NC0040711_Response to Permit Draft_20170616

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Julie Grzyb
NCDEQ — Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
985 Corinth Road
Moncure, North Carolina 27559
Tel [phone]
Toll Free 855-427-2826
Fax [phone]
June 16, 2017
RECEIVEDINCDENWR
JUN 2 3 2017
Subject NPDES NCO040711 Draft Permit Comments Water Quality
Moncure, Chatham County, North Carolina Permitting Section
Ms Grzyb
Arauco Panels USA, LLC has reviewed the draft NPDES permit received on Thursday May 18, 2017 and offer the
following comments
Condition A (1 ) BOD, TSS, and TN limits Arauco is requesting these limits be changed from mg/I to equivalent
lbs /day Lbs /day limits are normally used in NPDES permits throughout the state and Arauco believes that we
should not be held to more restrictive limits in particular when compared to our competition in NC The impact to
receiving water is based on total pounds per month and year of TN as noted in Condition A (7 ), and will be total
pounds of TSS and BOD in the Water Quality Modeling Plan required in Condition A (9 ) Lbs /day is actually
what the receiving stream sees on a daily basis and as noted above DEQ will be assessing environmental
impacts with data converted to lbs /day
2 Footnote 5 To clarify this requirement, Arauco suggests the language be changed from If total phenol is not
detected " to "If total phenol is below the Practical Quant1tation Limit (PQL) " This change would clarify the test
detection limit and be consistent with language found in Condition A (8 )
3 Condition A (9 ) a Arauco is requesting slightly more time to develop the Modeling Plan and suggest the
timeframe should be tied to commencement of discharge, not when the permit is effective Suggested language
"No later than 120 days from commencement of discharge, the permittee shall "
4 Condition A (9 ) a The condition says "All existing discharges in the section to be modeled shall be
considered " Arauco is unclear as to who all the existing discharges are and is unclear what "section" is being
referred to Arauco does not have access to "all discharges" data and expected treatment levels and should not
be required assess an unlimited number of point source and stormwater runoff issues the Cape Fear Basin
receives Arauco believes this condition should be specific to our discharge based on the Water Quality Modeling
Plan This sentence should be deleted
5 Condition A (9 ) a The permit does not require testing for "CBOD" and suggest this reference be deleted in the
last sentence in this condition
6 Condition A (11 ) Arauco is currently negotiating a Settlement Agreement with the NC Department of Justice
regarding lagoon freeboard and structural integrity evaluations of the lagoons and ponds Arauco communicated
suggested edits to DOJ on June 9 and expects the Agreement to be executed very shortly Therefore, this
condition in the NPDES Permit is redundant needs to be deleted
Should you have any questions, please contact John Bird, Corporate Environmental Manager, at 919-642-6658
Sincerely,
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RSchHer
Moncure Plant Manager