NC0023442_LV-2017-0159 Remmission_20170703

(1)Boise
Moncure Plywood Plant
July 3, 2017
Danny Smith
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Cascade
CERTIFIED MAIL / RETURN RECEIPT REQUEST
7016 2710 0000 7767 5035
Re- Moncure Plywood
NPDES Permit. NCO023442
Moncure, Chatham County, NC
Case No LV -2017-0159
Mr Smith,
306 Connth Rd
Moncure, NC 27559
(919)-542-2311
FAX [phone]
NC Dept Of Environmental Qu,l,ty
JUL 18 2017
Raleigh Regional Office
Please find attached the remission letter in regards to the Notice of Violation and Assessment of Civil Penalty for violations
of the North Carolina General Statute (G S ) 143-215.1(a)(6) and NPDES WW Permit No NC0023442, Case NO LV -
2017 -0159
If you have any questions regarding the information in this letter, please contact me at 803-385-4957
Si cerely
P
RECEIVED/NMEWWR
Brian Van Gelder
Eastern Region Environmental Manager AUG 18 2017
Boise Cascade Wood Products
Water duality
Permitting Section

P.O. Box 129
Morrisville, NC 27560
919-067-1239
MACCONNELL
& ASSOCIATES, P.C.
Supplement to Justification for Remission Request
Case Number: LV -2017-0159
County: Chatham
J
Assessed Party: Boise Cascade Wood Products LLC
Permit No.: NCO023442 Amount Assed: $387.78
Background:
1101 Nowell Road
Suite 118
Raleigh, NC 27607
Fax [phone]
The above referenced facility was recently upgraded from a single cell lagoon treatment system to
a recirculating media (E -Z Treat) system with UV -disinfection prior to discharge of effluent. The
system has the built-in capability to send lagoon water through the treatment system in limited
quantities. Construction was completed in January and start-up of the new facility was initiated.
Compliance with the permit limits have taken longer than expected, but indications are that the
corrective actions have had positive results and the plant will meet its permitted limits. We have
been working diligently with the Owner, Manufacturer and Operator to obtain the level of
performance the plant was designed to meet.
We have attached a listing of permit violation from start-up (January 2017) to the present (May,
2017), as well as the daily monitoring reports and letters from the Operator in Responsible Charge
(ORC) notifying the North Carolina Department of Environmental Quality of the violations. We
request remission of the penalties as all associates parties have worked diligently to bring the plant
into compliance without delay, and the violations were inadvertent. Areas of concern with respect
to performance are: BODS, TSS, Ammonia, Fecal Coliforms, Dissolved Oxygen and Flow. Please
see below for the reasons why there were violations and actions taken to correct the situation.
Findings and Actions Taken:
The following is a summary of our findings and actions taken.
Temperature:
1. The plant was started up in January with flow from the lagoon being added to the system.
The low temperature of the wastewater being treated resulted in a longer period for the
biology to colonize to the required level. This resulted in higher BOD and Ammonia levels.

Actions Taken:
Flow from the lagoon was significantly reduced/eliminated from being treated to allow for
increased wastewater temperature. Time was also needed for the biology to adapt.
Septic Tank:
1. During the inspection of the septic tank there was evidence (topping of the effluent filter
and staining midway up the influent piping) of the tank being surcharged which
corresponds with the periodic high-water alarm.
2. Return flow from the dosing pumps for denitrification was greater than optimal which
reduces the flow through the bypass valve to the UV unit and discharge tank.
Actions Taken:
1. Flow from the pod dosing pumps to the septic tank was reduced. This should help to reduce
the chance of surcharge and flushing of solids from the tank. It also increased the flow and
pressure to the pods which resulted in finer droplets and more desirable "misting" of spray
when dosing the pods.
E -Z Treat Pods:
1. The spray over the pod media had more droplets rather than the desirable fine mist. This
results in less treatment which affects the performance of treatment levels of the following
constituents BODS, TSS, and Ammonia.
2. The light brown growth on the Polystyrene beads was more prevalent. This was a positive
sign as it indicates that a healthy colony of biomass was forming to treat the wastewater.
3. One of the header pipes on one of the pods was disconnected from the fitting resulting in
water pouring over the pod. This would reduce performance.
4. Alkalinity was determined to be relatively low which has an effect on nitrification which
is the conversion of Ammonia to Nitrite/Nitrate. ,
Actions Taken:
1. See Septic Tank Actions Taken.
2. The built-in check valves on the pod dosing pumps were removed. They are not necessary
as the design has ball check valves in the piping. This increased the pressure and flow to
the pods which resulted in a fine mist. This should add to treatment performance.
3. The pipe was reconnected and glued to the fitting. Recommended that the Operator
periodically check pod media and spray bars on pod for clogging.
4. The manufacturer is fabricating mesh bags for crushed lime chunks to be inserted in the
bags and the bags will be placed below the bead bags. As water flows through the
limestone it wil—I add alkalinity to the recirculation water which will allow for nitrification.
By -Pass Valve:
1. The by-pass valve was over flowing the top and flow was being diverted back to the dosing
tank in lieu of being discharged through the UV unit. This could contribute to the surcharge
or backing up of flow and high alarms.

Actions Taken:
1. The Contractor added an extension of a few inches on the top of the by-pass valve. This
will ensure all the by-pass flow goes through the UV unit to the discharge tank.
2. Flow from the pod dosing pumps to the septic tank was reduced This should help to reduce
the chance of surcharge. It also increased the flow and pressure to the pods which resulted
in finer droplets and more desirable "misting" of spray when dosing the pods.
Dosing Tank:
1. The dosing tank had about 4 to 5 feet of sludge in the bottom of it. This is quite unusual
and could be result of surging/backing up of flow. Another possibility is that something in
the wastewater killed the biology on the beads which resulted in sludge. This needs to be
resolved to maintain the effluent quality and reduce wear on the pumps.
Actions Taken:
1. Actions in other section are described to prevent surging or the backing up of flow.
2. The sludge was hauled off to an acceptable facility.
UV Unit:
1. Upon inspection of the UV Unit, it was determined that the lamps were not all the way in
the sleeves. It was noted that there was biological growth on the sleeve below the bulbs.
This will result in elevated concentrations of fecal coliforms in the effluent.
Actions Taken:
1. Cords on the unit were lengthened and the lamps were inserted to the full depth of the
sleeve.
2. Sleeves are cleaned weekly by the Operator.
Discharge Tank:
1. The dosing tank had sludge in the bottom of it. This is quite unusual and could be result
of surging/backing up of flow. Another possibility is that something in the wastewater
killed the biology on the beads which resulted in sludge. This needs to be resolved to
maintain the effluent quality and reduce wear on the pumps.
Actions Taken:
1. Actions in other section are described to prevent surging or the backing up of flow.
2. The sludge was hauled off to an acceptable facility.
Discharge Flow Meter:
1. Flow from the plant has been averaging around 2,000 to 3,000 GPD. Following an event
in April, flows were in the +/- 20,000 GPD range. The cause of this event have not been
determined. Flows have returned to their typical range.
Actions Taken:
1. Flows are being monitored daily to determine if there is a source of inflow/infiltration. The
system will be checked during/following storm events.

Blower and Aeration:
1. The Blower was taken off line to see if it was responsible for regrowth of bacteria and/or
solids generation. As a result the D.O. level was too low.
Actions Taken:
1. The unit was put back on line.
Prepared
Gary S. MacC"arP'aJl, PE : � 4
°