NCS000151_Arauco Inspection Report DRAFT_20190530

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
Arauco Panels USA LLC
NORTH CAROLINA
Environmental Quality
May 30, 2019
Attn. Tom Queensberry, Owner
985 Corinth Road
Moncure, NC 27559
Subject: Compliance Inspection
Permit No. NCS000151
Arauco Panels USA LLC
Chatham County
Dear Mr. Queensberry:
On May 14, 2019, Alaina Morman and Lauren Garcia, inspectors with the North
Carolina Department of Environmental Quality (NCDEQ) - Division of Energy, Mineral and
Land Resources (DEMLR), met with site contacts at the facility located at 985 Corinth Road,
in Chatham County, to conduct a compliance inspection. The inspection consisted of
reviewing: the Stormwater Pollution Prevention Plan (SWPPP) and each of its components,
the facility's outfalls, and the overall site conditions. The inspection was conducted to
ensure stormwater best management practices are being followed, and to help fulfill
NCDEQ's goal of inspecting all permitted facilities during each permit period.
Permit:
This facility has Individual Stormwater Permit NCS000151 to discharge stormwater from
the industrial activity of manufacturing of reconstituted wood products [SIC 2493] under
the National Pollutant Discharge Elimination System (NPDES). The permit was originally
issued on October 21, 1994 and the current version of the permit was issued on May 1,
2009 and expired on April 30, 2014.
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part II,
Section A of the permit.
• A SWPPP was not available onsite; however, an SPRP Plan, dated January 7, 2011,
with a few administrative updates in 2012, was provided. When prompted, it was
stated that the documents we were given were the only ones available at the time.
• It should be noted that environmental staff were away at a conference. A current
SWPPP was emailed on 5/24/2019, updated to the day.
E��� North Carolina Department of Environmental Quality I Division of Energy. Mineral and Land Resources
,r-f A �
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
NORTH CAFlOI fN
�� ��+" r 919.70T9200

• The facility is required to develop and implement a good housekeeping and
preventative maintenance program, which includes conducting twice -annual facility
and stormwater system inspections.
o There were no records of such inspections present in the current SWPPP.
o The housekeeping and preventative maintenance procedures outlined in the
SWPPP have not been implemented at the site. Site conditions observed
during the site visit were unacceptable. The worst conditions were observed
around the particle board production building, in the eastern section of the
site. The milling equipment and surrounding area were layered in product.
o Chip/mill product was observed in large, uncovered piles around the area of
the particle board production building. The piles form as a result of the
movement of the product by front end loaders to covered barns for storage.
• The facility has two outfalls that each discharge from separate concrete lined
stormwater "basins." Stormwater around the production areas (the particle board
production building and the medium density fiberboard (MDF) production building)
flows into concrete channels that direct stormwater into the stormwater basins.
Product migrates in large volumes into these channels and is carried into the
stormwater basins.
o The stormwater basin that receives stormwater from the eastern section of
the property, near the particle board building, was observed to be filled with
large piles of wet and decaying chip/mill material. This stormwater basin
measures about 1 acre in size. The facility does not have a way to control
flow from this basin, through the outfall, into the receiving stream.
o The stormwater basin that receives stormwater from the western section of
the facility, near the MDF building, was observed to be filled with water and a
much smaller volume of chip/mill product. The facility does not have a way
to control flow from this basin, through the outfall, into the receiving stream.
This stormwater basin measures about 1 acre in size.
• The facility is required to record each instance of a Tier I response in the SWPPP.
The record should include the date and value of the benchmark exceedance, the
inspection date, the personnel conducting the inspection, the selected actions and
the date the selected actions were implemented, in accordance with Part II, Section
B, page 7 of 10 of the permit.
o Since 2009, the facility has had benchmark exceedances of one or more
monitoring parameters during each monitoring event. There were no records
present in the current SWPPP.
The facility is required to maintain a record of Tier II responses in the SWPPP.
o Since 2009, the facility has had benchmark exceedances of one or more
monitoring parameters during each monitoring event. The facility should
have taken part in monthly monitoring since at least 2010. There were no
records present in the current SWPPP.
NcrthCirolroOtpbrtmrM -of FaSrlrmM"UIQrf * F DtdsWD(Energy.Mneraland Land Rlaourcra
512North Salisbury Street I t612MaYServlceCenter I BakgggLNorth Carollna27694-r612
9L9.707.9200

Facility Site Review:
The facility operates a particle board production building and medium density fiberboard
(MDF) production building. Medium density fiberboard production processes wood chips
with steam and pressure. Particle board production uses a wood chip drying system prior
to processing the chips. The particle board production building is located in the eastern
section of the facility. The MDF production building is located in the western section of the
facility. Spray irrigation fields are also located in the western section of the facility. Two of
the facility's main wastewater ponds are located in the northeastern corner of the facility.
Two fire ponds and four other waste treatment ponds are located in the southeastern
corner of the facility. Totes and drums are located at the northern exterior of the particle
board mill. Not all drums were observed to be stored in proper secondary containment.
Site conditions around the particle board area and two main wastewater ponds in the
northern and eastern sections of the facility were extremely poor. As discussed above, the
facility has a very serious housekeeping issue. The housekeeping issue has led to a mass
accumulation of wood product to be deposited in the two stormwater basins at the facility.
The wood product remains in the stormwater basin for an undeterminable amount of time;
however, the basins were reported to be periodically cleared out with a frontend loader.
The wood product deposited in the basins is comparable to compost piles. The wood
product is baked in the sun, and then rehydrated during rain events. The leachate that
leaves compost piles is considered extremely detrimental to water quality. Generally, the
amount of water added to the compost pile determines the amount of leachate that is
produced. It is a significant concern for DEQ that the rehydrating and baking process the
chip/mill product undergoes is likely producing a dangerous amount of leachate that is
discharging into the receiving waterbody. As discussed above, the facility does not have a
way to control flow from the basins into the receiving body. Leachate is considered a
wastewater and is not an authorized discharge for Arauco under the current stormwater
permit.
Site conditions around the medium density fiberboard mill were moderate. The area
surrounding the MDF production building had less unmanaged chip/product. The site
conditions in the southern section of the facility, near the fire ponds and four additional
wastewater treatment ponds were good.
Receiving Waters:
Stormwater from this facility drains into Shaddox Creek, a class WS-IV stream in the Cape
Fear River Basin.
Self -Monitoring Program:
This facility is required to provide qualitative and analytical monitoring data twice
annually. Since 2009, the facility has had benchmark exceedances of one or more
monitoring parameters during each monitoring event. The most concerning exceedances
have been from BOD, COD, TKN, Total Nitrogen, and TSS. For example, the benchmark for
COD is 120 mg/l; COD samples between 2009 and 2019 have measured between 140 mg/1
and 2,800 mg/l.
N01-thCirolroUtpbrtmrM-of FrMt nM"U1Qrf * F DtdsWD(Energy.Mneraland Land Rlaourcra
45f512North Salisbury Street I t612MaYServlceCenter I RakgggLNorth Carollna27694-r612
-Z 9L9.707.9200

The facility is required to respond to benchmark exceedances through increased
monitoring, increased management actions, increased record keeping, and/or installing
BMPs in a tiered program, in accordance with Part II, Section B, pages 6-8 of 10, of the
permit. As a result of a Tier I response, the facility is required to conduct a stormwater
management inspection within two weeks of receiving the sampling results. The inspection
includes an investigation of the causes of benchmark exceedances. Causes are then
expected to be addressed and improvements implemented. The facility was unable to
provide records of improvements past 2011. A Tier II response involves another
investigation, improvements, and the institution of monthly monitoring. Again, the facility
was unable to provide records of improvements past 2011. Based on the provided
sampling data for the current permit term (beginning in May 2009) the facility should have
been participating in monthly monitoring since at least 2010. While the facility participated
in more than semiannual monitoring events in 2011, 2012, and 2017, the facility has never
completed monthly monitoring to the required specifications of a Tier II Response, in
accordance with Part I1, Section B, page 7 of 10.
If sampling results for the permit monitoring periods exceed the benchmark values for any
specific parameter at any specific outfall for more than four occasions, the permittee shall
notify the DWQ Regional Office Staff within 30 days of the receipt of the fourth analytical
results. DWQ was allegedly notified as an addendum to an application in 2016. This was the
only known attempt at a notification.
Corrective Actions:
• Housekeeping measures need to be overhauled at the facility. It should be made the
top priority of the facility to investigate and implement a system that will prevent
the free chip/mill wood products from reaching stormwater basins all together.
While periodically clearing the product out of the basin with a frontend loader is a
short-term solution for preventing leachate discharge from the unmanaged
composting chip/mill product, this will not address the cause of the benchmark
exceedances. As long as the chip/mill product amassed around the particle board
production building is so poorly mismanaged, there will continue to be issues with
the stormwater sampling results. The 2009-2019 monitoring data benchmark
exceedances are so high, the effluent leaving the site does not qualify as stormwater;
the effluent leaving the Arauco Panels USA LLC stormwater outfalls is wastewater.
This is especially important because the receiving waterbody, Shaddox Creek, is a
WS-IV, a water supply used for drinking, culinary, or food processing purposes.
• All totes and chemical drums need to be stored in proper secondary containment.
The determination from the inspection is the facility is not in compliance with the
conditions of their permit in its entirety. If you have any questions or need additional
information, please contact Lauren Garcia at [phone] or lauren.garciaOncdenr.gov.
Sincerely,
NcrthCir'AroOlpbrtmrM-of FrMt nM"U1Qrf * F DtdsWD(Energy.Mneraland Land Rlaourcra
512North Salisbury Street I t612MaYServlceCenter I BakgggLNorth Carollna27694-r612
9L9.707.9200

Lauren Garcia
Environmental Specialist II
Stormwater Program
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental
Quality
Enclosures: Inspection Report
cc: Tom Queensberry, Owner
Thad Valentine, DEMLR Raleigh Regional Office, [e-mail]
N01-thCir'AroUlpbrtmrM-of FrMt nM"U1Qrf * F DtdsWD(Energy.Mneraland Land Rlaourcra
512North Salisbury Street I t612MaYServlceCenter I BakgggLNorth Carollna27694-r612
9L9.707.9200