Minor Mod-Lagoon

41
State of North Carolina
DW RDepartment or Environmental Quality
Division of Water Resources
'� WATER QUALITY REGIONAL or
SECTION
Division of Water Resources NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
January 15, 2020
To: RRO-WQROS: Scott Vinson
From: Ashley Kabat, Water Quality Permitting Section - Non -Discharge Branch
Permit Number: WQ0003396
Applicant: Arauco North America, Inc.
Owner Type: Organization
Facility Name: Arauco - Moncure WWTF
Signature Authority: Jeff McMillian
Address: 985 Corinth Rd., Moncure, NC 27559
Fee Category: Non -Discharge Major
Comments/Other Information:
NC Dept of Environmental Qualit
JAN 17 2020
Raleigh Regional Office
Permit Type: Wastewater Irrigation
Project Type: Minor Modification
Owner in BIMS? Yes
Facility in BIMS? Yes
Title: Plant Manager
County: Chatham
Fee Amount: $0 - Minor Mod
Attached, you will find all information submitted in support of the above -referenced application for your review,
comment, and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed. ® Return a completed staff report.
❑ Attach an Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person fisted above.
RO-WQROS Reviewer: - . I -_� n Date:
FORM: WQROSNDARR 09-15 Page 1 of

ROY COOPER
Co rernor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
JEFF MCMILLIAN PLANT MANAGER
ARAUCO NORTH AMERICA, INC.
985 CORINTH RD.
MONCI:RF, NORTH CAROLINA 27559
Dear Mr. McMillian:
NORTH CAROLINA
Environmental Quality
January 16, 2020
Subject: Acknowledgement of
Application No. WQ0003396
Arauco - Moncure WWTF
Wastewater Irrigation System
Chatham County
The Water Quality Permitting Section acknowledges receipt of your permit application and
supporting documentation received on January 15, 2020. Your application package has been assigned the
number listed above, and the primary reviewer is Ashley Kabat.
Central and Regional Office staff will perform a detailed review of the provided application, and
may contact you with a request for additional information. To ensure maximum efficiency in processing
permit applications, the Division of Water Resources requests your assistance in providing a timely and
complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt of a complete application. If you have any questions, please contact
Ashley Kabat at [phone] or ashley.kabatncdenr.gov.
Sincerely,
Nathaniel D. Thornburg, Supervisor
Division of Water Resources
cc; Raleigh Regional Office, Water Quality Regional Operations Section
Permit File WQ0003396
EQNorth� Carolina Departmntt of Enviror-mentat Quality Division of Water Resources
` 512 North 5alishury Street ' 1617 Kla I Servic a Center i Raleigh. North Carolina 27699 1617
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$197079000

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arauco
CERTIFIED MAIL 7014 1200 0001 2700 4506
Return Receipt Requested
Division of Water Resources
Non -Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Permit Modification Extension Request
985 Corinth Road
Moncure, North Carolina 27559
Tel: [phone]
Toll Fiee:855 427 2826
fax: [phone]
January 10, 2020
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Arauco North America, Inc. is submitting this letter to request an extension to permit condition 1.1. in our
Non -Discharge Spray permit WQ0003396. This condition states, "Within 180 days of the effective date of
this permit, the Permittee shall submit a permit modification request to establish 2 feet of protection
from the 100-year floodplain for Pond 5."
Arauco operates a particleboard and medium density fiberboard manufacturing facility in Moncure, NC.
The wastewater irrigation system was originally permitted at Arauco in 1987-1988. At that time, only the
particleboard manufacturing line was in operation but in 2009 the medium density fiberboard facility was
constructed onsite and became operational. The addition of the facility significantly increased the amount
of wastewater produced and sprayed on the fields. This increase in wastewater generation and heavy
rainfall seasons led to the lagoons losing freeboard. On October 2016 and September 2018, hurricanes
caused major flooding near the facility to the point of Shaddox Creek overtopping the lagoon.
In February 2019 Arauco submitted a permit modification request to increase the daily influent flow to
the sprayfields. The Division of Water Resources issued permit WQ0003396 July 23, 2019 with a new
condition I.I. to raise the lagoon berm of Pond 5 2-feet above the 100-year floodplain. The condition
stipulated the permit application to raise the lagoon berm be submitted within 180 days of permit
issuance, which would be January 19, 2020. Arauco spent the next several months conducting engineering
studies to determine the feasibility of raising the lagoon berm. It was concluded, that raising the lagoon
berm would be infeasible due to the location of the facility and Pond 5. At that point, Arauco only had 2
months left before the permit application was due, which was not enough time to develop an alternative
storage solution.
Arauco met with DWR representatives December 13, 2019 to discuss the current situation and long-term
plan for the site. Arauco is planning on designing and constructing above ground tank storage to replace
the ponds. In addition to new wastewater storage, Arauco's long term plan is to close both ponds 5C and
5D. A major aspect of the long-term plan is to stop utilizing the spray fields and discharge to the City of
Sanford Publicly -owned Treatment Works (POTW) once the City completes its wastewater pipeline
extension project. Once a customer, Arauco will send as much water as permitted to the City from the
lagoons to lower the water level, while simultaneously using the new storage system and discharge permit
for newly generated wastewater. Once the lagoons have been drained, Arauco will develop a State
approved lagoon closure plan and close the lagoons.

Arauco is requesting an extension of Permit Condition 1.1 in Permit WQ0003396 to require submittal of a
permit modification application for the modified storage system until October 23, 2020; this will allow
enough time to conduct engineering studies and determine the most efficient wastewater storage
solution.
If you have any questions, please contact Yvonne Couts, Environmental Manager, at (919-545-5848).
Sincerely
#eMcMillian
Plant Manager

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Ashley Kabat
From: Rick Trone
Choose an item. Regional Office
Permit No.: (WQ0003396)
Facility name: Arauco-Moncure WWTF
Chatham County
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -
discharge and NPDES permit apolications and/or renewals. Please complete all sections as they are applicable.
1. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
a. Date of last site visit: 3. 14'2019
b. Site visit conducted by: Rick Trone
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Mr. Jeff McMillian and their contact information: 9(- 19) 642-6600 ext.
e. Driving directions: 985 Corinth Road, Moncure, NC 27559
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Sub -basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification:
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? ❑ Yes ❑ No ❑ N.`A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ NA
If no, please explain:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N:A
If no, please explain:
FORM: WQROSSR 04-14 Page I of 6

6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? [D Yes[] No ❑ NIA
If no, please explain: #,.
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ NIA
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ NIA
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters: Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N.--A
ORC: Yvonne Couts Certificate #: S111007988 Backup ORC: Amanda Grenier Certificate #:SI11000089
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: See current permit.
Proposed flow: NA
Current permitted flow: 39,525
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.).
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ NiA
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N.'A
If no, please explain:
FORM: WQROSSR 04-14 Page 2 of 6

i�
11. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ NIA
f no, please complete the following ex and table if necessary):
Monitoring Well
Latitude
Longitude
0 I 17
j , II
8 I N
] ! II
J I 17
1 I !I
I 17
1 1 11
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review:
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. NA
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
14. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
® Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.): See
BIMSILaserfiche
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? Yes
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N./A
If no, please explain:
15. Are there any issues related to compliancelenforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14 Page 3 of 6

IV. REGIONAL OFFICE RECOMMENDATIONS
I . Do you foresee any problems with issuancelrenewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item
Reason
From issuance of latest permit in July 2019, Arauco-Moncure was given 180
days to establish 2' of protection from the 100-year floodplain for Pond 5
(Condition I.1). Arauco-Moncure determined raising the lagoon berms was not
Timeline
feasible and is hereby requesting more time to assess the situation and long-
term plan for the site. Arauco-Moncure plans to design and construct above-
ground storage tanks to eventually replace Pond 5. RRO supports allowing
more time to submit a permit modification if the facility is required to submit a
timeline with specific dates regarding the above -ground storage tank option.
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
Permit modification A similar condition should be included requiring a permit modification for any
change to storage.
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
® Issue upon receipt of needed additional information
❑ issue
❑ Deny (Please state sons: }
6. Signature of report preparer: 71 1-
-
Signature of regional supervisor:
Date: r v
FORM: WQROSSR 04-14 Page 4 of 6