
006 HA1 Aqueous Zinc 6010D 15000 mg/L 17
007 HA2-0-0.5 Solid Arsenic 6010D 0.58 J mg/kg 19
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 4 of 42

Detection Summary (Continued)
Lot Number: WG29012
Sample Sample ID Matrix Parameter Method Result Q Units Page
007 HA2-0-0.5 Solid Barium 6010D 25 mg/kg 19
007 HA2-0-0.5 Solid Cadmium 6010D 30 mg/kg 19
007 HA2-0-0.5 Solid Chromium 6010D 2.3 mg/kg 19
007 HA2-0-0.5 Solid Lead 6010D 23 mg/kg 19
007 HA2-0-0.5 Solid Silver 6010D 0.63 mg/kg 19
007 HA2-0-0.5 Solid Zinc 6010D 1700 mg/kg 19
008 HA2-0.5-1.0 Solid Arsenic 6010D 2.8 mg/kg 21
008 HA2-0.5-1.0 Solid Barium 6010D 30 mg/kg 21
008 HA2-0.5-1.0 Solid Cadmium 6010D 47 mg/kg 21
008 HA2-0.5-1.0 Solid Chromium 6010D 6.5 mg/kg 21
008 HA2-0.5-1.0 Solid Lead 6010D 38 mg/kg 21
008 HA2-0.5-1.0 Solid Silver 6010D 0.41 J mg/kg 21
008 HA2-0.5-1.0 Solid Zinc 6010D 3000 mg/kg 21
009 HA2-1.0-1.75 Solid Arsenic 6010D 2.6 mg/kg 23
009 HA2-1.0-1.75 Solid Barium 6010D 34 mg/kg 23
009 HA2-1.0-1.75 Solid Cadmium 6010D 41 S mg/kg 23
009 HA2-1.0-1.75 Solid Chromium 6010D 18 mg/kg 23
009 HA2-1.0-1.75 Solid Lead 6010D 15 mg/kg 23
009 HA2-1.0-1.75 Solid Silver 6010D 0.54 J mg/kg 23
009 HA2-1.0-1.75 Solid Zinc 6010D 2600 S mg/kg 23
(65 detections)
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 5 of 42

Inorganic non-metals
Client: EnSafe Laboratory ID:WG29012-001
Description: HA1-0-0.5 Matrix: Solid
Date Sampled:07/28/2021 1537 % Solids: 88.0 07/29/2021 2300
Date Received:07/29/2021
Run Prep Method
1
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
(Soil pH meas) 9045D 1 07/29/2021 2250 NBW
10541
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
Soil pH measured in water @ 24.1 ° C
9045D 1.8
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 6 of 42

Metals
Client: EnSafe
Description: HA1-0-0.5
Date Sampled:07/28/2021 1537
Date Received:07/29/2021
Laboratory ID:WG29012-001
Matrix: Solid
% Solids: 88.0 07/29/2021 2300
Run Prep Method
1 3050B
1 7471B
2 3050B
Analytical Method Dilution
6010D 1
7471B 1
6010D
Analysis Date Analyst
07/31/2021 1250 KSH2
08/02/2021 1650 CMS2
5 07/31/2021 1254 KSH2
Prep Date Batch
07/30/2021 1124 10480
08/02/2021 1300 10481
07/30/2021 1124 10480
Parameter
CAS
Number
Analytical
Method
Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D
6010D
6010D
6010D
6010D
7471B
6010D
6010D
6010D
ND
33
36
1.1
110
ND
ND
0.30
2200
0.73 0.24
1.3 0.32
0.24 0.061
0.49 0.12
0.49 0.22
0.093 0.022
0.97 0.39
J 0.49 0.12
12 3.0
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 2
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 7 of 42

Inorganic non-metals
Client: EnSafe Laboratory ID:WG29012-002
Description: HA1-0.5-1.0 Matrix: Solid
Date Sampled:07/28/2021 1545 % Solids: 87.4 07/29/2021 2300
Date Received:07/29/2021
Run Prep Method
1
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
(Soil pH meas) 9045D 1 07/29/2021 2253 NBW
10541
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
Soil pH measured in water @ 24.2 ° C
9045D 2.0
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 8 of 42

Metals
Client: EnSafe
Description: HA1-0.5-1.0
Date Sampled:07/28/2021 1545
Date Received:07/29/2021
Laboratory ID:WG29012-002
Matrix: Solid
% Solids: 87.4 07/29/2021 2300
Run Prep Method
1 3050B
1 7471B
2 3050B
Analytical Method Dilution
6010D 1
7471B 1
6010D
Analysis Date Analyst
07/31/2021 1258 KSH2
08/02/2021 1653 CMS2
5 07/31/2021 1302 KSH2
Prep Date Batch
07/30/2021 1124 10480
08/02/2021 1300 10481
07/30/2021 1124 10480
Parameter
CAS
Number
Analytical
Method
Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D
6010D
6010D
6010D
6010D
7471B
6010D
6010D
6010D
ND
32
31
2.5
100
ND
ND
0.15
2000
0.72 0.24
1.2 0.31
0.24 0.060
0.48 0.12
0.48 0.22
0.091 0.022
0.96 0.39
J 0.48 0.12
12 3.0
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 2
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 9 of 42

Inorganic non-metals
Client: EnSafe Laboratory ID:WG29012-003
Description: HA1-1.75-2.0 Matrix: Solid
Date Sampled:07/28/2021 1552 % Solids: 79.9 07/29/2021 2300
Date Received:07/29/2021
Run Prep Method
1
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
(Soil pH meas) 9045D 1 07/29/2021 2255 NBW
10541
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
Soil pH measured in water @ 24.3 ° C
9045D 1.6
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 10 of 42

Metals
Client: EnSafe
Description: HA1-1.75-2.0
Date Sampled:07/28/2021 1552
Date Received:07/29/2021
Laboratory ID:WG29012-003
Matrix: Solid
% Solids: 79.9 07/29/2021 2300
Run Prep Method
1 3050B
1 7471B
3 3050B
Analytical Method Dilution
6010D 1
7471B 1
6010D
Analysis Date Analyst
07/31/2021 1305 KSH2
08/02/2021 1655 CMS2
20 08/02/20211049 JMH
Prep Date Batch
07/30/2021 1124 10480
08/02/2021 1300 10481
07/30/2021 1124 10480
Parameter
CAS
Number
Analytical
Method
Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D
6010D
6010D
6010D
6010D
7471B
6010D
6010D
6010D
3.8
35
80
6.7
130
ND
1.2
0.93
5300
0.88 0.29
1.5 0.38
0.29 0.074
0.59 0.15
0.59 0.27
0.093 0.022
1.2 0.48
0.59 0.15
59 15
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 3
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 11 of 42

Inorganic non-metals
Client: EnSafe Laboratory ID:WG29012-004
Description: HA1-2.0-2.92 Matrix: Solid
Date Sampled:07/28/2021 1557 % Solids: 82.4 07/29/2021 2300
Date Received:07/29/2021
Run Prep Method
1
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
(Soil pH meas) 9045D 1 07/29/2021 2257 NBW
10541
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
Soil pH measured in water @ 24.2 ° C
9045D 1.8
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 12 of 42

Metals
Client: EnSafe
Description: HA1-2.0-2.92
Date Sampled:07/28/2021 1557
Date Received:07/29/2021
Laboratory ID:WG29012-004
Matrix: Solid
% Solids: 82.4 07/29/2021 2300
Run Prep Method
1 3050B
1 7471B
3 3050B
Analytical Method Dilution
6010D 1
7471B 1
6010D
Analysis Date Analyst
07/31/2021 1313 KSH2
08/02/2021 1658 CMS2
10 08/02/20210705 JMH
Prep Date Batch
07/30/2021 1124 10480
08/02/2021 1300 10481
07/30/2021 1124 10480
Parameter
CAS
Number
Analytical
Method
Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D
6010D
6010D
6010D
6010D
7471B
6010D
6010D
6010D
1.2
18
57
2.5
41
0.036
ND
2.1
4200
0.91 0.30
1.6 0.39
0.30 0.076
0.60 0.15
0.60 0.27
J 0.090 0.022
1.2 0.49
0.60 0.15
30 7.5
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 3
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 13 of 42

Inorganic non-metals
Client: EnSafe Laboratory ID:WG29012-005
Description: HA1D-2.0-2.92 Matrix: Solid
Date Sampled:07/28/2021 1557 % Solids: 79.1 07/29/2021 2300
Date Received:07/29/2021
Run Prep Method
1
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
(Soil pH meas) 9045D 1 07/29/2021 2258 NBW
10541
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
Soil pH measured in water @ 24.2 ° C
9045D 2.0
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 14 of 42

Metals
Client: EnSafe
Description: HA1D-2.0-2.92
Date Sampled:07/28/2021 1557
Date Received:07/29/2021
Laboratory ID:WG29012-005
Matrix: Solid
% Solids: 79.1 07/29/2021 2300
Run Prep Method
1 3050B
1 7471B
2 3050B
Analytical Method Dilution
6010D 1
7471B 1
6010D
Analysis Date Analyst
07/31/2021 1329 KSH2
08/02/2021 1701 CMS2
5 07/31/2021 1333 KSH2
Prep Date Batch
07/30/2021 1124 10480
08/02/2021 1300 10481
07/30/2021 1124 10480
Parameter
CAS
Number
Analytical
Method
Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D
6010D
6010D
6010D
6010D
7471B
6010D
6010D
6010D
1.0
16
42
2.5
43
ND
ND
1.3
2600
0.91 0.30
1.6 0.39
0.30 0.076
0.60 0.15
0.60 0.27
0.093 0.022
1.2 0.49
0.60 0.15
15 3.8
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 2
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 15 of 42

Inorganic non-metals
Client: EnSafe
Description: HA1
Date Sampled:07/28/2021 1635
Date Received:07/29/2021
Laboratory ID:WG29012-006
Matrix: Aqueous
Run Prep Method
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 (pH - Field) SM 4500-H B-2011 1 07/28/2021 1635 ""
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
pH - Field
SM 4500-H B-20 1.1
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 16 of 42

Metals
Client: EnSafe
Description: HA1
Date Sampled:07/28/2021 1635
Date Received:07/29/2021
Laboratory ID:WG29012-006
Matrix: Aqueous
Run Prep Method
1
1
3005A
3 3005A
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
7470A 1 08/03/2021 1714 CMS2 08/03/2021 1341 10873
6010D 1 07/30/20211311 JMH 07/30/20210306 10477
6010D 100 07/30/20211947 JMH 07/30/20210306 10477
Parameter
CAS
Number
Analytical
Method Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D 0.38 J 0.75 0.13
6010D 4.6 1.3 0.16
6010D 240 25 3.0
6010D 2.9 0.50 0.065
6010D 20 0.50 0.24
7470A 0.00061 0.00020 0.000091
6010D 1.2 1.0 0.43
6010D 0.80 0.50 0.11
6010D 15000 100 13
mg/L 1
mg/L 1
mg/L 3
mg/L 1
mg/L 1
mg/L 1
mg/L 1
mg/L 1
mg/L 3
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 17 of 42

Inorganic non-metals
Client: EnSafe Laboratory ID:WG29012-007
Description: HA2-0-0.5 Matrix: Solid
Date Sampled:07/28/2021 1755 % Solids: 90.1 07/29/2021 2300
Date Received:07/29/2021
Run Prep Method
1
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
(Soil pH meas) 9045D 1 07/29/2021 2259 NBW
10541
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
Soil pH measured in water @ 24.2 ° C
9045D 2.2
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 18 of 42

Metals
Client: EnSafe
Description: HA2-0-0.5
Date Sampled:07/28/2021 1755
Date Received:07/29/2021
Laboratory ID:WG29012-007
Matrix: Solid
% Solids: 90.1 07/29/2021 2300
Run Prep Method
1 3050B
1 7471B
2 3050B
Analytical Method Dilution
6010D 1
7471B 1
6010D
Analysis Date Analyst
07/31/2021 1336 KSH2
08/02/2021 1703 CMS2
5 07/31/20211341 KSH2
Prep Date Batch
07/30/2021 1124 10480
08/02/2021 1300 10481
07/30/2021 1124 10480
Parameter
CAS
Number
Analytical
Method
Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D 0.58 J 0.77 0.26
6010D 25 1.3 0.33
6010D 30 0.26 0.064
6010D 2.3 0.51 0.13
6010D 23 0.51 0.23
7471B ND 0.089 0.021
6010D ND 1.0 0.41
6010D 0.63 0.51 0.13
6010D 1700 13 3.2
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 2
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 19 of 42

Inorganic non-metals
Client: EnSafe Laboratory ID:WG29012-008
Description: HA2-0.5-1.0 Matrix: Solid
Date Sampled:07/28/2021 1810 % Solids: 87.3 07/29/2021 2300
Date Received:07/29/2021
Run Prep Method
1
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
(Soil pH meas) 9045D 1 07/29/2021 2300 NBW
10541
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
Soil pH measured in water @ 24.2 ° C
9045D 2.2
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 20 of 42

Metals
Client: EnSafe
Description: HA2-0.5-1.0
Date Sampled:07/28/2021 1810
Date Received:07/29/2021
Laboratory ID:WG29012-008
Matrix: Solid
% Solids: 87.3 07/29/2021 2300
Run
1
1
2
3
Prep Method
3050B
7471B
3050B
3050B
Analytical Method
6010D
7471B
6010D
6010D
Dilution Analysis Date Analyst Prep Date Batch
1 07/31/2021 1344 KSH2 07/30/2021 1124 10480
1 08/02/2021 1706 CMS2 08/02/2021 1300 10481
5 07/31/2021 1349 KSH2 07/30/2021 1124 10480
10 08/02/20210709 JMH 07/30/2021 1124 10480
Parameter
CAS
Number
Analytical
Method
Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D
6010D
6010D
6010D
6010D
7471B
6010D
6010D
6010D
2.8
30
47
6.5
38
ND
ND
0.41
3000
0.79 0.26
1.4 0.34
0.26 0.067
0.53 0.13
0.53 0.24
0.085 0.021
5.3 2.1
0.53 0.13
26 6.6
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 1
mg/kg 2
mg/kg 1
mg/kg 3
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
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Page 21 of 42

Inorganic non-metals
Client: EnSafe Laboratory ID:WG29012-009
Description: HA2-1.0-1.75 Matrix: Solid
Date Sampled:07/28/2021 1820 % Solids: 88.5 07/29/2021 2300
Date Received:07/29/2021
Run Prep Method
1
Analytical Method Dilution Analysis Date Analyst Prep Date Batch
(Soil pH meas) 9045D 1 07/29/2021 2301 NBW
10541
Parameter
CAS Analytical
Number Method Result Q LOQ DL Units Run
Soil pH measured in water @ 24.3 ° C
9045D 3.3
su 1
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
W = Reported on wet weight basis
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 22 of 42

Metals
Client: EnSafe
Description: HA2-1.0-1.75
Date Sampled:07/28/2021 1820
Date Received:07/29/2021
Laboratory ID:WG29012-009
Matrix: Solid
% Solids: 88.5 07/29/2021 2300
Run Prep Method
1 7471B
2 3050B
3 3050B
Analytical Method Dilution
7471B 1
6010D 5
6010D 1
Analysis Date Analyst Prep Date Batch
08/02/2021 1714 CMS2 08/02/2021 1300 10481
07/31/2021 1421 KS H 2 07/30/2021 1124 10480
08/03/2021 0515 J M H 07/30/2021 1124 10480
Parameter
CAS
Number
Analytical
Method
Result Q LOQ
DL
Units Run
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Zinc
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
7440-66-6
6010D
6010D
6010D
6010D
6010D
7471B
6010D
6010D
6010D
2.6
34
41
18
15
ND
ND
0.54
2600
0.82 0.27
1.4 0.36
S 0.27 0.069
0.55 0.14
0.55 0.25
0.081 0.020
5.5 2.2
0.55 0.14
S 14 3.4
mg/kg 3
mg/kg 3
mg/kg 3
mg/kg 3
mg/kg 3
mg/kg 1
mg/kg 2
mg/kg 3
mg/kg 2
LOQ = Limit of Quantitation
ND = Not detected at or above the DL
H = Out of holding time
B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
W = Reported on wet weight basis
J = Estimated result < LOQ and > DL
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 23 of 42

QC Summary
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Page 24 of 42

Inorganic non-metals - Duplicate
Sample ID: WG29012-009DU
Batch: 10541
Analytical Method: 9045D
Matrix: Solid
Sample
Amount Result %RPD
Parameter (su) (su) Q Dil % RPD Limit Analysis Date
Soil pH measured in water @ 24.1 ° C 3.3 3.4 1 1.5 20 07/29/2021 2303
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 25 of 42

Metals - MB
Sample ID: WQ10477-001
Batch: 10477
Analytical Method: 6010D
Matrix: Aqueous
Prep Method: 3005A
Prep Date: 07/30/2021 0306
Parameter Result Q Dil LOQ DL Units Analysis Date
Arsenic ND 1 0.015 0.0025 mg/L 07/30/2021 1303
Barium ND 1 0.025 0.0031 mg/L 07/30/2021 1303
Cadmium ND 1 0.0050 0.00060 mg/L 07/30/2021 1303
Chromium ND 1 0.010 0.0013 mg/L 07/30/2021 1303
Lead ND 1 0.010 0.0047 mg/L 07/30/2021 1303
Selenium ND 1 0.020 0.0085 mg/L 07/30/2021 1303
Silver ND 1 0.010 0.0021 mg/L 07/30/2021 1303
Zinc ND 1 0.020 0.0025 mg/L 07/30/2021 1303
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 26 of 42

Metals - LCS
Sample ID: W010477-002
Batch: 10477
Analytical Method: 6010D
Matrix: Aqueous
Prep Method: 3005A
Prep Date: 07/30/2021 0306
Spike
Amount Result %Rec
Parameter (mg/L) (mg/L) Q Dil % Rec Limit Analysis Date
Arsenic 0.40 0.43 1 107 80-120 07/30/2021 1307
Barium 2.0 2.1 1 107 80-120 07/30/2021 1307
Cadmium 0.40 0.41 1 103 80-120 07/30/2021 1307
Chromium 2.0 2.1 1 107 80-120 07/30/2021 1307
Lead 0.40 0.42 1 105 80-120 07/30/2021 1307
Selenium 0.40 0.42 1 104 80-120 07/30/2021 1307
Silver 0.40 0.44 1 109 80-120 07/30/2021 1307
Zinc 2.0 2.1 1 107 80-120 07/30/2021 1307
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 27 of 42

Metals - MB
Sample ID: WQ10480-001
Batch: 10480
Analytical Method: 6010D
Matrix: Solid
Prep Method: 3050E
Prep Date: 07/30/2021 1124
Parameter Result Q Dil LOQ DL Units Analysis Date
Arsenic ND 1 0.75 0.25 mg/kg 07/31/2021 1242
Barium ND 1 1.3 0.33 mg/kg 07/31/2021 1242
Cadmium ND 1 0.25 0.063 mg/kg 07/31/2021 1242
Chromium ND 1 0.50 0.13 mg/kg 07/31/2021 1242
Lead ND 1 0.50 0.23 mg/kg 07/31/2021 1242
Selenium ND 1 1.0 0.41 mg/kg 07/31/2021 1242
Silver ND 1 0.50 0.13 mg/kg 07/31/2021 1242
Zinc ND 1 2.5 0.63 mg/kg 07/31/2021 1242
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 28 of 42

Metals - LCS
Sample ID: W010480-002
Batch: 10480
Analytical Method: 6010D
Matrix: Solid
Prep Method: 3050E
Prep Date: 07/30/2021 1124
Spike
Amount Result %Rec
Parameter (mg/kg) (mg/kg) Q Dil % Rec Limit Analysis Date
Arsenic 250 240 1 95 80-120 07/31/2021 1246
Barium 500 480 1 97 80-120 07/31/2021 1246
Cadmium 50 47 1 94 80-120 07/31/2021 1246
Chromium 250 240 1 97 80-120 07/31/2021 1246
Lead 250 240 1 96 80-120 07/31/2021 1246
Selenium 50 45 1 89 80-120 07/31/2021 1246
Silver 50 44 1 89 80-120 07/31/2021 1246
Zinc 100 97 1 97 80-120 07/31/2021 1246
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
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Page 29 of 42

Metals - MS
Sample ID: WG29012-009MS
Batch: 10480
Analytical Method: 6010D
Matrix: Solid
Prep Method: 3050E
Prep Date: 07/30/2021 1124
Sample Spike
Amount Amount Result %Rec
Parameter (mg/kg) (mg/kg) (mg/kg) Q Dil % Rec Limit Analysis Date
Arsenic 2.6 260 250 1 92 75-125 08/03/2021 0519
Barium 34 530 550 1 98 75-125 08/03/2021 0519
Cadmium 41 53 80 N 1 74 75-125 08/03/2021 0519
Chromium 18 260 260 1 93 75-125 08/03/2021 0519
Lead 15 260 260 1 94 75-125 08/03/2021 0519
Selenium ND 53 45 5 86 75-125 07/31/2021 1425
Silver 0.54 53 51 1 95 75-125 08/03/2021 0519
Zinc 2600 110 1900 N 5 -653 75-125 07/31/2021 1425
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
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Page 30 of 42

Metals - MSD
Sample ID: WG29012-009MD
Batch: 10480
Analytical Method: 6010D
Matrix: Solid
Prep Method: 3050E
Prep Date: 07/30/2021 1124
Sample Spike
Amount Amount Result %Rec % RPD
Parameter (mg/kg) (mg/kg) (mg/kg) Q Dil % Rec % RPD Limit Limit Analysis Date
Arsenic 2.6 240 220 1 89 13 75-125 20 08/03/2021 0523
Barium 34 480 490 1 96 11 75-125 20 08/03/2021 0523
Cadmium 41 48 85 1 91 5.5 75-125 20 08/03/2021 0523
Chromium 18 240 240 1 91 11 75-125 20 08/03/2021 0523
Lead 15 240 230 1 90 13 75-125 20 08/03/2021 0523
Selenium ND 48 42 5 87 8.5 75-125 20 07/31/2021 1429
Silver 0.54 48 45 1 92 13 75-125 20 08/03/2021 0523
Zinc 2600 96 2600 N,+ 5 52 32 75-125 20 07/31/2021 1429
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
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Page 31 of 42

Metals - MB
Sample ID: WQ10481-001
Batch: 10481
Analytical Method: 7471B
Matrix: Solid
Prep Method: 7471B
Prep Date: 08/02/2021 1300
Parameter Result Q Dil LOQ DL Units Analysis Date
Mercury
ND 1 0.083 0.020 mg/kg 08/02/2021 1645
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
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Page 32 of 42

Metals - LCS
Sample ID: W010481-002
Batch: 10481
Analytical Method: 7471B
Matrix: Solid
Prep Method: 7471B
Prep Date: 08/02/2021 1300
Parameter
Spike
Amount Result %Rec
(mg/kg) (mg/kg) Q Dil % Rec Limit Analysis Date
Mercury
0.83 0.87 1 105 80-120 08/02/2021 1647
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
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Page 33 of 42

Metals - MS
Sample ID: WG29012-009MS
Batch: 10481
Analytical Method: 7471B
Matrix: Solid
Prep Method: 7471B
Prep Date: 08/02/2021 1300
Parameter
Sample Spike
Amount Amount Result %Rec
(mg/kg) (mg/kg) (mg/kg) Q Dil % Rec Limit Analysis Date
Mercury
ND 0.83 0.87 1 105 80-120 08/02/2021 1717
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
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Page 34 of 42

Metals - MSD
Sample ID: WG29012-009MD
Batch: 10481
Analytical Method: 7471B
Matrix: Solid
Prep Method: 7471B
Prep Date: 08/02/2021 1300
Parameter
Sample Spike
Amount Amount Result %Rec % RPD
(mg/kg) (mg/kg) (mg/kg) Q Dil % Rec % RPD Limit Limit Analysis Date
Mercury
ND 0.89 0.94 1 106 7.8 80-120 20 08/02/2021 1720
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
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Page 35 of 42

Metals - MB
Sample ID: WQ10873-001
Batch: 10873
Analytical Method: 7470A
Matrix: Aqueous
Prep Method:
Prep Date: 08/03/2021 1341
Parameter Result Q Dil LOQ DL Units Analysis Date
Mercury
ND 1 0.00020 0.000091 mg/L 08/03/2021 1708
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
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Page 36 of 42

Metals - LCS
Sample ID: W010873-002
Batch: 10873
Analytical Method: 7470A
Matrix: Aqueous
Prep Method:
Prep Date: 08/03/2021 1341
Parameter
Spike
Amount Result %Rec
(mg/L) (mg/L) Q Dil % Rec Limit Analysis Date
Mercury
0.0020 0.0019 1 97 80-120 08/03/2021 1711
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
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Page 37 of 42

Metals - MS
Sample ID: WG29012-006MS
Batch: 10873
Analytical Method: 7470A
Matrix: Aqueous
Prep Method:
Prep Date: 08/03/2021 1341
Parameter
Sample Spike
Amount Amount Result %Rec
(mg/L) (mg/L) (mg/L) Q Dil % Rec Limit Analysis Date
Mercury
0.00061 0.0020 0.0025 1 94 80-120 08/03/2021 1717
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 38 of 42

Metals - MSD
Sample ID: WG29012-006MD
Batch: 10873
Analytical Method: 7470A
Matrix: Aqueous
Prep Method:
Prep Date: 08/03/2021 1341
Parameter
Sample Spike
Amount Amount Result %Rec % RPD
(mg/L) (mg/L) (mg/L) Q Dil % Rec % RPD Limit Limit Analysis Date
Mercury
0.00061 0.0020 0.0025 1 96 1.7 80-120 20 08/03/2021 1719
LOQ = Limit of Quantitation
DL = Detection Limit
ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
= RSD is out of criteria
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
Note: Calculations are performed before rounding to avoid round -off errors in calculated results
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 39 of 42

Chain of Custody
and
Miscellaneous Documents
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 40 of 42

PACE ANALYTICAL SERVICES, LLC
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Pace Analytical Services, LLC (formerly Shealy Environmen al Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 41 of 42

PACE ANALYTICAL SERVICES, LLC
Clieltc ENSAF£
No
I .
Samples Receipt Checklist (SRC) (MEaO1BC-15] RevisatIO%22 f2020
Issulr.g Authority: Pact tNNV - WCOL Page 1 of 1
Sample Receipt Checklist (SRC)
Cnc Icr InSp E9d byrd;lL.en JSY[ f Taa2_23 Lots_ S'lCi2�ud1
CI mart ❑ UP$ FI JEnl Other.
Were+:ustu:i:... scats present on the 000[er?
NA 2. If cttstod� soRis were present, tiaarc they ir* and unbroken?
rill. Ship JD; /i- z Chlorine St'ip ]IJ 1cstcd by::
Original temperature upon Veceipt? Valved (Corrected) temperature upon te;.eipl %Solid Snap -Clip TT.1;
5.9 /5-9 is NA } 1rs •C: NA 1. NA. oc NA /NA ae
A'lethod: 7- 1T Eripa-atarc Blank T ainstBo:tles 1R Gull ID: = 1R Gun Correu.iolt Factor.
method of eaOlant: ❑✓ Wet Ice [ce f ackk Er Dry. Ice fl Norm.
3, if tamperattwe of any cooler cxceedeel6.0T, was Project 14:ir i .r Notified?
PM was ['Jt7tified phone! email ? face-to-face (circa one).
11INA 4. Is die commercial ca.irier's pck:kin.ii slip attach atj (0 this roern"
y ■ Nr)
d Ycs No
Yes L J Nc
Yes ❑ No
k es No
5. Avert pmpor rustady procedures (rclinquis:iedheEeivec;) followed?
6- Were sample ]IJs fisted on the COC7
7. Vere aRrple lbs fish..[ till al] camp [e contgiiets?
a- Was coilecton date & time fisted on the COC?
Was colloo:ioii dale & tirrin I-sted or all satril,le cur,tairters?
]a. Did 411 container .Lila] information (ID, date. tulle) agree ;Nit the COC,'
I f . Were testa to Le perturmed lined on the DOG?
12. Did all samples arrives m the proper [LaiiLain rlt for eachnd+or in good cp,di:iun
( Unbroken, lids co, _
Was adequate sump le volume avai]ab:c? ..
Wero all sairp[Ls rcevi>r'cd wthin '.4 the Folding time or48. hours, whichever names first?
15,luVcre }'sam�sle¢ containers misSilliOcxix s (circle one.) sari -pies Nat ]ist^.il ❑n COC7
16. For \ A and RSK- [75 wriples, were lwbbles present `resl-yizo'° (V.."or 6 nm in diameter)
ar.y of the VOA vials?
17. Were &I DRQjmct-aIshruLrierit simples received 0.1 a ']H of < 2?
ll! Two B T aA 18. Were all cyanide sainpies reca�ivud at a pia 12 and sulfide wimples received it a pH> 9?
19, Vrere all app[n tible hilt/TKiJI ysinitie+?}len0samples fro
rea.idual whlorine?
Sample Preservation
20 Were el:ent reriarka&r:qucsts (i.e- reque tod dilutnmx, h1 ±I+1SD de ianLltions
correctly Lrenacriheai from lac tOC tag t[te oommEnt aeCtion in LIMS?
21. Ws Ih..quote numbor lister[ an the container I?hef7 If Quin, 1?
(Must be completed for any .an_ple(s) I, l:.-,rrr xtly preserver] 0- will 17e110spe,Cc.)
San ple(s) re.t wcr received Mom -le -et preserved and were adjusted at:u-dingvv
in sample receiving with NA mL afcitc]e one: 14280.4, J*1O3 1-IdI, NaOH using SR 4 NA
15me of preservation " - 2 r murc than one preservative is 'wiled, please note itr Etc con icien14 below.
Arnp[e(s) N'
were l'E iVt5dwith h4JEAlleS >6 mitt in diameter.
Samples(s) were ra:.ci ed With. TRC 0_5 mga, i if + ] 9 is nit) and wer
adjusted aceording]y in sample. receiving with sodium thiosnliate (Na�81O3) with Shealy ID; NA
SR bareodc labels tafilicd by JS 1 pat,: 7r29i20<I
Comments:
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Page 42 of 42

Attachment D
August 16, 2021 Email

From: Charles G. Howell
To: Menzel, Jeff
Cc: Timothy Basilone; Phil Coop
Subject: RE: [External] RE: Sampling this week
Date: Monday, August 16, 2021 11:47:00 AM
Attachments: imaae001.onq
image002.pnq
2021-8-3 West Creek Surface Water Samolina Pace Lab Analytical Results.odf
Good morning Jeff,
Below (in blue) is a summary of last week's pond sampling from EnSafe personnel that was on -site
and attached are the lab results from the surface water samples collected on 8/3.
Work sampling below the liners of the Depleted Pond and the south end of the Raffinate pond
wrapped up around 3:30 this afternoon (8/11). See below for some details on each pond:
Depleted Pond
The liner system was comprised of two layers of XR5 with Geonet between. The sand/gravel
bedding material was dry and not cemented like we saw within the Raffinate pond. We didn't
see any evidence of gypsum crystals either. One of the borings HA7 was advanced to roughly 3.7
feet into the soil underlying the sand/gravel bedding material which was about 1.5 feet thick.
Total depth of that hole from the top of the sand/gravel layer was just shy of 5 feet.
South Raffinate Pond
We had a few more issues with the Raffinate Pond. We found that there were liquids remaining
between several layers of liner. Originally we proposed 3 locations to be advanced however with
the liquid made it impossible and we only ended up advancing 1 location below the liners. The
likelihood of contaminating the sample with the liquid was high in those two areas. The
sand/gravel layer in the one location we could advance was very difficult to penetrate and
contained gypsum. The soil layer below the sand/gravel was also dry and difficult to advance the
hand auger.
No liquids were encountered in the locations advanced below the liners. We ended up
submitting 14 samples to the lab 3 of which we asked them to hold pending results of the
interval above. This was a slight deviation from the sampling plan, but I think it will provide us a
good soil column profile of the Depleted pond. The liner crew was onsite patching our holes
when we left the site. They were patching each layer we cut from the bottom up.
Please let me know if you have any questions.
Regards,
Charles Howell
Environmental Manager
American Zinc Products, LLC
484 Hicks Grove Rd.

Mooresboro, NC 28114
0 [phone]
C: [phone]
cghowell®azr.com
AZP
AMERICAN
ZINC PFROD1JCTS
An AZR CI, 1-y
From: Menzel, Jeff <[e-mail]>
Sent: Friday, August 13, 2021 1:02 PM
To: Phil Coop <[e-mail]>; Charles G. Howell <[e-mail]>
Subject: RE: [External] RE: Sampling this week
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Were you all able to complete the depleted and raffinate pond sampling this week? Or were there
other units that were also sampled?
Any free liquids detected under the raffinate pond during this round of sampling? Lastly, have you
received the surface water samples results taken on 8/3?
Thanks
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
Jeff.menzelPncdenr.gov
PO Box 117
Black Mountain, NC 28711
1/-1--0a-1;i)
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Phil Coop [mailto:[e-mail]]
Sent: Tuesday, August 10, 2021 4:40 PM
To: Menzel, Jeff <[e-mail]>; Charles G. Howell <[e-mail]>
Subject: [External] RE: Sampling this week

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Yes Jeff, We are on schedule. My sampling team is there now setting up. They will start sampling
early tomorrow morning and hope to finish in one day.
Phil
Phillip G. Coop, CHMM
Principal
EnSafe Inc.
5724 Summer Trees Dr.
Memphis, TN 38134
[0] 901-937-4229 [C] 901-833-3471
From: Menzel, Jeff <[e-mail]>
Sent: Tuesday, August 10, 2021 3:32 PM
To: Phil Coop <[e-mail]>; Charles G. Howell <[e-mail]>
Subject: Sampling this week
Phil and Charlie,
Just checking in to see if you are still continuing with the sampling work this week.
If you have a tentative schedule you could relay that would be helpful for coordination.
Thanks,
Jeff
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
Jeff.menzelPncdenr.gov
PO Box 117
Black Mountain, NC 28711
� Q

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

ace Analytical® A\ A L Y T I C A L
August 10, 2021
REPO
RT
ENSAFE - Knoxville
Sample Delivery Group: L1386714
Samples Received: 08/05/2021
Project Number: 24799
Description: AZR-Mooresboro-SW
Report To:
Brian Caldwell
308 N. Peters Road, Ste. 200
Knoxville, TN 37922
Entire Report Reviewed By:
4\i lcCk D/OjdUl
Jennifer Gambill
Project Manager
Results relate only to the items tested or calibrated and are reported as rounded values. This test report shall not be
reproduced, except in full, without written approval of the laboratory. Where applicable, sampling conducted by Pace
Analytical National is performed per guidance provided in laboratory standard operating procedures ENV-SOP-MTJL-0067 and
ENV-SOP-MTJL-0068. Where sampling conducted by the customer, results relate to the accuracy of the information provided,
and as the samples are received.
Pace Analytical National
12065 Lebanon Rd Mount Juliet, TN 37122 615-758-5858 800-767-5859 www.pacenational.com
Cp
2
TC
3
Ss
4
Cn
6
Qc
7
GI
8
AI
9
Sc
ACCOUNT:
ENSAFE - Knoxville
PROJECT:
24799
SDG:
L1386714
DATE/TIME:
08/10/2115:31
PAGE:
1 of 16

TABLE OF CONTENTS
Cp: Cover Page
Tc: Table of Contents
Ss: Sample Summary
Cn: Case Narrative 4
Sr: Sample Results 5
#1 L1386714-01 5
#2 L1386714-02 6
#2D L1386714-03 7
Qc: Quality Control Summary 8
Mercury by Method 245.1 8
Metals (ICP) by Method 200.7 9
Metals (ICPMS) by Method 200.8 11
GI: Glossary of Terms 14
Al: Accreditations & Locations 15
Sc: Sample Chain of Custody 16
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/2115:31 2 of 16

SAMPLE SUMMARY
#1 L1386714-01 WW
Collected by Collected date/time Received date/time
BC/JG 08/03/2113:36 08/05/21 08:00
Method
Mercury by Method 245.1
Metals (ICP) by Method 200.7
Metals (ICP) by Method 200.7
Metals (ICPMS) by Method 200.8
#2 L1386714-02 WW
Batch
Dilution Preparation Analysis Analyst Location
date/time date/time
WG1718556 1 08/09/2110:45 08/10/2110:18 ABL Mt. Juliet, TN
WG1718545 1 08/06/21 06:29 08/07/21 04:53 KMG Mt. Juliet, TN
WG1718545 1 08/06/21 06:29 08/07/2114:20 KMG Mt. Juliet, TN
WG1717789 1 08/06/21 06:31 08/06/21 23:08 JPD Mt. Juliet, TN
Collected by Collected date/time Received date/time
BC/JG 08/03/2113:54 08/05/21 08:00
Method Batch Dilution Preparation Analysis Analyst Location
date/time date/time
Mercury by Method 245.1 WG1718556 1 08/09/2110:45 08/10/2110:27 ABL Mt. Juliet, TN
Metals (ICP) by Method 200.7 WG1718545 1 08/06/21 06:29 08/07/21 04:55 KMG Mt. Juliet, TN
Metals (ICP) by Method 200.7 WG1718545 1 08/06/21 06:29 08/07/2114:29 KMG Mt. Juliet, TN
Metals (ICPMS) by Method 200.8 WG1717789 1 08/06/21 06:31 08/06/21 23:12 JPD Mt. Juliet, TN
#2D L1386714-03 WW
Collected by Collected date/time Received date/time
BC/JG 08/03/2113:54 08/05/21 08:00
Method Batch Dilution Preparation Analysis Analyst Location
date/time date/time
Mercury by Method 245.1 WG1718556 1 08/09/2110:45 08/10/21 09:47 ABL Mt. Juliet, TN
Metals (ICP) by Method 200.7 WG1718545 1 08/06/21 06:29 08/07/21 05:04 KMG Mt. Juliet, TN
Metals (ICP) by Method 200.7 WG1718545 1 08/06/21 06:29 08/07/2114:32 KMG Mt. Juliet, TN
Metals (ICPMS) by Method 200.8 WG1717789 1 08/06/21 06:31 08/06/21 23:15 JPD Mt. Juliet, TN
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/2115:31 3 of 16

CASE NARRATIVE
All sample aliquots were received at the correct temperature, in the proper containers, with the
appropriate preservatives, and within method specified holding times, unless qualified or notated within
the report. Where applicable, all MDL (LOD) and RDL (LOQ) values reported for environmental samples
have been corrected for the dilution factor used in the analysis. All Method and Batch Quality Control
are within established criteria except where addressed in this case narrative, a non-conformance form
or properly qualified within the sample results. By my digital signature below, I affirm to the best of my
knowledge, all problems/anomalies observed by the laboratory as having the potential to affect the
quality of the data have been identified by the laboratory, and no information or data have been
knowingly withheld that would affect the quality of the data.
4\i k &A/lib
Jennifer Gambill
Project Manager
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/2115:31 4 of 16

#1
Collected date/time: 08/03/21 13:36
SAMPLE RESULTS - 01
L1386714
Mercury by Method 245.1
Result Qualifier MDL RDL Dilution Analysis Batch
Analyte ug/I ug/I ug/I date / time
Mercury U 0.100 0.200 1 08/10/202110:18 WG1718556
Metals (ICP) by Method 200.7
Result Qualifier MDL RDL Dilution Analysis Batch
Analyte ug/I ug/I ug/I date / time
Aluminum 880 59.2 200 1 08/07/2021 04:53 WG1718545
Calcium 5050 47.3 1000 1 08/07/2021 04:53 WG1718545
Magnesium 1850 115 1000 1 08/07/2021 04:53 WG1718545
Potassium 2820 313 1000 1 08/07/202114:20 WG1718545
Sodium 2200 444 1000 1 08/07/202114:20 WG1718545
Metals (ICPMS) by Method 200.8
Result Qualifier MDL RDL Dilution Analysis Batch
Analyte ug/I ug/I ug/I date / time
Antimony U 1.72 5.00 1 08/06/2021 23:08 WG1717789
Arsenic 0.401 J 0.195 1.00 1 08/06/2021 23:08 WG1717789
Barium 101 0.476 5.00 1 08/06/2021 23:08 WG1717789
Beryllium 0.312 J 0.201 1.00 1 08/06/2021 23:08 WG1717789
Cadmium 2.37 0.160 1.00 1 08/06/2021 23:08 WG1717789
Chromium U 5.60 20.0 1 08/06/2021 23:08 WG1717789
Cobalt 5.49 0.142 2.00 1 08/06/2021 23:08 WG1717789
Copper 1.28 0.670 1.00 1 08/06/2021 23:08 WG1717789
Iron 719 44.7 100 1 08/06/2021 23:08 WG1717789
Lead 5.48 0.513 2.00 1 08/06/2021 23:08 WG1717789
Manganese 391 0.982 5.00 1 08/06/2021 23:08 WG1717789
Nickel 2.20 0.514 2.00 1 08/06/2021 23:08 WG1717789
Selenium U 0.437 2.00 1 08/06/2021 23:08 WG1717789
Silver U 0.144 1.00 1 08/06/2021 23:08 WG1717789
Thallium U 0.176 1.00 1 08/06/2021 23:08 WG1717789
Vanadium 1.70 J 0.466 5.00 1 08/06/2021 23:08 WG1717789
Zinc 241 7.96 20.0 1 08/06/2021 23:08 WG1717789
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/2115:31 5 of 16

#2 SAMPLE RESULTS - 02
Collected date/time: 08/03/21 13:54
L1386714
Mercury by Method 245.1
Analyte
Mercury
Result Qualifier MDL RDL Dilution Analysis
ug/I ug/I ug/I date / time
U
Metals (ICP) by Method 200.7
Batch
0.100 0.200 1 08/10/202110:27 WG1718556
Result Qualifier MDL RDL Dilution Analysis Batch
Analyte ug/I ug/I ug/I date / time
Aluminum 1140 59.2 200 1 08/07/2021 04:55 WG1718545
Calcium 1580 47.3 1000 1 08/07/2021 04:55 WG1718545
Magnesium 1240 115 1000 1 08/07/2021 04:55 WG1718545
Potassium 2620 313 1000 1 08/07/202114:29 WG1718545
Sodium 4970 444 1000 1 08/07/202114:29 WG1718545
Metals (ICPMS) by Method 200.8
Result Qualifier MDL RDL Dilution Analysis Batch
Analyte ug/I ug/I ug/I date / time
Antimony U 1.72 5.00 1 08/06/2021 23:12 WG1717789
Arsenic 1.11 0.195 1.00 1 08/06/2021 23:12 WG1717789
Barium 21.5 0.476 5.00 1 08/06/2021 23:12 WG1717789
Beryllium U 0.201 1.00 1 08/06/2021 23:12 WG1717789
Cadmium 213 0.160 1.00 1 08/06/2021 23:12 WG1717789
Chromium U 5.60 20.0 1 08/06/2021 23:12 WG1717789
Cobalt 18.0 0.142 2.00 1 08/06/2021 23:12 WG1717789
Copper 7.68 0.670 1.00 1 08/06/2021 23:12 WG1717789
Iron 69.0 J 44.7 100 1 08/06/2021 23:12 WG1717789
Lead U 0.513 2.00 1 08/06/2021 23:12 WG1717789
Manganese 1170 0.982 5.00 1 08/06/2021 23:12 WG1717789
Nickel 5.18 0.514 2.00 1 08/06/2021 23:12 WG1717789
Selenium 1.21 J 0.437 2.00 1 08/06/2021 23:12 WG1717789
Silver U 0.144 1.00 1 08/06/2021 23:12 WG1717789
Thallium U 0.176 1.00 1 08/06/2021 23:12 WG1717789
Vanadium U 0.466 5.00 1 08/06/2021 23:12 WG1717789
Zinc 6900 7.96 20.0 1 08/06/2021 23:12 WG1717789
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/2115:31 6 of 16

#2 D
Collected date/time: 08/03/21 13:54
SAMPLE RESULTS - 03
L1386714
Mercury by Method 245.1
Analyte
Mercury
Result Qualifier MDL RDL Dilution Analysis
ug/I ug/I ug/I date / time
U
Metals (ICP) by Method 200.7
Batch
0.100 0.200 1 08/10/2021 09:47 WG1718556
Result Qualifier MDL RDL Dilution Analysis Batch
Analyte ug/I ug/I ug/I date / time
Aluminum 1130 59.2 200 1 08/07/2021 05:04 WG1718545
Calcium 1570 47.3 1000 1 08/07/2021 05:04 WG1718545
Magnesium 1220 115 1000 1 08/07/2021 05:04 WG1718545
Potassium 2550 313 1000 1 08/07/202114:32 WG1718545
Sodium 4780 444 1000 1 08/07/202114:32 WG1718545
Metals (ICPMS) by Method 200.8
Result Qualifier MDL RDL Dilution Analysis Batch
Analyte ug/I ug/I ug/I date / time
Antimony U 1.72 5.00 1 08/06/2021 23:15 WG1717789
Arsenic 1.13 0.195 1.00 1 08/06/2021 23:15 WG1717789
Barium 23.6 0.476 5.00 1 08/06/2021 23:15 WG1717789
Beryllium U 0.201 1.00 1 08/06/2021 23:15 WG1717789
Cadmium 223 0.160 1.00 1 08/06/2021 23:15 WG1717789
Chromium U 5.60 20.0 1 08/06/2021 23:15 WG1717789
Cobalt 18.9 0.142 2.00 1 08/06/2021 23:15 WG1717789
Copper 8.12 0.670 1.00 1 08/06/2021 23:15 WG1717789
Iron 77.8 J 44.7 100 1 08/06/2021 23:15 WG1717789
Lead U 0.513 2.00 1 08/06/2021 23:15 WG1717789
Manganese 1240 0.982 5.00 1 08/06/2021 23:15 WG1717789
Nickel 5.38 0.514 2.00 1 08/06/2021 23:15 WG1717789
Selenium 1.11 J 0.437 2.00 1 08/06/2021 23:15 WG1717789
Silver U 0.144 1.00 1 08/06/2021 23:15 WG1717789
Thallium U 0.176 1.00 1 08/06/2021 23:15 WG1717789
Vanadium U 0.466 5.00 1 08/06/2021 23:15 WG1717789
Zinc 7230 7.96 20.0 1 08/06/2021 23:15 WG1717789
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/2115:31 7 of 16

WG1718556
Mercury by Method 245.1
QUALITY CONTROL SUMMARY
L1386714-01,02,03
Method Blank (MB)
(MB) R3690066-1 08/10/21 09:36
MB Result
Analyte ug/I
Mercury U
MB Qualifier
MB MDL MB RDL
ug/I ug/I
Laboratory Control Sample (LCS)
0.100 0.200
(LCS) R3690066-2 08/10/21 09:38
Spike Amount LCS Result
Analyte ug/I ug/I
Mercury
LCS Rec.
Rec. Limits LCS Qualifier
3.00 3.02 101 85.0-115
L1386120-02 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1386120-02 08/10/21 09:40 • (MS) R3690066-3 08/10/21 09:43 • (MSD) R3690066-4 08/10/21 09:45
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I
Mercury 3.00 0 3.05 3.08 102 103 1 70.0-130 0.979 20
L1386714-03 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1386714-03 08/10/21 09:47 • (MS) R3690066-5 08/10/21 09:49 • (MSD) R3690066-6 08/10/21 09:51
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I % % % % %
Mercury 3.00 0 3.05 3.08 102 103 1 70.0-130 0.979 20
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/21 15:31 8 of 16

WG1718545
QUALITY CONTROL SUMMARY
Metals (ICP) by Method 200.7
L1386714-01,02,03
Method Blank (MB)
(MB) R3689147-1 08/07/21 03:58
MB Result
Analyte ug/I
Aluminum U
Calcium U
Magnesium U
Method Blank (MB)
MB Qualifier
MB MDL MB RDL
ug/I ug/I
59.2 200
47.3 1000
115 1000
(MB) R3689159-1 08/07/2113:55
MB Result MB Qualifier MB MDL MB RDL
Analyte ug/I ug/I ug/I
Potassium U 313 1000
Sodium U 444 1000
Laboratory Control Sample (LCS)
(LCS) R3689147-2 08/07/21 04:01
Spike Amount LCS Result LCS Rec. Rec. Limits LCS Qualifier
Analyte ug/I ug/I % %
Aluminum 10000 9980 99.8 85.0-115
Calcium 10000 9920 99.2 85.0-115
Magnesium 10000 9780 97.8 85.0-115
Laboratory Control Sample (LCS)
(LCS) R3689159-2 08/07/2113:57
Spike Amount LCS Result LCS Rec. Rec. Limits LCS Qualifier
Analyte ug/I ug/I % %
Potassium 10000 9590 95.9 85.0-115
Sodium 10000 9710 97.1 85.0-115
L1382838-02 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1382838-02 08/07/21 04:03 • (MS) R3689147-4 08/07/21 04:09 • (MSD) R3689147-5 08/07/21 04:11
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I % % % % %
Aluminum 10000 U 9960 10200 99.6 102 1 70.0-130 2.14 20
Calcium 10000 51600 64900 65600 133 140 1 70.0-130 V V 1.09 20
Magnesium 10000 11800 21900 22100 102 103 1 70.0-130 0.753 20
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/21 15:31 9 of 16

WG1718545
QUALITY CONTROL SUMMARY
Metals (ICP) by Method 200.7
L1386714-01,02,03
L1386868-02 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1386868-02 08/07/21 04:14 • (MS) R3689147-6 08/07/21 04:17 • (MSD) R3689147-7 08/07/21 04:19
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I % % % % %
Aluminum 10000 U 9970 9910 99.7 99.1 1 70.0-130 0.608 20
Calcium 10000 2800 12700 12500 98.7 96.7 1 70.0-130 1.55 20
Magnesium 10000 498 10200 10100 96.9 96.1 1 70.0-130 0.729 20
L1382838-02 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1382838-02 08/07/2114:00 • (MS) R3689159-4 08/07/2114:06 • (MSD) R3689159-5 08/07/2114:09
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I % % % % %
Potassium 10000 7860 17300 17600 94.5 97.0 1 70.0-130 1.41 20
Sodium 10000 68300 77700 78100 94.5 98.6 1 70.0-130 0.519 20
L1386868-02 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1386868-02 08/07/2114:12 • (MS) R3689159-6 08/07/2114:14 • (MSD) R3689159-7 08/07/2114:17
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I
Potassium 10000 1610 10900 10900 93.2 93.2 1 70.0-130 0.0429 20
Sodium 10000 0 9760 9780 97.6 97.8 1 70.0-130 0.150 20
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/21 15:31 10 of 16

WG1717789 QUALITY CONTROL SUMMARY
Metals (ICPMS) by Method 200.8 L1386714-01,02,03
Method Blank (MB)
(MB) R3689037-1 08/06/21 20:43
MB Result MB Qualifier MB MDL MB RDL
Analyte ug/I ug/I ug/I
Antimony U 1.72 5.00
Arsenic U 0.195 1.00
Barium U 0.476 5.00
Beryllium U 0.201 1.00
Cadmium U 0.160 1.00
Chromium U 5.60 20.0
Cobalt U 0.142 2.00
Copper U 0.670 1.00
Iron U 44.7 100
Lead U 0.513 2.00
Manganese U 0.982 5.00
Nickel U 0.514 2.00
Selenium U 0.437 2.00
Silver U 0.144 1.00
Thallium U 0.176 1.00
Vanadium U 0.466 5.00
Zinc U 7.96 20.0
Laboratory Control Sample (LCS)
(LCS) R3689037-2 08/06/21 20:47
Spike Amount LCS Result LCS Rec. Rec. Limits LCS Qualifier
Analyte ug/I ug/I % %
Antimony 50.0 55.0 110 85.0-115
Arsenic 50.0 53.4 107 85.0-115
Barium 50.0 48.3 96.6 85.0-115
Beryllium 50.0 45.0 90.0 85.0-115
Cadmium 50.0 51.6 103 85.0-115
Chromium 50.0 55.0 110 85.0-115
Cobalt 50.0 55.4 111 85.0-115
Copper 50.0 50.9 102 85.0-115
Iron 5000 5380 108 85.0-115
Lead 50.0 49.6 99.2 85.0-115
Manganese 50.0 54.2 108 85.0-115
Nickel 50.0 55.7 111 85.0-115
Selenium 50.0 51.2 102 85.0-115
Silver 50.0 55.0 110 85.0-115
Thallium 50.0 49.2 98.4 85.0-115
Vanadium 50.0 53.8 108 85.0-115
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/21 15:31 11 of 16

WG1717789 QUALITY CONTROL SUMMARY
Metals (ICPMS) by Method 200.8 L1386714-01,02,03
Laboratory Control Sample (LCS)
(LCS) R3689037-2 08/06/21 20:47
Spike Amount LCS Result LCS Rec. Rec. Limits LCS Qualifier
Analyte ug/I ug/I %
Zinc 500 532 106 85.0-115
L1382739-01 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1382739-01 08/06/21 20:50 • (MS) R3689037-4 08/06/21 20:57 • (MSD) R3689037-5 08/06/21 21:01
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I % % %
Antimony 50.0 U 55.4 54.6 111 109 1 70.0-130 1.46 20
Arsenic 50.0 0.280 51.4 49.6 102 98.7 1 70.0-130 3.54 20
Barium 50.0 14.3 64.9 63.5 101 98.5 1 70.0-130 2.27 20
Beryllium 50.0 U 47.8 46.3 95.6 92.6 1 70.0-130 3.16 20
Cadmium 50.0 U 54.4 53.2 109 106 1 70.0-130 2.17 20
Chromium 50.0 U 53.3 52.2 107 104 1 70.0-130 2.11 20
Cobalt 50.0 U 52.2 51.3 104 103 1 70.0-130 1.86 20
Copper 50.0 3.63 54.2 53.0 101 98.8 1 70.0-130 2.19 20
Iron 5000 556 5780 5630 104 102 1 70.0-130 2.56 20
Lead 50.0 U 52.8 53.7 106 107 1 70.0-130 1.68 20
Manganese 50.0 25.4 77.8 75.7 105 100 1 70.0-130 2.81 20
Nickel 50.0 1.37 52.7 52.3 103 102 1 70.0-130 0.756 20
Selenium 50.0 U 50.1 48.5 100 97.1 1 70.0-130 3.18 20
Silver 50.0 U 54.3 54.7 109 109 1 70.0-130 0.619 20
Thallium 50.0 U 52.8 51.3 106 103 1 70.0-130 3.02 20
Vanadium 50.0 U 51.2 50.8 102 102 1 70.0-130 0.643 20
Zinc 500 84.6 601 585 103 100 1 70.0-130 2.80 20
L1386566-03 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1386566-03 08/06/21 21:04 • (MS) R3689037-6 08/06/21 21:08 • (MSD) R3689037-7 08/06/21 21:11
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I
Antimony 50.0 U 53.4 57.4 107 115 1 70.0-130 7.34 20
Arsenic 50.0 0.594 50.7 50.8 100 100 1 70.0-130 0.239 20
Barium 50.0 53.8 99.0 106 90.5 104 1 70.0-130 6.76 20
Beryllium 50.0 U 46.1 47.1 92.3 94.1 1 70.0-130 2.00 20
Cadmium 50.0 U 51.9 53.7 104 107 1 70.0-130 3.48 20
Chromium 50.0 U 49.9 51.1 99.8 102 1 70.0-130 2.39 20
Cobalt 50.0 0.164 51.8 51.6 103 103 1 70.0-130 0.481 20
Copper 50.0 0.871 51.3 51.7 101 102 1 70.0-130 0.801 20
Iron 5000 U 5300 5130 106 103 1 70.0-130 3.11 20
ACCOUNT: PROJECT: SDG: DATE/TIME: PAGE:
ENSAFE - Knoxville 24799 L1386714 08/10/21 15:31 12 of 16

WG1717789 QUALITY CONTROL SUMMARY
Metals (ICPMS) by Method 200.8 L1386714-01,02,03
L1386566-03 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1386566-03 08/06/21 21:04 • (MS) R3689037-6 08/06/21 21:08 • (MSD) R3689037-7 08/06/21 21:11
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte ug/I ug/I ug/I ug/I % % % % %
Lead 50.0 U 49.6 51.7 99.3 103 1 70.0-130 4.11 20
Manganese 50.0 31.9 80.8 82.2 97.7 101 1 70.0-130 1.73 20
Nickel 50.0 1.25 53.3 53.1 104 104 1 70.0-130 0.318 20
Selenium 50.0 U 52.1 52.0 104 104 1 70.0-130 0.141 20
Silver 50.0 U 54.1 56.8 108 114 1 70.0-130 4.88 20
Thallium 50.0 U 50.6 50.8 101 102 1 70.0-130 0.236 20
Vanadium 50.0 0.594 50.9 50.8 101 100 1 70.0-130 0.167 20
Zinc 500 U 495 502 98.9 100 1 70.0-130 1.38 20
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/21 15:31 13 of 16

GLOSSARY OF TERMS
Guide to Reading and Understanding Your Laboratory Report
The information below is designed to better explain the various terms used in your report of analytical results from the Laboratory. This is not
intended as a comprehensive explanation, and if you have additional questions please contact your project representative.
Results Disclaimer - Information that may be provided by the customer, and contained within this report, include Permit Limits, Project Name,
Sample ID, Sample Matrix, Sample Preservation, Field Blanks, Field Spikes, Field Duplicates, On -Site Data, Sampling Collection Dates/Times, and
Sampling Location. Results relate to the accuracy of this information provided, and as the samples are received.
Abbreviations and Definitions
MDL
RDL
Rec.
RPD
SDG
U
Analyte
Method Detection Limit.
Reported Detection Limit.
Recovery.
Relative Percent Difference.
Sample Delivery Group.
Not detected at the Reporting Limit (or MDL where applicable).
The name of the particular compound or analysis performed. Some Analyses and Methods will have multiple analytes
reported.
Dilution
If the sample matrix contains an interfering material, the sample preparation volume or weight values differ from the
standard, or if concentrations of analytes in the sample are higher than the highest limit of concentration that the
laboratory can accurately report, the sample may be diluted for analysis. If a value different than 1 is used in this field, the
result reported has already been corrected for this factor.
Limits
These are the target % recovery ranges or % difference value that the laboratory has historically determined as normal
for the method and analyte being reported. Successful QC Sample analysis will target all analytes recovered or
duplicated within these ranges.
Original Sample
The non -spiked sample in the prep batch used to determine the Relative Percent Difference (RPD) from a quality control
sample. The Original Sample may not be included within the reported SDG.
Qualifier
This column provides a letter and/or number designation that corresponds to additional information concerning the result
reported. If a Qualifier is present, a definition per Qualifier is provided within the Glossary and Definitions page and
potentially a discussion of possible implications of the Qualifier in the Case Narrative if applicable.
Result
The actual analytical final result (corrected for any sample specific characteristics) reported for your sample. If there was
no measurable result returned for a specific analyte, the result in this column may state "ND" (Not Detected) or "BDL"
(Below Detectable Levels). The information in the results column should always be accompanied by either an MDL
(Method Detection Limit) or RDL (Reporting Detection Limit) that defines the lowest value that the laboratory could detect
or report for this analyte.
Uncertainty
(Radiochemistry)
Confidence level of 2 sigma.
Case Narrative (Cn)
A brief discussion about the included sample results, including a discussion of any non -conformances to protocol
observed either at sample receipt by the laboratory from the field or during the analytical process. If present, there will
be a section in the Case Narrative to discuss the meaning of any data qualifiers used in the report.
Quality Control
Summary (Qc)
This section of the report includes the results of the laboratory quality control analyses required by procedure or
analytical methods to assist in evaluating the validity of the results reported for your samples. These analyses are not
being performed on your samples typically, but on laboratory generated material.
Sample Chain of
Custody (Sc)
This is the document created in the field when your samples were initially collected. This is used to verify the time and
date of collection, the person collecting the samples, and the analyses that the laboratory is requested to perform. This
chain of custody also documents all persons (excluding commercial shippers) that have had control or possession of the
samples from the time of collection until delivery to the laboratory for analysis.
Sample Results (Sr)
This section of your report will provide the results of all testing performed on your samples. These results are provided
by sample ID and are separated by the analyses performed on each sample. The header line of each analysis section for
each sample will provide the name and method number for the analysis reported.
Sample Summary (Ss) This section of the Analytical Report defines the specific analyses performed for each sample ID, including the dates and
times of preparation and/or analysis.
Qualifier
Description
J
V
The identification of the analyte is acceptable; the reported value is an estimate.
The sample concentration is too high to evaluate accurate spike recoveries.
ACCOUNT:
ENSAFE - Knoxville
PROJECT:
24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/2115:31 14 of 16

ACCREDITATIONS & LOCATIONS
Pace Analytical National 12065 Lebanon Rd Mount Juliet, TN 37122
Alabama
Alaska
Arizona
40660 Nebraska NE-OS-15-05
17-026 Nevada TN000032021-1
AZ0612 New Hampshire 2975
Arkansas 88-0469 New Jersey—NELAP TN002
California 2932 New Mexico' TN00003
Colorado TN00003 New York 11742
Connecticut PH-0197 North Carolina Env375
Florida E87487 North Carolina' DW21704
Georgia NELAP North Carolina 3 41
Georgia 1 923 North Dakota R-140
Idaho TN00003 Ohio—VAP CL0069
Illinois 200008 Oklahoma 9915
Indiana C-TN-01 Oregon TN200002
Iowa 364 Pennsylvania 68-02979
Kansas E-10277 Rhode Island LA000356
Kentucky16 KY90010 South Carolina 84004002
Kentucky 2 16 South Dakota n/a
Louisiana A130792 Tennessee' 4 2006
Louisiana LA018 Texas T104704245-20-18
Maine TN00003 Texas 5 LAB0152
Maryland 324 Utah TN000032021-11
Massachusetts M-TN003 Vermont VT2006
Michigan 9958 Virginia 110033
Minnesota 047-999-395 Washington C847
Mississippi TN00003 West Virginia 233
Missouri 340 Wisconsin 998093910
Montana CERT0086 Wyoming A2LA
A2LA — ISO 17025 1461.01 AIHA-LAP,LLC EMLAP
A2LA — ISO 17025 5 _ 1461.02 DOD
Canada _ 1461.01 USDA
EPA—Crypto TN00003
Drinking Water 2 Underground Storage Tanks 3 Aquatic Toxicity ° Chemical/Microbiological 5 Mold 6 Wastewater n/a Accreditation not applicable
* Not all certifications held by the laboratory are applicable to the results reported in the attached report.
*Accreditation is only applicable to the test methods specified on each scope of accreditation held by Pace Analytical.
100789
1461.01
P330-15-00234
ACCOUNT: PROJECT:
ENSAFE - Knoxville 24799
SDG: DATE/TIME: PAGE:
L1386714 08/10/2115:31 15 of 16

c170
EJIISAFE
—��
EnSafe
800-588-7962
CHAIN OF CUSTODY AND ANALYTICAL REQUEST RECORD
COC No. Page i of
1
Inc.
Project Name: A 0 ; _ N(� re, _r� , 5
PO No.
Project No. z;f 7 �' Phase
Site Location: Z _ vC(�,� rC�
Sample Analysis Requested (Enter number of containers for each test)
(3)4
'Extra Volume for MS/MSD
HOLD
Sampler/Site Phone# /6 ( f d j 1 7 2 IA
Total No. of Containers
.f
.
0
y{
J (�r� ! P� Turnaround Time(specify): �%2standard
Lab ID
Sample ID
Location ID
(sys_loc_code)
Date
(mm/dd/yy)
Time
(Military)
)hhmm)
Matrix
Code
(1)
Sample
Type
(2)
Depth-
fbgs
-# 1%
Z i
f 33(�
WS
/J
•74.Z.
Z
S l ,/L r
i 35 q-
`i'k
Jd
h�
Z 0
fp Z v
e/ )
(3 S-{
vJ5
K
1
._
- Sample Receipt Checklist
COC Seal Present/Intact: Y N
_ COC Signed/Accurate: ...^Y N VOA
Bottles arrive intact: -,7'YN Pres.Correct/Check:
Correct bottles used: :::1---N
- Sufficient volume sent: 'y N
RAD Screen <0.5 mR/hr: ----Y---,
l
If Applicable
Zero Headspace:
Y ;i
/S N
—
Field Comments:
Lab Comments:
Sample Shipment and Delivery Details
Number of coolers in shipment:
Resin uished by (signature) Date Time
1 S- V 2 i /e.71 v
)C
Received
1
by (sig
at Date Time
f- (( Z /z...L
Samples Iced?(check) Yes
Method of Shipment:
No
>'%
2
z
Airbill No:
3
3 �'1M fIC____g c'p�I p.,
Date Picked Up:
-- c2
-D3
(1) Matrix Code: AA=AIr, AQ=Air QC Matrix, CK=Caulk, GS=Soil Gas, LF=Free Product, LN=Liquid Waste, MS=Mastic, Oi1=0i1, Pr=Paint, SC=Cement/Concrete, SE=sediment, SF=Fitter Sandpack, SL=Sludge, SN=Miscellaneous Sotd/Bullding Materials, SO=Soil, SQ=Soil/Solid Q4 ,7
Matrix, ST=Solid Waste, SW=Swab/Wlpe, TA=Animal Tissue, TP=Plant Tissue, WG=Ground Water, WL=Leachate, WO=Ocean Water, WP=Drinking Water, WQ=Water QC Matrix, WS=Surface Water, SU=Sewer Water, W W=Waste Water '11L,'1
(2) Sample Type: AB -Ambient Blank, EB=Equipment Blank, FB=Field Blank, Rd -Field Duplicate Sample, FR=FIeid Replicate, MB=Material Blank, N=Nomwl Environmental Sample, RB=Material Rinse Blank, TB=Trip Blank

Attachment E
September 7, 2021 Email

From: Charles G. Howell
To: Menzel, Jeff
Cc: Burch, Brent; Davidson, Landon; Heim Tim; Kobus de Wet; Timothy Basilone
Subject: AZP Status Updates
Date: Tuesday, September 7, 2021 10:52:00 AM
Attachments: imaae001.pnq
Attachment 1 - July and Aug 2021 Soil Sampling Results Under Raffinate and Dep. Sol. Ponds.pdf
Attachment 2 - DP Sol Raffinate Pond Hand Auger Location Map.pdf
Attachment 3 - Results Summary of Ravines 4 5 6 Surface Water Samples Collected by EnSafe on 8-18-21.pdf
Attachment 4 - Result Summary of Ravines 4 5 6 Sediment Samples Collected by EnSafe on 8-18-21.pdf
Attachment 5 - 2021-8-18 Ravines 4 5 6 Surface Water and Sediment Sampling Location Map.pdf
Attachment 6 - 2021-8-25 West Ponds Investigation SAP Mod Memo.pdf
Mr. Menzel,
This email is to provide you with a summary of analytical results for sample collection activities that
have been conducted and update you as to the status of the Sampling and Analysis Plan for the
Raffinate Pond Remedial Investigation.
• Analytical results for soil samples collected from beneath the raffinate pond and depleted
solution pond
o See Attachment 1 Analytical results for soil samples collected on July 28, 2021, and
August 11, 2021, from beneath the Raffinate Pond and Depleted Solution Pond.
Sample identification ending in "BEDM" indicates the soil sample was taken at top
of bedrock.
• Map showing sample locations for soil samples referred to in Attachment 1
o See Attachment 2: Raffinate Pond and Depleted Solution Pond Soil Sample Location
Map
• Surface water sample results from ravines 4, 5, & 6
o See Attachment 3: Summary of analytical results for surface water samples
collected on August 18, 2021, from Ravines 4, 5, & 6.
• Sediment sample results from ravines 4, 5, & 6
• See Attachment 4: Summary of analytical results for sediment samples collected on
August 18, 2021, from Ravines 4, 5, & 6
• Map showing sample locations for water and sediment samples referred to in Attachments 3
and 4
o See Attachment 5: Surface Water and Sediment Sampling Location Map
• Planned date for soil sampling under maintenance pond
• See Attachment 6: As noted, work to collect soil samples from beneath the
maintenance pond was originally scheduled to occur on August 31, 2021. This work
has been postponed and is currently scheduled to occur on September 8th, 2021.
• Planned dates for subsurface soil and groundwater sampling
o Remedial Investigation work is scheduled to commence during the week of
September 20, 2021
• Updated subsurface soil and groundwater sampling schedule
o See Attachment 6: West Ponds Investigation SAP Mod Memo dated August 25,
2021. Note on page 2 it is stated that mobilization for investigation work is
scheduled to commence on September 30th. Please be advised this date should
th

read September 20 .
Please let me know if you have any questions.
Regards,
Charles Howell
Environmental Manager
American Zinc Products, LLC
484 Hicks Grove Rd.
Mooresboro, NC 28114
0 [phone]
C: [phone]
cghowell®azr.com
AZa
AMERICAN
ZINC PRODUCTS
M,+3Rcovien.

Pond:
Sample Location:
Sample ID:
Sample Date:
Start Dep h (feet):
End Depth (Feet):
Raffinate Pond
Depleted Solutions Pond
HA1
HA1-0-0.5
7/28/2021
0
0.5
HA1
HA1-0.5-1.0
7/28/2021
0.5
1
HA1
HA1-1.75-2.0
7/28/2021
1.75
2
HA1
HA1-2.0-2.92
7/28/2021
2
2.92
HA1 (Dup)
HA1D-2.0-2.92
7/28/2021
2
2.92
HA2
HA2-0-0.5
7/28/2021
0
0.5
HA2
HA2-0.5-1.0
7/28/2021
0.5
1
HA2
HA2-1.0-1.75
7/28/2021
1
1.75
HA5
HA5 0-0.5
8/11/2021
0
0.5
HA5
HA5 0.5-0.8
8/11/2021
0.5
0.8
HA5BEDM
HA5BEDM
8/11/2021
HA5BEDM (Dup)
HASBEDMD
8/11/2021
HA6
HA6 0-0.5
8/11/2021
0
0.5
HA6 1
HA6 0.5-0.75
8/11/2021
0.5
0.75
HA6BEDM
HA6BEDM
8/11/2021
HA7
HA7 0-0.5
8/11/2021
0
0.5
HA7
HA7 0.5-1.0
8/11/2021
0.5
1
HA7
HA7 2.5-3.0
8/11/2021
2.5
3
HA7
HA7 3.0-3.75
8/11/2021
3
3.5
HA7BEDM
HA7BEDM
8/11/2021
Method
CAS No.
Analyte
Units
SW6010
7440-38-2
Arsenic
mg/kg
0.73 U
0.72 U
3.8
1.2
1
0.58 ]
2.8
2.6
2.5
2.5
1.6
0.75
1.5
1.4
1.7
4.6
3.3
6.2
5.2
2.2
SW6010
7440-39-3
Barium
mg/kg
33
32
35
18
16
25
30
34
27
23
39
36
44
100
32
29
24
58
330
37
SW6010
7440-43-9
Cadmium
mg/kg
36
31
80
57
42
30
47
41
32
33
20
18
0.27 U
0.25 U
0.25 U
0.26 U
0.25 U
11
7.8
0.22 U
SW6010
7440-47-3
Chromium, Total
mg/kg
1.1
2.5
6.7
2.5
2.5
2.3
6.5
18
20
19
4.6
4
37
63
6.1
22
15
18
19
5.5
SW6010
7439-92-1
Lead
mg/kg
110
100
130
41
43
23
38
15
41
16
34
24
31
47
2.1 3
17
11
26
44
2.4
SW6010
7782-49-2
Selenium
mg/kg
0.97 U
0.96 U
1.2
1.2 U
1.2 U
1 U
5.3 U
5.5 U
5.2 U
4.9 U
0.91 U
0.93 U
5.5 U
5 U
5 U
5.2 U
4.9 U
5.1 U
5.1 U
4.4 U
SW6010
7440-22-4
Silver
mg/kg
0.3 3
0.15 ]
0.93
2.1
1.3
0.63
0.41 ]
0.54 3
0.99
1.2
0.4 3
0.44 3
0.55 U
0.5 U
0.5 U
0.52 U
0.49 U
0.51 U
0.51 U
0.44 U
SW6010
7440-66-6
Zinc
mg/kg
2200
2000
5300
4200
2600
1700
3000
2600
1400
1700
800
710
32
51
44
34
30
380
570
50
SW7471
7439-97-6
Mercury
mg/kg
0.093 U
0.091 U
0.093 U
0.036 ]
0.093 U
0.089 U
0.085 U
0.081 U
0.092 U
0.08 U
0.084 U
0.076 U
0.083 U
0.084 U
0.076 U
0.094 U
0.084 U
0.09 U
0.092 U
0.079 U
SW9045
PH
pH
SU
1.8
2
1.6
1.8
2
2.2
2.2
3.3
3
3.3
2.8
2.8
5.3
5.3
7.8
6.9
7.1
4.3
4.3
8.6
Notes:
CAS No. = Chemical Abstracts Service number
mg/kg = milligrams per kilogram
SU = standard units
J = estimated concentration
U = analyte not detected above laboratory method detection limit
Bold = detected

tionMap_v2.mxd
9
LEGEND
HAND AUGER LOCATION
DEPLETED SOLUTIONS TANK
RAFFINATE TANK
NAD 1983 STATE PLANE
NORTH CAROLINA FEET
0 20 40
SCALE IN FEET
RAFFINATE AND DEPLETED SOLUTIONS
POND HAND AUGER SAMPLING LOCATION MAP
AMERICAN ZINC PRODUCTS
484 HICKS GROVE ROAD
MOORESBORO, NC 28114
REQUESTED BY:
AW
DRAWN BY:
RK
DATE:
9/3/2021
PROJECT:
0888824799
E IISAFE
Creative thinking.Custom solutions.
800.588.7962 I www.ensafe.com
Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS Us r Community. Imagery date - 02/01/2019.

Summary of Surface Water Sample Results from Ravines 4, 5, and 6: August 18, 2021
AZP - Mooresboro, NC
Ravine
Ravine 4
Ravine 5
Ravine 6
Sample Location
1
2
3
4
4
5
6
6
7
8
9
1
2
3
4
1
Sample ID
R4-1-
WS
R4-2-
WS
R4-3-
WS
R4-4-
WS
R4-4D-
WS
R4-5-
WS
R4-6-
WS
R4-6D-
WS
R4-7-
WS
R4-8-
WS
R4-9
WS
RS-1-WS
R5-2-WS
R5-3
RS 4 WS
R6-1-WS
Samp e Date
8/18/2021
NA
8/18/2021
NA
Method
CAS
No.
Analyte
Units
Results pg/L
6020B
7440
38-2
Arsenic
pg/L
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
NA
<1.0
<1.0
NS
<1.0
NA
6020B
7440-
39-2
Barium
pg/L
37
35
37
35
34
31
25
23
24
24
NA
15
13
NS
10
NA
6020B
7440
43-9
Cadmium
pg/L
74.6
80.2
90
118
120
155
131
128
<1.0
2.8
NA
<1.0
<1.0
NS
<1.0
NA
6020E
16965
83-1
Chromium
pg/L
<2
<2
<2
<2
<2
<2
<2
<2
<2
2
NA
<2
<2
NS
<2
NA
6020B
7439-Lead
92-1
pg/L
<1
<1
<1
1.0
1.1
1.8
3.6
3.6
5.4
22.4
NA
<1
<1
NS
<1
NA
6020B
7439-
97-6
Mercury
(Total)
pg/L
<0.20
<0.20
<0.20
<0.20
<0.20
<0.20
<0.20
<0.20
<0.20
<0.20
NA
<0.20
<0.20
NS
<0.20
NA
6020B
7782
49-4
Selenium
pg/L
<5
<5
<5
<5
<5
<5
<5
<5
>5
<5
NA
<5
<5
NS
<5
NA
6020B
7782
22-4
Silver
pg/L
<1
<1
<1
<1
<1
<1
<1
<1
<1
25.6
NA
<1
<1
NS
<1
NA
6020E
7440-
66-6
Zinc
pg/L
2800
3020
3330
4510
4460
5820
4870
4670
103
256
NA
<20
<20
NS
113
NA
4500H+B-
2011
NA
pH
s.u.
5.18
5.55
5.36
4.87
5.03
5.12
5.38
5.38
6.20
5.64
NA
6.59
5.96
5.67
6.44
NA
Notes:
NA = Not Analyzed. No water present.
D = in sample identification indicates a duplicate
NS = Not sampled due to potential interference with iron bacteria flocculant; field water quality parameters collected only

Summary of Sediment Sample Results from Ravines 4, 5, and 6: August 18, 2021
AZP - Mooresboro, NC
Ravine
Ravine 4
Ravine 5
Ravine 6
Sample Location
1
2
3
4
4
5
6
6
7
8
9
1
2
3
4
1
Sample ID
R4-1-
SED
R4-2-
SED
R4-3-
SED
R4-4-
SED
R4-4D-
SED
R4-5-
SED
R4-6-
SED
R4-6D-
SED
R4-7-
SED
R4-8-
SED
R4-9-
SED
R5-1-
SED
R5-2-
SED
R5-3
R5-4-
SED
R6-1-
SED
Sample Date
8/18/2021
Units mg/kg
Method
CAS
No.
Analyte
Units
6020B
7440-
38 2
Arsenic
mg/kg
<1.34
<.1.36
<1.29
1.91
1.49
<1.36
1.75
<1.27
<1.29
1.37
2.79
<1.33
<1.45
NS
5.64
2.80
6020E
7440
39-3
Barium
mg/kg
19.9
<13.6
<12.9
<13.7
14.6
<13.6
<12.4
<12.7
<12.9
39.0
41.7
15.7
18.0
NS
66.3
99.6
6020E
7440
43-9
Cadmium
mg/kg
2.89
2.25
1.52
3.74
5.06
0.864
1.62
0.980
<0.644
<0.630
15.9
<0.667
<0.725
NS
<0.882
<0.730
6020E
7440
47-3
Chromium
mg/kg
14.5
3.27
1.86
11.2
16.0
1.65
7.83
1.92
2.73
10.7
25.1
8.28
13.3
NS
27.2
21.2
6020E
7439-
92-1
Lead
mg/kg
4.77
5.44
4.94
19.2
16.9
2.97
9.58
3.85
3.31
17.4
47.6
4.12
4.46
NS
30.0
18.1
6020B
7439
97-6
Mercury
(Total)
mg/kg
<0.0403
<0.0409
<0.0386
<0.0412
<0.0413
<0.0407
<0.0371
<0.0380
<0.0387
0.0378
<0.0385
<0.0400
<0.0435
NS
<0.0529
<0.0438
6020E
7782
49-2
Selenium
mg/kg
<2.68
<2.73
<2.57
<2.74
<2.75
<2.71
<2.48
<2.53
<2.58
<2.52
<2.56
<2.67
<2.90
NS
<3.53
<2.92
6020E
7440
22-4
Silver
mg/kg
<0.671
<0.682
<0.643
<0.686
<0.689
<0.678
<0.619
<0.633
<0.644
<0.630
<0.641
<0.667
<0.725
NS
<0.882
<0.730
6020E
7440
66-6
Zinc
mg/kg
72.3
56.1
43.8
84.5
110
31.2
56.6
33.8
14.3
34.5
296
17.6
<14.5
NS
121
41.6
9045D
pH
s.u.
5.84
5.89
5.61
5.69
5.60
5.25
4.93
5.03
6.09
5.34
5.85
6.43
6.01
NS
5.49
5.59
SW
DRYWT
Moisture
%
25.5
26.7
22.2
27.1
27.4
26.2
19.2
21.0
22.4
20.6
22.0
25.0
31.0
NS
43.3
31.5
Notes:
All results are reported on dry weight basis.
D = duplicate sample
NS = Not sampled due to potential interference with iron bacteria flocculant

X:\AZP\SampleLocationMap.mxd
R4-9
R4-5
RAVINE
DEPLETEDa
POND
RAFFINATE
POND.
MAINTENANCE
POND i L
•
STORMWATER
POND r,„
ti
LEGEND
SEDIMENT
• SURFACE WATER
O OTHER
RAVINES
NAD 1983 STATE PLANE
NORTH CAROLINA FEET
0 200 400
SCALE IN FEET
SURFACE WATER AND SEDIMENT
SAMPLING LOCATION MAP
AMERICAN ZINC PRODUCTS
484 HICKS GROVE ROAD
MOORESBORO, NC 28114
REQUESTED BY:
AW
DRAWN BY:
MS
DATE:
9/3/2021
PROJECT:
0888824799
ENSAFE
Creative thinking.Custom solutions.
800.588.7962 I www.ensafe.com
Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

AZP West Ponds Investigation SAP Modifications 2021
SAFE
creative thinking. custom solutions.
Technical Memorandum
To: Charles Howell — Environmental Manager — American Zinc Products
Timothy Basilone — Vice President Environmental Affairs — American Zinc Recycling
From: EnSafe
Re: American Zinc Products (AZP) — Mooresboro, NC — West Ponds Investigation SAP Mod
Date: August 25, 2021
Upgradient Groundwater Wells Construction Modification
The West Ponds Investigation Sampling and Analysis Plan (SAP) submitted on August 9, 2021
stated that two groundwater monitoring wells would be installed to the southeast and east of the
pond area. The wells would be installed to cross the vadose zone and would provide info on the
areas groundwater elevation. To meet this objective, we will install these as piezometers (PZs) and
they will be constructed with 1-inch PVC casing.
Upgradient Groundwater Piezometer Location Modification
The SAP stated that a well (piezometer) be placed on the southeast and east sides of the facility to
aid in determining groundwater flow direction. EnSafe has inspected the proposed area and has
determined that the surface elevation for the far eastern PZ is well below the surface elevation of
the west ponds. This extreme gradient will not aid in determining flow direction for the west ponds
investigation. EnSafe would like to move the far eastern piezometer to the northern boundary of
the site as seen in the proposed boring/well location map below.
Proposed Boring Location Adjustments
As discussed in the SAP up to 5 of the proposed boring locations will be converted to 2-inch PVC
monitoring wells pending review of the lithology and potential to produce groundwater. The
locations listed in the original map have been adjusted slightly due to the location accessibility. The
locations listed in the map below are proposed and are under review by the onsite utility group to
ensure no subsurface utilities conflict with the boring locations. EnSafe is planning to review each
location with members of AZP the week of August 30th to ensure the boring areas are free of
subsurface utilities and that the locations are accessible via drill rig.
1

AZP West Ponds Investigation SAP Modifications 2021
• Proposed Soil Boring Location
• Proposed Piezor a °cation
Subsurface Soil and Groundwater Sampling Schedule
Currently EnSafe is planning on mobilizing to site on September 30th to begin on the subsurface soil
and groundwater sampling scope of work. Drilling and well install is estimated to take 3 to 4 days.
Once the groundwater monitoring wells and PZs have been installed, they will be developed no
sooner than 24-hours after installation to allow the well materials to "cure". Sampling and
measuring groundwater elevations will not occur sooner than 24-hours after initial development.
With the required time after install for curing and equilibration the sampling event is currently
scheduled for the week of September 27t"
2

AZP West Ponds Investigation SAP Modifications 12021
Surface Water and Sediment Sampling
One round of surface water and sediment sampling has been completed. This followed a large rain
event. A second sampling is being planned to determine concentrations during drier weather. In
addition, hardness has been added to the list of constituents to be analyzed.
Maintenance Pond Sampling
The plant is completing installation of a replacement above grade tank in the Maintenance Pond.
Sub -liner sampling of this pond in accordance with the Sampling and Analysis Plan is scheduled for
August 31, 2021.
3

Attachment F
Process Modification Summary

Process Modifications
As described below, AZP has converted the Raffinate Pond (FE-211) and Depleted
Solution Pond (FE-212) to storage tanks with the liner system serving as secondary
containment.
This configuration consists of a fiberglass reinforced plastic (FRP) storage and pump tanks,
with a high -density polyethylene (HDPE) piping connection between the two tanks. The
modification from the original (as -built) configuration to the proposed interim configuration is
shown in Figure 1B.
From depletion To gypsum precip
\T
T T T TT/
►- Depleted soln pond
tianinate to leacn SX
Raffinate from SX
TT
T T T T T T T T/
Raffinate pond
1 1 1 1 1 1 1 1 1 1 1
Original configuration. Double liner serve as primary and secondary containment
Automatic shut off valve
From depletion
To gypsum precip
Raffinate to leach SX
Automatic shut off valve
Raffinate from SX
T T T T T T T T T
Raffinate buffer tank
I)
- 4
Planned interim configuration. Ponds serve as lined secondary containment.
Key features of the configuration for the two ponds are as follows:
• Process solution will flow under gravity from the SX circuit, directly into the horizontal
buffer tank, which is connected to a vertical pump tank, placed inside the existing pump
wet well. The solution will be pumped from the vertical pump tank to the next process
stage.
• The pump speed will be controlled to maintain the level in the tanks at a constant value.
• An automatic shut off valve will also be installed in the pipe feeding the buffer tank, to limit
the risk of overflowing the tank.

• In this configuration, the lined ponds will serve only as secondary containments, receiving
rainwater, falling on the footprint of the pond. Any liquid in the pond will be pumped back
into the tanks, or to the metals removal circuit, which is common practice with all secondary
containments onsite.
The system will provide good access for visual inspection of the integrity of the tanks,
piping connection and pond liner, eliminating the reliance on tell -tale pipes.
Future Enhancements
• High density polyethylene tanks with FRP lining are being designed and will be installed
in the wet wells of both ponds.
• Permanent pumping systems are in process of development for movement of storm
water to the tanks or to the metals removal circuit.
• Storm water control around the ponds is being enhanced to minimize accumulation into
the ponds and prevent erosion around the anchor trench of existing liners.
Additional Process Modifications
As completed on both the Raffinate and Depletion ponds, the Maintenance Pond is being
drained and cleaned for conversion to a storage tank system with the existing liner system
acting as a secondary containment for rainwater collection. The solution from the tanks will be
returned to the process through the SX at FE-209. This is a two -tank system to allow for more
capacity. Target completion is 9-25-21.
«faint Pond To F E-
Froin SX Containinarils 209