WQ0003396_CEI Response_20190403

985 Corinth Road
Moncure,North Carolina 27559
Tel: 42-6600
arauco Toll Free:855-427
-2826
Fax:[phone]
April 3, 2019
CERTIFIED MAIL 7018 2290 00014576 3375
Return Receipt Requested
NC Dept of Environmental Quality
Rick Bolich
Division of Water Resources APR - 8 2019
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609 Raleigh Regional Office
Subject: Compliance Evaluation Inspection
Arauco North America, Inc. is submitting this response to the Division of Water Resources pertaining to
the Compliance Evaluation Inspection performed March 14, 2019. Arauco was asked to address the
following issues:
U. 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%.
On January 25, 2019, Arauco submitted an application to have the current influent flow rate increased
from 56,000 gpd to 120,000 gpd.Since the inspection,Arauco has received a letter requesting additional
information for this permit modification. One additional request was to change the flow measurement
location. Arauco would like to change the flow measurement location from the influent to SD to total
water entering the system, measured at Pond 3. Arauco would also like to have a flow balance instead of
a hard-influent flow limit.Arauco would like to take the total flow in, minus total flow out, and as long it
is a negative value, signifying more water is being treated than entering the system, this would be
complying. Arauco would also maintain all freeboard limits.
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.
To mitigate groundwater well exceedances, Arauco has significantly reduced the amount of wastewater
sprayed on to the irrigation fields. The following is the total gallons of wastewater sprayed on the fields
over the last 3 years:
• 2016—11,943,000 gallons
• 2017-6,397,000gallons
0 2018-2,536,000gallons

In addition to reducing spray,Arauco is working with the City of Sanford to become a customer of the Big
Buffalo W WTP upon completion of the pipeline in late 2019-early 2020. Once a customer, the amount of
wastewater applied to the spray fields will be reduced significantly more.
If you have any questions, please contact Yvonne Couts, Environmental Manager, at(919-545-5848).
Slrxqrely
/���
11clMgi llian
Plant Manager