WQ0003396_Plan of Action_20201119

arauco
CERTIFIED MAIL
Return Receipt Requested
Division of Water Resources
Attn: Scott Vinson
3800 Barrett Drive
Raleigh, NC 27609
Subject: Incident #202003275 Lagoon 5C Freeboard Level
985 Corinth Road
Moncure, North Carolina 27559
Tel: [phone]
Toll Free: 855-427-2826
Fax: [phone]
November 19, 2020
On November 12, 2020 central North Carolina and the Moncure region experienced excessive rainfall due
to residual effects of Hurricane Eta. The Arauco — Moncure facility experienced in excess of 6 inches of
rainfall in less than 24 hours and between 6-8" in 72 hours due to this severe storm activity. No breach of
the wastewater ponds occurred during this event, but lagoon freeboard was severely reduced, as all ponds
are open air. The freeboard levels after the significant rainfall event are below (please note our gauges
read in tenths of a foot so, for example, 1.4 represents 1 and 4/10s of a foot):
Pond
Level
Comments/Condition
1
1.4
Freeboard level is compliant and impoundment has no
structural compromise.
2
1.4
Freeboard level is compliant and impoundment has no
structural compromise.
3
1.4
Freeboard level is compliant and impoundment has no
structural compromise.
4
1.4
Freeboard level is compliant and impoundment has no
structural compromise.
5D
1.3
Freeboard level is compliant and impoundment has no
structural compromise.
5C
.6
Freeboard level is below permit limit of 1' but has been
improving since the rainfall event. No unallowable
discharges have occurred and impoundment has no
structural compromise. A pump is being used to transfer
water to 5D to increase freeboard, and a contractor will be
onsite 11/20/2020 to repair another valve to allow for
further water transfer to 5D.
With the commissioning and connection to a new City of Sanford wastewater pipeline the week before
the significant rainfall event, Arauco is no longer permitted to Pump and Haul wastewater to the City's
public treatment works and only recently began sending treated wastewater through this line. The new
Industrial User Permit (IUP) for the site limits daily average flow to the city at 150,000 gallons - 50,000
gallons less daily than the pump and haul permit. This commissioning process, in conjunction with a lower

allowable daily effluent flow, has led to a decrease in lagoon freeboard over the typical amount. Arauco
has been discharging water from pond 5C to pond 5D, as allowed in our permit, since the event, but is
limited as to how much can be transferred at one time due to the discharge limits in our IUP permit, and
the need to maintain an acceptable freeboard limit in pond 5D. The facility is committed to returning 5C
to a compliant freeboard level as it was prior to the extreme rainfall as expeditiously as our permit and
systems allow. No unallowable discharges have been noted by the facility at any point.
If you have any questions, please contact Savannah Carroll, Environmental Manager, at 919-545-5848 or
at 843-544-3025.
Sincerely,
4111L
Jeff McMillian
Plant Manager