WQ0016338_Final Permit_20061228

W AT�R Michael F. Easley, Governor
G William G. Ross Jr,, Secretary
7 North Carolina Department of Environment and Natural Resources
O .0 Alan W. Klimek, P.E. Director
Division of Water Quality
December 28, 2006
CERTEHED MAIIL — # 7006 2150 0003 54661323
RETURN RECEIPT REQUESTED
Randall F. Andrews .
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
Subject: Permit No. WQ0016338
ALCHEM, Inc.
Bauxite Residuals Monofill
Surface Disposal Program
Rowan County
Dear Mr. Andrews:
In accordance with your application received on September 30, 2004, we are forwarding herewith
Permit No. WQ0016338, dated December 28, 2006, to ALCHEM, Inc. for the on -site surface disposal of a
silica residual from bauxite digestion, This permit shall be effective from the date of issuance until November
30, 2011, shall void Permit No. WQ0016338 issued March 1, 1999, and shall be subject to the conditions and
limitations as specified therein.
According to the engineering report prepared by Boyle Consulting Engineers, PLLC, on October 24,
2005 entitled "Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis", the
existing fill at the site is not suitable to provide direct foundation support for the intended construction of
buildings for industrial purposes. The existing berm that contains stormwater runoff from the bauxite fill area
was judged to be unsuitable to remain as constructed. A recent visit to the site by NCDENR personnel
disclosed some seepage locations along the outside of the berm at elevations below the surface of the ponded
stormwater runoff. In view of these inadequacies, the Division is requiring that the berm be replaced or .
properly repaired and that the structural and hydraulic integrity of the new or repaired structure be verified by
a licensed engineer (Condition I.1.). The addition of further bauxite material to the fill area is prohibited until
this is accomplished and the engineer's report is received by the Division (Condition 1.2.). Please pay
particular attention to the monitoring and reporting requirements contained in this permit. Failure to establish
an adequate system for collecting and maintaining the required operational information will result in future
compliance problems.
An Assessment of Civil Penalties and a Notice of Violation was issued against the facility under
Permit Number WQ0016338 on August 18 and 19, 2003, respectively, in response to a release of residuals into
a drainage/wooded area and an intermittent stream. The permittee was cited for inadequate corrective actions
in response to a release of residuals into an unnamed tributary to Second Creek and the resulting depression of
pH in the water of the tributary. No thCarolina
Naturally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet; http;//h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

An earthen berm has since been constructed completely around the fill material area to correct the
problem and to keep the fill on the site. Although the fill is currently contained, the capacity of the enclosed
area is limited, and the perrnittee is required to submit a site life estimate for the fill area, as well as a long-
range plan for residuals disposal that shall include a timetable for implementation, and actively seek alternate
disposal/reuse options with a proposed schedule for implementation, under the conditions of Permit Number
WQ0002702, issued on December 28, 2004. Permit Number WQ0002702 further requires the earthen bean to
be maintained so as to keep the fill and/or accumulated rainwater from leaving the fill area. In addition, this
Permit WQ0002702 also required submittal of a map per Condition 31. within 60 days of permit issuance; the
Division has no record of that submission. Submittal of the information required in Permit WQ0002702 is
necessary to evaluate the adequacy of this residuals management system. This permit may be re -opened to
address any concerns developed as a result of the review of this information and the information submitted
under Conditions I.1. and 1.2. (see below), as well as any additional compliance issues.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right
to request an adjudicatory hearing upon written request within thirty (30) days following receipt of this permit.
This request must be in the form of a written petition, conforming to Chapter 150B of North Carolina General
Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North
Carolina 27699-6714. Unless such demands are made, this permit shall be final and binding.
If you need additional information concerning this matter, please contact David Goodrich at (919)
715-6162.
Sincere ,
-;Alan W. Klimek, P.E.
cc: Rowan County Health Department
Mooresville Regional Office, Aquifer Protection Section
Aquifer Protection Section, Central Office
Technical Assistance and Certification Unit
Permit Files

NORTH CAROLINA
ENVIItONINIENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
SURFACE DISPOSAL OF RESIDUALS SOLIDS (503 exempt) PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Alchem, Inc.
Rowan County
FOR THE
operation of a bauxite residuals monofill surface disposal program on Alchem, Inc.'s property at 8135 Red
Road, Rockwell, North Carolina using approximately 3,000 dry tons per year of residuals from the sources
listed in Condition Il 2, with no discharge of wastes to the surface waters, pursuant to the application received
on September 30, 2004, and in conformity with the project plan, specifications, and other supporting data
subsequently filed and approved by the Department of Environment and Natural Resources and considered a
part of this permit.
This permit shall be effective from the date of issuance until November 30, 2011, shall void Permit
No. WQ0016338 issued March 1, 1999, and shall be subject to the following specified conditions and
limitations:
1. PERFORMANCE STANDARDS
Within ninety (90) days of permit issuance, the berm structure containing the storrnwater runoff
from the bauxite fill area shall be replaced, or properly repaired in such a fashion as to address the
concerns noted on page 19 of the report entitled "Report of Preliminary Geotechnical Exploration
& Earthen Embankment Analysis" issued by Boyle Consulting Engineers, PLLC on October 24,
2005. The replacement or repairs shall establish structural and hydraulic integrity within the berm
structure. This integrity shall be verified by field examination and testing performed by, or under
the direction of, a licensed engineer. An engineering report attesting to the structural and hydraulic
integrity of the berm structure, that is signed and sealed by an engineer licensed in the State of
North Carolina, shall be submitted to the Division at the conclusion of the verification procedure.
Two copies of this report shall be submitted to the Aquifer Protection Section's Mooresville
Regional Office at 610 East Center Street, Suite 301, Mooresville, North Carolina 28115.
2. The addition of bauxite material to the fill area is prohibited until such time as the berm structure
has been replaced or properly repaired and its structural and hydraulic integrity have been verified
by field examination and testing performed by, or under the direction of, a licensed engineer, and
the engineering report is received by the Division.

3. The residuals program shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastes resulting from the operation of this program.
4. This permit shall become voidable in the event of failure of the residuals program to adequately
protect the assigned water quality standards of the surface waters and groundwaters.
The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwaters resulting from the operation of this program.
b. In the event that the bauxite surface disposal program is not operated satisfactorily, including the
creation of nuisance conditions, the Perrnittee shall cease the reuse operation and take any
immediate corrective actions as may be required by the Division of Water Quality (Division).
II. OPERATION AND MAINTENANCE REOUMEMENTS
The facilities and application sites shall be properly maintained and operated at all times.
2. No residuals other than the following are hereby approved for use in accordance with this permit:
Permit Volume
Source County _ Number (dry tons/year)
Alchem, Inc. Leached Bauxite Rowan WQ0002712 3,000
Only residuals that are non -hazardous under the Resource Conservation and Recovery Act
(RCRA) shall be disposed in the surface disposal unit.
4, The pollutant concentrations in the residuals that will be disposed of in the surface disposal unit
shall not exceed the following Ceiling Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Arsenic
30
Chromium
200
Nickel
210
The following buffer zones shall be maintained:
a. 400 feet between an active surface disposal unit and any habitable residence;
b. 100 feet between an active surface disposal unit and any public or private water supply source,
all streams classified as WS or B, waters classified as SA or SB and any Class I or Class Ii
impounded reservoir used as a source of drinking water;
c. 100 feet between an active surface disposal unit and any stream, lake, river, or natural
drainage way;
d. 50 feet between an active surface disposal unit and property lines (if the original permit was
issued with the buffer distance to property line as 100 feet, updated maps must be submitted
and new acreage delineated for the buffer to be reduced);
e. 10 feet between an active surface disposal unit and any interceptor drains or surface water
diversions (upslope);

f. 25 feet between an active surface disposal unit and any interceptor drains or surface water
diversions (downslope); and
g. 25 feet between an active surface disposal unit and any groundwater lowering and surface
drainage ditches.
Upon classification by the Water Pollution Control System Operators Certification Commission
(WPCSOCC), the Permittee shall designate and employ a certified operator to be in responsible
charge (ORC) and one or more certified operator(s) to be back-up ORC(s) of the surface disposal
unit in accordance with 15A NCAC 8G .0201. The ORC shall visit the unit in accordance with
15A NCAC 8G .0204 or as specified in this permit and shall comply with all other conditions
specified in these rules.
A copy of this permit shall be maintained on site when residuals are being conveyed and/or
disposed of in the surface disposal unit during the life of this permit. A spill prevention and
control plan shall be maintained on site at all times.
Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residuals treatment area onto the adjacent property or into any
surface waters.
No residuals shall be utilized for land reclamation within one foot of a seasonal high water table
and within three feet of a permanent water table.
10. No residuals shall be used as pipe bedding for sanitary sewer, storm sewer, or potable water lines.
11. The permittee shall insure that the transportation of the residuals does not cause any adverse
impact, i.e. transport in a leak -proof truck for wet material, ensure that trucks are covered for dry
material, or otherwise protected to prevent any adverse impact resulting from operation.
12. Adequate provisions shall be taken to prevent any surface runoff from occurring at any active or
dormant residuals unit. If runoff cannot be prevented, a collection system shall be installed with
the capacity to handle runoff from a 24-hour, 25-year storm event. All collected runoff shall be
disposed in a manner approved by the Division.
13. Adequate provisions shall be taken to prevent wind erosion from conveying pollutants or residuals
from, the surface disposal site onto the adjacent property or into any surface waters.
14. Food crops, feed crops and fiber crops shall not be grown on an active residuals unit, unless
approval has been requested and received from the Division.
15. Appropriate measures shall be taken to control public access to the surface disposal unit during
active use and for the 35-month period following closure of the surface disposal unit. Such
controls may include fencing, and the posting of signs indicating the activities being conducted at
the unit.
III. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue analyses)
deemed necessary by the Division to insure protection of the environment will be established and
an acceptable sampling and reporting schedule shall be followed.

2. Proper records shall be maintained by the Permittee tracking all application activities. These
records shall include, but are not necessarily limited to the following information:
a. location of residuals utilization
b. volume of residuals disposed in gallons/year, dry tons/year, or kilograms/year
A residuals analysis shall be conducted twice per year from the date of permit issuance by the
Permittee and the results maintained on file by the Permittee for a minimum of five years. The
residuals analysis shall include the following parameters:
Arsenic
Nickel
Magnesium
Cadmium
Selenium
Sodium
Chromium
Zinc
Manganese
Copper
Barium
pH
Lead
Silver
Phosphorous
Mercury
Calcium
Aluminum
After the residuals have been monitored for two years at the above frequency, the Permittee may
submit a request to the Division for a permit modification to reduce the frequency of monitoring
for pollutant concentrations. In no case, however, shall the frequency of monitoring be less than
once per year when residuals are applied to the land.
4. Residuals generated by the approved residuals source -generating facility listed in Condition 1.6
shall be analyzed to demonstrate that they are non -hazardous under RCRA every five years. A
corrosivity, ignitability, and reactivity analysis, as well as a Toxicity Characteristics Leaching
Procedure (TCLP) analysis shall be conducted on residuals generated by each approved residuals
source -generating facility. If residuals generated by a particular residuals source -generating
facility are disposed of in the surface disposal unit at a frequency less than annually; the analyses
shall be required for each calendar year in which a disposal event occurs. The results of all
analytical determinations shall be maintained on file by the Permittee for a minimum of five years.
The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide) (0.008)
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
Laboratory analysis as required by Condition HI.1, Condition M.2, and Condition IE.3 shall be
performed/gathered on the residuals as they are to be disposed of in the surface disposal unit.
Furthermore, analytical determinations made pursuant to the monitoring and reporting
requirements of this permit shall be made by a laboratory certified by the Division for the required
parameter(s) under 15A NCAC 211.0800 or 15A NCAC 21-1.1100.

Proper records shall be maintained by the Permittee tracking all application activities associated
with the surface disposal unit. All records shall be kept by the Permittee for a minimum of period
of five years from the date of disposal. These records shall include, but are not necessarily limited
to, the following information:
a. Date and freeboard level measurements in the surface disposal unit;
b. Source and date or residuals disposed of in the surface disposal unit;
c. Volume of residuals disposed of in the surface disposal unit in gallons per year, dry tons per
year, or kilograms per year;
d. Cumulative volume of residuals disposed of in the surface disposal unit in gallons or cubic
yards (i.e., excluding freeboard);
e. Remaining volume in the surface disposal unit in gallons or cubic yards (i.e., excluding
freeboard); and
f. An estimate of the remaining useful disposal life for the surface disposal unit in years (i.e.,
excluding freeboard).
Three copies of all required information, monitoring and reporting requirements as specified in
Conditions III 2, 111 3, III 4 and III 6 shall be submitted annually on or before March 1 of the
following year to the following address:
NCDENR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone number
[phone], as soon as possible, but in no case more than 24 hours or on the next working day
following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence with the surface disposal program which results in the disposal of significant
amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the surface disposal program resulting in a release of material to receiving
waters.
c. Any time that self -monitoring information indicates that the facility has gone out of
compliance with the conditions and limitations of this permit or the parameters on which the
system was designed.
d. Any process unit failure, due to known or unknown reasons, that renders the facility incapable
of adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system transporting residuals to the
disposal site.
Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) days following first knowledge of the occurrence. This report must outline the
actions taken or proposed to be taken to ensure that the problem does not recur.

IV. GROUNDWATER REQUIREMENTS
The COMPLIANCE BOUNDARY for the surface disposal unit is specified by regulations in 15A
NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary for the
disposal system individually permitted on or after December 31, 1983 is established at either (1)
250 feet from the waste disposal area, or 50 feet within the property boundary, whichever is closer
to the waste disposal area. An exceedance of Groundwater Quality Standards at or beyond the
Compliance Boundary is subject to remediation action according to 15A NCAC 2L .0106(d)(2).
The REVIEW BOUNDARY is established around the surface disposal unit midway between the
Compliance Boundary and the perimeter of the surface disposal unit. Any exceedance of
Groundwater Quality Standards at the Review Boundary shall require action in accordance with
15ANCAC 2L .0106 (d)(1).
Any groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
V. INSPECTIONS
The Permittee or his designee shall inspect the residuals storage, transport, and disposal facilities
to prevent malfunctions and deterioration, operator errors and discharges which may cause or lead
to the release of wastes to the environment, a threat to human health, or a nuisance. The Permittee
shall maintain an inspection log or summary including at least the date and time of inspection,
observations made, and any maintenance, repairs, or corrective actions taken by the Permittee.
This log of inspections shall be maintained by the Permittee for a period of five years from the
date of the inspection and shall be made available to the Division or other permitting authority,
upon request.
2. Any duly authorized officer, employee, or representative of the Division may, upon presentation
of credentials, enter and inspect any property, premises or place on or related to the surface
disposal site or facility at any reasonable time for the purpose of determining compliance with this
permit; may inspect or copy any records that must be kept under the terms and conditions of this
permit; and may obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
A set. of all plans and specifications approved by the Division, as well as any as -built plans for the
residuals conveyance facilities and surface disposal unit shall be retained by the Permittee for the
life of the facilities/unit,
This permit shall become voidable unless the surface disposal activities are carried out in
accordance with the conditions of this permit, the supporting materials, and in the manner
approved by this Division.
This permit is effective only with respect to the nature and volume of wastes described in the
application and other supporting data.
4. This permit is not automatically transferable. In the event that there is a desire for the facilities to
change ownership or a name change of the Permittee, a formal permit request must be submitted
to the Division accompanied by an application fee, documentation from the parties involved, and
other supporting materials as may be appropriate. The approval of this request will be considered
on its merits and may or may not be approved.
Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina General
Statute 143-215.6A to 143-215.6C.

6. The annual administering and compliance fee must be paid by the Perrnittee within thirty (30)
days after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit as specified by 15 NCAC 2H .0205 (c)(4).
The issuance of this permit does not exempt the Perinittee from complying with any and all
statutes, rules, regulations, or ordinances which may be imposed by other government agencies
(local, state, and federal) which have jurisdiction, including but not limited to applicable river
buffer rules in 15A NCAC 2B.0200, erosion and sedimentation control requirements in 15A
NCAC Chapter 4 and under the Division's General Permit NCG010000, and any requirements
pertaining to wetlands under 15A NCAC 2B .0200 and 2H .0500.
8. The Perrnittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the facilities
described therein, and if warranted, will extend the permit for such period of time and under such
conditions and limitations as it may deem appropriate.
This permit may be modified, or revoked and/or reissued to incorporate any conditions, limitations
and monitoring requirements the Division deems necessary in order to adequately protect the
environment and public health adequately.
10. The Division shall be notified in writing at least 180 days prior to closing of the surface disposal
unit. A formal closure plan and a post -closure management care program for the surface disposal
unit shall be submitted at that time. This information shall be specific to the surface disposal unit
as well as relate to the Permittee's future plans for the land. A schedule for implementing both the
closure plan and the post -closure management care program shall be provided as well.
Permit issued this the 28"' day of December 2006
NORTH C OLINA E IRONMENTAL MANAGEMENT COMMISSION
L
Sian W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0016338

ALCHENL INC.
Randal F. Andrews
Consultant
2042 Buie Philadelphus Road • Red Springs, NC 28377
rfa@y,semr.net
Office (910) 843-212t. Exi. 2.3
■ Complete items 1, 2. and 3. Also complete
item 4 if Restricted Delivery is desired.
• Print your name and address on the reverse
so that we can return the card to you.
= Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
Randall F. Andrews
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
Mobile [phone]
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If YES, enter delivery address below: © No
3. service Type
Certified Mall 0 Express Mail
n Registered ❑ Ratum Receipt for Merchandise
Cl Insured Mall ❑ C.D.D-
4• Restricted Delivery? (Extra Fee) ;K Yes
2. 7006 2150 0003 5666 1323
PS Form 3811, February 2004 Domestic Retum Receipt 102595-02-M-154t'
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DIVISION OF WATER QUALM?
AQUIFER PROTECTION SECTION -
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