NCS000151_Facility Comments on Draft Permit_20201023

arauco
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
985 Corinth Road
Moncure, North Carolina 27559
Tel; 919.642-6600
Toll Free; 855 927 2826
Fax:[phone]
October 23, 2020
Subject: NPDES Stormwater Draft Permit Renewal Comments—Arauco North America, Inc
Arauco - Moncure would like to provide the below comments for NCDEQ's consideration regarding the
stormwater non -discharge permit draft received by the facility October 13, 2020:
Arauco Moncure remains the only wood products panel mill in North Carolina with a site specific non -
discharge stormwater permit. All other wood panel mills in North Carolina, of which there are five, have
general industry permits. General industry permits require monitoring only of TSS and COD, on a
quarterly basis. The proposed draft permit for Arauco— Moncure would require more frequent
monitoring of COD and TSS, as well as TKN, Phenol, Total Nitrogen, Total Phosphorous, pH, and Oil and
Grease (on one of our two outfalls). The limits associated with these additional discharge compounds
appear to be based on limits in historical Moncure site permits, but are not based on any industry
standard, as all other industry facilities in North Carolina are only subject to the general industrial limits
for wood products (120 mg/L for COD, and 100 mg/L of TSS). COD is a particularly challenging
benchmark for wood products due to the tannins and lignin found in woody materials that are difficult
to filter, settle, and treat biologically. Arauco has found through experience in other States and via
freedom of information that other wood products facilities in North Carolina similarly struggle with this
benchmark.
The original issuance of a site specific stormwater non -discharge permit occurred in 1995 as a result of a
consent decree between the then owner of the site, Weyerhaeuser Company, and the state (at that
time North Carolina Department of Environment, Health and Natural Resources— DEHNR). This Consent
decree was issued in part due to a Notice of Violation and repeated challenges with non-stormwater
discharges as a result of the spray irrigation wastewater treatment system operated by the site under a
separate NPDES non -discharge spray permit (NPDES number WQ0003396). As a result of this consent
decree, the state issued a site specific stormwater permit, and Weyerhaeuser Company agreed to
construction of concrete lined stormwater basins and conveyance ditches, and a wastewater treatment
lagoon system. This wastewater treatment lagoon system allowed for settling and pretreatment through
facultative biological activity to reduce potential stormwater impacts from spray irrigation runoff.
Routine housekeeping, monitoring, and reporting were also adopted as part of this new permit.
Construction for these improvements was completed by July 12, 1996 and the consent decree was
closed. An additional concrete lined stormwater retention basin was constructed in 2008 to further
mitigate stormwater impacts from the new MDF facility.
More recently Arauco has continued to demonstrate the site's commitment to stormwater impact
mitigation through several continual improvements:
• Arauco has piloted several wastewater plants and expended a significant amount of labor and
financial resources in developing a plan to reduce nutrients to stormwater via this permitting

985 Corinth Road
M ,North Carolina 27559
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Te1:919-642-6600
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Toll Free: 855-427-2826
Fax:[phone]
process. Ultimately, a wastewater pipeline from the City of Sanford
was announced in 2017, which changed the direction of the project.
Arauco strongly believes that connection to the Sanford wastewater pipeline by end of year
2020 will open several opportunities for reducing nutrient discharges offsite. The pipeline will
allow Arauco to virtually eliminate the application of high nutrient wastewater to sprayfields on
site and also allow for additional containment via rerouting of certain stormwater runoffs to
treatment.
• Concrete dams around the waste fiber storage area in the middle of the facility to collect
stormwater to be absorbed by the waste material were added in 2019, with diverter valves
installed several years previous to allow for potential non-stormwater discharges to be diverted
to the wastewater treatment ponds, without entering the stormwater outfall.
• Arauco was also issued a new water quality permit for surface irrigation WQ0003396 mandating
a plan to achieve 2' freeboard from the top of the flood plain as of January 19, 2020. An
application and design plans for the new berm was submitted October 22, 2020 and should
further reduce offsite impacts as Arauco plans to construct a large, engineered berm around
lagoon #5 to greatly reduce the future potential of inflow and overflow.
• Arauco has added "utility" labor positions who's sole role is maintaining housekeeping
standards and cleaning process and industrial waste around the site, with focus on wood dust
and fibrous material removal.
• An additional reject wood fiber silo was recommissioned in August 2020 to reduce the amount
of resinated fiber stored on the ground, with potential for runoff to the stormwater conveyance
system and impacts on outfall water quality.
Due to the original impetus for issuance of a site specific non -discharge stormwater permit, which has
been addressed through the construction of a wastewater lagoon treatment system, reduction and
eventual cease of spray field treatment by the end of 2020, connection to a wastewater pipeline by
December 2020, and concrete stormwater conveyance and retention system construction, Arauco
believes that the challenges prompting the original issuance of site specific discharge limits have been
addressed. Further, the discharge requirements set forth in the site specific permit are based on
historical permit limits imposed as a result of a resolved consent decree, and are not in line with any
other wood panel products stormwater permit requirements in the state of North Carolina. Arauco has
demonstrated through best management practices and the above mentioned continual improvements
that we are committed to stormwater stewardship and requests that the site be issued discharge
monitoring requirements comparative to other wood panel industries in the state, namely COD and TSS.
Arauco recognizes that this draft permit has already undergone the public comment period, and should
the facility's request be granted, this public comment period may be required to restart. Please address
comments or questions to the site Environmental Manager, Savannah Carroll at
[e-mail] or 919-545-5848.
Sincerely, I/.
i
Savanna Carroll
Environmental Manager