NCS000381_COMPLETE FILE - HISTORICAL_20091005

STORMWATER DIVISION CODING SHEET
RESCISSIONS
PERMIT NO.
DOC TYPE
El COMPLETE FILE -HISTORICAL
DATE OF
RESCISSION
❑ C�,,)oo 1005
YYYYMMDD

In
MA
.NCDENR
North Carolina Department of Environment and Natura
Division of Waste Management
Beveriy Eaves Perdue Dexter R. Matthews
Governor Director
October 5, 2009
CERTIFIED MAIL 7005 1160 0004 7952 0223
RETURN RECLIPT REQUESTED
Mr. Harden Blackwell
President
Terininix Pest Control Company
11.0. Box 14009
Greensboro, NC 27415
Resources
Dee Freeman
Secretary
Re: NOTICI+; OF RECULATORY REQUIRKNIENTS FOR CONTAMINANT ASSI�SSMu,N4'
AND CLI, ,ANUP, former Terminix .Pest Control Company, 3495 Lco Street, Winston-Salem,
NC, 27105, Forsyth County, I HSB Inventory No. not yet assigned
Dear Mr. Blackwell:
We are writing to solicit YOU cooperation in monitoring, testing, analyzing and reporting on the above
listed site located at the specified address. The Division of Waste Management (the "Division'') leas
determined that there is a release, or substantial threat of a release info the environment of a hazardous
substance from the facility. The facility will be referred to in the rest of our letter as the "Site." Based
on the continued elevated detections of the chlorinated pesticides dieldrin, endrin ketone and chlordane
in stream sediments andlor surface water, the Division considers the Site to be a high priority for
assessment.
]'or yOUr review, we have enclosed, with Uur letter, an addendtim. page, that contains a location aerial
slap (l-1gure 1) and the accompanying tables I and 2. The map and tables indicate the locations and
analytical results for samples collected by Winston-Salem Regional Office (WSRO) personnel from
Bowen 131-anch. Locations for these samples are approximately 250 feet south of the former Terminix
facility building at the subject address. Surface water samples collected from location SW-407 have
indicated a continuing presence of chlorinated pesticides since 2005 when the WSRO began periodic
monitoring of Bowen Branch. The WSRO initiated this monitoring due to the number of known sites
that have released various contaminants of concern into the stream. Collectively, the discharge of these
contaminants has impaired strewn duality for a distance of approximately two miles downstream.
`fhe portion of the stream that has been impacted by the aforementioned organochlorinc pesticides
appears to be approximately 350 feet in length. Analytical data from sampling points SW-306, SW-307,
585 Waughtown Street, Winston-Salem, North Carolina 27107-2275
Phone [phone] FAX [phone] Internet httpalwastenotnc org
An Eeual Orwrlunily 1 Affirmative Action Employer -Printed on Dual Purpose Recycled Paper

Requirements for Contaminmt Assessment and Clcnnup
Pormer Terminix Pest Control Company-3495 Leo Street
October 5, 2009
page 2
and SW-308 indicates increasing concentrations of the pesticides in the downstream direction towards
sampling point SW-407 (Table 1). These concentrations exceed the applicable levels established in
North Carolina Administrative Code (NCAC) Title 15A Subchapter 213 for surface water standards.
Sediment samples also indicate increasing levels of. pesticides in the downstream direction as well. Ail
of the water and sediment samples have been collected under stream baseflow conditions.
Consequently, the water and sediment sample concentrations are strongly suggestive of a groundwater
source located within the immediate vicinity of the collection points.
For many years, the immediate area surrounding the subject portion of the stream has been used by
homeless and transient people for overnight stays. Additionally, the stream appears to have served as a
soLII'Ce of drinking water during these stays. Consequently, the Forsyth County Health Depar€rnent, In
2005, requested that the stream be j)osted to warn of contaminants of concern. Approximately, two
miles of impacted stream is posted with such warning signs. In most of the posted areas along the
stream, access is unrestricted to tine general public. Such unrestricted access exists within the vicinity of
the former Terminix facility as well as along the 350-foot length of impacted stream referenced
previously.
You will note from Table 2 that the sediment sample resu3ts indicate that the pesticide levels are
significantly above the ecological risk screening values established by the U.S. Environmental
Protection Agency. Consequently, the ecology of the stream continues to be severely impaired due to
the presence of the pesticides of concern.
Although, you indicated during our recent phone conversations that the WSRO had a file related to your
former facility, we have been unable to locate such a Cite as it was apparently purged by the NCDENR
Division of Water Quality ("DWQ"), a number of years ago. Consequently, at our request, your office,
on August 5, 2009, provided some documentation relevant to the purged site file. The documentation
indicates that in December 1987, the organochlorine pesticide chlordane was detected in the soils
surrounding subject facility building. Based on the very limited documentation that we have been
provided, it appears that the levels of chlordane in soil were above the established action levels at the
time, prompting the DWQ to require soil abatement in the chlordane -impacted areas around the
"Terminix building. No drawings or figures were contained in the documentation provided to our office,
though correspondence provided does refer to such in discussing the areas that were slated for soil
abatement.
The, documentation provided to the WSRO also contained an analytical report from the North Carolina
DWQ laboratory Section for two samples collected by DWQ personnel oil June 2, 1987, These
samples were collected from apparently two separate locations (denoted as stations 4 and 5) in Bowen
Branch. 'File lab field sheets indicate that the samples were collected downstream from the subject site.
'1'lie specific positions of the sampling locations, however, are unclear, as the report did not include a
location map. The report from the DWQ Laboratory indicates that dieldrin was detected in both samples
at concentrations of 0.06 and 0.10 micrograms per liter, respectively. You will notice that these
concentrations also exceed the State 2B standards referenced above and in Table 1.
The documentation provides no evidence that further follow! up sampling Was performed to determine
the extent of the concentrations in the stream, nor does there appear to have been an effort to define the
vertical or horizontal extent of the pesticide contamination around the Terminix building. At the time of
the 1987 and 1988 correspondence between NCDLNIZ and Terminix, groundwater was likely not
considered as a potentially important pesticide transport mechanism for discharge into the stream. Such
a lack of consideration was not uncommon within the industrial, regulatory or research communities.
Pesticide movernent from soils and into groundwater was believed to be largely inconsequential. As a

Requirements for Contaminann Assessment and Cleanup
Former Terminix Pest Conlrol Company-3495 Leo street
October 5, 2009
Page 3
result, most assessment and remedial efforts were directed towards rninirnizing runoff into surface Neater
bodies. Only in recent decades, have environmental investigations at pesticide sites started to include
groundwater assessment and remediation phases.
Although Terminix appears to have received a letter of no further action (NFA) from the DWQ, such a
letter always includes the uncle rstanding that a responsible party is not absolved of contamination that is
either not reported to the State or else is discovered after the NFA letter was issued. Such an
understanding necessitates that closed site files be reopened for further investigation and remediation if
site conditions warrant. I"or the reasons that were previously discussed, the former Terminix Leo Street
facility appears to be a site where more investigation and potentially additional remediation is required.
In light of the fact that gr•ourulwater at the subject property appears to have been impacted by pesticides
of concern, the Division requests that you concluct a site assessment under the supervision of the
Inactive Hazardous Sites Branch. Within thirty (30) clays of your receipt of our letter, please submit a
draft Site Assessment Plan (flan) that complies with the current .Inactive Hazardous Sites Branch
Guidelines for Assessment and Cleanup(ww�Ar:wastetiotiic.org/-,fholne/lhsgLlide.litln). The draft Plan
must be organized in sections corresponding to the following items and include:
€. Site location information including site street address, longitude and latitude, and
site and surrounding property land use.
2. A summary of all management practices employed at the Site for hazardous
wastes and any wastes that may have contained hazardous substances, including a list of
types and amounts of waste generated (with RCRA waste codes), treatment and storage
methods, and ultimate disposition of wastes; a description of the facility's past and
current RCRA status; the location and condition of any vessels currently or previously
used to store any chemical products, hazardous substances or wastes; and a summary of
the nature of all on -site hazardous substance releases, including one-time disposals or
spills.
3. United States (ecological Survey topographic maps sufficient to display
topography within a one -mile radius of the Site.
4. A site survey plat (prepared and certified by a Professional band Surveyor)
including scale; benchmarks; north arrow; locations of property boundaries, buildings,
structures, all perennial and non -perennial surface water features, drainage ditches, dense
vegetation, known and suspected spilt or disposal areas; underground utilities, storage
vessels, existing on -site wells; and identificatiorn of all adjacent property owners and laud
usage.
A description of local geologic and hydrogeologic conditions.
6. Inventory and mal> of all wells, springs, and surface -water intakes used as sources
of potable water within one-half mile radius orthe center of the Site. If the Site is greater
than one hunched (100) acres in size, the inventory and map must cover a one -mile radius
from the center of each source area.

Requirements for Contaminant Assessment surd Cleanup
Former Terminix Pest Control Company-3495 Leo Street
October 5, 2009
Page 4
7. Identification of environmentally sensitive areas on and adjacent to the Site
including:
State Parks
Areas Important to Maintenance of Unique Natural Communities
Sensitive areas Identified Under the National Estuary Progratn
Designated State natural Areas
State Seashore, Lakeshore and River Recreational Areas
Rare Species (state and federal Threatened and Endangered)
Sensitive Aquatic l labitat
State WU and Scenic Rivers
National Seashore, Lakeshore and River Recreational Areas
National Parks or Monuments
Federal Designated Scenic or Wild Rivers
Designated and Proposed federal Wilderness and Natural Areas
National Preserves and forests
federal Land designated for (lie protection of Natural Ecosystems
State -Designated Areas for Protection or Maintenance of Aquatic Fife
State Preserves and Forests
Terrestrial Areas Utilized for I3reeding by barge or Dense Aggregations of Animals
National or State Wildlife Refuges
Marine Sanctuaries
National and State Historical Sites
Areas Identified Under Coastal Protection legislation
Coastal Barriers or Units of a Coastal Barrier Resources System
Spawning Areas Critical for Maintenance of fish/Sllcllflslr Species within River,
Lake or Coastal Tidal Waters
Migratory Pathways and Deeding Areas Critical for Maintenance of Anadromous Fish
Species within River ]teaches or Areas in Lakes or Coastal Tidal Waters in which such
Fish Spend Extended Periods of'firnes
State Lands Designated for Wildlife or Game Management
Wetlands
8. A list ofail hazardous substances which have been used or stored at the ,Site, and
approximate amounts and elates of use or storage as revealed by availablewritten
documentation and interviews with a representative number of former and current
emhloyces or occupants possessing relevant information.
9. Site environmental permit history, including copies of all federal, state, and local
environmental permits, past and present, issued to or within the custody or control of the
subject property.
10. A summary ol'all previous and ongoing environmental investigations and
environmental regulatory involvement with the Site, and copies of all associated reports
and laboratory data.
11. Proposed procedures for characterizing site geologic and hydrogeologic
conditions and identifying and delineating each contamination source as to each affected
environmental medium, including any plan for special assessment such as a geophysical
Survey.
12. Proposed methods, locations, depths of, and justification for, all sample collection
points for all media sampled, including monitoring well locations and anticipated
screened intervals.

m
Requirements for Contaminant Assessment and Cleanup
Formel I cmiinix Nil Control Compruty-3495 Leo Strca
October 5, 2009
Page 5
13. Proposed field and laboratory procedures for quality assurance/quality control.
14, Proposed analytical parameters and analytical methods for all samples.
15. A contact name, address and telephone number for the principal consultant and
laboratory, and qualifications and certifications of all consultants, laboratories and
contractors expected to perform work in relation to this Plan. Any laboratory retained
must currently be cither certified to analyze applicable certifiable parameters under Title
15A oftheNorth Carolina Administrative Code, Subchapter 2I-1, Section ,0800, or be a
contract laboratory under the EITA Contract Laboratory Program.
16. Equipment and personnef decontamination procedures.
17. A proposed schedule for site activities and reporting.
18. Any other information considered relevant by the rernediating party.
19. [Use eitlier: f1 signed and notarized certification by a corporate official in charge
of a princilmil business fi.mction for businesses or Your signecl and notarized cerlificalion
for individual owners] stating: "f certify that, to the best of my knowledge, after
thorough investigation, the information contained in or accompanying this certification is
trlle, accurate, and complete."
20. A signed and notarized certification by the consultant responsible for the day-to-
day remedial activities stating: "1 certify that; to the best of my knowledge, after thorough -
investigation, the information contained in or accompanying this certification is true,
accurate, and complete."
21. ' If the Plan includes any work that would constitute the "practice of engineering"
as defined. by N.C.G.S. 89C, the signature and seal of a professional engineer is required.
22. If the Plan includes any work that would constitute the "public practice of
geology" as defined by N.C.G.S. 89E, the signature and seal of a licensed geologist is
required.
The Division will notify Terrninix Pest Control of any changes needed in the Plan and of the time within
which the changes must be made. Your facility may not implement the flan until it is approved in
writing by the Division. Ally desired modifications to the approved Flan or work schedule must be
approved by the Division prior to in�pfenZcrftation. Terminix 'est Control must notify theDivision no
less than ten (10) days prior to any field activity.
Following completion of the site assessment, Terminix Pest Control must provide a Site Assessment
Report (Report) documenting implementation of the approved Plan. The Report must be organized in
sections corresponding to the following items and include:
I . A narrative description of how the assessment was conducted, including a
discussion of any variances From the approved Plan.
2. A description of groundwater monitoring well design and installation procedures,
including well drilling methods used, completed drilling logs; "as built" drawings of all

Requirements for Contaminant Assessment and Cleanup
Former Terminix Pest Control Conilmy-3495 Leo Street
October 5, 2009
Page G
2. A description of groundwater monitoring well design and installation procedures,
including well drilling methods used, completed drilling logs, "as built" drawings of all
monitoring wells, well construction techniques and materials, geologic logs, and copies
of all well installation permits.
3. A map, drawn to scale, showing all soil, surface water and sediment sample
locations and monitoring well locations in relation to known disposal areas or other
sources of contamination. Monitoring wells must be surveyed to a known benchmark.
Soil sample locations must be surveyed to a known benchmark or flagged with a secure
marker until after the remedial action is completed. Monitoring well locations and
elevations must be surveyed by a .Professional Land Surveyor.
4. A description of all laboratory quality assurance and quality control procedures
followed during the remedial investigation.
5. A description of procedures used to manage drill cuttings, purge water and
(1ccoIltan1inatlon welter.
6. A summary of site geologic conditions, inckiding a descriltion of soils and
characteristics of the vadose zone.
7. A descriptions of site hydrogeologic conditions (if hazardous substances have
beet) detected in groundwa(er), including current uses of groundwater, notable aquifer
characteristics, a water table elevation contour slap with groundwater flow patterns
depicted, tabulated groundwater elevation data, and a description of procedures used for
measuring water levels.
8. Tabulation of analytical results for all sampling (including sampling dates and soil
sampling depths) and copies of all laboratory reports (including QAIQC support data
rcferenced'to spel;ili(; samples).
9. Soil, groundwater, surface water and sediment contaminant delineation maps and
cross sections, including scale and sampling points with contaminant concentrations.
10. A description of 1?rocedures and the results of any special assessments such as
geophysical surveys, immunoassay testing -(ETA SIAI-846 4000 series. methods), soil gas
surveys, or test pit excavations.
11. Copies of all field logs and notes; and, where available, color copies of site
photographs.
12. A demonstration, supported by sampling data, that the horizontal and vertical
extent of hazardous substance contamination in each affected medium has been
delineated to the satisfaction of the Division in accordance with the current version of the
Division's Inactive Hazardous Sites Branch Guidelines for Assessment and Cleanup.
13. Any other information considered relevant by the rernediating party.

Requirements for Corrlamimurt Assessment and Cleanup
Former'rerminix Pest Control Compwmy-3495 Leo street
Octottcr 5, 2009
Page 7
14, [Use either: A signed and notarized certification by a corporate official in Chal-ge
of a principal business function for businesses or Your signed and notarized certification
for individual owners] stating: "I certify that, to the best of my knowledge, after
thorough investigation, the information contained in or accompanying this certification is
true, accurate, and complete."
15, A signed and notarized certification by the consultant responsible for the clay -to-
day remedial activities stating: "I certify that, to the best oC my knowledge, after thorough
investigation, the information container[ in or accompanying this certification is true,
accurate, and complete."
16. If the Plan includes any work that would constitute the "practice of engineering''
as clef ined by N.C.G,S. 89C, the signature and seal of a professional engineer is required.
If the flan includes any work that would constitute the "public practice of geology" as
defined by N.C.G.S. 89E, the signature and seal of a licensed geologist is required.
The Division will notify `Terminix Pest Control of any changes tieeded in the assessment or the Report
due to any hazard posed by the Site or discrepancies with the approved Site Assessment Plan, and of the
time within which changes must be made. When the Division determines that the site assessment is
complete, the Division will notify Terminix Pest Control in writing.
At documents submitted to the Division in relation to this work must be sent to Collin Day in the
WSRO and at the letterhead mailing address.
To protect public health and the environment, the Division has the authority under N.C.G.S. 130A-
3 1 0.1(c) to order tiny responsible party to ConduCt such monitoring, testing, analyses and reporting as
deemed reasonable and necessary to ascertain the nature and extent of any hazard posed by a Site. Prior
to 1ssiting site assessment orders, however, the Division sends letters ,such as ours to offer responsible
parties the opportunity to work cooperatively with the Division.
This offer shall expire at the close of business on the 30`" day following your receipt of this letter, so
please notify the Division, in writing, if Terminix Pest Control intends to comply with our request. If
you have any questions, concerning the assessment request, please contact'us at [phone].
Sincerely,
Collin Day
1-lydrogeologist
CC William Whiteheart
P.O. Box 40
Lewisville, NC 27023
WSRO Files

Requirements for Contaminant Assessment <vid Cleanup
Former Terrninix Pest Control Company-3495 Leo Street
October 5, 2009
Page 9
Figure 1. 1992 aerial photo location map showing Bo�ven Branch sampling points in
relation to the former `Ferminis Leo Street facility

1Requiremenls for Contamin:uu Assessment and Cleanup
Former Terminix Pest Coturol Company-3495 Leo Street
October 5, 2009
page 9
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t•
Human Health
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cologic,
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m?k`x,dtt?
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Ecological
MollltOr-ing
Sampling
Risk chronic
Point
Date
Screening
Value (a/kg)
0.0019
0.0023
S W-305
6/4/2008
Trace
ND'
E...a�.1nntxsiiSr`Cr..-•,`:,..��0.180
? „f
�+�`"1r,.+:{,k��:�.,
il Y'4r-308
6/`Y/2008
'r,��'_:,,�4C-,'C='
��Fa�iw:�:i`���
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t '1
0. 1 80
e
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�-�
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,.�.'. �. ,:il
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.:.r ar
SW-407
6/2.1/2005
}z x<;''
r=irk a
0.464
0.32E1
SW-407
9/7/2005
;j"'',;a,.�'
0.480
ND 1
S W-�407
6/4/2008
=" = .y
= t ' T_
0.450
0.150
1. ND=Non Detect
Table 1. Surface Water Sample Results for Bowen Branch Pesticide Impact Area.

Requirements for Contaminant Assesstsrent and Cleanup
former Terminix Pest Control Company-3495 Leo Street
October 5, 2009
Page 10
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3/24/2009
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3/24/2009
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3/24/2009
224
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390
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; _
:';
Sl=D-30$
3/24/2009
'h jc7
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380
722.1
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3/24/2009
?w�
w �`', r:
224
ND
ND
ND ND NA
54.2
1. ND=Non Detect
2. NA=Not Analyzed for the Constituent
3. USEPA Acute and Chronic Risk Screening Values are the same Value for contaminants of concern
Table 2. Sediment Sampling Results for ,June 2008 and March 2009 for Organochbrine Pesticides

Beverly Eaves Perdue
Governor
Mr. harry R. Hodge
Agrium
1 Commerce Street
Florence, AL 35630
Dear Mr. Hodge:
JA
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
February 13, 2009
Dee Freeman
RECEIVED Secretary
N.C. pent. of ENR
FEB 17 2009
Winston-Salem
Regional Office
Subject: Rescission of individual Permit
Permit NCS000381
Agrittm
Forsyth County
Reference is made to your recent request for rescission of coverage under the subject NPDES Individual PCI-Init. [n your
letter received on December 5, 2007, you stated that your business has closed and all activities have ceased. In accordance
With your request, permit number NCS000381 is rescinded, effective immediately.
Operating a treatment facility, discharging wastewater or discharging specific types ofstormwater to waters of the State
Without a valid NPDES permit will subject the responsible party to a civil penalty of up to $25,000 per day. Enforcement
action will be certain for persons that have voluntarily relinquished permit coverage when, in fact, continuing permit
coverage was necessary. If, in retrospect, you feel the site still requires permit coverage, you should notify this office
immediately. Furthermore, if in the future you wish to again discharge to the State's surface waters, you must First apply
for and receive a new NPDES permit.
I ['the facility is in the process of being -sold, you will be performing a public service if you would inform the new or
prospective owners of their potential need for NPDES permit coverage.
1l'you have questions about this matter, please contact Sarah Young at [phone].
Sincerely,
ORIGINAL SIGNED BY
KEN PICKLE
Coleen 1-1. Sullins
cc: Winston-Salem Regional 0011ce
Slormwaler Permitting Unit
Central Files - wlauachmenls
Fran McPherson, DWQ 13udgct Office
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Caroliria 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 9i9.807-64941 customer Service: 1-877-623-6748
Internet: www.nmaterquality.erg
An Equal Opportunity 1 A15rmaliva Actbri Employer
One
NorthCarolina
Nutur,allry

MEMO
Division of Water Quality
Winston-Salem Regional Office
November 20, 2008
Memorandum to: Bradley Bennett, Stormwater Permitting Unit
Through: Steve W. Ted*-ity
WSRO Wate Supervisor
From: Rose Pruitt P
Environmental Specialist
Subject: Agrinm
NCS000381
Forsyth County
Storrnwater Permit Recission Request
OK to rescind SW permit.
Facility torn down.

Agrium
Bill Weis
Remediation Specialist
March 3, 2008
Ms. Rose Pruitt
North Carolina Department of Environment and Natural Resources
585 Waughton Street
Winston-Salem, NC 27107
Agrium U.S. Inc.
7540 West 160" Street, Suite 130
Overland Park, KS 66085
Direct: [phone]
Cell: [phone]
Re: Request for Additonal Information Regarding Termination of Stormwater Permit
Permit Number NCS000381, Forsyth County
Dear Ms. Pruitt:
This letter is to follow-up our meeting of February 13, 2008, regarding the additional actions requested by
the North Carolina Department of Environment and Natural Resources at the former Royster-Clark
facility prior to termination of storm water permit NCS000381. As we discussed, business operations
have ceased at the subject facility and Agrium is making plans to remove buildings and equipment
remaining on the property. As part of these demolition activities, Agrium will address the housekeeping
items presented in your letter of December 19, 2007.
We are currently preparing a spending request and a bid package to complete demolition activities at the
subject facility. Upon approval of the demolition funding and receipt of bids for necessary removal
activities, Agrium intends to begin the activities requested in your December 19, 2007 letter. A start date
for this work is not known at this time, but expected to be this spring. We will advise you of the schedule
for these activities following development of a demolition plan.
If you have.questions regarding the proposed site activities or need additional information, please contact
me at [phone]. 'Thank you for your assistance in this matter.
Sincerely,
Bill Weis

Royster Clark response to Inspection
Subject: Royster Clark response to Inspection
From: "Bill Weis" <bweis a agrium.com>
Date: Mon, 03 Mar 2008 11:14:29 -0700
To: <rose.pruitt@ nemail.net>
CC: "Daren Couture" <DCotrture rr agrium.com>, "Fred Duncan" <fdunean a agrium.corn>, "Larry
I -lodge" <JIodge a agrium.com>, "Ted Hartman" <TI-lartman a agrium.com>
Rose:
Attached is the response letter you asked for confirming our intent to complete the
additional closure activities which were requested in your letter of 12/19/07. We
don't have a schedule for completing this work yet, but plan to take care of it as
part of the building demolition. We will keep you advised of a demolition schedule
when we have one.
Let me know if you have questions or need additional information.
Thanks
Bill Weis
Blue Valley Business Park
7540 West 160th Street
Suite 130
Overland Park, Kansas 66085
Phone: (913) 851-C158
Fax: [phone]
Cell: [phone]
IMPORTANT NOTICE
This E-Mail transmission and any accompanying attachments may contain confidential
information intended only for the use of the individual. or entity named above. Any
dissemination, distribution, copying or action taken in reliance on the contents of
this E-Mail. by anyone other than the intended recipient is strictly prohibited and
is not intended to, in anyway, waive privilege or confidentiality. If you have
received this E-Mail in error please immediately delete it and notify sender at the
above E-Mail address.
Agrium uses state of the art anti -virus technology on all incoming and outgoing
E-Mail. We encourage and promote the use of safe E-Mail management practices and
recommend you check this, and all other E-Mail and attachments you receive for the
presence of viruses. The sender and Agrium accept no liability for any damage caused
by a virus or otherwise by the transmittal of this E-Mail.
j 11 Content-`1'ypc: application/pHNCDENR Stormwater Reply 03_03_08(1001.pcil'i
i1 Content -Encoding: base64
I of 1 3/3/2008 1:23 PM

■ Complete kems,11, 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:
I { gent
x ❑ Addressee
B. ceived by( Pitd Name) C. DZta,of 99livery
D. Is delivery address different from item 1? ❑ Yes
If YES, enter delivery address below: ❑ No
Mr. Larry 146dge
Agrium US Inc.
] Co nlnerce Strect 3. ler0cerype
Florence, AL 35630 Orcertilled Mail ❑ F4ress Mall
❑ Registered 07ketum Recelpt for Merchandise
- - ❑ Insured Mail ❑ C.Q.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
7007 0710 0001` 5586 9875' [GII/ PEfm,+ 2scr'ssr`dr1
PS Form 3811, February 2004 Domestic Return Recel rP 1.7-3 j P 7 102595-02-M-1540

I
UNITED STATES
i A
Al
USPS
if"-Ir -AGE
0 Sender: Please print your name, address, and ZIP+4 in this box 0
NCDENR- Water Quality Section
585 Waughtown Street
Winston-Salem, NC 27107
i , , .1, 'I'll f 11 1111 r I 1 1 1 1 d I I i I I i I I H I I I fl

U.S. Posta! Service TM
VG,E,RT1,FpJtiIEMAILT,,RECEIPTc Mail Only; No Insurance 6average Pravlded)
�Fo%de ll ier'y't,i�foma}r��z ��ito•.�wcbstSe 9twww,��ans.corno
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Postage R Fees
ant Mr. Larry Hodge
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Aarium US Inc.
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orP( 1. Commerce Stree
���STC`,�
Florence. AL 35630
L

Certified Mail Provides:
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"mpartant Reminders:
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o Certified Mail is not available for any class of intemationat mail.
■ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For
valuables, please consider Insured or Registered Mail.
■ For an additional fee, a Return Receipt may be requested to provide proof of
delivery. To obtain Return Receipt service, please complete and attach a Return
Receipt (PS Form 3811) to the article and add applicable postage to cover the
fee. Endorse mailpiece "Retum Receipt Requested". To receive a fee waiver for
a duplicate return receipt, a USPSe postmark on your Certified Mail receipt is
required.
■ For an additional fee, delivery may be restricted to the addressee or
addressee's authorized agent. Advise the clerk or mark the maiipiece with the
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cle at the post office for postmarking. If a postmark on the Certified Mail
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IMPORTANT: Save this receipt and present it when making an inquiry.
3S Form 3e00, August 2006 (Reverse) PSN 7530-024)00.9047

■ 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.
Article Addressed to:
Billy Pirkle
Atrium US Inc.
3105 Glenn Avenue
NAIinston-Salem, IBC 27105
A. Sig lure
❑ Agent
X ❑Addressee
B. Received 9f' ( Printed Name) C. Date of Delivery
D. Is delivery address different from item t? ❑ Yes
If YES, enter delivery address below: ❑ No
3. Se Ice Type
d Certified Matt
0 gxpress Mall
❑ Registered
URetum Receipt for Merchandise
❑ Insured Mall
0 0,01).
4. Restricted Delivery? (Extra Fee) ❑ Yes
7007 0710 0001 5586 9882
PS Fomi,3811' February 20f)4 ( ( l I ( f Dorneitic Retum Receipt �— Q _ Ae 595-024-154C

UNITED STATES �ITR
Paid
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F ta
0 Sender: Please print your name, address, and ZIP+4 in this box 0
NCDENR- Water Quality Section
P. for"- i ' '-�
585 Waughtown Street
Winston-Salem, NC 27107

U.S. Postal Seri=,- Of
,CERt IFIEDM_�IILTr, RECEIPT
ff -(Dorriestl7Mal1[OirlZN7lnsura>:ce Coverage ProvfdFCf)=
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certirled Fee 5
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n AgriLim US Inc.
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Certified Mail Provides:
a A mailing receipt
■ A unique identifier for your maitpiece
■ A record of delivery kept by the Postal Service for two years
'mportant Reminders.
■ Certified Mail may ONLY be combined with First -Class Mail® or Priority Mail®.
■ Certified Mail is not available for any class of international mail.
r NO INSURANCE COVERAGE IS PROVIDED w!ih Certified Mail. For
valuables, please consider Insured or Registered Mail.
a For an additional fee, a Return Receipt may be requested to provide proof of
delivery. To obtain Return Receipt service, please complete and attach a Return
Receipt (PS Form 3811) to the article and add applicable postage to cover the
fee. Endorse mailpiece "Return Receipt Requested". 1t-oreceive a fee waiver for
a duplicate return receipt, a LISPS® postmark on your Certified Mail receipt is
required,
r For an additional fee, delivery may be restricted to the addressee or
addressee's authorized agent. Advise the clerk or mark the maifpiece with the
endorsement "Restricted Delivery".
s If a postmark on the Certified Mail receipt is desired, please present the arti-
cle at the post office for postmarking. If a postmark on the Certified Mail
receipt is not needed, detach and affix label with postage and mail.
MPQRTANT: Save this receipt and present it when mailing an inquiry,
�S Form 3800, August 2006 (Reverse) PSN 7530-02-000-9047

F VVArE Michael F. Easley, Governor
9pG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins Director
Division of Water Quality
December 19, 2007
CERTIFIED MAIL 7007 0710 0001 5586 9875
RETURN RECEIPT REQUESTED
Agrium US Inc
Nlr. Larry Hodge
I Commerce St
Florence AL 35630
CERTIFIED MAIL 7007 0710 0001 5586 9882
RETURN RECEIPT REQUESTED
Billy Pirkle
Agrium U S Inc
3105 Glenn Ave
Winston Salem NC 27105
SUBJECT: REQUEST FOR ADDITIONAL INFORMATION REGARDING
Permit Rescission
Royster Clark Incotl)orated
Permit No: NCS000381
Forsyth County
Dear Mr. I -lodge:
In response to your request to rescind Permit. No NCS000381, I need additional information
regarding the inspection that was conducted on December 18, 2007 by Rose Pruitt and Steve
Tedder of the Winston Salem Regional Office. The inspection was conducted at the Royster
Clark/ Agrium facility located at 3105 Gletui Ave, Winston Salem NC, Forsyth County in response
to your request to rescind the current Permit dttc to plant closure. Tile inspectors were met at the
facility by Kerry Cooner, an employee of Agrium Inc. At the time of the inspection some
remaining areas of potential stormwater contamination were noted as follows:
An area between the warehouse and the manufacturing area was observed to be heavily
impacted with spilled product. The Division recommends this contaminated soil be
removed to a depth of approximately I foot along both sides of. the train tracks and
replaced with new soil.
// 1 5*'
�^
�Ra�,&i. A�
Th
NCDENR
585 Waughtown Street Winston-Salem, NC 27107 [phone] Fax [phone]

Royster Clark/Agrium
December 19, 2007
Page 2 of 3
ti�
2. Clynjicai and fuel tanks need verification that their contents have been removed and the
secondary containment area should be cleaned out and remaining spilled fuel renioved
properly. Please seek assistance frorn a professional environmental company in this matter.
3. Remove fluid contents in secondary containment area for ammonia tank as above.
4. Remove all remaining sand piles.
S. The back open shed and storage area should be swept and completely cleaned out. The
carboy containing nitrogen resin should be removed.

Royster Clark/Agrium
•r December 19, 2007
Page 3of3
G. Baas and their contents that were observed near the concrete stonrnwater basin should be
removed along with any spilled contents.
These issues will require your attention before the Division will further consider your request for
rescission of Permit No NCS000381. If you or your staff has any questions, please do not hesitate
to contact Rose Pruitt at 336-771-5000.
Sincerely,
Steve W Tedder
Water Quality Regional Supervisor
Winston-Saleni Region
Division of Water Quality
cc: Kerry Cooner, A�,rlum Inc, 112 Cambridge Plaza Dr Suite 102, WS NC 27104
Keith Huff, City of Winston-Salem Storm Water Division
Bob Ragland, Forsyth County Environmental Affairs
Central Files
Collin Day, WSRO Waste Management
Sherry Knight, WSRO Aquifer Protection
Bradley Bennett, NPDES Stormwater
WSRO
li

Safety kleen letter
Subject: Safety kleen letter
From. "Daren Couture" <DCouture a agrium.com>
Date: Tue, 19 Feb 2008 08:10:58 -0700
To: <rose.pruitt a ncmai1.net>
Hi Rose
It was nice talking to you last week.
As promised, please find attached the Letter (on letterhead) from Safety Kleen
regarding the tank cleaning which took place in the Winston Salem plant.
We are working on the Scope of work for the demolition to include the elements we
discussed last week.
Thanks
Daren J. Couture, C.P.M., CPIM, CIRM
Manager, Asset Recovery
Agrium Inc.
Phone: [phone]
Fax: [phone]
[e-mail]
IMPORTANT NOTICE !
This E-Mail transmission and any accompanying attachments may contain confidential
information intended only for the use of the individual or entity named above. Any
dissemination, distribution, copying or action taken in reliance on the contents of
this F-Mail by anyone other than the intended recipient is strictly prohibited and
is not intended to, in anyway, waive privilege or confidentiality. If you have
received this E-Mail in error please immediately delete it and notify sender at the
above E-Mail address.
Agrium uses state of the art anti -virus technology on all incoming and outgoing
E-Mail. We encourage and promote the use of safe E-Mail management practices and
recommend you check this, and all other E-Mail and attachments you receive for the
presence of viruses. The sender and Agrium accept no liability for any damage caused
by a virus or otherwise by the transmittal of this E-Mail..
Subject: FW: Fax Message (206-350-2709)
From: "Brownlee, Brian" <Brian.Brownlee a safety-klcen.com>
Date: Mon, 18 Feb 2008 08:56:42 -0600
To: "Daren Couture" <DCouture a agrium.com>
Good Morning Mr. Couture!
Here is the signed copy you requested.
Thank you!
Brian Brownlee
-----Original Message -----
From: K7.Net - (336-861-4250) [mailto:[e-mail]
Sent: Friday, February 15, 2008 8:05 PM
To: Brownlee, Brian
Subject: Fax Message (206-350-2709)
1 of2 2/19/2008 10:14 AM

FEB 15 2038 20:35 FIR SAFTY KLEEN 3-364-a136 861 4250 TO 1206353273S P.01
MS
88"0880 0
December 20, 2007
)Brain Brownlee
Safety- Kleen Corporation
Re: Agrium
Winston-Salem, NIC
Shamrock Environmental was pleased in work with Safety —Kleen in the completion of
tank cleaning services at the location above. Shamrock pumped the following tanks on
the Agrium site, two sulfuric acid tanks, two phosphoric acid tanks, two scrubber units,
mud silos, and three coating oil tanks. Shamrock removed all the free flowing material
and sludge with a vacuum truck. Shamrock did not power wash any of the tanks, only
pumped material.
;h,�,k-�� on17
Pete Hall
Industrial Services Operation Manager
1
SAPETY•KLEEN SYSTEMS. INC.
6180 OLD MENDENNALI. ROAD ARCHDALE, NC 27263
** TOTAL PAGE.01 **

rz�i�s-�v� �:� s
0 I
'�;N�^�

about:blank
Raleigh, NC 27699-1617
Phone: [phone] ext. 578
Fax: [phone]
email: aisha.lau@ncata-I net
Website: http://h2o.�nr.state.nc.lis/suistormwater.ht!nl
Never doubt that a small group of thoughtful, committed citizens can
change the world; indeed, it's the only thing that ever has.
Margaret Mead
Rose Pruitt
NCDENR-DWQ Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
--------------------------------------------------------
Bradley Bennett
N.C. Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone] ext. 525
Fax: [phone]
email: bradley.oennectencmail.ne'l
Website: ht tp://h2.o.c_nr.stag-..n .us/su/scormwa .er.html
4 of4 12/7/2007 1:30 PM

1�igrium
Agrium U.S., Inc.
Larry R. Hodge CSP
1 Commerce Street
Florence, Alabama 35630
Office [phone]
Cell [phone]
Facsimile (256) 764- l 199
November 30, 2007
Mr, Bradley Bennett
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617 V �` a
A
RE: Stormwater Permit at Winston-Salem
Agrium U.S., Inc. operated the granular N-P-K fertilizer plant at Wuto - em. Agrium made
the decision back in April of this year to cease production and initiate closure of the facility. All
necessary activities such as relieving inventory, emptying and cleaning tanks etc. were
completed during the summer and fall. The plant was officially closed on November 7, 2007.
The plant operated under the NPDES Permit No. NCS000381.
This permit was issued to the Royster-Clark Corporation on October 1, 2000. The permit
expired September 30, 2005. Royster-Clark applied for renewal six months prior to the
expiration elate. In about August of 2006 Aisha Lau sent Royster-Clark notice that the state was
behind with permitting and that the permit would be forthcoming at some point in the future. On
September 30, 2006 the Agrium U.S., Inc. acquisition of Royster-Clark became final. Agrium
applied to the NC water division for a permit transfer on September 29, 2006. No
correspondence has been received back from the water division as of today.
With closure of the facility Agrium U.S., Inc. is asking that the NPDES Permit No, NCS000381
be rescinded.
Your help in this matter is greatly appreciated. if you have any questions or need more
information please contact me at one of the above numbers.
Sincerely,
Larr . Hodge

wArF9Qc
(711 YIY _lid
June 19, 2006
CERTIFIED MAIL 7003 1680 0004 6392 3383
RETURN RECEIPT REQUESTED
J. Billy PirkIe
Managing Director
Royster-Clark, Inc.
P.O. Box 1986
Collinsville, )L 62234
Michael F. Fasicy, Governor
William G. Ross Jr., Sceretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of water Quality
Subject; Notice of Violation and Requirement to Address Storm water Runoff in Corrective Action Plan, IMC Rainbow
Facility, 3105 Glenn Avenue, Winston-Salem, Forsyth County; GW Incident No. 12284; Ranking E/60
Dear Mr. Pirkle:
This letter is to inform you of two illegal discharges that have occurred in recent months at your Winston-Salem facility. The levels of
nutrients and metals contained in these discharges were of such magnitude that we are requiring you to address the issue of surface
runoff in the groundwater corrective action plan (CAP) that you are required to submit to our office. Please see the enclosed copies of
the analytical reports for the two subject discharges.
On January 27, 2006 personnel from the WSRO Aquifer Protection Section responded to a phone call from Mr. Mike Brenner of
Atlantic Scrap reporting the discharge of a green colored liquid onto the Atlantic Scrap property. Sample results for this discharge are
noted on the attached analytical report labeled "DD-404." This discharge flowed through an intermittent drainage ditch underneath
U.S. Highway 52, but did not reach Bowen Branch. According to Royster-Clark staff, the discharge was a release from the storm
water containment area that was constructed as part of the pond closure plan.
On March 23, 2006 personnel from the WSRO Aquifer Protection Section responded to a phone call from Mr. Bill Perry of Atlantic
Scrap who reported that a large volume of water was flowing onto the Atlantic Scrap property. This discharge, like that from the
January 27 event flowed through the same intermittent drainage ditch underneath U.S. highway 52. Initially the flow was diverted by
Atlantic Scrap personnel, but was eventually allowed to drain into Bowen Branch because the discharge continued for a week.
Analytical results for the March 23 discharge are labeled "SW404." Local staff at the Royster-Clark facility stated that the source of
the discharge was a break in the onsite municipal waterline.
Although the former storm water ponds have been closed at the Royster Clark site, it is clear from the nutrient and metals
concentrations in these recent discharges that serious problems exist with surface runoff. The runoff impacts not only Bowen Branch
directly through channel flow into it, but also the underlying groundwater as well.
Division of Water Quality / Aquifer Protection Section
585 Waughtown Street„Winston-Salem NC 27107
Phone; [phone] Fax: [phone] Imcmcc httpa/www.ncwattiquality.org.
ior`ihnCaroina
AaNnally
Customer Service
1-977-623-6748

Mr, Billy Pirckle
Royster-Claris, Inc.
June 19,2006
Page 2 of 2
You are advised that the discharge of hazardous substances onto the land or into waters of the State is a violation of North Carolina
General Statute (NCGS) 143-215.83(a). This statute requires that anyone in violation"...shall immediately undertake to collect and
remove the discharge and to restore the area affected by the discharge as nearly as may be to the condition prior to the
discharge..." per NCGS 143-215.84(a). This letter serves as the Notice of Violation for the subject site.
You are also advised that the WSRO will not approve any CAP that does not address the issue of surface water runoff at the Royster-
Clark property. Our office sees no value in mitigating groundwater off of the site property when contaminants are allowed to move by
way of overland flow onto adjacent properties to either discharge directly into Bowen Branch or permeate into the subsurface and
recharge shallow groundwater.
Our office received on June 5, 2006 a letter from Mr. Steve Schroeder of RMT regarding the preparation of the CAP for the subject
site. We would like to clarify several issues raised by Mr, Schroeder in order that there be no further misunderstanding as to what is
required for plan preparation. The remaining paragraphs of our letter address these issues.
First, there appears to be some misunderstanding on the part of RMT concerning the issue of the identification of responsible parties
for particular contaminants. The recent soil and groundwater investigations conducted by Atlantic Scrap and the North Carolina
Department of Transportation concluded that there are significant concentrations of lead and arsenic that can be attributed to the past
practices conducted at the former Virginia Carolina Chemical and Carolina Ore facilities. These investigations, however, did not
indicate any elevated concentrations of zinc or phosphorous. Both of these elements are contaminants for which Royster-Clark is
responsible for addressing in the CAP. Previous groundwater sampling events have demonstrated that zinc and phosphorous are
contaminants of concern that have sources attributable to the Royster Clark site. In the case of zinc, it has been demonstrated through
repeated samples collected by WSRO personnel that the metal is persistent in toxic concentrations as far as one mile downstream from
the Royster-Clark Winston-Salem facility. Consequently, we consider zinc along with ammonia to be two of the most serious
problem contaminants within the Bowen Branch watershed.
Based upon stream and spring sampling conducted over the past two years by our office, we are assigning another contaminant to the
Royster-Clark facility, for which corrective action must be addressed. Fluoride has been detected in spring samples at concentrations
up to 6.27 milligrams per liter (mg/L), which is well above the state 2B surface water standard of 0.17 mg/L as well as being above the
state 2L groundwater standard of 2 mg/L.
Our office does not have the exact location for the benchmark elevation used for the water level reference in the Atlantic Scrap
investigation. Earth Tech performed the groundwater assessment that was conducted on the Atlantic Scrap property. All of the
locations of the piezometers and wells, including the benchmark, were surveyed by Earth Tech field personnel and should be readily
available. To obtain the location of the benchmark in question, we request that you contact Mr. Rob Holland at the following address:
Earth Tech
701 Corporate Center Drive
Suite 475
Raleigh, NC 27607
919-854-6241
The piezometers that were installed closest to Bowen Branch were removed following the end of the fieldwork associated with the
Atlantic Scrap investigation. Our office had required the installation of these piezometers as part of the notice of violation and
requirement to conduct groundwater assessment letter sent to Atlantic Scrap on August 2, 2005. The piezometers were installed in a
very localized area and were used to examine the effect of the small onsite wetlands on the geochemistry and hydrology of the nearby
springs that flow into Bowen Branch. Consequently, these piezometers were not designed as permanent monitoring points to monitor
groundwater discharge within the portion of the watershed being impacted by contaminants from Royster-Clark. There is a serious

Mr. hilly Pircklc
Royster-Clark, Inc,
June19,2006
Page 3 of
need to install a series of permanent nested piezometers along the groundwater discharge boundary at Bowen Branch in order to
understand the physical hydrology within the area. Along with these piezometers, there is also the need to define the horizontal extent
of the groundwater contamination on the Atlantic Scrap property. To this end additional monitoring wells, besides well TW-5 will
need to be installed. It is the responsibility of Royster-Clark to perform the assessment necessary for installation of these additional
piezometers and monitoring wells on the Atlantic Scrap property. Consequently, the corrective action plan submitted to the WSRO
must have provisions for this additional assessment. A CAP must be submitted to the WSRO within 120 days of your receipt of our
letter.
Failure to submit the required report or failure to expeditiously eliminate the contaminant source in the affected area may result in the
recommendation of enforcement action including: (1) the issuance of a special order against you under the authority G.S. 143-215.2;
(2) a request to the Attomey General to institute an action for injunctive relief; and (3) a civil penalty of up to $10,000 per day in
accordance with G.S. 143-215.6.
Personnel from our office will be available to discuss the various issues regarding the corrective action plan after a mutually
acceptable time for the discussion can be established. Please contact Collin Day to schedule a time and date for the teleconference or
if you have questions regarding the above matters.
Sincerely yours,
Sherri Knight
Regional Supervisor
cc: Lisa Clark, RMT
P.O. Box 16778
Greenville, SC 29606-6778
Rose Pruitt, DWQ-WSRO
WSRO Files

COUNTY :
FORSITH
QUAD NO:
REPORT TO :
WSRO
Regional Otl-rc
COLI.ECTOR(S)
: C DAY
DATE:
=31200f
TIME:
PURPOSE:
"M-AU Imo.
Owner:
Location or Site:
De..iprion of —plreg ponu
Sampling Medsod
Remarks:
LABORATORY ANALYSIS
BOP 310
COD High 340 m
COD law 335 m
Coliform.MFFecal31616 /loom]
Cold : MFToW 31504 1100m1
TOC
Turbidity STU
Residue., suw4nded 530 mgrt.
Taw Su solids
P" ru:iss
Alkslini to pH 4.5 mg/L
Alkalinity to pH 8.3
Cerbonue
Hicmbonate m"
Carbwt diezide m -
Chko Kk
Chromium: Hea t037
Color True 80
L\jaeide -1 mg/L
COMMENTS:
DIVISION OF WATER QUALITY
Chemistry Laboralory Repen f Grsesd W'attr Qasl3ty
AMPk.E PR &UA
PROMNE I]EMERGL4CY
Ej CHAR OF CUSTODY
E-]404
W❑ SAMPLETYPE
ATI.ANF]C SCRAP SW4M
Lkn Solids 70300
m
Fuaide 951
Hardness, mta1900
mgA.
Hardness- coon-carb 902
m
Phenols 32730
U
5 'fre Coed 95
aer hos/cm2
Sulfate
MO -
Sulfide 745
m
MBAS
MVL
O'd and Crease
m
Silica
Boron
Formaldehyde
mP/t-
X
NH3 -N 610
3100 J3
X
T -N m N 625
3000 J3
rn.
X
NO2 +NO3 as n 630
160
u
X
P: Total n P 665-
2100
R.
PO4
mpA,
Nirrrte (NO, � N) 620
m$/L
Nitri:e(N%w Aj6k5
mI I.
A •Silver 46W
u
AFAhw ixmm 46557
X
ArAr is 4655 3
170 J2 ug/h
Ba,Bmium 46558
UWL
Ca Cdcirm 46552
m
X
Cd-Cadmium 46559
3.2 u PL
X
jCr1Momi.m46560
89 ag/L
X
Cu- CpM 1042
150
X
Fe- lrM 1045
890 UgA.
- Mervuly 71900
ug.R.
K-Poo ssiurh 46555
M • M sium 927
mg/
X
Ma-M 1055
640 u
Na- Sodium 929
pwx
X
Ni-Nickel
49 u 4.
X
P64—d 465CA
10U uwL
X
Se-Seknium
21
X
Zri-Zi c 46567
310 ugA.
l.ab Ntmrber AB02403
Darc Rux od 31247M6
Trine Rsoeived : 9.00 AM
Rcocivad By DS
Relemed By ; SMM
Date reported: 4126.QMM
Orgarochlm ine Pcsiicides
Otis—unhosaharus Pesticides
Arad
Gasoline
Atso7403 CW406 ama Surpk t. M—h 06 El—W Me.6 sd N, Wft

DIVISION OF WATER QUALITY
Chemistry L.bor.tory Report! Ground Water O.Wity
COUNTY :
FORSYT13
SAMPLE PR(ORITY
QUAD NO:
E]ROUTL E �fMERGtNCY
REPORT TO :
WSRO
Regional Offm
CRMNOFCUSfODY
COLLE(.'fOR(S)
: C DAY
DD,4
DATE:
(A7R006
W❑ SAMP3.F. TYPF.
TIME:
�—
PURPOSE:
M!MLAHl r
Ownee.
ATLANTIC SCRAP h'CDOT RIGHT OF WAY
( anon n Site;
Derliptitm of sampling pcin
Sampling Medmd:
Ra ria
LABORATORY ANALYSIS
BOD 310 -aA-
MD Mgh 340
COD Low 335 m -
Colifomr. MF Fecal 31616 1100ml
Cdifarm MF Tou131504 ll DOmI
7OC
T.d.6 NTU
Residue., SuspeMed 530
Total Suspem6cd so[.&
H un is
Alkalinny to pli 4.5
Alkalinity !n H 8.3
Cerbormte MVL
Birarbonetc m
Carbon dimidc M94-
x
Chloride 10
Clnamium- Hex 1032 u
Color. True 80 c.u.
C}anide 72D mg/L
CO."F—N" JS
Dins. Solid: 703DD
MgA.
Fluoride 951
Hudam tmel 900
m
Hxdaess (non-cmb)9ff2
MgL
Phmofs 32730
UVL
Specific Cond. 95
urrd>osl m2
SulfAc
ME/L
Sulfide 745
m
MBAS
m
Dil end Grew
m
Silica
m
8aon
Formakleh de
mg/L
X
NH3 .s % 6l0
14
X
TKN m N 625
61
m
X
NO2 *NO3 m n 630
6.13
m
X
P: Total u P 661
4.8
m
PO4
m
Nio-ar NO, as N)620
mg/L
Nat. (NO, m \T) 615
MVL
A Silva 46566 u
AI -Aluminum 46557 u -
As-Arseaie 46SS
Da-Daium 46558 USA.
Ca- al6urn 46552
Cd-Cadmium 46559
Cr{'hrvmirmt 465W WWL
C.- Cbpw 1042
Fe- Iran 1045 u
Hg- M 719W u
K-Pot.ssium 46555
M&- Magnesium 927 mWL
Mn-. 1055 u
Na Sodirnn 919
Ni-Nickel UFA
Pb-Lead 46564
Se-Scicnium ugfL
71r-7-inc 46567
L.rb-Jumba AB00999
butFt".cd : 2f3R006
Ti— Reorxved 8:30 AM
Recaved By : DS
Relented By : JSW
Dame rcportcd : 2/2412006
Acid R betides
Pesticides
PB00049 Lb R.,.ft Ar G— DdWg.!nary 30. 20M

Stream Pesticide and Herbicide Data Collected and Reported to Date
m
a
c 5
i ao
o
1%
Confirmed Specific Chlorinated Pesticides a
Unidentified
Peaks
Chlorinated
Pesticides
Unidentified
Peaks Acid
Herbicides
Unidentified
Peaks
Nitrogen
Pesticides
Unidentified
Peaks Organo
Phosphate
Pesticides
Bromacll
(uglL)
Additional
Semi•VOC
NC Dept of
Ag
Sediment
Data
DCPA
Dieldrin
n nn
Ketone
Heptachlor
Fresh water
CCC (ug1L)
0,002
0,002
0.004
Human
Health
jorganism
only)(ug1L)
0.000144
0,000214
V
SW407
1/25/2005
not sam led
SW402
1/25/2005
ND
0.169
0.12
ND
7
>10
1
1
4
ND
ND
SW503
1125/2005
0.022
0.031
0.05
0,071
>10
>10
1
0
n
SW-605
5/3/2005
ND
ND
ND
ND
>10
>10
1
0
ND
ND
ND
SW-610
5/3/2005
N❑
ND
ND
ND
5
>10
1
0
ND
ND IND
SW-615
5/3/2005
ND
ND
ND
ND
3
>10
1
0
ND
ND
ND
SW-620
5/3/2005
ND
ND
ND
ND
3
7
1
0
ND
ND
ND

Y
a
0
U
O
P
E
z
2
2 E
N
0 9
a 3
E
2
w
N
a
E
c
M W -01
12r2811994
125
0.63
<0.1
17
32
0.13
MW-01
1/1011995
26
0,37
<0.1
t9
40
0.13
MW-01
1131/1995
<0,006 S
24
0.33
<OAD
0.31
34
0.12
MW-01
6/2011995
<0.006 M
65
0.44
1300
MW-01
1117/1996
<0.003
69
0.57
1400
MW-01
1012512001
<0.01
0.3
28
<0.50
0.2
MW-0SA
- 612011995......
_.
<0,015M,
_ _ 1
91 ^
c0.10 _
2100. _
-
MW-01A
_.._1H711996
_
<0.015.M
_
.87
<0.10. _.
1900
_
02 MW-
17J2811994
200
16
<0.1
300
<10
1.5
MW-02
111011995
220
15
140
300
<10
1.3
MW-02
1/31/1995
<0.006 S
200
16
0.12
0.31
19
1A
MW-02
6/20/1995
<0.10
<0.10
<10
MW-02
1/1611996
<0.003
<0.10
<0.10
<10
MW-02
1012512001
0.67 1
15 1
170
<0.50
111
MW-03 . w
. - 12/2811994
-
_ -
840 N. _
8.3 ..j _ 1460.
36 1..
_ .,
2200 12.4
_
MW-03._..
.. - 1/10/1995.
_ '_.
-. _..
__- _.
830
6.2_.__
260 .37.
......
2200
1.5
MW-03 _
. 1/31/1995
... - _
_" _
0.021 S-
420... _.:
7.4 _ _
140 ._..
,.....
35- _ ...
1DDO
6,1.-_... ..
MW-03 -
- 612011995
. _.. . _
_ ..
<O,008 M
__ _.
_
5.2 . _
�.
0.10
Be ...
MW-03 _
__ ..111611996
_ _ ..
_ ., __
<0.003 . _
_ -
_.._.
6.0
_
<0.10 _-,,
97 .
MW-04
12128/1994
1600
3.8
520
50
3900
1.3
MW-04
ltI011995
710
6.1
280
110
2000
4
MW-04
113111995
<0.06 S
940
7.2
330
220
19W
3.5
MW-04
6/16119951
0,056
130
19
3500
MW-04
1/17/1996
<0.015 M
97
13
2800
MW-04A
12J28/1994
_
__ .- _
13000: .-
101) --,.
220
670
_
1BODO
0.15 _
MW-04A
1/1011995
.. ...._
...
_
570D... __
62 _ _
1200
420 _-
16000 _:.
0.17.
MW-04A-.
_1131/1905
<0.06S :
5600 _
49._ __
1600 _
120-
16000
0.089 _
MW-04A.
_ ._.1012412001
.:
0,093_._.
46 ' __._
92
120-.
0.013E -_
MW-04B
1131M995
0,013 S
10000
23
530
<0.10
3800
24
MW-04B
10/24/2001
1
<0.01 1
46 1
330
<0,50
160
MW-05..
._ -_ 12/28/1994
1780
_ .. :
11. 156
100 .._
._
780
1.5
MW-05..
.111011995
.__ ___
1100 ..
16 P
84 _.. _
110 .
_ _
.. ._ _
2A
MW-05
.2/1/1995
-
0.083 S.
680
9.7__ __
86
73 _
820
1.5
MW-05 ..-_
_.. _ 6/16/1995
-_ _2
<0.015 M-
_ _ .
21
O.I5
29DO
_ _
MW-05------
1/18/1996
_, _.. --
-_-__...
<0.03 M
_ _ _ .
_ _
18.. _
--
<0.10
2800 .
MW-05
10/2512001
.__ .,__ - ..
_ _. .
0.16 _ _ :
_ . _
56 - .
_
300_
61 _. .
13 _ _ ,
MW-OSA
6116/1995
<0.003
1.8
<0,10
550
MW-05A
1/18f1996
<0.003
1.3
<0.10
520
MW-06.
12f2811994
._ _.. _. _.
r
, . -. _ _._
92 _ _ _
fi.1
5.4._ _-
38,:,_
_.
30 ._.. _
0.17
MW-06 -
1/10/1995
_
94.. ._ .
2.9_ ..._ _
1.1
39 _ _
- _
930
0.19 --
MW-06-
211I1995
.____ _.
<0.006S-
01 --- -
.1.7__.
0.46_�-
_
1.1 ,
37__ _
0.16 _
MW-06. :
6l20I1995.
<O.ODGM
_-
_- ..0.64,
<0.10.
<10.,
_.: ._._...,
MW-08 _
1l1fil1996
_ _ ..
<0.003,
3.7.
<0.10- �_
54
MW-06
_-10/25l2001
_
<0.01
1.1...
39 - _
0.62_ ._
0.33
MW-06
2/1/1995
- _ _ _
.
_-.-_
92
__ _
0.13, _
1,4 _..-.._.
35_--___
MW-07
12/28I1994
12000
15
670
110
5400
1.5
MW-07
111011995
14000
16
1300
110
54DO
1.7
MW-07
2/1/1995
<0.03 S
13000
16
780
0.75
5600
1.6
MW-07
611611995
<0.003
31
0.15
2100
O
n
W
F
O
E
Q
a
9
o
U
o
A
m
E
m
o
E
C
a
g
_
Z
a
'c
a
L
C
a
gCL
z
m
O
r
O...
a
N
p
u
MW-07
1/17/1996
<0,015 M
28
<0.10
2400
MW-08.
'_ 12/28/1994
'.
_._
.. _
100 _ __
0.67- .__.
<0.1 _
31 _ _
__
<10:r
0.58_
MW-08 -
_ 1/10/1995
__ __
-._
99-
0.54 __
0.15 __
3D
<10 _
0.56.. .
MW-08.-
2/1/1995
.. -
<O.D06 S
99_
0.63.. _
0.12
__ ...
2.6
<10...
0.52 ..
MW-08 .
_ -. 10/25/2001
_ _ _ . -
:-- -
<O.01 . _ .
_
0.92 _- , ..
- - r .
22 _ ._
1.5
MW-09
2/1/1995
0,013 S
47
14
230
0.17
1400
6,9
MW-09
10/25/2001
0,12
4
160
0.79
1.6
MW-10
1/31/1995
<0.006 S
230
13
81
0.40
840
2.2
MW-10
10/25/2001
<0.01
36
130
<0.50
5.8
MW-10A
113111995
_
<O.W6 S.
10- _ .
0:72
<0.10
<0.10
<10 _. -
0.054
MW-10A
.. _ IO12S/2001
<0.01 __
_
0.27 ._._
-_ - -
370
0,59.._
-
0.046
VW-10A
- 10/2512001
<0.01 _
D,24, -
16 J ..
<0.50_ _•
0.039 .. _
MW-11
2/111995
0.0084 S
970
170
950
0.34
12000
16
MW-it
10f2512001
0.67
39
370
1.2
1
112
MW-1IA.
_.2 l/l995
_ _ _
_ _
<0.018 S
480 .
125 s.
780 . _
,.-_ ...
1.2, _
8200- __
7.5 _
MW-1IA.
_1012512001
.: - _
_..
0.13 _
21
_ _
100 .
2,8... _
3.6
MW-12
2/111995
<O.0065
40
2.3
0.10
0.17
<10
0.094
MW-12
10/25/2001
0.022
1
11.2
4.8
<0.50
0.17

w^ -n^ T
6, o m o m
c Monitoring
u
o
0
DATE
Z
K
pH
Z
Specific
Conductance
(uMHOS)
rn
Arsenic, total
(u g)L)
a
v
Chloride
(mg1L)
0
in
Manganese,
total (mg1L)
ca
N
NH3 (mgJL)
N
�
NO3+NO2as
N (mglL)
o
Phosphorus,
total (mg1L)
(h
w
Sulfate
(mg7L)
a
v,
Zinc, total
a
w
rn
Lead (mWL)
o
Copper
m
(mglL)
w
Aluminum
{mgfL)
m
Magnesium
{mgfL)

Bowen Branch Sediment Sample Results Accopanied by Most Recent Surface Water Saml
OI
16
0
_J
J
CD
0
y Y
C
w
u
E
_
c
0
£
y OI
c E
°i-
f
c
aciY
°
cc
M
a°
Q
E
ci
c°s
E
IMC-004-SD
(SW402)
12/14/2004
4
268
8
79
29107
224
323
IMC-003-SD (SW
501)
12/14/2005
10
42
10
1622
59363
193
733
IMC-002-SD SW-
5031SW-407
12/14/2004
24
622
24
539
81412
229
507
IMC-001-SD (SW
610
12/14/2004
12
30
8
24
25694
56
260

a
E
_
E 4 E
=
a Su
"Water
c
_f
_o_
• c
c
c
n
z.EE
N J ci o �z
i
_
SW407
12l6726OO
I�6
No
Sam ling
Data Corrected
2 iO4l2001
6.531 80 NM 0.13 0.07 025 a.04
119120041
No Sampling
Data Colleced
I 112WO05
2112005
I No Sam Sing
6.08 14D 14 0.60 1 NM NM NM 1 19
Data Collected _
� - -
0,07 O.DOb�<0.005 <O.t151 3,9 ko.DDs 21 NM NM
SW402
121W000
No Sampling
Data Collected
10242001
1 513112D0216.03
6.57 110 NM 0.25 0.06 0.94 0.02 NM
121 NM NM �0.1b5 0,69 0,267
1�O��
��06
1V.NM
0.440 D,C9 1 12 002 NM
1I
1125/2005
6.46 114 14 asa NM NM NM 19
a,07 cD,005a<0_Do5 <D.05 3.9 <O.W5 11 _
SW5D2
1=(O T000
62 NM NM C.39 0,08 1.9 0.01
lOr24/200i
6.331 130 NM o.25D 1 007 1 1.5 0.02 NM
10.076
MMOD4
5r312OD2
5.9 f_ 172 23 1 0.42 1 0.57 1.0 0.10 12
5.641 775 I NM NM 0.173 2.38 0103 NM
1 1) 14
4_t67
No Samples
C011ettad
SW501
5.07
NM
NM 1 2.70
29
12
0.02
NM 0.99
r_I
I121062000
1W412001
489
140a
NM 1.80
22
8.3
0.02
NM D76
5f3120a2
62312004
4.45 2190 NM NM
4.8 1962 $50 _ 11
26.6 12.04 0.180 NM 10.834
61 14 0.10 230 I �.2
i
I
111092004
5.08 1800 5D4 2.99
60 11 O.t74 NM S.OB
0.020
0.026
a0.05
4i.4
NM
NM
NM
I
1252005
NoSamples
Collected
---�
12200
M
67
17
002MSW503
7.7
1DI42041
.5D5
2700
1 NM 400
65
I 14
0.03
N�M
1�50
5r312002
_5.30
4.5
32701
NM I NM
69.4
16.6
0.375
NM
11.11
1
-�
rNM
6232004
4�11
2862
900 5.0
100
20
0.10
396
20
_
_
11/09/2004
5.2
2800
12371 4.32
49
16
0.16
NM
1.38
0.018
0.030
<D.05
62.9
NM
NM
125EOO5
5.fi1
2460
2/112005
5.27
2400
�1
_
_
4 6
ND
-I
SW406
12/082000
No Sampling Oata
NM 11000 NM 4.90 620
Collected
10f2412007
B,6
0,02
NM
6.40
11
5/312002
4.56
84DD
NM
NM
455
63
1.12
NM
4,49
_
6/2312004
4.0
3392
490
8 6
25D
64
<0.10
1000
4.3
111090004
5.2
27DO
484
1 4.71
140
1 46 1
0,05
NM
2.30
0.11
0-016
0.13
36
0.048
NM
NM
1g512005
-
�
3.2
X
SW61D
2/11'2006
6_61
690
136
0.98
NM
NM
NM
106
0.40
<0.005<0.00&
<0.05
13.1
0.006
4.6
2l8f2005
NM
700
NM
I 0.94D
15
5.9
0
NM
0.3
NM
NM
NM
NM
NM
7R
SW-615
378r2005
1 5,64
179
21
0.21
2,7
2.8
0,34
23
1 0.15
1 0.0061<O.005'
<0.05
3.9
<0.01
2.0
051
SW-620
3f82005
7.00
122
12
0.15
1.2
1.6
0,25
13
0,09
O.[NJB
<0.005,
<0.05
2.9
<0.01
N❑
NM
Spying
Tributaries
t0
Sampling
Point
SW-503
=
=
E
ir
E
E
.o
c-
0
v
E
i
E
E
E
E
E
-
-
i
c
_
SW555
1�7tlan
8�37
16M
NM I
NM
4,6
0.45
aD15 �
0.830
15
0,15
NM
NM
NM
0,640
L.
I NM
NM
.0�4 _I1
111221 004
1 842 1
245a
564
1 200
I
3.6
14
6.23
7,0
628
NM
1.45
I NM
0.086 <0.005 a.19
NM NM NM
115.2-1
NM
NM
NM
ND
N❑
ND
ND
I
2r2212D05
1�8.5-1
I
3200
N M
NM
200
I�
-
SW556 1
1179r2D04
1 7,29
120DC
NM
1 6.4
I NM
NM
NM
NM
2.6
10.0100,0096O,C171
44
NM
�V002
73
177500
2125
14.38
530
30
0
426
3 .10
0.M05
NM
0.39
28
I
M212
1000
1000N
NM
M
550
35.
35
NM
NM NM
M
NM
0.52
6.7
0 V
�V
Page 1

Table
' f
PARAME'CER(}
--NC
GWQS(21
^LOCATION/SAMPLEDA IT
hiSh` 0i
��444 _. ; " I-o�1.:a 1�1t�11995. i/37�1995 - lE1}l25/2001
Metals
Arsenic, dissolved
0.05
NA
NA
NA
NA
NA
Arsenic, total
0.05
NA
NA
NA
<0.006 S
<0.01
Cadmium, dissolved
0.005
NA
NA
NA
NA
NA
Cadmium, total
0.005
<0.005
<0.005
<0.0006 M
0.0012
<0.0011 A u(0.76
Manganese, dissolved
0.05
NA
NA
NA
NA
NA
Manganese, total
0.05
16A
a' u0.63 A
037 -;..
_; 0:33 -;
. _,_ _0.3 a: W
Zinc, dissolved
2.1
NA
NA
NA
NA
NA
Zinc, total
2.1
0.13
0.13
0.13
0.12
0.2
Wet Chemistry
Chloride
250
26
25
26
24
NA
Nitrogen, ammonia
-
0.27
<0.1
<0.1
<0.10
NA
Nitrogen nitrate
10
NA
I":'=c;
NA
s714:�:F
NA
Nitrogen, nitrate nitrite
10
19
NA
28
Phosphorus, total
0.56
0.12 P
0.55
0.31
<0.50
Sulfate
250
35
32
40
34
1 NA
Field indicator
pH (s.u.) 6.5-8.5 6.5 6.6
Analytical results are reported in milligrams per liter (mg/L) unless otherwise noted.
c� North Carolina Ground Water Quality Standards
< - Concentration less than the Quantitation Limit or not validated if accompanied by "u" qualifier.
- Duplicated analysis not within control limits.
NA - Not analyzed.
A - Analvte detected in method blank.
B (inorganic) -The analyte has been detected between the method detection limit and the reporting hinit.
DA - Dissolved analyte greater than total analyte; analyses passed QC based on precision criteria.
DF - Dissolved analyte greater than total analyte; analyses failed QC based on precision criteria.
j Concentration considered an estimate based on data validation.
j - Estimated concentration.
M - Elevated detection Limit due to matrix effects.
N - Spiked sample recovers not within control Limits.
P - Digested spike recovery fails accuracy criteria; post -digestion spike recovery accepted.
S - Value u•as determined by the Method of Standard Additions (MSA).
u - Laboratory reported detection not validated during data validation process.
Shading indicates values exceeding NC GWQS.
RM1, Inc. \ Royster Clark, lNrnston Salenr, NC
P:txyelrol70277tninit2ao3t,kf;VH tsum-tls
WORKING COPY
March 2003

Table
u'
- PARAiNETERnI
n'
r; NC.e
-AGWQs�'' `
LOCATION/SAMPLEDATE -
_ _ w M[N 02� -
47:2124f1994 - =142811994 � 1/10/1995 1f31/1995-,-14125/2001
Metals
Arsenic, dissolved
US
NA
NA
NA
NA
NA
Arsenic, total
0.05
NA
NA
NA
<0.006 S
0.67: ;.°a-
Cadmium, dissolved
0.005
NA
NA
NA
NA
NA
Cadmium, total
0.005
0.012-f!
_0.01'1;:. -
0.011..:.,
0.0096 `
0.011 A~ 0.76
Manganese, dissolved
0.05
NA
NA
NA
NA
NA
Manganese, total
0.05
; 25 �.
16 - - -
15
g_ . • ;,
16
15
Zinc, dissolved
2.1
NA
NA
NA
NA
NA
Zinc, total
2.1
0,86
1.5
1.3
1.4
1.1
Wet Chemistry
Chloride
250
240
200
220
200
NA
Nitrogen, ammonia
--
3.8
<0.1
140
0.12
NA
Nitrogen, nitrate
10
NA
300'-��,
NA
200 _ �.
NA
Nitrogen, nitrate + nitrite
10
-410 -
= 300_
`300 _
NA
"170'
Phosphorus, total
--
0,13
0.25
0.35
0.31
<0.50
Sulfate
250
<10
<10
<10
19
NA
Field Indicator
pH (s.u.) 6.5-8.5 - .51• = ''_4.7F 3.7. 4:1 , •;
Analytical results are reported in milligrams per liter (mg/ L) unless otherwise noted.
t'f North Carolina Ground Water Quality Standards
< - Concentration less than the Quantitation Limit or not validated if accompanded by "u" qualifier.
• - Duplicated analysis not within control limits.
NA - Not analyzed.
A - Analvte detected in method blank.
B (inorganic) - The analyte has been detected between the method detection limit and the reporting limit.
DA - Dissolved analyte greater than total analyte; analyses passed QC based on precision criteria.
DF - Dissolved analyte greater than total analyte; analyses failed QC based on precision criteria.
j - Concentration considered an estimate based on data validation.
1- l;stimated concentration,
M - Elevated detection limit due to matrix effects.
N - Spiked sample recovery not within control limits.
P - Digested spike recovery fails accuracy criteria; post -digestion spike recovery accepted.
S - Value was determined by the Method of Standard Additions (MSA).
u - Laboratory reported detection not validated during data vabdation process.
Shading indicates values exceeding NC GWQS.
RMT, inc. � Royster Clark, Winston Salem, NC
P:4++y�"1 zovrtExart4zoo3t,LnvHisesumiLs
WORKING COPY
March 2003

Table
WORKING COPY
x
PAAAMETFR - �_
VC r
GWOS
LOCATTON/SAMPLEDAT"E
77
x MW-03 ry
t
MW-04
994 <1 994,' 995-. 995
994'-.3 994 995 995
Metals
Arsenic, dissolved
0.05
NA
NA
NA
NA
NA
NA
NA
NA
Arsenic, total
0.05
NA
NA
NA
0.021 S
NA
NA
NA
<0.06 S
Cadmium, dissolved
0.005
NA
NA
NA
NA
NA
NA
NA
NA
Cadmium, total
0.005
! 0:015 -
':0.044;'
r.,„fl.0068-"0.016`='
<O.0115N°0.011
. '
_ �r0.01$
0.016�"'
Manganese, dissolved
0.05
NA
NA
NA
NA
NA
NA
NA
NA
Manganese, total
0.05
= _' ,12 P_..
=; .8 3:
z 6:2
7 4'.
0.43 u ` -
W 3.8;
- 6.1 '..:
=: - 7.2
Zinc, dissolved
2.1
NA
NA
NA
NA
NA
NA
NA
NA
Zinc, total
2.1
::i:4.2
..2 4 .,.w'
1.5.T
61' m
0.12
3.3
4 ;-
3 5
Wet Chemistry
Chloride
250
230
.
6Q1
_
710:
-;-940-n-;ry
Nitro en, ammonia
--
140
460
260
140
530
520
280
330
Nitrogen, nitrate
10
NA
,� 36 3_s'?
NA
P_:53:6
NA
: 50 =
NA
:.565�
Nitrogen nitratef nitrite
10
=;"-180
36 _;"„
37
NA
` ;30+'W-
_ »50 _..
130_.< .:'
NA
Phosphorus, total
--
80
52
110
35
460
430
230
220
Sulfate
250
^a: 1600 .
:~22()D.n x
; `; w 2200 „ ;
_ ° :1000;
36iTd , `:.
~'r 3900 ..
.Y i = 2000`_
_ 1900 ".
`.'
Field Indicator
pH {s.u.) 6.5 8.5 6T 3 9 `': ` •_ °,4:6 3.9:. _ -'•
S0 Analvtical results are reported in milligrams per liter (mg/L) unless otherwise noted.
tat North Carolina Ground Water Quality Standards
< - Concentration less than the Quantitation Limit or not validated if accompanied by "u' qualifier.
' - Duplicated analysis not within control limits.
NA - Not analyzed.
A - Analyte detected in method blank.
5 (inorganic) -The anah-te has been detected between the method detection limit and the reporting limit.
DA - Dissolved anaiyie greater than total analyte; analyses passed QC based on precision criteria.
DF - Dissolved analyte greater than total analyte; analyses failed QC based on precision criteria.
j - Concentration considered an estimate based on data validation.
j - Estimated concentration.
M - Elevated detection limit due to matrix effects.
N - Spiked sample recovery not within control limits.
P - Digested spike recovery fails accuracy criteria; post -digestion spike recovery accepted.
S - Value was determined by the Method of Standard Additions (MS A)_
u - Laboratory reported detection not validated during data validation process.
Shading indicates values exceeding NC G WQS.
RMT, lite. Royster Clark, 6Vinsfnn 5alenr, NC
P:Utyaral702nyFacelt20031XSViWS�� i, March2003

Table
WORKING COPY
:
is FARAMMR.
'
4C
GWQ3 }
M F.RCATIOAf%SAMPLEDAT'E
e i,
_ MW=04A .
i
14iW-04B M
12/7 1994 .. 995 995 '. 1 0pi.-
-.1/31/199� V "1 001.
Metals
Arsenic, dissolved
0.05
NA
NA
<0.06 S
NA
<0.006 N1
NA
Arsenic, total
0.05
NA
NA
<0.06 S
; ` 0'.093 _."
' . 0.013 S''-
<0.01
Cadmium, dissolved
0.005
NA
NA
'r0.035;DA-.,
NA
0.44 _-
NA
Cadmium, total
0,005
0.055
0.032 a
.0.013°A. Q.76
=:044'
0.36
Manganese, dissolved
0.05
NA
NA
=:-59 DA' ..
NA
25 DA-'-;:
NA
Manganese, total
0,05
-`100
- 62
49, -
:46
:23
' ` _ 48 _ -_-
Zinc, dissolved
2.1
NA
NA
0.11 DF
NA
=.25 DA,
NA
Zinc, total
2.1
0.15
0.17
U.089
0.013 i3
24'. ":
—60__: `
Wet Chemistry
Chloride
250
`13QQO;w
-57Q0 t
NA
.1Q000 M-3,
NA
Nitrogen, ammonia
--
220
1200
NA
530
NA
Nitrogen, nitrate
10
670 , ;;-
NA
NA
90 2
NA
Nitrogen, nitrate +nitrite
10
670 :
_ 420
4`1��A2�0
-. 92
NAPhosphorus,
total
--
110
110
120
<0.10
<0.50
Sulfate
250
W16000 — ,
-16000w
NA
'3800_"
NA
Field Indicator
pH (s.u.) 6.5-8.5 ' 5 2 '6.1'S.3 ., 6 2 3
P1 Analytical results are reported in milligrams per liter (mg/L) unless otherwise noted.
ai North Carolina Ground Water Quality Standards
< - Concentration less than the Quantitation Limit or not validated if accompanied by "u" qualifier.
- Duplicated analysis not within control limits.
NA - Not analyzed.
A - Analvte detected in method blank.
B (inorganic) - the analyte has been detected betwLvn the method detection limit and the reporting limit.
DA - Dissolved analyte greater than total analyte; analyses passed QC based on precision criteria.
DF - Dissolved analyte greater than total analyte; analyses failed QC based an precision criteria.
j - Concentration considered an estimate based on data validation.
) - Estimated concentration.
M - Elevated detection limit due to matrix effects.
N - Spiked sample recovery not within control limits.
P - Digested spike recovery fails accuracv criteria; post -digestion spike recovery accepted.
S - Value was determined by the Method of Standard Additions (MSA).
u - Laboratory reported detection not validated during data validation process.
Shading indicates values exceeding NC GWQS.
RMT, Inc. 5 Royster Clark, Winston Salem, NC
P: LH�Iral%m_;�l ��1 �ao.3ti.ut,+ri�t�m�r�
A -larch 2003

Table
WORKING COPY
'PARAMETFAnt
NC
GWQS t
L0CATION/SAl13PLEDATE
a
MIh' Os -. -
KPs
MW 05
9% 0/.995. i 2/1/1995-`.10/2S/20M
_.
I2t2O994 gt1995 2jI/I995- 2/Ifi995 `. 1(125/2001
Metals
Arsenic, dissolved
0.05
NA
NA
NA
NA
NA
NA
NtA
NA
NA
Arsenic, total
0.05
NA
NA
'r_0.083 S'-'
', -. 0.16 - -
NA
NA
<0.006 S
NA
<0.01
Cadmium, dissolved
0.005
NA
NA
NA
NA
NA
NA
NA
NA
NA
Cadmium, total
0.005
<0.005
0.0028
0.004
a 0.027 Tel
<0.005
Q.DiB.e::.:
0.00099
NA
<0.0017 Au 0.76)
Manganese, dissolved
0.05
NA
NA
NA
NA
NA
NA
NA
NA
NA
Manganese, total
0.05
n 11 =
16 I?'
9.7„ :-_
-_ '56° -
6 1
2:9-._
1 7
NA
•1 1
Zinc, dissolved
2.1
NA
NA
NA
NA
NA
NA
NA
NA
NA
Zinc, total
2.1
1.5
' _ - 2.4'-
1.5
; .13. r '=
0.17
0.19
0.16
NA
0.33
Wet Chemistry
Chloride
250
.780�.:;1100
6$fl--
NA
92
94
91
92
NA
Nitrogen, ammonia
--
56
84
86
NA
1.4
11
0.46
0.13
NA
Nitro en nitrate
10
�_ i0fl =a
NA
;'89:6
NA
n�� 36 ,
NA
33 9 ;
-" =279
NA
Nitrogen, nitrate + nitrite
10
100 �
? ;110
NA
;r L 390 - ,
, m 36_ :`
; 539
NA
NA
39..
Phosphorus, total
--
44
79
73
61
0.62
1
1.1
1.4
0.62
Sulfate
250
820 ",L
NA
30
35
37
35
NA
Field Indicator
pH {s.u.} 6.5-85 .W,4 8y b�"� 9
an4.6 . 44=,-.-.. 48 ,_ _- .5:2_ 48 '� _.
_
_ .�� 49w.
n) Analytical results are reported in milligrams per liter (mg/ L) unless otherwise noted.
as North Carolina Ground Water Quality Standards
< - Concentration less than the Quantization Limit or not validated if accompanied by "u" qualifier.
- Duplicated analysis not within control limits.
NA - Not analyzed.
A - Analyte detected in method blank.
B (inorganic) - The analyte has been detected between the method detection limit and the reporting limit.
DA - Dissolved analyte greater than total analyte; analvses passed QC based on precision criteria.
DF - Dissolved analyte greater than total analyte; analyses failed QC based on precision criteria.
j - Concentration considered an estimate based on data validation.
l - Estimated concentration.
M - Elevated detection linut due to matrix effects.
N - Spiked sample recovery not within control limits.
P - Digested spike recovery fails accuracy criteria; post -digestion spike recovery accepted.
S - Value was determined by the Method of Standard Additions (MSA).
u - Laboratory reported detection not validated during data validation process.
Shading indicates values exceeding NC G WQS.
RMT, Inc. t Roysfer Clark, i Wnsfori Salem, NC
P: y Hydro4 %02771 Fsnit?00.71Mt1?listR,mstS
March 2003

Table
WORKING COPY
c
PARAM�TERol
"_GWQS I
rt. CAT10N/SAMPLEDATE
r
` ` bi►N 07.
MW-OB
12j78/1944i.,1/1D/1495199512128/1494
",Qf1995•: Y2%3/144a �iQ125/2001°
Metals
Arsenic, dissolved
0,05
NA
NA
<0.03 5
NA
NA
<0.003
NA
Arsenic, total
0.05
NA
NA
<0.03 5
NA
NA
<0.006 S
<0.01
Cadmium, dissolved
0.005
NA
NA
0,0049 DA
NA
NA
0.0034 DA
NA
Cadmium, total
0.005
2r 0.0052 .'
0.0028
0.0042
<0.005
0.0018
0.0031
0.0014
Manganese, dissolved
0.05
NA
NA
v 15 °:
NA
NA
a 0.65 DA..
NA
Manganese, total
0.05
= 1516"
.
- :
` .;0.63 Otis,
_ - ,.6.92"•.
Zinc, dissolved
2.1
NA
NA
1.5
NA
NA
0.56 DA
NA
Zinc, total
2.1
1.5
1.7
1.6
0.58
0.56
0.52
0.59
Wet Chemistry
Chloride
250
12000` n=
'14000 ri
'.'. -13000 : _'
100
99
99
NA
Nitrogen, ammonia
--
670
1300
780
<01
0.15
0.12
NA
Nitrogen, nitrate
10
110
NA
41:4 s
NA_'26.ti
P >.
NA
Nitrogen, nitrate +nitrite
10
110 a
_ 110 `_
NA
�' 31 :: _
't30
NA
� 222 7 .
Phosphorus, total
--
0.17
1.1
0.75
2.1
1.6
2.6
1.5
Sulfate
250
� E-s 5400 '
T"5400 L
:' :#�5600.",",`
<10
<10
<10
NA
Field Indicator
pH (s.u.) 6.5-8.5 ®- 3 8 ; = 6.8 4 5,
Analytical results are reported in milligrams per liter (mg/ L) unless otherwise noted.
izt North Carolina Ground Water Quality Standards
< - Concentration less than the Quantitation Limit or not validated if accompanied by "u" qualifier.
" - Dup€icated anaiysis not within control limits.
NA - Not analyzed.
A - Analyte detected in method blank.
5 (inorganic) - The analyte has been detected between the method detection limit and the reporting Limit.
DA - Dissolved analyte greater than total analyte; analyses passed QC based an precision criteria.
DF - Dissolved analyte greater than total analyte; analyses failed QC based on precision criteria.
j - Concentration considered an estimate based on data validation.
j - Estimated concentration.
M - Elevated detection limit due to matrix effects.
N - Spiked sample recovery not within control limits.
P - Digested spike recovery fails accuracy criteria; post -digestion spike recovery accepted.
S - Value was determined by the Method of Standard Additions (MSA).
u - Laboratory reported detection not validated during data validation process.
Shading indicates values exceeding NC G WQS.
RMT, fitc. � Royster Clark, Winsfon Salem, NC
P.lttyd,-y,02771 L M120034Xf[Wistwmsis
March 2003

Table
WORKING COPY
PARAMETERI')a
,._.
-
W
-GWQS)
h4._ k LOCATIOI!/SANIPLEDATE
" MW-09 r '
_
_
MW 10 �':> '
(DU-01401)
s�
_5
-
='�hy1�Wy-�10A �.,n��/�
f
MW 11
995• rl
�y�-�"
995 11
995 1 001 1 001'.
2/i/I995 . 10/25/ZD01m
Metals
Arsenic, dissolved
0,05
NA
NA
NA
NA
NA
NA
NA
NA
NA
Arsenic, total
0.05
0.013 S
'"_ ; Q:12=' :
<0.006 S
<0.01
<0.006 S
<0.01
<0.01
0.0084 S
Cadmium, dissolved
0.005
NA
NA
NA
NA
NA
NA
NA
NA
NA
Cadmium, total
0.005
0.007=_:
<0.0027 Au (0.76)
0,0086 �E
:'_ 0.019, , :„
<0.0003
<0.001
<0.001
.. -
0.046
Manganese, dissolved
0.05
NA
NA
NA
NA
NA
NA
NA
NA
NA
Manganese, total
0.0514
36... ter,.391,
0.72
2
., Q 24170
Zinc, dissolved
2.1
NA
NA
NA
NA
NAµ
NAm
NA
NA
NA
Zinc, total
2.11-r?--5.�'6.94e,-"
1.6
=+2:2
a• S'8 -
0.054
0.046
0.039
"16
�T-.72
Wet Chemistry
Chloride
250
47
NA
230
NA
10
NTA
NA
= 970'. _ _
NA
Nitrogen, ammonia
--
230
NA
81
NA
<0.10
NA
NA
950
NA
Nitrogen nitrate
10
7.36
NA
6.4
NA
NA
;r 170
NA
Nitrogen, nitrate + nitrite
10
NA
- ; `160 -_
NA
`" 130 W
NA
-" 370 ''
: 16 J _
NA
370
Phosphorus, total
--
0,17
0.79
0.40
<0.50
<0.10
0.59
<0.50
0.34
1.2
Sulfate
250
I400
NA
r�F840--==
NA
<10
NA
NA
NA
Field Indicator
_ 5:5_ �;54,?
�.:_ m. n
PH (s.u.J 6.5-8.5 M 3 6 - _,4 4 1.6 _" e v,-.4 :�- --.:
Analytical results are reported in milligrams per liter (nig/L) unless otherwise noted,
ai North Carolina Ground Water Qualitv Standards
< - Concentration less than the Quantization Limit or not validated if accompanied by "u" qualifier.
" - Duplicated analysis not within control limits.
NA - Not analyzed.
A- Analyte detected in method blank.
B (inorganic) - The analyze has been detected between the method detection limit and the reporting limit.
DA - Dissolved analyze greater than total analyte; analvses passed QC based on precision criteria.
DF - Dissolved analyte greater than total analyte; analyses failed QC based on precision criteria.
j - Concentration considered an estimate based on data validation.
] - Estimated concentration.
M - Elevated detection limit due to matrix effects.
N - Spiked sauipie recovery nut within contrui hinits.
P - Digested spike recovery fails accuracy criteria; post -digestion spike recovery accepted.
S - Value was determined by the Method of Standard Additions (MSA).
u - Laboratory reported detection not validated during data validation process.
Shading indicates values exceeding NC GWQS.
RMT, lnc. � Royster Clark, Winston Safent, NC
r:lHyd.oy7o27;�aeg120Qi1M➢VHiswim-its March 2003

Table
WORKING COPY
t-
FARAMEPE.Rttl
iNC _ -
GWQSt�
owsM 3LOCAU PLEi7AFE
MW-11A .
`'` iMW 12
2%3%1995 ^ ... _ 1Q%L5/?d101
=995 10/L5�2M ,
Metals
Arsenic, dissolved
0.05
<0.018 S
NA
NA
NA
Arsenic, total
0.05
<0.018 S
I==0.13 __
<0.006 S
0.022
Cadmium, dissolved
0.005
;0.038.,.x_
NA
NA
NA
Cadmium, total
0.005
m:g0.065'>::e`-
0.02 =' a
0.0012
<0.001
Manganese, dissolved
0.05
25 ."
NA
NA
NA
Manganese, total
0.05
25
Zinc, dissolved
2.1
7.5:'- �
NA
I NA
NA
Zinc, total
2.1
-7.5
0.094
0.17
Wet Chemistry
Chloride
250
480,:�
NA
40
NA
Nitrogen, ammonia
--
780
NA
0.10
NA
Nitrogen, nitrate
14
_: _i34 sa=;
NA
4.2
NA
Nitrogen, nitrate +nitrite
10
NAg100.
=-"'a "
NA
4.8
Phosphorus, total
-
1.2
2.8
0.17
<0.50
Sulfate
250
°; ; 8200:s `3
NA
I <10
I NA
Field Indicator
pH (s.u.) 6.5-8.5j 3:9 ,.z 3rvw > 451
Analytical results are reported in milligrams per liter (mg/ L) unless otherwise noted.
m North Carolina Ground Water Quality Standards
< - Concentration less than the Quantitation Limit or not validated if accompanied by "u" qualifier.
• - Duplicated analysis not within control limits.
NA - Not analyzed.
A - Analvte detected in method blank.
8 (inorganic) -The analyte has been detected between the method detection limit and the reporting limit.
DA - Dissolved analyte greater than total analyte; analyses passed QC based on precision criteria.
DF - Dissolved analyte greater than total analyte, analyses failed QC based on precision criteria.
j - Concentration considered an estimate based on data validation.
J - Estimated concentration.
M - Elevated detection limit due to matrix effects.
N - Spiked sample recovery not within control limits.
F - Digested spike recovery fails accuracy criteria; post -digestion spike recovery accepted.
S - Value was determined by the Method of Standard Additions (MSA).
u - Laboratory reported detection not validated during data validation process.
Shading indicates values exceeding NC CWQS.
RMT, Inc. � Royster Clark, Winston salew, NC
P:1Hyeiral%02M Ear y 2001 NTWHist .18 March 2003

II fil'II{f sill iIIIIIIIII

Ll
,

Em
1
�.:
1 let,
€tt
a a
"
ie -• M. wK Elva
n kMF i s
4k
k
i
n.
d

9YNJ ft
AL
�Jj
A,
t Ir
Figure No.: Site/Client: NC DOT Site #54, Winston-Salem, NC/
North Carolina Department of Transportation C LP
20 20 April 1960 Aerial Photograph of NC DOT Site #54 Services, P.C.
and Adjacent Properties. NC DOT Mission # 17;
Frame # 172; NC DOT Photogrametry Unit. —
F-20

Figure No.: Site/Client: NC DOT Site #54, Winston-Salem, NC/ CLP
3 North Carolina Department of Transportation
20 April 1960 Aerial Photograph of Waste Mgmt./ Services, P.C.
Nrfk. Sthrn. RR/Carolina Ore Co.; NC DOT Mission _
# 17 • Frame # 172 • NC DOT Photo ramet Unit.
F-41

F-1

Compliance Inspection Report
Permit: NCS000381 Effective: 09/29/00 Expiration: 09/30105 Owner: Agrium U S Inc.
SOC: Effective: Expiration: Facility: Rayster Clark , corpor}ted
County: Forsyth 3105 Glenn Ave
Region: Wnsfon-Salon
WnsCn Salem NC 27105
Contact Person: Billy Pirkle Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 12/18/2007 Entry Time: 10 00 AM
Primary Inspector: Ruses Pruitt
Secondary Inspector(s):
Steve W 'fedder
Reason for Inspection: Other
Permit Inspection Type: Storruwater Discharge, Individual
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Certification: Phone:
Exit Time: 10 45 ANI
Phone: 3KI-771-5000
Phone:
Inspection Type: StorrnwtJter
Paste 1
3

Permit: WS000381 Owner -Facility: A(p urn U S lm[
Inspection Date: 1211 W2007 Inspection Type: Stormwaler Reason for Visit: 0iwr
Inspection Summary:
Request to rescind permit as a result of facility closing. Site inspection 12/18/2007 with Steve Tedder, DWQ regional
supervisor and Kerry Cooner with Agnum Some areas still afforded potential stormwater contamination Clean up of the
following areas was recommended before calling for relnspection:
(1) Remove approximately a toot of contaminated soil on both sides of RR tracks between the main building and
manufacturing area and replace with clean soil.
(2) Verify fuel and chemical tanks are empty and clean out secondary containment area Recommend use of qualified
environmental company.
(3) Remove remaining sand piles
(4) Remove contaminated water in ammonia tank secondary containment area.
(5) Clean out/sweep the back of the open shed and storage area Remove carboy with nitrogen resin
(6) General housekeeping, remove/sweep bags near concrete stormwater well.
Page 2

Permit: NCS000381
SOC:
County: Forsyth
Region: Winston-Salem
Compliance Inspection Report
Effective: 09129/00 Expiration: 09/30/05 Owner: Agriurn U S Inc
Effective: Expiration: Facility: Royster Clark Incorporated
3105 Glenn Ave
Contact Person: Biliy Pirkle Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/18/2008 Entry Time: 08 30 AM
Primary Inspector: Rose Pruitt
Secondary Inspector(s):
Steve W Tedder
Reason for Inspection: Follow-up
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Winston Salem NC 27105
Phone: [phone]
Certification:
Exit Time: 08 45 AM
Phone:
Phone: [phone]
Phone:
Inspection Type: Compliance Evaluation
Page 1

Permit: NC;S000381 Owner - Facility: Agriiam U S Inc
Inspection hate: 11)18/2009 Inspection Type: Comphariw Evaluation Reason for Visit: Follow tip
Inspection Summary:
Met with Kerry Cooner (Agrium) at site, Facility has been torn down. All tanks, sand piles, buildings removed OK to
rescind SW permit_ Memo sent to SW permitting 11/20/2008
page 2

9
Nov 18, 2008 001
M
Nov 18, 2008 011
Nov 18, 2008 012
Nov 18, 2008 017
Nov 18, 2008 003
Nov 18, 2008 013
Nov 18. 2008 018
Nov 18. 2008 014
Nov 18, 2008 005
Nov 18. 2008 010

il
..............
.7
Compliance Inspection Report
Permit: NC;S000381 Effective: 09129100 Expiration: 09130i05 Owner: Agnum U S Inc
SOC: Effective: Expiration: Facility: Royster Clark Incorporated
County: Forsyth 3105 Glenn Ave
Region: Winston-Salem
Winston Salem NC 27105
Contact Person: BNY Pirkle Phone: [phone]
Directions to Facility:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04120/2007
Primary Inspector: Rose Pruitt
Secondary Inspector(s):
Entry Time: 01 00 PM
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant f] Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Certification: Phone:
Exit Time: 02 00 PN1
Phone: [phone]
Inspection Type: Stormwater
Page 1

Permit: NC8000381 Owner - Facility: Agrium U S Inc
Inspection Date: 04120Y2007 Inspection Type: Slormwater Reason for Visit: Rouhne
Inspection Summary:
Inspection conducted by Andy Allen, City of WS Stormwater Division
Page 2

Name of Facility:
Date: 4/20/2007
Time: 1:00 P.M.
IMA
sto,rm"
In
n Fof m
Agrium U.S. Inc.
Comments & Observations (addressed in order from Part 10 of the Inspection Form):
1 The floor trench in the finished, bagged fertilizer loading dock has been filled -in with concrete.
There is a collection well at the left end of the trench in order to contain any rainwater that is blown
into the canopy area. When the collection well is full, the water is pumped to the air scrubber.
2) Pallets leave the facility with finished, bagged fertilizer. Any pallets that are needed by Agrium
are purchased from A&J Pallet. The refurbish pallets are free of any product.
3) Any 1-ton burlap bags are stored indoors. Advised Agrium to document their inspections of this
material handling area to ensure compliance with their individual stormwater permit.
4) The catch basin adjacent to the bulk loading area drains to the Emergency Catch Basin.
5) Advised Agrium to document all cleaning activities of the Emergency Catch Basin, as per their
individual stormwater permit (Section 8 - Facility Insoection Proaram).
6 A rium's SPPP has been updated and incorporated all missing, pertinent information, as per their
individual stormwater permit.
Facility representative(s) that attended reOspection Mr. Matt Olson
Titie(s). Plant Manager
Signature(s) of City Stormwater Inspector
Title{sy Environmental Control Su ervisor

Refurbished pallets used by Agrium - free of any product or residue
Captured stormwater runoff stored inside Emergency Catch Basin

Floor trench in finished, bagged fertilizer loading area - filled -in with concrete
Collection well at finished, bagged fertilizer area - any gathered rainwater is pumped to air scrubber

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General Comments:
tllydrogeological
Absence of hydrogeologic cross -sections with equipotentials and specific contaminant isopleths
is troubling.
Why is there no information/details about well construction (e.g., depth, screened interval, etc.)?
Table 3 -- Summary of Water Level Measurements 2"`' column: Elevations of measuring points
arc inconsistent with actual elevations at the site. This implies that a North Carolina Registered
[wand Surveyor did not survey the wells. If that is the case, then the report's authors are in
conflict with North Carolina Law and regulations promulgated by the North Carolina Board of
l xaminers for Engineers and Surveyors because they are publicly practicing surveying without
proper IICCI1sUre. If the Board has licensed them as a surveyor, then they probably are not
conforming to the standard of practice required by the board. Either way, this should probably
be brought to the attention of the North Carolina Board of Examiners for Engineers and
Surveyors. There are apparently no remaining monuments in the area to tie a survey to the North
Carolina grid system. However, there are several elevation markers in the area certified by the
North Carolina Geodetic Survey. Providing the correct elevations for well heads at the site
Should be a simple task.
Why are there no elevation data for monitor well MW-09?
The stream to the east (Unnamed Tributary to Brushy Fork Creek tributary oil RMT's Maps but
referred to as Bowen Boulevard Branch elsewhere) must be at least a Class C stream. The
presence ofammonia in the stream and the temporal increase in ammonia concentrations
(according to the authors) indicates that emergency measures should be taken to stop the plume
from entering the surface water. The ammonia discharge from groundwater to surface water is
likely to be toxic to aquatic organisms from the point of discharge to the stream bed to areas far
down the watershed. The distance the problem reaches downstream will depend on flow the
through the stream. Therefore, there should really be weirs along the stream to measure surface
water flow through time as part of the monitoring program. There is no control for the water
level in the stream. Need piezometers adjacent to the stream in addition to weirs so that one can
tell the flow through the stream, and where it changes from a losing stream to a gaining stream
(i.e., begins to receive contaminant plume versus pushing it away). Authors admit that
contaminated groundwater from the site is discharging to the stream on Page 3. Why are they
not cleaning this up?
It is clear that lagoons have contaminated groundwater and now surface water through
groundwater discharge. It also appears that there may be another source area on the south end of
the building near monitor wells MW-11A and MW-I 1. Plume is not defined vertical or
horizontally. Which wells are part of the review boundary and which wells are part of the
compliance boundary as required by 2L?

There is a strong downward gradient at this site and an apparent paucity of monitor wells in the
bedrock. Expect that bedrock fractures will be more contaminated than what is seen ill the
shallow monitor wells.
Why was monitor well MW-7 not sampled/measured?
There is no control for 48', 50' and 52' contours past MW-5. There is no control for the 56'
contour past south corner of the building. Appearance of ammonia in stream bed indicates that
pontentiometric surface as shown in Figure 2 does not represent groundwater flow direction well
and under estimates the distance from the source area to the stream.
Geochemistry
Why arc there no measurements ORP and dissolved oxygen measurements for groundwater and
surface water? Also, be aware that elevated concentrations of ammonia can wreak havoc on
pfi/ORP probes. Therefore, great care should be taken to use the proper equipment and analyze
the data accordingly.
The concentration of arsenic in Groundwater and surface water is troubling. This is particularly
true since the State's toxicologist believes that concentrations above 20 parts per trillion present
an unacceptable cancer risk.
The nitrate and ammonia concentrations are clearly in violation of Title 15A NCAC Subchapter
2I. Section .0202. There probably needs to be hydraulic containment of this plume once its
spatial extent is defined.
What is the torrn/speciation of the phosphate in groundwater? 1,100 mg/L is quite high indeed!
There seems to be little relationship between specific conductance and the chloride/sulphate
phosphorous concentration in groundwater. Very strange, the authors should be explain this in
the report.
Turbidity is very high. Why? Except for MW-04A where it is 0.0 NTU (is this a typo?). In fact,
groundwater is more turbid than surface water!
Why was uranium not measured? North Carolina doesn't have a specific groundwater standard
(dumping limit if'you will) for uranium, but that indicates that anything above background would
be in violation of the standard. Also, note that the SDWA does have an applicable standard for
total uranium at 30 micrograms per liter.
Radiological analytical results provide little information for evaluation. At a minimum, they
Should report the counting efficiency of the instruments and/or state explicitly that the values
they report have been corrected for counting efficiency.
The authors are in a weak position to talk about background samples at this site. The well they
call background has higher activities than many of the other wells. Seems that there is a lot of

investigation to be done here. The large piles of granular materials seen in old aerial
photographs could be phosphogypsum. It is interesting that they tell you that the material is just
sand, since they claim at other times that they have no knowledge of what went on before 1999.
Also, note that old aerial photography shows the lagoons overflowing and running in to a ditch
along US Hwy 52. 1 understand that there are burial areas onsite but the RP claims that super-
phosphate was buried. This makes little sense in that super -phosphate is part of the commodity
that the plant is producing. Why throw away something of value, particularly when you are in
the business of making that product. Unless of course, there was a problem with the product.
An alternative scenario is that the material that was buried was phosphogypsum. It would be
really be worthwhile for you to read the info at
1Zttlz ,'!«� °w.ardaman.com �uhsi��husphogpsum_disposal.htm and
http:l-�v�v4v.complianceregs.cc}rn/4()C'FR/P(il_162.1-11-M and
lit tp_:/l\v\ w.epa.gov/radiation%rieshaps/strbpartrlstibpartr.litnt=IScc.",,)061.20T%)2ORadi€►lit-
220`,/o20sampIinisn-'020and`%.2()111eaSuiement`V02Oprocedures and
lItt )://www.e }a.,ov/radiation/ncslia)s/sub zartr/index.litml. Expect about five tons of -gypsum for
every ton of phosphoric acid produced. Where did they put it? Unconditional release can only
occur If the radionuclide activity in the phosphogypsum is <0.37 Bq/gram
(lit tp://calgwebe.agrium.cone/in_the _ community/2657.cfin and
�!Lrt�loadsl"Type 05_Florida_ Phosphogypsum_MSDS140(�U.PDI ). Did
the plant produce phosphoric acid in the past?
Possible sources of Radionuclides:
Background/naturally occurring
Phosphate ore
Phosphogypsum
"Thorium catalyst in the oxidation of ammonia to nitrate and/or in the reduction of sulphuric acid
which is then used to dissolved the phosphate ore.
Attachment 3 is of no apparent value. —At very least, authors should provide theoretical basis for
trying to match various species. It appears that they are blindly comparing values hoping to find
a trend.
Need more narrative from the laboratory, particularly since the had strong matrix effects and
results are all "biased low".
Arsenic could come from the production of the sulphuric acid if performed on site as it was at the
adjacent VCCC factory and from the phosphate ore. Note that there are many other trace
components of the phosphate ore that could be concentrated and discharged by the fertilizer
manufacturing process. Many of these would be toxic to aquatic life (lead, fluoride, bromide,
etc.). Why are these not part of the analytical package for the wastewater lagoon closure
groundwater monitoring program'?
Need analyses of 238-uranium, 235-uranium, and 232-thoriurn and all of their daughter products
through the decay series. Soil sampling and radiological analyses should be done for disposal
pits, storage areas, and lagoon areas, and anywhere else, a release may have occurred. We know

that the uranium will tend to partition with the phosphoric acid and the radium and thorium with
the gypsum. So, if there has been disposal of phosphogypsum, one would see it in the activity of
226-radium. That is, i f there is no disposal, one would expect the activity of 226-radium to be
consistent with the activity of 238-uranium (think secular equilibrium). The only 226-radium
around would be from the decay of 238-uranium. One would expect some differential removal
of the 238-uranium by weathering, but it would likely be minor compared to the excess 226-
radium you would see if phosphogypsum were disposed of on site.
Decay Series
Half-life
232-Th Decay Series
_.....................
Half-life
P38-U
........---..................
238-U
4.51 E9 yrs
232-Th
1.41 E10 yrs
234-Th
24.1 dais
228-Ra
5.77 yrs
234-Pa
234-U
6.75 hours
2.47E5 yrs
228-Ac
228-Th
6.13 hours
226-Ra
1,600 yrs
224-Ra
3.64 days
222-Rn
3.823 days
220-Rn
55 sec.
Notice that the longest half-life for each series is the ultimate parent product. In the absence of
additional input of daughter compounds and significant leaching of parent compounds, the
amount of daughter products will depend on the activity of the parent (activity = number of
atoms x decay constant). I would look for areas where there was a large unsupported activity of'
226-radium. Such areas are likely to have received phosphogypsum.
I.fyou want to convert the activities (picocurics/liter) shown in the analytical reports to mass per
volume (picograms/liter):
Activity m. c x �, x N Where, c = counting efficiency, = decay constant, and N = number of
atoms of a particular isotope.
I picocuric = 0,37 disintegrations per sec
So, 172 picocuries/liter = 6.364 disintegrations per second = 381.84 disintegrations per minute
=2.0083E8 disintegrations per year
2.0083E8/ X = number of atoms of 226-Ra
t, = 4.332E-5/yr for 226-Ra,
so,
The number of 226-Ra atoms - 4.636E 12
Avogadro's number = 6.02252E23 atoms/mole
So, there is 4.636E12 atoms/6.02252E23 atoms/mole = 7.698E-12 moles of 226-Ra per liter of'
water. Which is roughly 1.74E-9 grams/liter or 1.74 nanograms of 226-Ra per liter of water; a

pretty small mass indeed! However, one should ask if this amount (activity) of 226-radium is
supported by the activity of 238-uranium, If it is not, then there is likely to be waste disposal.
Global issue
The policy of the NC DENR is not to allow a contaminant plume in groundwater to discharge to
a surface water body and exceed the surface water standard. There could be a difficult precedent
setting issue here if Royster Clark is allowed to let their plume to continue to discharge to
surface water. Under CERCLA, they are responsible for past problems at the site jointly and
severally. So, even if they say they didn't know about it, they are not off the hook here.
Benninger's Contact info:
Larry K. Benninger
Professor of Geological and Marine Sciences
Chair of Geological Sciences
University of. North Carolina
CB#3315 Mitchell Hall
Chapei Hill, NC 27599-3315
Phone [phone]