NCS000151_BIMS Report_20190530

Compliance Inspection Report
Permit: NCS000151
SOC:
County: Chatham
Region: Raleigh
Contact Person: Jim Skinner
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Effective: 05/01/09 Expiration: 04/30/14 owner: Arauco North America Inc
Effective: Expiration: Facility: Arauco NA Moncure Facility
985 Corinth Rd
Inspection Date: 05/14/2019
Primary Inspector: Alaina Morman
Secondary Inspector(s):
Title:
EntryTime: 10:OOAM
Lauren Garcia
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification:
Moncure NC 27559
Phone: [phone]
Phone:
Exit Time: 12:OOPM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 4

Permit: NCS000151 Owner - Facility: Arauco North America Inc
Inspection Date: 05/14/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part 11, Section A of the permit.
• A SWPPP was not available onsite; however, an SPRP Plan, dated January 7, 2011, with a few administrative updates
in 2012, was provided. When prompted, it was stated that the documents we were given were the only ones available at the
time.
• It should be noted that environmental staff were away at a conference. A current SWPPP was emailed on 5/24/2019,
updated to the day.
• The facility is required to develop and implement a good housekeeping and preventative maintenance program, which
includes conducting twice -annual facility and stormwater system inspections.
o There were no records of such inspections present in the current SWPPP.
o The housekeeping and preventative maintenance procedures outlined in the SWPPP have not been implemented at the
site. Site conditions observed during the site visit were unacceptable. The worst conditions were observed around the
particle board production building, in the eastern section of the site. The milling equipment and surrounding area were
layered in product.
o Chip/mill product was observed in large, uncovered piles around the area of the particle board production building. The
piles form as a result of the movement of the product by front end loaders to covered barns for storage.
• The facility has two outfalls that each discharge from separate concrete lined stormwater "basins." Stormwater around
the production areas (the particle board production building and the medium density fiberboard (MDF) production building)
flows into concrete channels that direct stormwater into the stormwater basins. Product migrates in large volumes into these
channels and is carried into the stormwater basins.
o The stormwater basin that receives stormwater from the eastern section of the property, near the particle board building,
was observed to be filled with large piles of wet and decaying chip/mill material. This stormwater basin measures about 1
acre in size. The facility does not have a way to control flow from this basin, through the outfall, into the receiving stream.
o The stormwater basin that receives stormwater from the western section of the facility, near the MDF building, was
observed to be filled with water and a much smaller volume of chip/mill product. The facility does not have a way to control
flow from this basin, through the outfall, into the receiving stream. This stormwater basin measures about 1 acre in size.
• The facility is required to record each instance of a Tier I response in the SWPPP. The record should include the date
and value of the benchmark exceedance, the inspection date, the personnel conducting the inspection, the selected actions
and the date the selected actions were implemented, in accordance with Part 11, Section B, page 7 of 10 of the permit.
o Since 2009, the facility has had benchmark exceedances of one or more monitoring parameters during each monitoring
event. There were no records present in the current SWPPP.
• The facility is required to maintain a record of Tier II responses in the SWPPP.
o Since 2009, the facility has had benchmark exceedances of one or more monitoring parameters during each monitoring
event. The facility should have taken part in monthly monitoring since at least 2010. There were no records present in the
current SWPPP.
Facility Site Review:
The facility operates a particle board production building and medium density fiberboard (MDF) production building. Medium
density fiberboard production processes wood chips with steam and pressure. Particle board production uses a wood chip
drying system prior to processing the chips. The particle board production building is located in the eastern section of the
facility. The MDF production building is located in the western section of the facility. Spray irrigation fields are also located in
the western section of the facility. Two of the facility's main wastewater ponds are located in the northeastern corner of the
facility. Two fire ponds and four other waste treatment ponds are located in the southeastern corner of the facility. Totes and
drums are located at the northern exterior of the particle board mill. Not all drums were observed to be stored in proper
secondary containment.
Site conditions around the particle board area and two main wastewater ponds in the northern and eastern sections of the
facility were extremely poor. As discussed above, the facility has a very serious housekeeping issue. The housekeeping
issue has led to a mass accumulation of wood product to be deposited in the two stormwater basins at the facility. The
wood product remains in the stormwater basin for an undeterminable amount of time; however, the basins were reported to
be periodically cleared out with a frontend loader. The wood product deposited in the basins is comparable to compost piles.
The wood product is baked in the sun, and then rehydrated during rain events. The leachate that leaves compost piles is
considered extremely detrimental to water quality. Generally, the amount of water added to the compost pile determines the
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Permit: NCS000151 Owner - Facility: Arauco North America Inc
Inspection Date: 05/14/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
amount of leachate that is produced. It is a significant concern for DEQ that the rehydrating and baking process the chip/mill
product undergoes is likely producing a dangerous amount of leachate that is discharging into the receiving waterbody. As
discussed above, the facility does not have a way to control flow from the basins into the receiving body. Leachate is
considered a wastewater and is not an authorized discharge for Arauco under the current stormwater permit.
Site conditions around the medium density fiberboard mill were moderate. The area surrounding the MDF production building
had less unmanaged chip/product. The site conditions in the southern section of the facility, near the fire ponds and four
additional wastewater treatment ponds were good.
Receiving Waters:
Stormwater from this facility drains into Shaddox Creek, a class WS-IV stream in the Cape Fear River Basin.
Self -Monitoring Program:
This facility is required to provide qualitative and analytical monitoring data twice annually. Since 2009, the facility has had
benchmark exceedances of one or more monitoring parameters during each monitoring event. The most concerning
exceedances have been from BOD, COD, TKN, Total Nitrogen, and TSS. For example, the benchmark for COD is 120 mg/I;
COD samples between 2009 and 2019 have measured between 140 mg/I and 2,800 mg/I.
The facility is required to respond to benchmark exceedances through increased monitoring, increased management
actions, increased record keeping, and/or installing BMPs in a tiered program, in accordance with Part II, Section B, pages
6-8 of 10, of the permit. As a result of a Tier I response, the facility is required to conduct a stormwater management
inspection within two weeks of receiving the sampling results. The inspection includes an investigation of the causes of
benchmark exceedances. Causes are then expected to be addressed and improvements implemented. The facility was
unable to provide records of improvements past 2011. A Tier II response involves another investigation, improvements, and
the institution of monthly monitoring. Again, the facility was unable to provide records of improvements past 2011. Based on
the provided sampling data for the current permit term (beginning in May 2009) the facility should have been participating in
monthly monitoring since at least 2010. While the facility participated in more than semiannual monitoring events in 2011,
2012, and 2017, the facility has never completed monthly monitoring to the required specifications of a Tier II Response, in
accordance with Part II, Section B, page 7 of 10.
If sampling results for the permit monitoring periods exceed the benchmark values for any specific parameter at any specific
outfall for more than four occasions, the permittee shall notify the DWQ Regional Office Staff within 30 days of the receipt of
the fourth analytical results. DWQ was allegedly notified as an addendum to an application in 2016. This was the only
known attempt at a notification.
Corrective Actions:
• Housekeeping measures need to be overhauled at the facility. It should be made the top priority of the facility to
investigate and implement a system that will prevent the free chip/mill wood products from reaching stormwater basins all
together. While periodically clearing the product out of the basin with a frontend loader is a short-term solution for preventing
leachate discharge from the unmanaged composting chip/mill product, this will not address the cause of the benchmark
exceedances. As long as the chip/mill product amassed around the particle board production building is so poorly
mismanaged, there will continue to be issues with the stormwater sampling results. The 2009-2019 monitoring data
benchmark exceedances are so high, the effluent leaving the site does not qualify as stormwater; the effluent leaving the
Arauco Panels USA LLC stormwater outfalls is wastewater. This is especially important because the receiving waterbody,
Shaddox Creek, is a WS-IV, a water supply used for drinking, culinary, or food processing purposes.
• All totes and chemical drums need to be stored in proper secondary containment.
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Permit: NCS000151 Owner - Facility: Arauco North America Inc
Inspection Date: 05/14/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Yes No NA NE
■❑❑❑
❑■❑❑
■❑❑❑
❑■❑❑
Comment: The SWPPP had not been updated annually.
The SWPPP was not available onsite: however was email, updated to the day, on 5/24/2019.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment: Qualitative Monitoring showed consistant benchmark exceedances comparable to wastewater.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ 0 ❑
Comment:
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