WQ0003396_Additional Information Response #2_20210419

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Civil & Environmental Consultants, Inc.
April 19, 2021
Ms. Lauren Raup-Plummer
Division of Water Resources
Raleigh Regional Office
North Carolina Department of Environmental Quality
512 North Salisbury Street
Raleigh, NC 27699-1617
Dear Ms. Raup-Plummer:
Subject: Application No. WQ0003396
Additional Information Request 92
Arauco — Moncure WWTF
Chatham County
CEC Project 195-440
Per NCDEQ's review of the above referenced project, CEC is providing additional information as
requested by you on your letter dated March 18, 2021.
C. Application:
The table under IVA in General Requirements indicates that the Erosion & Sedimentation
Control Plan and the Wetlands 401 permit are pending and have not yet been submitted to
their respective agencies for review. The provided email correspondence within
Attachment I of the response package indicates that the Wetlands 401 permit was still in
discussion and not yet submitted for review. Pursuant to 15A NCAC 02T .0104 (c)(6)
please provide documentation that these permits have been applied for as they are part of
the critical pathway for the proposed work.
Resolution: The Wetlands 401 permit was submitted March 11, 2021. Regarding the permitting
status of the isolated wetland impacts, please see the attached April 15, 2021 e-mail (and e-mail
string) from Stephanie Goss and Sue Homewood of the NC DWR Winston Salem Regional Office,
regarding a concurrence with CEC's and ACOE's isolated wetlands determination. As the current
project design is dependent on NC DWR's acceptance to our March 11, 2021 submittal, the
Erosion & Sedimentation Control and Floodplain Permit applications have not been submitted
pending NCDEQ concurrence. The critical pathway for the proposed work is NC DWR 's approval
with the concurrence CEC received from the ACOE. If this approval is not received, the project
will be required to be redesigned.
April 19, 2021: Per the attached e-mail, please note that the March 11, 2021 submittal was
approved by NCDEQ on April 15, 2021. We are now proceeding with preparation of the Erosion
3701 Arco Corporate Drive, Suite 400 1 Charlotte, NC 28273 1 p: 980-237-0373 f: 980-237-0372 1 www.cecinc.com

Ms. Lauren Raup-Plummer — NCDEQ
CEC Project 195-440
Page 2
April 19, 2021
& Sedimentation Control and Floodplain Permit applications. We anticipate submittal of the
permit applications within two to three weeks.
2. The response to Item CA within the previous additional information request was a revised
application submitted with the response to General Requirements IV.8 modified to indicate
that written documentation of compliance with General Statute § 143 Article 21 Part 6 was
not provided. However, this documentation is required for the proposed work due to the
storage facilities being located within the 100-year flood plain. It appears that there may
have been some confusion about the document referenced. Please note that this
documentation is to be provided by a local government entity (i.e., Chatham County) and
is separate from the 401/404 permitting process. Please review GS 143-215.51 through
GS 143-215.61 for additional information regarding floodway regulation and provide the
written documentation of compliance as required.
Resolution: The current project design is dependent on NC DWR's acceptance to our March 11,
2021 submittal. Therefore, the Erosion & Sedimentation Control and Floodplain Permits have not
been submitted for pending NCDEQ concurrence. The critical pathway for the proposed work is
NC DWR's approval with the concurrence CEC received from the ACOE. If this approval is not
received, the project will be required to be redesigned.
April 19, 2021 Update: Per the attached e-mail, please note that the March 11, 2021 submittal
was approved by NCDEQ on April 15, 2021. We are now proceeding with preparation of the
Erosion & Sedimentation Control and Floodplain Permit applications. We anticipate submittal
of the permit applications within two to three weeks.
O. Residuals Management Plan:
1. Your response indicated that materials excavated out of Pond 5D will be placed in Pond
5C as outlined in the current Residuals Management Plan. Does Pond 5C have sufficient
capacity to accept these residuals? Additionally, your response referenced that sludge
analyses to date indicate that the process sludge is within the acceptable range for land
application. Our records do not indicate that a land application permit is active for Arauco
— Moncure WWTF. Please note that a separate residuals management permit is required if
waste residuals are to be land applied.
Resolution: Materials excavated out of Pond 5D has been estimated to be 6,519 cubic yards.
Pond 5C has an estimated capacity of 20, 667 cubic yards to the existing embankment. As shown
in the attached exhibit, Pond 5C has sufficient capacity to accept these residuals. Therefore, we
do not expect to have to land apply waste residuals.
Civii & Environmental Consultants, Inc.

Ms. Lauren Raup-Plummer — NCDEQ
CEC Project 195-440
Page 3
April 19, 2021
Please let us know if you need any additional information in support of this review.
Sincerely,
CIVIL, & ENVIRONMENTAL CONSULTANTS, INC.
Erik P. Messina, P.E. George P. Tyri , P.E.
Project Manager Project Manager
Enclosures
cc: S. Carroll, Arauco
J. Bird, Arauco
Civii & Environmental Consultants, Inc.

ATTACHMENT 1
Civil & Environmental Consultants, Inc.

Tyrian, George
From: Thomas, Kevin
Sent: Thursday, April 15, 2021 3:34 PM
To: Messina, Erik; Tyrian, George
Subject: FW: [External] RE: NC DEQ Isolated Waters Determination Request Submittal Packet;
Arauco Flakeboard / 1985 Corinth Road / Moncure / Chatham County
Gents.
The Division has concurred with our determination on the two isolated features.
Please let the Client know and please let them know we greatly appreciated the opportunity to be of service.
Take care and talk soon,
Kevin Thomas, PWS & LSS (NC, SC & FL) / Senior Project Manager
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive - Suite 400 - Charlotte, NC 28273
Toll -Free: 855-859-9932 - Direct: 980-260-2035 - Fax: [phone]
Mobile: [phone] - http://www.ceeine.com
Senior Leadership - Integrated Services - Personal Business Relationships
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notify the sender by reply electronic communication and immediately delete this message from your system.
From: Goss, Stephanie <[e-mail]>
Sent: Thursday, April 15, 2021 3:02 PM
To: Thomas, Kevin <[e-mail]>
Subject: RE: [External] RE: NC DEQ Isolated Waters Determination Request Submittal Packet; Arauco Flakeboard / 1985
Corinth Road / Moncure / Chatham County
Kevin,
I apologize for the delay in getting back to you.
The Division concurs with your determination for the features.
Stephanie Z. Goss
Environmental Program Consultant
Division of Water Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 276og
919-791-4256
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Thomas, Kevin [mailto:[e-mail]]
Sent: Wednesday, April 14, 2021 2:11 PM
To: Goss, Stephanie <[e-mail]>
Subject: RE: [External] RE: NC DEQ Isolated Waters Determination Request Submittal Packet; Arauco Flakeboard / 1985
Corinth Road / Moncure / Chatham County
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hi Stephanie.
Any update? The Client owes NC DEQ an update and I was just checking in.
Hope all is well.
Kevin Thomas, PWS & LSS (NC, SC & FL) / Senior Project Manager
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive - Suite 400 - Charlotte, NC 28273
Toll -Free: 855-859-9932 - Direct: 980-260-2035 - Fax: [phone]
Mobile: [phone] - http://www.ceeine.com
Senior Leadership - Integrated Services - Personal Business Relationships
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notify the sender by reply electronic communication and immediately delete this message from your system.
From: Goss, Stephanie <[e-mail]>
Sent: Thursday, April 1, 2021 4:04 PM
To: Thomas, Kevin <[e-mail]>
Subject: RE: [External] RE: NC DEQ Isolated Waters Determination Request Submittal Packet; Arauco Flakeboard / 1985
Corinth Road / Moncure / Chatham County
Kevin,
I apologize for the delay in getting back to you. I have been swamped and I have not been able to review your
documentation. I will review as soon as soon as possible.
Stephanie Z. Goss
Environmental Program Consultant
Division of Water Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 276o9
919-791-4256
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Thomas, Kevin [mailto:[e-mail]]
Sent: Thursday, April 1, 2021 10:18 AM

To: Homewood, Sue <[e-mail]>; Goss, Stephanie <[e-mail]>
Cc: Messina, Erik <[e-mail]>; Tyrian, George <[e-mail]>
Subject: [External] RE: NC DEQ Isolated Waters Determination Request Submittal Packet; Arauco Flakeboard / 1985
Corinth Road / Moncure / Chatham County
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Ms. Homewood and Goss.
Just checking to make sure you have everything you need to make your determinations.
Please let me know if I can help facilitate as the Client is up against a deadline impose by NC DEQ.
I hope everyone has a great Easter weekend.
Kevin Thomas, PWS & LSS (NC, SC & FL) / Senior Project Manager
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive - Suite 400 - Charlotte, NC 28273
Toll -Free: 855-859-9932 - Direct: 980-260-2035 - Fax: [phone]
Mobile: [phone] - http://www.ceeine.com
Senior Leadership - Integrated Services - Personal Business Relationships
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notify the sender by reply electronic communication and immediately delete this message from your system.
From: Thomas, Kevin
Sent: Thursday, March 11, 2021 3:13 PM
To: Homewood, Sue <[e-mail]>; Goss, Stephanie <[e-mail]>
Cc: Messina, Erik <[e-mail]>; Tyrian, George <[e-mail]>
Subject: NC DEQ Isolated Waters Determination Request Submittal Packet; Arauco Flakeboard / 1985 Corinth Road /
Moncure / Chatham County
Ms. Homewood and Goss.
Please find attached an Non-404 Isolated Waters (Wetland) Determination Request Submittal
for Arauco Flakeboard at their facility near the city of Moncure in Chatham County, NC. Once
you've had time to review the submittal please let me know if it is complete, or if you need
further information to make your determination.
Take care and talk soon.
Kevin Thomas, PWS & LSS (NC, SC & FL) / Senior Project Manager
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive - Suite 400 - Charlotte, NC 28273

Toll -Free: 855-859-9932 - Direct: 980-260-2035 - Fax: [phone]
Mobile: [phone] - http://www.ceeine.com
Senior Leadership - Integrated Services - Personal Business Relationships
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notify the sender by reply electronic communication and immediately delete this message from your system.
From: Homewood, Sue <[e-mail]>
Sent: Tuesday, February 2, 2021 10:11 AM
To: Thomas, Kevin <[e-mail]>; Goss, Stephanie <[e-mail]>
Cc: Messina, Erik <[e-mail]>; Tyrian, George <[e-mail]>
Subject: RE: [External] RE: SAW-2020-01778 (Arauco Flakeboard / 1985 Corinth Road / Moncure / Chatham County
Thanks Kevin,
There are no exempted activities under 02B .0230, those are deemed permitted activities that match the 404
exemptions in the USACE regulations for jurisdictional wetlands. Did you mean the exemptions listed in Section 02H
.1300(c)?
If so, those rules are specific to what is exempt from permitting for isolated wetlands. So the first step is to determine it
is isolated, which is different than "excluded". Isolated is the old "no significant nexus" determination. It sounds like
this wetland would fall into that category but I want to be sure we're all saying the same thing so that it's clear for future
situations.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Thomas, Kevin <[e-mail]>
Sent: Tuesday, February 2, 2021 9:42 AM
To: Homewood, Sue <[e-mail]>; Goss, Stephanie <[e-mail]>
Cc: Messina, Erik <[e-mail]>; Tyrian, George <[e-mail]>
Subject: RE: [External] RE: SAW-2020-01778 (Arauco Flakeboard / 1985 Corinth Road / Moncure / Chatham County
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Hi Sue
Thank you for the rapid reply as the Client is in need of a response to NC DEQ comments, for the pond, very soon. The
initial delineation was performed in September 2020, and we were all just becoming familiar with the New Navigable
Waters Protection Ruling (NWPR). I'm attaching our original findings. What you will note is WA-3 (The isolated or
excluded feature) is classified as Palustrine Unconsolidated Bottom Permanently Flooded Excavated Wetland. You will
note on figure 6 that the "feature" takes the shape of the base of the existing berm.
WA-3 was created in Upland Soil (See attached Report with both On-line and Published Soil Maps) by excavating
material (Non-Hydric Soil) for construction of the existing Berm. We feel WA-3 would be considered exempt as
described in 15A NCAC 02B .0230 as an isolated man-made pond/wetland, and it was created as a portion of the
Discharges of treated effluent into isolated wetlands and isolated classified surface waters resulting from activities that
receive NPDES Permits or State Non -Discharge Permits.
CEC utilized the NWPR language as it is now the accepted Rule in 49 of 50 states, with the one exception being Colorado.
Please advise if our original Report, Attached, will serve as enough documentation to rule the feature (WA-3) as exempt,
allowing the Client to proceed with the expansion of the Berm?
Talk soon,
Kevin Thomas, PWS & LSS (NC, SC & FL) / Senior Project Manager
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive - Suite 400 - Charlotte, NC 28273
Toll -Free: 855-859-9932 - Direct: 980-260-2035 - Fax: [phone]
Mobile: [phone] - http://www.ceeine.com
Senior Leadership - Integrated Services - Personal Business Relationships
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notify the sender by reply electronic communication and immediately delete this message from your system.
From: Homewood, Sue <[e-mail]>
Sent: Monday, February 1, 2021 5:04 PM
To: Thomas, Kevin <[e-mail]>; Goss, Stephanie <[e-mail]>
Cc: Messina, Erik <[e-mail]>; Tyrian, George <[e-mail]>
Subject: RE: [External] RE: SAW-2020-01778 (Arauco Flakeboard / 1985 Corinth Road / Moncure / Chatham County
Hi Kevin,
Wetlands are protected under NC state regulations 15A NCAC 02B .0231 (State Wetland Standards) and
cannot be impacted except through appropriate permitting frameworks/regulations. The current State
permitting frameworks for wetlands that are NOT federally jurisdictional, and therefore not subject to Section
404 of the Clean Water Act are:
1. Isolated wetlands may be permitted in accordance with 15A NCAC 02H .1300 et. seq.
2. There is currently no permitting mechanism to authorize impacts to federally non -jurisdictional
wetlands that are not Isolated.

The term "Isolated" was used by the USACE prior to June 2020. And the Division will follow the same process
used by the USACE. You will want to conduct analysis of whether there is a "significant nexus" for the wetland
in question as outlined in Clean Water Act Jurisdiction Following the U.S. Supreme Court's Decision in Rapanos
v United States & Carabell v. United States. If you want Division confirmation of your analysis then you would
send your documentation to the appropriate DWR regional staff. The Division may need to conduct a site visit
after submittal of documentation and prior to confirmation.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Thomas, Kevin <[e-mail]>
Sent: Monday, February 1, 2021 2:26 PM
To: Goss, Stephanie <[e-mail]>; Homewood, Sue <[e-mail]>
Cc: Messina, Erik <[e-mail]>; Tyrian, George <[e-mail]>
Subject: [External] RE: SAW-2020-01778 (Arauco Flakeboard / 1985 Corinth Road / Moncure / Chatham County
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Ms. Goss and Homewood.
Please find attached the Approved JD for the above referenced site, in Chatham County, NC.
Ms. Goss, you may recall we spoke on Dec, 2, 2020 about this project. The Client operates a particle wood
manufacturing plant in Moncure, NC. NC DEQ is requiring Arauco to raise the existing top elevation of the existing Ponds
berm two feet above the published FEMA FIRM Map 100 year flood plain elevation (See attached AJD or Figure 6). To
meet the states requirements the berms base will need to be expanded into the excluded feature WA 3.
Per your request I have included Ms. Homewood on this communication, as I'd like some direction on how we should
proceed with the project. NC DEQ is requiring this work to be done to the existing ponds and at this time the only
alternative is to expand the existing pond berm base and height.
Thank you for your time and we look forward to hearing from y'all soon.
Talk soon.
Kevin Thomas, PWS & LSS (NC, SC & FL) / Senior Project Manager

Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive - Suite 400 - Charlotte, NC 28273
Toll -Free: 855-859-9932 - Direct: 980-260-2035 - Fax: [phone]
Mobile: [phone] - http://www.ceeine.com
Senior Leadership - Integrated Services - Personal Business Relationships
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notify the sender by reply electronic communication and immediately delete this message from your system.
From: Thomas, Kevin
Sent: Wednesday, December 2, 2020 10:36 AM
To: [e-mail]
Subject: FW: SAW-2020-01778 (Arauco Flakeboard / 1985 Corinth Road / Moncure / Chatham County
Thanks for the call.
Kevin Thomas, PWS & LSS (NC, SC & FL) / Senior Project Manager
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive - Suite 400 - Charlotte, NC 28273
Toll -Free: 855-859-9932 - Direct: 980-260-2035 - Fax: [phone]
Mobile: [phone] - http://www.ceeine.com
Senior Leadership - Integrated Services - Personal Business Relationships
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notify the sender by reply electronic communication and immediately delete this message from your system.

ATTACHMENT 2
Civil & Environmental Consultants, Inc.

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REFERENCE
1. EXISTING CONDITIONS DATA COMBINED FROM SURVEYS BY MIKE CAIN SURVEYING DATED
1 1-14-2016 & 8-30-2017, PATTERSON LAND SURVEYING, P.A. DATED 12-4-2015, AND
GIS DATA OBTAINED FROM THE CHATHAM COUNTY GIS DATABASE. DATA WAS ADJUSTED TO
GENERATE BASE MAP AS NEEDED.
2. PRELIMINARY WATERS OF THE UNITED STATES DELINEATION AND DETERMINATION WAS
PERFORMED BY CIVIL & ENVIRONMENTAL CONSULTANTS, INC. ON SEPTEMBER 8 & 9, 2020.
EXISTING PROPERTY LINE
EXISTING INDEX CONTOUR
--
EXISTING INTERMEDIATE CONTOUR
EXISTING GRAVEL
EXISTING CONCRETE
EXISTING STRUCTURE
POTENTIAL NON —JURISDICTIONAL WETLAND
POTENTIAL JURISDICTIONAL WETLAND
EXISTING FEMA FLOOD ZONE BOUNDARY
NOTES:
1. SEE SHEET C001 FOR GENERAL NOTES
2. CONTRACTOR SHALL REFER TO OTHER PLANS WITHIN THIS SET FOR OTHER
PERTINENT INFORMATION. IT IS NOT THE ENGINEER'S INTENT THAT ANY SINGLE
PLAN SHEET IN THIS SET OF DOCUMENTS FULLY DEPICT ALL WORK ASSOCIATED
WITH THE PROJECT.
3. PRELIMINARY WATERS OF THE UNITED STATES DELINEATION AND DETERMINATION
REPRESENTS BEST PROFESSIONAL JUDGEMENT REGARDING POTENTIAL OF
ON —SITE WETLANDS, STREAMS, AND OTHER WATER FEATURES AT THE TIME OF
THE INVESTIGATION TO BE USED FOR PRELIMINARY PROJECT PLANNING ONLY.
PRIOR TO ANY CONSTRUCTION OR EARTH DISTURBANCE, A FORMAL APPROVED
JURISDICTIONAL DETERMINATION (AJD) SHOULD BE OBTAINED FROM THE UNITED
STATES ARMY CORPS OF ENGINEERS (USACE).
FINAL DESIGN
NOT RELEASED FOR CONSTRUCTION
BEFORE YOU DIGI
CALL 1-800-632-4949
N.C. ONE —CALL
CENTER ITS THE LAW
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