WQ0003396_Inspection_20190315

ROY COOPER
Governor
MICHAEL S.REGAN +.
Secretary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
March 15, 2019
Henry Scheller, Plant Manager
Arauco North America
955 Corinth Road
Moncure,NC 27559
Subject: Compliance Evaluation Inspection
Arauco Panels-Moncure WWTF
Closed-Loop Recycle/Conjunctive Reclaimed Water/Wastewater
Irrigation
Permit Number W00003396
Chatham County
Mr. Scheller,
On March 14,2019,Rick Trone of the Raleigh Regional Office and Ashley Kabat of the Central office of
the Division of Water Resources conducted a compliance evaluation inspection of the wastewater
irrigation system at Arauco Panels. The purpose of this inspection was to ensure compliance with the
subject permit and inspect the facility for permit renewal. During the inspection,the cooperation and
assistance of Ms. Yvonne Couts was helpful and appreciated.
This compliance evaluation inspection consisted of the following:
• Review of the permit;
• Review of the owner/facility information;
• Review of ORC logbooks,calibration documentation,Non-discharge wastewater monitoring
reports(NDMR),Non-discharge application reports(NDAR),Compliance Monitoring Forms
(GW-59)and;
• On-site inspection of treatment components and spray fields
The current permit was issued April 22, 2013 and expired on November 30,2016. Permit renewal and
permit modification documents were received by this office on February 8,2019. Because of a history of
compliance issues with this system,Arauco would like to modify the system. Currently, the facility is
permitted to Pump and Haul up to 300,000 gallons of wastewater per day to Sanford's Big Buffalo
W WTP because the spray field system at Arauco cannot handle the current amount of water generated.
The City of Sanford is currently in the process of constructing a sewer line extension to serve Arauco.
This will allow Arauco the ability to pretreat wastewater and send it directly to the Big Buffalo W WTP.
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I MOD Barrett Drive I Raleigh.North Carolina 27609
r� /`� 919.791.4200

Mr.Henry Scheller
Arauco Panels NA
Page 2 of 3
3115119
The facility is permitted to operate a closed-loop recycle and conjunctive reclaimed water system. These
systems have not been used in some time,however,the facility hopes to repurpose this equipment to
assist in their pretreatment process.Arauco has also proposed an increase in their permitted flow limits
from 56,000 gallons per day to 120,000 gallons per day.
Components of the wastewater system appeared to be overall well-maintained.The effluent flowmeter
was last calibrated on March 12, 2018 and is due to be replaced soon.The facility keeps thorough records
of maintenance and activities involving the system including equipment calibration(e.g., pH meters,
irrigation equipment).
NDMR and NDAR forms are submitted as required with all information. Selected months of NDMR data
was compared against lab paperwork.No discrepancies were noted. Enco Labs analyzes effluent samples.
The facility is compliant with effluent sampling,however fecal coliform results are very high.A review
of sampling data indicates fecal numbers have decreased since the current ORC began operating the
system.These high fecal counts may suggest the system is not treating the effluent to a high enough
degree.This issue may be related to the age of the system. It should be noted that the current permit does
not have effluent limits for any parameter. The facility frequently exceeds the permitted limit for flow at
PPI 002(Influent flow to Side D of Lagoon 5), see condition violation below.
GW-59 reports for 2017-2018 were reviewed. Lab results for selected months were reviewed against
GW-59's for accuracy.No discrepancies were noted. It appears the facility is sampling groundwater as
required. Sherrill Environmental pulls samples from monitoring wells.The facility has a history of
exceedances of Total Dissolved Solids and Chlorides across multiple monitoring wells, see condition
violation below.Additionally,the facility is required to sample a surface water sampling station(SCMS).
Lagoons 5C and 5D were observed and appeared to be in satisfactory condition.The berm separating the
clean and dirty sides of lagoon 5 is quite low and storm events have caused the berm to be submerged.
Ponds 14 were also observed and appeared to be in overall good condition.A pump is set up in this area
to transfer wastewater to a tanker truck for movement to Big Buffalo W WTP. The package plant was also
inspected.All lights and alarms functioned when tested and the bar screen appeared to be mostly free of
debris.The clarifier did have a surface covering of solids.This apparently is an issue that occurs from
time to time.It should be noted that this package plant is considerably aged but appeared to be well
maintained at this time.
The facility maintains 9 spray fields with center pivot spray systems. With the current Pump and Haul
permit,the facility has much reduced the amount of water being sprayed on the fields.At the time of the
inspection,the spray system was not activated due to wet conditions.The fields were observed and
appeared to be well maintained and all fields had a nice cover of rye that looked healthy. Standing water
was observed near the center of Field 10. Standing water was also observed along the edges of Fields 2
and 3.This water is due to recent wet conditions, not spray events.A representative soil analyses for
spray fields was last conducted August 20, 2018. The NC Department of Agriculture performed the soil
analyses and no lime was recommended at that time.

Mr.Henry Scheller
Arauco Panels NA
Page 3 of 3
3/15/19
The following permit condition deficiencies were noted during the March 14,2019 compliance
inspection and records review:
II.Performance Standards
Condition 5,which states that, "Effluent quality shall not exceed the limitations specified in Attachment
A."The facility frequently exceeds the permitted limit for flow at PPI 002(Influent flow to Side D
of Lagoon 5). For the time November 2017-November 2018,flow at PPI 002 exceeded permitted
limits by 33.1%.
IV.Monitoring and Reporting Requirements
Condition 13, which states that,"...Monitoring wells shall be sampled thereafter at the frequencies and
for the parameters specified in Attachment C..."The facility has a history of exceedances of Total
Dissolved Solids and Chlorides across multiple monitoring wells.These exceedances are more than
limits specified in the current permit.
This office requests that you respond to this letter in writing within 30 days of receipt.
Your response should be sent to this office at the letterhead address. Your response should
address the following items as noted above. Please include in your response all corrective actions
already taken and a schedule for completion of any corrective actions not addressed.
If you have any questions about this inspection or this letter,please contact Rick Trone at
rick.trone(a cn denr.gov or 919-7914257.
Sincerely,
Rick Bolich,L.G.
Assistant Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
RRO Files