WQ0003396_Additional Information Request #1_20210107

DocuSign Envelope ID: 39DC973A-2DF0-4C6A-98CB-D7836945B471
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
JEFF MCMILLIAN — PLANT MANAGER
ARAUCO NORTH AMERICA, INC.
985 CORfNTHROAD
MONCURE, NORTH CAROLINA 27559
Dear Mr. McMillian:
NORTH CAROLINA
Environmental Quality
January 7, 2021
Subject: Application No. WQ0003396
Additional Information Request
Arauco — Moncure WWTF
Wastewater Irrigation
Chatham County
Division of Water Resources' Central and Regional staff has reviewed the application package
received November 3, 2020. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on February
8, 2021.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through P, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with an
electronic copy submitted to my attention at the email address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3660 or Lauren.Plummer(ancdenr.gov. Thank you for your cooperation.
S� c grcld By:
�/,llA/�,?Jf�, R((.lA,�i—�Q.UvYy1.Y11.Q/�r
1�f'Ba�-Plummer, Engineer III
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
George P. Tynan, PE — Civil & Environmental Consultants, Inc. (Electronic Copy)
Erik P. Messina, PE — Civil & Environmental Consultants, Inc. (Electronic Copy)
Permit Application File WQ0003396
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA
oePenmamorE.W. .,Q.si1 /`� 919.707.9000

DocuSign Envelope ID: 39DC973A-2DF0-4C6A-98CB-D7836945B471
Mr. Jeff McMillian
January 7, 2021
Page 2 of 5
A. Cover Letter:
1. A construction sequence was not provided within the engineering documents. It is unclear what
steps are necessary to perform the proposed modifications to Pond 5. Will a plant shutdown be
required in order to drain Ponds 5C and 5D? Please provide a detailed project timeline including
operational impacts and construction sequence.
B. Application Fee:
1. No Comment.
C. Application:
1. Item IL 1, our records list "Arauco North America, Inc." as the Permittee and "Arauco — Moncure
WWTF" as the Facility associated with WQ0003396, please ensure that the facility name is
consistent between the application, plans, specifications, agreements, etc.
2. Per General Requirements IV.1 and our records, the most recent permit issuance date is March 26,
2020 for Version 3.1 of WQ0003396. Please update the application accordingly.
3. Proposed modifications to stormwater/wastewater storage Pond 5 may require additional
permits/certifications described in General Requirements IVA Please review and indicate which
permits/certifications are applicable (e.g. stormwater, wetlands, dam safety), and for those
applicable permits/certifications please provide a status update.
4. The response to General Requirements IV.8 indicates that written documentation of compliance
with § 143 Article 21 Part 6 was provided; however, this documentation was not found in the
submittal package.
5. Item VI.3 was left blank in the submitted application. Please review this item and update the
application accordingly.
6. The response to Item VL8 indicates that the depth to bedrock is unknown. In the second part of
the question, the applicant indicates that hydraulic conductivity requirements for the liner are not
applicable. Is the depth to bedrock known from the nearby monitoring well logs and is it greater
than four feet? Please provide clarification and update the application accordingly.
The proposed modifications will alter the geometry of existing Pond 5 and include removal of
material from the Pond 5 footprint. The site visit performed by Non -Discharge Branch staff
observed that nearby surface waters are located at elevations that appear to be visually similar to
the elevation of the existing pond. Please provide mean seasonal high water table (SHWT) data
per Item VL9 to support that liner protections are not needed as part of this design to prevent
groundwater infiltration. Please note, that the mean SHWT depth value should also be added to
the table provided in Item VI.12.
Item VI.10 was left blank in the submitted application. Please provide the specification page
references for the liner installation and testing requirements. Please note, the specification section
reference should also be added to the table provided in Item VI.12.

DocuSign Envelope ID: 39DC973A-2DF0-4C6A-98CB-D7836945B471
Mr. Jeff McMillian
January 7, 2021
Page 3 of 5
Per Section VIII regarding setbacks, the proposed modification alters the footprint of
treatment/storage units and will require this section to be completed in the application. Please
complete this section and provide any necessary documentation as needed.
D. Property Ownership Documentation:
1. No comment.
E. Soil Evaluation:
1. Not applicable.
F. Agronomist Evaluation:
1. Not applicable.
G. Hvdroeeolo2ic Report:
A hydrogeologic report was not provided. Information related to bedrock and the seasonal high
water table (SHWT) are necessary for the proposed modification.
H. Water Balance:
1. The proposed modification alters the footprint and geometry of Pond 5. This modification affects
total volume and to surficial area for local run-off collection. Will these changes affect the existing
permitted rate? Please verify that the pond is sized adequately given the changes in surface area.
I. Eneineerine Plans:
Sheet C300 provided notes regarding the proposed impervious fill/liner and compacted fill
material; however, these notes pertained to physical properties and did not include any chemical
analysis requirements. The proposed fill material source should be identified and evaluated so that
it can be confirmed that fill material will be free from any contaminants, etc. If there is some
question about the quality of the source, then testing should be considered.
Per Sheet C300, a portion of the expanded Pond 5 footprint impacts an isolated wetland area that
was delineated by the United States Army Corps of Engineers prior to the site visit performed by
Non -Discharge Branch staff on December 4, 2020. The area to be impacted was not quantified on
Sheet C300, and it is our understanding that a decision regarding the permitting of isolated wetland
impacts at the State and Federal level is to be discussed at the January 2021 North Carolina
Environmental Management Commission (EMC) meeting. Please provide an update regarding
whether permitting is obtainable for the proposed impacts.
3. Per Sheet C300, Ponds 5C and 5D will be separated by a berm; however, it does not appear a
discharge line is to be installed between Pond 5C and Pond 5D to replace the one being removed
as part of the proposed work. At the December site visit, Pond 5C was operating with
approximately 1 foot of freeboard, and the site contact indicated that they do use the discharge line
to maintain the water elevation in Pond 5C. The proposed work does not increase the berm

DocuSign Envelope ID: 39DC973A-2DF0-4C6A-98CB-D7836945B471
Mr. Jeff McMillian
January 7, 2021
Page 4 of 5
elevation for Pond 5C. Additionally, the footprint of Pond 5C is to be decreased to allow for the
Pond 5D modifications. It is unclear whether Pond 5C will be able to discharge to lower its volume
and continue to serve as local stormwater storage.
4. Per the Plan Set, it is unclear whether the inlet and discharge piping from Pond 5D is to be modified
as part of this work as the inlet and outlet structures were not depicted as part of the existing
conditions or site grading plan sheets.
J. Specifications:
1. Within Section 31 0100 EARTHWORK, please address the following:
a. The specifications reference the "Geotechnical Engineering Report for Existing Arauco Pond
Embankments" dated September 25, 2017 for specific soils information and compaction
requirements. This document was not included in the submittal but the information within this
report should be included in the specifications under signature and seal.
b. Fill material specifications within Part 2 PRODUCTS do not indicate soil type requirements or
distinctions between impervious liner fill material and compacted berm fill material. Please review
this section and provide additional information as necessary.
c. Within Part 3.2 (A) FILLING AND COMPACTION keyways at the toe of the slopes and benching
are referenced as being indicated on the Plan Set. A detail or other note indicating the keyways at
the toe of each fill slope was not depicted in the drawings. Please review the specifications and
plan drawings and revise as necessary.
Dewatering specifications within Section 31 04 00 EXCAVATION AND BACKFILL were
standard and did not appear to address the considerable volume of water that is to be removed out
of Ponds 5C and 5D to perform the proposed work. Additionally, process wastewater will still be
generated as it does not appear that the facility will be halting operations during construction.
Please provide additional information regarding the management of wastewater and local
stormwater during the proposed modification work.
K. Engineering Calculations:
The proposed modifications will also be adjusting the effective volume of Pond 5C which is
included in the permit. Please provide engineering calculations for the existing and proposed
volumes of Pond 5C, Pond 51), and combined Pond 5.
L. Site Map:
1. Site maps provided in Appendix F were not signed, sealed, and dated by a North Carolina licensed
Professional Engineer and/or Professional Land Surveyor.
M. Power Reliability Plant:
1. No comment.
N. Operation & Maintenance Plan:

DocuSign Envelope ID: 39DC973A-2DF0-4C6A-98CB-D7836945B471
Mr. Jeff McMillian
January 7, 2021
Page 5 of 5
1. No comment.
O. Residuals Management Plan:
1. The existing residuals management plan refers to residuals being periodically cleaned from the
pond. A plan for the disposal of pond solids generated during the proposed modification was not
provided. It is anticipated that a volume of solids will be removed in order to construct the enlarged
berm.
P. Additional Documentation:
➢ Certificate of Public Convenience and Necessity:
1. Not applicable.
➢ Existing Permit:
1. No comment.
➢ Final Environmental Document:
1. Not applicable.
➢ Floodway Regulation Compliance:
1. Pond 5 and the proposed modifications are located within the 100-year floodplain, please
provide written documentation from all local governing entities that the facility is in
compliance with all local ordinances regarding construction or operation of wastewater
treatment and/or disposal facilities within the floodplain.
➢ Operational Agreements:
1. Not applicable.
➢ Threatened or Endangered Aquatic Species Documentation:
1. No comment.
➢ Wastewater Chemical Analysis:
1. No comment.