WQ0003396_Compliance Report_20221123

DocuSign Envelope ID: 85F18269-1122-4D72-92BC-96AEFE5A6D65
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Henry Scheller, Plant Mananger
Arauco North America
955 Corinth Road
Mocure, NC 27559
Subject:
NORTH CAROLINA
Environmental Quality
November 30, 2022
Compliance Evaluation Inspection
Permit # WQ0003396
Facility: Arauco - Monocure WWTF/WW Irrigation system
Chatham County
Ms. Scheller,
On November 14, 2022, Jim Westcott and Tyler Clark from the Raleigh Regional Office
visited your wastewater treatment and irrigation system and met with Savannah Carroll to
evaluate compliance with the subject permit. Ms. Carrols' comprehensive tour of your
facility was informative and greatly appreciated.
The facility is permitted for the operation .03952 (MGD) wastewater treatment and
irrigation facility consisting of a 33.85-acre spray irrigation area and all associated piping,
valves, controls, and appurtenances with no discharge of wastes to surface waters.
The permit, which was issued August 6, 2021, is current and effective through July 31,
2025.
At the time of inspection, required maintenance, discharge, flow and meter calibration
records, spill prevention plan, residuals management plan, annual standard soil fertility
analysis, ORC documentation, GW-59 records and NDMR, NDAR were available for review.
The facility currently is transferring all its internal process waters to the city of Sanford's
Big Buffalo WWTF and totals a monthly average of 110,00 GPD under an administrative
waiver for non -discharge since November 6, 2020 and continues to operate under
Industrial User Permit (IUP 000042). The facility is permitted to discharge up to 150,000
GPD. The facility is permitted to operate a closed loop recycle and conjunctive reclaimed
North Carolina Department of Environmental Quality 1 Division of Water Resources
Raleigh Regional Office I 3800 Barren Drive I Raleigh, North Caro1ma 27609
919 791 4200

DocuSign Envelope ID: 85F18269-1122-4D72-92BC-9BAEFE5A6D65
water system which is currently not in use. All the 9 active spray fields have been offline
since June 2020.
The treatment system has been secured since November 2020. Residuals management plan
records indicate the remaining material collected from the W/W system was removed July
9, 2021 and transferred to pond C for residuals storage.
The Wastewater Treatment system has been secured since November 2020. Enco lab
draws the facility samples prior to discharge to the collection system once per six months
(O&G 4x/six months), the city of Sanford draws 4x/six months.
Sherill environmental draws monitoring well samples for GW-59 analysis and process
discharge waters including samples from a surface water sampling station located at a
downstream point of Shattock creek.
The permit does not have limits for any parameter other than monthly flow average,
frequency, and sample type. Record of certification for the facility ORC and backup ORC
were on file and available for review. Facility NDMR and NDAR forms were submitted as
required and reviewed.
The effluent flow meter(s) were last calibrated April 28, 2022 and are calibrated every six
months by Kewtech for both domestic and industrial water. Soils analysis was not
conducted during 2020. Analysis was conducted and records available for 2021 and 2022.
GW-59 reports for 2020-2021 were reviewed and corresponding lab results were reviewed
against the documents for accuracy from Pace Analytical. No discrepancies in the data were
noted and the facility is drawing the required samples as required by the permit.
Numerous wells at the facility have reported permit exceedances during the latest
sampling event (7/22/2022). Neary every monitoring well, excluding MW-20 at the facility
had reporting exceedances for the following parameters:
• MW-3: pH
• MW-4: TDS, Chloride
• MW-5: TDS, Chloride
• MW-8: TDS, Chloride, Fecal coliform
• MW-9: TDS, Fecal coliform
• MW-18R: pH
• MW-19: TDS, Chloride, Fecal coliform
• MW-20: no exceedances
• MW-21: TDS, Fecal coliform
Well MW-3 is within the review boundary. Wells MW-4, MW-5, MW-8, and MW-9 are
located between the review boundary and compliance boundary. Wells MW-18R, MW-19,
North Carolina Deossinicnt of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center 1 Raleigh, North Carolina 27699.1611
919.707.9000

DocuSign Envelope ID: 85F18269-1122-4D72-92BC-96AEFE5A6D85
MW-20 and MW-21 are all located outside of the permit compliance boundary. TDS and
chloride exceedances are historical and have been above permitted limits since 2005.
A visible inspection was attempted for all nine monitoring well on the property. All but one
well (MW-9) was inspected for locks and any potential damage. All wells were found to be
in satisfactory condition except for MW-5 which had a cracked concrete well pad possibly
damaged by mowing equipment. Wells MW-19, MW-20 and MW-21 are all located in the
floodplain of nearby Shaddox Creek to the east and could be subject to inundation during
an extreme flooding event.
Lagoons 5C and 5D were evaluated. The earthen dam separating the two lagoons has been
temporarily replaced by a large water filled coffer dam securing lagoon 5D while residual
materials were being removed and transferred to 5C. Additionally, the berm(s) are under
construction to build up the freeboard level(s) 2 feet or greater to meet the protection
requirements of the 100-year flood plain requirements of lagoon 5D.
The spray fields currently not in use are being evaluated for potential planting of certain
species of trees in conjunction with NC state as a potential research site to evaluate
nutrient uptake and removal efficiencies in remediated sites.
If you have questions or comments about this inspection or the requirements to take
corrective action (if applicable), then please contact Jim Westcott at
james.westcottOncdenr.gov or 919-791-4247.
Sincerely,
Decualened by:
EINALssa . M auA.ut,t,
B291eEMAB32141F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Laserfiche
North Carolina L7k,pmtne¢t of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
919 707.9000

DocuSign Envelope ID: 85F18289-1122-4D72-92BC-96AEFE5A6D65
iak915
North Carolina Department of Envunnmental Quality I Division of Water Resources
512 North Salisbury Street 1 16 k I Mail Service Center I Raleigh, North Carolina 27699-161 L
919.707.9000

Permit: WQ0003396
SOC:
County: Chatham
Region: Raleigh
Compliance Inspection Report
Effective: 08/06/21
Effective:
Expiration: 07/31/25 Owner : Arauco North America Inc
Expiration: Facility: Arauco - Moncure WWTF
985 Corinth Rd
Contact Person: Yvonne Couts Title: ORC
Directions to Facility:
South US1, exit onto Old US Hwy 1, Left on Corinth Rd, facility on left.
System Classifications: SI, WW2,
Primary ORC: Patrick Mays
Secondary ORC(s):
Patrick Mays
Rawindraraj Mylvaganam
On -Site Representative(s):
Related Permits:
Inspection Date: 11/14/2022 Entry Time 01:OOPM
Primary Inspector: James Westcott
Secondary Inspector(s):
Timothy Clark
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: II Compliant 0 Not Compliant
Question Areas:
▪ Treatment Flow Measurement -Effluent
▪ Treatment Flow Measurement -Water
Use Records
• Record Keeping
▪ End Use -Irrigation
• Treatment Disinfection
III Storage
• Wells
(See attachment summary)
Certification: 1010112
1009460
1007617
Moncure NC 27559
Exit Time: 03:30PM
Phone: [phone]
Phone: [phone]
919-642-6600
919-542-2128
Phone: [phone]
Inspection Type: Compliance Evaluation
▪ Treatment Flow Measurement -Influent
▪ Treatment
▪ Treatment Lagoons
• Treatment Influent Pump Station
IMI End Use -Infiltration
▪ End Use -Reuse
•
•
•
•
•
Miscellaneous Questions
Treatment Barscreen
Treatment Sludge Storage/Treatment
Treatment Clarifiers
Treatment Flow Measurement
Standby Power
Page 1 of 9

Permit: WQ0003396 Owner - Facility:Arauco North America Inc
Inspection Date: 11/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
At the time of inspection, required maintenance, discharge, flow and meter calibration records, spill prevention plan,
residuals management plan, annual standard soil fertility analysis and NDMR, NDAR and GW-59 records were available for
review.
The facility currently is transferring all its internal process waters to the city of Sanford's Big Buffalo WWTF and totals a
monthly average of 110,00 GPD under an administrative waiver for non -discharge since November 6, 2020 and continues to
operate under Industrial User Permit (IUP 000042). The facility is permitted to discharge up to 150,000 GPD. The facility is
permitted to operate a closed loop recycle and conjunctive reclaimed water system which is currently not in use. All the 9
active spray fields have been offline since June 2020.
The treatment system has been secured since November 2020. Residuals management plan records indicate the remaining
material collected from the W/W system was removed July 9, 2021 and transferred to pond C for residuals storage.
The Wastewater Treatment system has been secured since November 2020. Enco lab draws the facility samples prior to
discharge to the collection system once per six months (O&G 4x/six months), the city of Sanford draws 4x/six months.
Sherill environmental draws monitoring well samples for GW-59 analysis and process discharge waters including samples
from a surface water sampling station located at a downstream point of Shattock creek.
The permit does not have limits for any parameter other than monthly flow average, frequency, and sample type. Record of
certification for the facility ORC and backup ORC were on file and available for review. Facility NDMR and NDAR forms were
submitted as required and reviewed.
The effluent flow meter(s) were last calibrated April 28, 2022 and are calibrated every six months by Kewtech for both
domestic and industrial water. Soils analysis was not conducted during 2020. Analysis was conducted and records available
for 2021 and 2022.
GW-59 reports for 2020-2021 were reviewed and corresponding lab results were reviewed against the documents for
accuracy from Pace Analytical. No discrepancies in the data were noted and the facility is drawing the required samples as
required by the permit.
Numerous wells at the facility have reported permit exceedances during the latest sampling event (7/22/2022). Neary every
monitoring well, excluding MW-20 at the facility had reporting exceedances for the following parameters:
• MW-3: pH
• MW-4: TDS, Chloride
• MW-5: TDS, Chloride
• MW-8: TDS, Chloride, Fecal coliform
• MW-9: TDS, Fecal coliform
• MW-18R: pH
• MW-19: TDS, Chloride, Fecal coliform
• MW-20: no exceedances
• MW-21: TDS, Fecal coliform
Well MW-3 is within the review boundary. Wells MW-4, MW-5, MW-8, and MW-9 are located between the review boundary
and compliance boundary. Wells MW-18R, MW-19, MW-20 and MW-21 are all located outside of the permit compliance
boundary. TDS and chloride exceedances are historical and have been above permitted limits since 2005.
A visible inspection was attempted for all nine monitoring well on the property. All but one well (MW-9) was inspected for
locks and any potential damage. All wells were found to be in satisfactory condition except for MW-5 which had a cracked
Page 2of9

Permit: W00003396 Owner - Facillty:Arauco North America Inc
Inspection Date: 11/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
concrete well pad possibly damaged by mowing equipment. Wells MW-19, MW-20 and MW-21 are all located in the
floodplain of nearby Shaddox Creek to the east and could be subject to inundation during an extreme flooding event.
Lagoons 5C and 5D were evaluated. The earthen dam separating the two lagoons has been temporarily replaced by a large
water filled coffer dam securing lagoon 5D while residual materials were being removed and transferred to 5C. Additionally,
the berm(s) are under construction to build up the freeboard level(s) 2 feet or greater to meet the protection requirements of
the 100-year flood plain requirements of lagoon 5D.
The spray fields currently not in use are being evaluated for potential planting of certain species of trees in conjunction with
NC state as a potential research site to evaluate nutrient uptake and removal efficiencies in remediated sites
Page 3 of 9

Permit: WQ0003396 Owner - Facility: Arauco North America Inc
Inspection Date: 11/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
TVDe
Single Family Spray, LR
Activated Sludge Spray, LR
Activated Sludge Drip, LR
Single Family Drip
Reuse (Quality)
Lagoon Spray, LR
Infiltration System
Activated Sludge Spray, HR
RecyclelReuse
Treatment
Yes No NA NE
O
o
o
o
•
•
•
•
Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? 0 ❑ 0 .
Do all treatment units appear to be operational? (if no, note below.) DOOM
Comment: The W/W treatment system has been off line beginning November 2020 and all line power
secured / tied to the lift station for transfer of facility process water to the city of Sanford.
Treatment Influent Pump Station
Is the pump station free of bypass lines or structures?
Is the general housekeeping acceptable?
Are all pumps present?
Are all pumps operable?
Are floats/controls operable?
Are audio and visual alarms available?
Are audio and visual alarms operational?
# Are SCADA/Telemetry alarms required?
Are SCAPA/Telemetry available?
Are SCADA/Telemetry operational?
Comment:
Treatment Flow Measurement -Influent
Is flowmeter calibrated annually?
Is flowmeter operating properly?
Does flowmeter monitor continuously?
Does flowmeter record flow?
Does flowmeter appear to monitor accurately?
Yes No NA NE
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Yes No NA NE
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Comment: Q meter is calibrated by Kewtech every six months and the date of last calibration was 4/28/22.
Page 4 of 9

Permit: WQ0003396 Owner - Facility: Arauco North America Inc
Inspection Date: 11/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Treatment Flow Measurement -Water Use Records
Is water use metered?
Are the daily average values properly calculated?
Yes No NA NE
• ❑❑❑
▪ ❑❑❑
Comment: Daily Q is measured and the city of Sanford uses an average to determine billing for each
month.
Treatment Flow Measurement -Effluent
Is flowmeter calibrated annually?
Is flowmeter operating properly?
Does flowmeter monitor continuously?
Does flowmeter record flow?
Does flowmeter appear to monitor accurately?
Yes No NA NE
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• ❑ ❑ ❑
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Comment: Q meter calibrated every six months. Facility averages approx. 110.000 GPD. Running average
approx. 50.000 of internal process water.
Standby Power Yes No NA NE,
Is automatically activated standby power available? •❑ ❑ ❑
Is generator tested weekly by interrupting primary power source? •❑ ❑ ❑
Is generator operable? •❑ ❑ ❑
Does generator have adequate fuel? •❑ ❑ ❑
Comment:
Treatment Barscreen Yes No NA NE
Is it free of excessive debris? DOOM
Is disposal of screenings in compliance? ❑ ❑ ❑
Are the bars spaced properly? ❑ ❑ ❑
Is the unit in good condition? DOOM
Comment. Treatment system has been secured since November 2020.
Treatment Clarifiers Yes No NA NE
Are the weirs level? ❑ ❑ ❑
Are the weirs free of solids and algae? ❑ ❑ ❑
Is the scum removal system operational? DOOM
Is the scum removal system accessible? DOOM
Is the sludge blanket at an acceptable level? DOOM
Is the effluent from the clarifier free of excessive solids? DOOM
Comment: Treatment system has been secured since November 2020.
Treatment Sludge Storage/Treatment Yes No NA NE
Is the aeration operational? ❑ ❑ ❑ M
Is the aeration pattem even? ❑ ❑ ❑
Page 5of9

permit: WQ0003396 Owner - Facility: Arauco North America Inc
Inspection Date: 11/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
If required, are Sanitary "Ts" present in tankage? ❑ ❑ ❑ •
Comment: Treatment system has been secured since November 2020. Residuals manacement plan
records indicate the remaninu material collected from the W/W system was removed July 9.
2021 and transferred to pond C for residuals stoaraae.
Treatment Disinfection as No NA NE
Is the system working? ❑ ❑ ❑
Do the fecal coliform results indicate proper disinfection? ❑ ❑ ❑ •
Is there adequate detention time (>=30 minutes)? ❑ ❑ ❑ •
Is the system properly maintained? ❑ ❑ ❑ ■
If gas, does the cylinder storage appear safe? ❑ ❑ ❑
Is the fan in the chlorine feed room and storage area operable? ❑ ❑ ❑
Is the chlorinator accessible? ❑ ❑ ❑
If tablets, are tablets present? ❑ ❑ ❑•
Are the tablets the proper size and type? ❑ ❑ ❑ •
Is contact chamber free of sludge, solids, and growth? ❑ ❑ ❑
If UV, are extra UV bulbs available? DOOM
If UV, is the UV intensity adequate? ❑ ❑ ❑
# Is it a dual feed system? ❑ 0 0 •
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? ❑ ❑ ❑
If yes, then is there a Risk Management Plan on site? ❑ ❑ ❑•
If yes, then what is the EPA twelve digit ID Number? (1000- )
If yes, then when was the RMP last updated?
Comment: Treatment system has been secured since November 2020. Enco lab draws the facility samples
prior to discharge to the collection system once per six months (O&G 4x/six months), the city of
Sanford draws 4x/six months. Records for ORC and backup ORC are on file and were available
for review.
Record Keeping Yes No NA NE
Is a copy of current permit available? • ❑ ❑ ❑
Are monitoring reports present: NDMR? M000
NDAR? •❑ ❑ ❑
Are flow rates less than of permitted flow? ❑ • ❑ ❑
Are flow rates less than of permitted flow? ❑•❑ ❑
Are application rates adhered to? ❑ ❑ 0 •
Is GW monitoring being conducted, if required (GW-59s submitted)? • 0 ❑ ❑
Are all samples analyzed for all required parameters? •❑ ❑ ❑
Are there any 2L GW quality violations? •❑ ❑ ❑
Is GW-59A certification form completed for facility? •❑ ❑ ❑
Is effluent sampled for same parameters as GW? •❑ ❑ ❑
Page 6 of 9

Permit: W00003396 Owner - Facillty:Arauco North America Inc
Inspection Date: 11/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Do effluent concentrations exceed GW standards?
Are annual soil reports available?
# Are PAN records required?
# Did last soil report indicate a need for lime?
If so, has it been applied?
Are operational logs present?
Are lab sheets available for review?
Do lab sheets support data reported on NDMR?
Do lab sheets support data reported on GW-59s?
Are Operational and Maintenance records present?
Were Operational and Maintenance records complete?
Has permittee been free of public complaints in last 12 months?
Is a copy of the SOC readily available?
No treatment units bypassed since last inspection?
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O 0110
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Comment: 9 on site spray fields are inactive and have been decomitioned since June 2020. Sherill
environmental draws monitoring well samples for both W/W and GW-59 analysis / reports
including samples from a surface water sampling staion located at a downstream point of
Shattock creek.
End Use -Irrigation Yes No NA NE
Are buffers adequate? •❑ ❑ ❑
Is the cover crop type specified in permit? • 0 ❑ ❑
Is the crop cover acceptable? •❑ ❑ ❑
Is the site condition adequate? MIDE1121
Is the site free of runoff / ponding? M ❑ ❑ ❑
Is the acreage specified in the permit being utilized? •❑ ❑ ❑
Is the application equipment present? •❑ ❑ ❑
Is the application equipment operational? 0.00
Is the disposal field free of limiting slopes? •❑ ❑ ❑
Is access restricted and/or signs posted during active site use? ❑ ❑ ❑ ■
Are any supply wells within the CB? DOOM
Are any supply wells within 250' of the CB? ❑ ❑ ❑
How close is the closest water supply well? ❑ ❑ ❑
Is municipal water available in the area? DOOM
# Info only: Does the permit call for monitoring wells? •❑ ❑ ❑
Are GW monitoring wells located properly w/ respect to RB and CB? MOOD
Are GW monitoring wells properly constructed, including screened interval? MOOD
Are monitoring wells damaged? 00110
Page 7 of 9

Permit: WQ0003396 Owner - Facility: Arauco North America Inc
inspection Date: 11/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Comment: The 9 on site spray fields are inactive and have been secured since June of 2020.
End Use -Infiltration
# Is the application High Rate or Low Rate?
Are buffers maintained?
Are any supply wells within the CB?
Are any supply wells within 250' of the CB?
Is municipal water available in the area?
Are GW monitoring wells required?
Are GW monitoring wells located properly w/ respect to RB and CB?
Are GW monitoring wells properly constructed, including screened interval?
Is a usable green area maintained?
Is the disposal site acceptable?
is the distribution equipment acceptable?
Is the disposal site free of ponding?
Is the disposal site free of breakout?
Are the disposal sites free of solids, algae, etc.?
Do the records show that the fields are properly maintained?
Are the disposal sites free of vegetation?
Do any surface water features appear to be adversely Impacted by GW discharge?
No chemicals or rototiller used to eliminate vegetation, solids, algae, etc.?
Yes No NA NE
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Comment' Several of the monitoring wells have exceedances of TSS and Chlorides within the compliance
boundrv.
End Use -Reuse
Is the acreage in the permit being utilized?
Does the acreage specified in the permit correspond to the measured acreage at the site?
Are all essential units provided in duplicate?
Is an automatically activated standby power source available?
Is the equalization capacity adequate?
Is aerated flow equalization present?
Has the turbidity meter been calibrated in the last 12 months?
Does the turbidity meter have recording capabilities?
Is all flow diverted at the appropriate times?
Is all upset wastewater diverted from reuse storage unit?
Is all upset wastewater treated, retreated, or disposed of acceptably?
Is upset wastewater treated prior to discharge to irrigation storage?
is public access restricted from irrigation area during active site use?
Yes No NA NE
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111000
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Page 8 of 9

permit: WQ0003396 Owner - Facility: Arauco North America Inc
Inspection Date: 11/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
if golf course, is a sign posted in plain sight on the club house?
Is the cover crop acceptable?
Are buffers adequate?
Is the site free of pondinglrunoff?
Is the acreage in the permit being utilized?
Is the application equipment acceptable?
Is the application area free of limiting slopes?
How close is the closest water supply well?
Are any supply wells within the CB?
Are any supply wells within 250' of the CB?
Is municipal water available in the area?
Are GW monitoring wells required?
Are GW monitoring wells located properly w/ respect to RB and CB?
Are GW monitoring wells properly constructed, including screened interval?
❑ ❑❑■
• ❑ ❑❑
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• 000
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• 000
• 000
• 00111
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• 000
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• 000
Comment: The spray irrigation fileds have been out of service since June 2020 and a permit waiver is
active for the transfer of Q directly to the city of Sanford Big Buffalo WWTF via a direct tie in to
the city collection system.
Soils analysis was not conducted during 2020. Analysis was conducted and records availalble
for 2021 and 2022.
Page 9 of 9

1
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Est
Jim ■