NCS000151_Email RE Facility Disagrees with CO Response on Draft Permit_20201030

Gamble, Aana C
From: John Bird <[e-mail]>
Sent: Friday, October 30, 2020 1:41 PM
To: Gamble, Aana C; Savannah Carroll
Cc: Valentine, Thad; Jeff McMillian; Garcia, Lauren V; Georgoulias, Bethany; Lucas, Annette
Subject: RE: [External] RE: Draft Permit NCS000151 - Arauco NA Moncure Facility
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Aana,
As you can imagine, this is not a satisfactory response to us. We feel strongly that our compliance issues are
compounded by an overly complicated stormwater permit as compared to competitors in North Carolina. Can you all
provide a regulatory basis for all of the analytes and the benchmark limits imposed on Moncure?
We understand COD, TSS, and O/G as mentioned in Savannah's prior email. The other analytes and limits appear to be
arbitrary. For example, phenol has never been a chemical we have processed or utilized on site.
Thank you,
John Bird
John Bird, P.E.
Arauco North America
843-544-5277
From: Gamble, Aana C <[e-mail]>
Sent: Friday, October 30, 2020 1:18 PM
To: Savannah Carroll <[e-mail]>
Cc: Valentine, Thad <[e-mail]>; Jeff McMillian <[e-mail]>; John Bird
<john.bird @arauco.com>; Garcia, Lauren V <[e-mail]>; Georgoulias, Bethany
<[e-mail]>; Lucas, Annette <[e-mail]>
Subject: RE: [External] RE: Draft Permit NCS000151- Arauco NA Moncure Facility
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Ms. Carroll,
Thank you for providing information relevant to Arauco Moncure's draft NPDES Individual Industrial Stormwater Permit
and progress made onsite via email on October 23, 2020. After review, DEMLR has concluded that lack of evidence of
progress in meeting permit requirements and persistent compliance issues do not provide a strong basis for changes.
The draft permit sent to you on October 13, 2020 will be issued as written.
However, once the planned changes described in your email have been put into place and progress has been made on
meeting permit requirements, Arauco Moncure may submit a permit modification request in writing to DEMLR to
request changes to monitoring requirements before the permit term ends.
Please let me know if you have any questions. Feel free to contact me at anytime via email at [e-mail]
or phone at [phone].

Sincerely,
Aana Gamble
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 1612 Mail Service Center
Raleigh, NC 27699-1612
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Savannah Carroll <[e-mail]>
Sent: Friday, October 23, 2020 11:36 AM
To: Gamble, Aana C <[e-mail]>
Cc: Valentine, Thad <[e-mail]>; Jeff McMillian <[e-mail]>; John Bird
<[e-mail]>
Subject: RE: [External] RE: Draft Permit NCS000151 - Arauco NA Moncure Facility
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[e-mail]
Thanks Aana,
Let me know if there is information I can provide or questions you have.
Thank you, have a great weekend yourself!
Savannah Carroll
Environmental Manager
(0): 919-545-5848
(C): 843-544-3025
From: Gamble, Aana C <[e-mail]>
Sent: Friday, October 23, 2020 11:21 AM
To: Savannah Carroll <[e-mail]>
Cc: Valentine, Thad <[e-mail]>; Jeff McMillian <[e-mail]>; John Bird
<john.bird @arauco.com>
Subject: RE: [External] RE: Draft Permit NCS000151- Arauco NA Moncure Facility
%, Este es un correo externo. No abra/descargue archivos desconocidos; no haga clic en enlaces sin antes verificar la procedencia de
los correos.
Ms. Carroll,

Thank you for your comments on the draft permit. I will discuss your response with my colleagues and get back to you as
soon as I can.
Have a great weekend,
Aana Gamble
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 1612 Mail Service Center
Raleigh, NC 27699-1612
D7 E
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Savannah Carroll <[e-mail]>
Sent: Friday, October 23, 2020 11:02 AM
To: Gamble, Aana C <[e-mail]>
Cc: Valentine, Thad <[e-mail]>; Jeff McMillian <[e-mail]>; John Bird
<[e-mail]>
Subject: RE: [External] RE: Draft Permit NCS000151- Arauco NA Moncure Facility
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[e-mail]
Aana,
Thank you for the draft permit and attached cover letter. In reviewing the draft, Arauco Moncure would like to provide
the below comments for NCDEQ's consideration (I have included a more formal signed letter attached):
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
3

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 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 spray fields 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 savannah.carroll(@arauco.com or 919-545-5848.
Thank you,

Savannah Carroll
Environmental Manager
(0): 919-545-5848
(C): 843-544-3025
From: Gamble, Aana C <[e-mail]>
Sent: Tuesday, October 13, 2020 4:08 PM
To: Savannah Carroll <[e-mail]>
Cc: Valentine, Thad <[e-mail]>; Jeff McMillian <[e-mail]>
Subject: RE: [External] RE: Draft Permit NCS000151 - Arauco NA Moncure Facility
%, Este es un correo externo. No abra/descargue archivos desconocidos; no haga clic en enlaces sin antes verificar la procedencia de
los correos.
Savannah,
No problem at all! I appreciate you getting back to me.
I have attached a copy of the draft NPDES Individual Industrial Stormwater Permit for Arauco Panels USA LLC — Moncure
Facility (permit number NCS000151), as well as a cover letter. I apologize for the long delay in getting this draft to your
facility for review, as we have had quite a bit of turnover in the stormwater permitting group. Please review the draft
permit and submit and questions or comments to me within 15 days of receipt. If you need extra time, please let me
know within that 15-day period. Additionally, please note that this draft permit has already been through the public
notice process, so any major changes to the draft would require an additional public notice period.
Thank you very much! Please don't hesitate to contact me with any questions or comments.
Sincerely,
Aana Gamble
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 1612 Mail Service Center
Raleigh, NC 27699-1612
D7 E
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Savannah Carroll <[e-mail]>
Sent: Tuesday, October 13, 2020 3:48 PM
To: Gamble, Aana C <[e-mail]>
Subject: [External] RE: Draft Permit NCS000151 - Arauco NA Moncure Facility

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[e-mail]
Good Afternoon Ms. Gamble,
It does, I hope you are well yourself! I am the Environmental Contact for our Moncure facility. My apologies for missing
you, we have had an upset condition in our mill operations so I have been in and out of the office all day. I look forward
to receiving the draft permit, let me know if there is any further assistance I can provide.
Thank you!
Savannah Carroll
Environmental Manager
(0): 919-545-5848
(C): 843-544-3025
From: Gamble, Aana C <[e-mail]>
Sent: Tuesday, October 13, 2020 3:10 PM
To: Savannah Carroll <[e-mail]>
Subject: Draft Permit NCS000151- Arauco NA Moncure Facility
Importance: High
��.�- Este es un correo externo. No abra/descargue archivos desconocidos; no haga clic en enlaces sin antes verificar la procedencia de
los correos.
Good afternoon Ms. Carroll,
I hope this email finds you well! I am writing to verify that you are the environmental contact for the Arauco NA
Moncure Facility. I believe our system has Yvonne Couts listed in that position, but I was having some trouble contacting
her, and her phone number leads to your voicemail.
If you are the environmental contact, I will be sending you a copy of the draft NPDES Individual Industrial Stormwater
Permit for your facility (permit no. NCS000151). Please advise.
Thank you very much!
Aana Gamble
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 1612 Mail Service Center
Raleigh, NC 27699-1612
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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.