WQ0003396_Application_20200115

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 Free: 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 1.1. 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
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eM cMillian
Plant Manager