WQ0003380_Additional Information Request_20210910

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
MICHAEL GOLDEN — PLANT MANAGER
GEORGIA-PACIFIC WOOD PRODUCTS LLC
139 BREWINGTON ROAD
DUDLEY, NORTH CAROLINA 28333
Dear Mr. Golden:
NORTH CAROLINA
Environmental Quality
September 10, 2021
Subject: Application No. WQ0003380
Additional Information Request
Georgia-Pacific — Dudley Plywood
Facility CLRS
Closed -Loop Recycle System
Wayne County
Division of Water Resources' Central and Regional staff has reviewed the application package
received June 28, 2021. 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 October 11, 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 M, 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 our upload site (URL: hiips://edocs.deg.nc.gov/Fonns/NonDischarg_e-
Branch-Submittal-Form-Ver2).
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.
Sincerely
L.1n�,uSid by1vW:Ul1P.GUAP—�QaLWlm
i�,Y��§4lummer, Engineer III
Division of Water Resources
cc: Washington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Donald Baker, PE — Don Baker Engineering LLC (Electronic Copy)
Permit Application File WQ0003380
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 CAROHNA -
Deaa�entote.Wro,memsiQuality r 919.707.9000

Mr. Michael Golden
September 10, 2021
Page 2 of 4
A. Cover Letter:
1. No comment.
B. Application Fee:
1. No comment.
C. Application:
The wastewater flow, provided under the General Requirements section (Item IV), appears to be
for the modifications (e.g. what is to be added to the overall capacity of the system) and a total
system capacity was not provided. Looking through the submitted documents, there appears to be
a discrepancy regarding the current closed -loop recycle system's capacity. Within the Operation
and Maintenance (O&M) Plan the facility is described as a 286,443 gallon per day (GPD)
wastewater treatment and closed -loop recycle system; this appears to be the combined volume of
the surge basin (121,984 gallons) and the log heating vat water recycle system (164,459 gallons).
The existing permit, dated October 29, 2018, lists a total capacity of 221,984 GPD which is the
combined volume of the surge basin (same as above) and the log heating vat water recycle system
(100,000 gallons). The modifications are purported to add an additional 38,006 gallons which does
not account for the difference. Please review and revise the application and provide both the
existing, as constructed, facility capacity and the proposed facility capacity upon completion of the
vat modifications.
Within the application Item V.3., the applicant indicated that the Dudley Plywood Facility closed -
loop recycle system has the ability to store the effluent when recycling cannot be conducted as
required by 15A NCAC 02U .0404. The proposed modification includes the addition of two (2)
19,003 gallon vats served by singular pumps, and it is unclear if the current facility configuration
is sufficient should the equipment within either Vat 8 or Vat 9 become inoperable. The project
narrative and O&M plan indicate the water in the "cold water section" is kept low to hold 7 vats in
any emergency, but it is unclear whether it is capable of holding 9 vats, as proposed. Is the "cold
water section" referring to the surge basin? Additionally, the O&M plan indicates that each chopper
pump has a spare in case of failure, are these spares compatible with the proposed chopper pumps
in Vats 8 and 9? Please provide additional information and review and revise the submittal, if
necessary.
D. Property Ownership Documentation:
1. No comment.
E. Water Balance:
1. No comment.

Mr. Michael Golden
September 10, 2021
Page 3 of 4
F. En2ineerin2 Plans:
Call -outs or notes indicating the designed freeboard within the proposed vats and moat extension
were not provided. It is unclear whether the moat and vats are designed to contain the accumulation
of water from a 25-year, 24-hour storm event with 1 foot of freeboard as required pursuant to 15A
NCAC 02U .0404(c)(6). Please revise the plans using call -outs or notes to indicate that the
requirement is met.
G. Specifications:
1. A complete set of specifications are to be provided separate from the engineering plans pursuant to
15A NCAC 02T .0105. Specifications should include material and installation requirements for
proposed structures, piping, pumps, and all other appurtenances, at minimum. Specifications must
be signed, sealed, and dated by a North Carolina licensed Professional Engineer in good standing.
A project construction sequence was not provided, and it is unclear whether the proposed
modifications will impede the operation of the existing closed -loop recycle system. Please provide
a construction sequence and indicate which tasks (if any) will require bypassing or operations
shutdown.
H. Engineering Calculations:
1. No comment.
I. Site May:
The different facility components are depicted piecemeal between several of the engineering
drawings. Please provide an additional site map that depicts/identifies the essential components of
the closed -loop recycle facility (e.g. the surge basin, vats 1-7, proposed vats 8 and 9, the
scrubber/clarifier, the ash settling basins, the veneer dryer washdown storage tank) as required
pursuant to 15A NCAC 02T .0105(c)(5). Please also consider indicating which components are
related to the cold -water and hot-water sections as they are designated within the O&M Plan.
J. Power Reliability Plan:
1. No comment.
K. Operation & Maintenance Plan:
1. See Comments C.1 and C.2.
L. Residuals Management Plan:
1. No comment.

Mr. Michael Golden
September 10, 2021
Page 4 of 4
M. 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. Not applicable.
➢ Threatened or Endangered Aquatic Species Documentation:
1. No comment.
➢ Wastewater Chemical Analysis:
1. A wastewater chemical analysis was not provided. Please confirm that no changes to the
composition of the recycled industrial effluent have occurred since the last permit issuance.