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HomeMy WebLinkAboutNCS000151_Engineering Alternatives Analysis_20190913Kennedy/Jenks Consultants Engineers & Scientists, P.C. North Carolina Board of Engineers & Surveyors License No. C-4225 3121 Grand Oak Ln. New Hill, NC 27562 919-605-5642 Engineering Alternatives Analysis 13 September 2016 Prepared for Arauco Panels USA, LLC 985 Corinth Road Moncure, INC 27559 K/J Project No. 1676008.10 Engineering Alternatives Analysis Arauco Panels USA, LLC Final Submittal 13 September 2016 %ACq��Q� p v�y'r f 4 SEAL r• — ��)`��r5[� 042402 ae Prepared under the supervision of Robert Chrobak North Carolina Professional Engineer No. 042402, Expires 12/31/2017 KENNEDYMENKS CONSULTANTS Engineers & Scientists, P.C. North Carolina Board of Engineers & Surveyors License No. C-4225 3121 Grand Oak Lane New Hill, NC 27562 503423-4000 JOB NO. '1676008.10 Table of Contents Listof Tables.............................................................................................................................. m Listof Figures............................................................................................................................. iii Listof Appendices...................................................................................................................... iii Listof Acronyms.........................................................................................................................iv Introduction.....................................................................................................1 Background..................................................................................................... 1 Summary of Wastewater Generating Operations ................................. 1 MDFProduction........................................................................ 1 Particleboard Mill...................................................................... 1 Existing Wastewater Permits................................................................ 2 Non -Contact Cooling Water Permit ........................................... 2 Non Discharge Spray Irrigation Permit ...................................... 2 Existing Wastewater Treatment Facilities ............................................. 4 Proposed Improvements to Wastewater Treatment Plant ................................ 4 Section 1: Determine if Proposed Discharge will be Allowed ......................6 1.1 Federal Standards................................................................................ 6 1.1.1 Effluent Limit Guidelines for Surface Water Discharge .............. 7 1.1.1.1 Particleboard........................................................... 7 1.1.1.2 Medium Density Fiberboard .................................... 7 1.1.2 Pretreatment Requirements...................................................... 7 1.2 State Water Quality Standards............................................................. 8 1.2.1 Water Body Classification......................................................... 8 1.2.2 Special Designations................................................................. 8 1.2.2.1 Critical Supply Watershed ....................................... 8 1.2.2.2 Protection of Waters Downstream of Receiving Waters .................................................... 9 1.2.2.3 Outstanding Resource Waters ................................. 9 1.2.3 Applicable Water Quality Standards .......................................... 9 1.2.3.1 Statewide Water Quality Standards ......................... 9 1.3 Basin -Specific Standards................................................................... 10 1.3.1 Turbidity.................................................................................. 10 1.3.2 Fecal Coliform......................................................................... 10 1.3.3 Chlorophyll a in the Cape Fear River ....................................... 10 1.4 Wasteload Allocations in the Cape Fear Basin ................................... 10 1.4.1 Discharge through WWWRF Outfall........................................ 11 1.4.2 Discharge through Haw River Outfall...................................... 11 1.5 Nutrient Offset for Surface Water Discharge ...................................... 12 Engineering Alternatives Analysis, Arauco Panels USA, LLC i y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc Table of Contents (cont'd) Section 2: Provide Reasonable Projections for Population and Flow ........13 Section 3: Evaluate Technologically Feasible Alternatives .......................14 3.1 Alternative A. Connection to an Existing Wastewater Treatment System............................................................................................... 14 3.1.1 Pump Station.......................................................................... 14 3.1.2 Forcemain............................................................................... 14 3.1.2.1 Velocity Range ...................................................... 14 3.1.2.2 Static Head............................................................ 15 3.1.2.3 Total Dynamic Head .............................................. 15 3.1.2.4 Alignment..............................................................15 3.1.3 Hauled Wastewater Option ..................................................... 15 3.2 Alternative B. Land Application........................................................... 15 3.2.1 Increase Irrigation Area........................................................... 15 3.2.2 Nutrient Limitations................................................................. 16 3.2.3 Crop Sensitivity to TDS........................................................... 16 3.3 Alternative C. Wastewater Reuse ...................................................... 17 3.4 Alternative D. Direct Discharge to Surface Water .............................. 18 3.5 Alternative E. Combination of Alternatives .......................................... 18 Section 4: Evaluate Economic Feasibility of Alternatives .........................19 4.1 Alternative A. Connection to an Existing Wastewater Treatment System............................................................................................... 19 4.1.1 Haul Wastewater to the Big Buffalo WWTP ............................. 20 4.2 Alternative B. Land Application........................................................... 20 4.3 Alternative C. Wastewater Reuse ...................................................... 21 4.4 Alternative D. Direct Discharge to Surface Water ............................... 22 4.5 Alternative E. Combination of Alternatives .......................................... 22 References............................................................................................................................... 23 Engineering Alternatives Analysis, Arauco Panels USA, LLC ii y1projects\2016proj\1676008.10_arauco_npdes\09_reports-memos\9.09_reporl\engineering allernalives\eaa report\eaa_report-fnal_13sept2016.doc Table of Contents (cont'd) List of Tables Table 1: Permit No. NCO040711 Effluent Limits......................................................................... 2 Table 2: Groundwater Standards................................................................................................ 3 Table 3: Hydraulic Application Limits for Irrigation Fields............................................................ 3 Table 4: Applicable State Water Quality Standards.................................................................... 9 Table 5: WWWRF and Arauco Monthly Average Wasteload Allocations .................................. 11 Table 6: Performance Fiber and Arauco Monthly Average Wasteload...................................... 12 Table 7: Wastewater Flow Rate Projections by Source............................................................ 13 Table 8: Average Effluent Concentrations Pond 3 Effluent....................................................... 13 Table 9: Treated Effluent Characteristics.................................................................................. 14 Table 10: Crop Sodium Sensitivity............................................................................................ 16 Table 11: Crop Potassium Sensitivity....................................................................................... 17 Table 12: Economic Assumptions for Cost Estimates............................................................... 19 Table 13: Annual Cost Summary for POTW Discharge............................................................ 20 Table 14: Cost Summary for Hauled Waste to POTW.............................................................. 20 Table 15: Cost Summary for Land Application Discharge......................................................... 21 Table 16: Cost Summary for Wastewater Reuse...................................................................... 21 Table 17: Cost Summary for Direct Discharge to Surface Water .............................................. 22 Table 18: Cost Summary for Combination of Alternatives......................................................... 22 List of Figures 1 Vicinity Map 2 Site Plan with Water and Wastewater Schematic 3 Moncure Area Plan 4 Outfall Map 5 Treatment Schematic 6 Forcemain Alignment 7 Combination Wastewater Treatment and Discharge Schematic List of Appendices A Wastewater Land Application Evaluation — Shaffer Soil Services, Inc. B Technical Memorandum: Nutrient Offset Justification C Cost Estimate Detail Engineering Alternatives Analysis, Arauco Panels USA, LLC iii y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc Table of Contents (cont'd) List of Acronyms % Percent < Less than °C degrees Centigrade AMSL above mean sea level APCD Air Pollution Control Device BAT best available treatment Big Buffalo WWTP Sanford Big Buffalo Wastewater Treatment Plant BOD5 five-day biochemical oxygen demand BPT best practicable treatment CFR Code of Federal Regulations COD chemical oxygen demand County Chatham County CY Cubic yards DEQ Department of Environmental Quality EAA Engineering Alternatives Analysis EPA Environmental Protection Agency FM forcemain fps Feet per second ft feet g/I grams per liter gal Gallon gpd Gallons per day HDPE high -density polyethylene HQW High Quality Waters Hr hour KW-hr Kilowatt per hour Ib/d Pounds per day MDF Medium density fiberboard MGD Million gallons per day MGY Million gallons per year NCAC North Carolina Administrative Code NESHAP national emissions standards for hazardous air pollutants NPDES National Pollutant Discharge Elimination System NPV net present value NTU nephelometric turbidity unit O&M Operations and maintenance ORW Outstanding Resource Waters PB Particleboard PCWP plywood and composite wood products Engineering Alternatives Analysis, Arauco Panels USA, LLC iv y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc Table of Contents (cont'd) POTW publicly -owned treatment works SIC Standard Industrial Code SU Standard units TDH Total dynamic head TDS Total dissolved solids The Mill Particle Board Mill and Fiberboard Mill combined TMDL Total Maximum Daily Load evaluations TSS total suspended solids USDA United States Department of Agriculture WESP wet electrostatic precipitator WWSP wastewater pump station WWWRF Western Wake Water Reclamation Facility Engineering Alternatives Analysis, Arauco Panels USA, LLC y:Iprojects12016proj11676008.10_arauco_npdes109_reports-memos19.09_reporAengineering alternativesleaa reportleaa_report-fnal_13sept2016.doc Introduction Background Arauco Panels USA, LLC operates a particleboard (PB) Mill and medium density fiberboard (MDF) Mill. The combined mills (referred to herein as "the Mill") are located at 985 Corinth Road, Moncure, North Carolina. A regional vicinity map is shown in Figure 1. The Mill began operation in 1975 manufacturing MDF and expanded to particleboard in 1987. In 2012, Arauco acquired the entire site and currently operates both facilities. A Mill site plan is included as Figure 2 and a nearby Moncure area map showing the location of the Mill is provided in Figure 3. Summary of Wastewater Generating Operations The Mill generates an average of 56,000 gallons per day (gpd) of wastewater; however, peak wastewater to Pond 5D can be up to 100,000 gpd when heavy rains occur. Both rainfall and evaporation influence total volume of wastewater, and there is a net gain in the wastewater ponds due to precipitation. MDF Production The MDF production area is located on the north end of the facility. MDF production processes wood chips with steam and pressure. This process results in a source of wastewater called "squeeze water". The fibers are combined with resins and binders and pressed to form panels which are finally dried. Air pollution control devices under the Mill's Title V Operating Permit also generate blowdown. Primary point sources of wastewater in MDF production include: • Squeeze Water • MDF Sumps and oil/water separator • Keller Scrubber blowdown • MDF Scrubber blowdown • Non -contact cooling water • Steam condensate All wastewater from MDF flows to a 100,000 gallon "Screened Water Tank", and then to a dissolved air flotation system, followed by reverse osmosis. This system is ineffective due to the wastewater characteristics, and is not used. Particleboard Mill The PB Mill uses a wood chip drying system prior to processing the chips. Exhaust from the drying process is directed to a wet electrostatic precipitator (WESP) to reduce air emissions under the Mill's Title V permit. Soluble and fine materials can remain in the recirculation loop causing fouling in the WESP nozzles. To manage fouling and clean the WESP fields, the system periodically doses potassium hydroxide (43 percent [%]) to the WESP. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 1 y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc 3Morr.isville - -. CFearring,on �G® f J ► .fir+ r� r I'ram' aleigh 1 Nor''. arofina 9h�eltl�t� .T• Ape x . Y ' * •� '�' .T v CG a! i41, • :■ ONew.•Hill r• -•r, 1 f.Q 4 Li AA V•. Haliy•5prings M Mg �Moncu`re 'fi a►�. �y� 4�� 'jFO q u aY4 V,arina f i � 5 y ■ A ■ ; _try •• f . . Irrigation Fields Keller Scrubber R.O. Reject MDF Scrubber MDF Su Filter mps/ Backwash OWS Wet ESP Hogged Fuel Pile I 1 MDF Mill / Particle Board Mill / Squeeze Spray Irrigation Field Water _ Sand — _ _ _ I Filter / and -- #1 / Domestic WWTP Irrigation Fields ' r •FkW T'01 CORINTH ROADski ft-. f - y I � M Lq HAW RIVER 4 LEGEND Wastewater Water ----� Irrigation Z 0 20 40 1/32"=1'-0" Kennedy/Jenks Consultants Arauco Panels USA, LLC Engineering Alternatives Analysis 1676008.10 Site Plan with Water and Wastewater Schematic Figure 2 DEEP RIVER CAPE FEAR RIVER ",- 101 HAW RIVER ARAUCO MILL SITE s l 4 ti X, 1- 0 N 0 1 2 APPROXIMATE SCALE IN MILES BUCKHORN DAM Kennedy/Jenks Consultants Arauco Panels USA, LLC Engineering Alternatives Analysis 1676008.10 Moncure Area Plan Figure 3 Primary point source discharges from the PB Mill include: • WESP • Press Pit • Non -Contact Cooling Water Existing Wastewater Permits The Mill currently holds two permits related to wastewater generated at the Mill. Non -Contact Cooling Water Permit Boiler blowdown and steam condensate can be discharged to the Haw River under National Pollutant Discharge Elimination System (NPDES) Permit No. NCO040711. This permit expired on 31 July 2016, and a renewal application was submitted to the Department of Environmental Quality (DEQ). Effluent concentration limits in the permit are summarized in Table 1. Table 1: Permit No. NCO040711 Effluent Limits Effluent Characteristic Monthly Average Limit Daily Maximum Limit Total Suspended Solids 30 mg/L 45 mg/L Temperature Shall not cause more than 2.8 °C receiving stream increase; shall not o cause ambient water temperature to exceed 32 C Turbidity Shall not cause receiving stream turbidity to exceed 50 NTU pH Shall not be less than 6.0 or more than 9.0 standard units Notes/Abbreviations: Reference: North Carolina Administrative Code (NCAC) 15A 213 mg/L = milligrams per liter NTU = nephelometric turbidity unit °C = degrees Centigrade Non Discharge Spray Irrigation Permit The wastewater treatment and irrigation system operates under a Closed -Loop Recycle/Conjunctive Reclaimed Water/Wastewater Irrigation System permit (Non -discharge Permit #WQ0003396) issued by North Carolina DEQ. The permit was issued in April 2013 and is effective until 30 November 2016. The Mill operates the irrigation system used to irrigate row crops, which is farmed under a contract to produce silage for non -human consumption. The Spray Irrigation Permit covers operation of a 126,000 gpd wastewater treatment and surface irrigation facility. The narrative requirements of the permit related to operations and maintenance of the treatment system are as follows: • Freeboard in Ponds 1, 2, 3, 4 and 5 (Sides C and D) shall have a minimum of one (1) foot at any time. • Pond 5D is permitted to serve as primary wet -weather storage for process wastewater with the following operation and maintenance requirements. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 2 y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc o Pond 5C is permitted to be used as make-up water to the MDF and PB mills or for storage of stormwater. o Wastewater from Pond 5D may be transferred to Pond 5C to maintain required freeboard level for temporary storage. o Wastewater transferred to Pond 5C shall be transferred back to Pond 5D once water levels have been lowered through irrigation. o Wastewater in Pond 5C shall comply with monitoring requirements in Table 1. o Wastewater temporarily stored in Pond 5C may be utilized as make up water to MDF or PB mills if water quality allows. • The flow limitation of the process wastewater to Pond 5D is 56,000 gpd. The non -discharge permit does not provide end -of -pipe concentration or waste load limits; instead, the permit provides groundwater standards that shall not be exceeded. Groundwater samples are required three times per year to monitor the parameters summarized in Table 2. Table 2: Groundwater Standards Parameter Daily Maximum Chloride 250 mg/L Total Nitrate as Nitrogen 10 mg/L pH 6.5 - 8.5 SU Total dissolved solids 500 mg/L Abbreviations: mg/L = milligrams per liter SU. = standard unit Table 3 provides the hydraulic limits of irrigation on the irrigation fields under the non -discharge permit. Table 3: Hydraulic Application Limits for Irrigation Fields Net Area Application Rate Yearly Maximum Quantity Field (acres) (inches/hour) Application (MGY) (inches/year) 02 3.64 0.60 52 5.14 03 2.27 0.60 52 3.21 04 4.58 0.20 12.74 1.58 05 4.63 0.20 12.74 1.60 06 5.67 0.35 52 8.01 07 5.65 0.60 52 7.98 08 2.83 0.60 52 4.00 09 4.58 0.60 52 6.47 10 5.64 0.60 52 7.96 TOTAL 45.94 Abbreviations: MGY = million gallons per year Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 3 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc The permitted quantity of wastewater allowed for land application exceeds the amount of wastewater generated on an annual basis. However, the timing of irrigation must carefully be controlled to avoid irrigating during precipitation, when the ground is frozen, or outside the growing season. The dependence on weather brings an element out of the Mill's control which may cause wastewater to accumulate without the opportunity to treat and irrigate. Agronomic rates determine the limiting quantities allowed on the fields. A preliminary evaluation of agronomic limitations based on a proposed treatment plant installation is provided in Appendix A (Shaffer Soil Services letter dated 14 June 2016). The Mill has noted they appear to be hydraulically limited to an average irrigation rate of 24,000 gpd. Existing Wastewater Treatment Facilities Figure 3 presents a schematic of the existing wastewater sources and existing treatment processes. In preparing this Engineering Alternatives Analysis (EAA) report, we have considered that the proposed surface water discharge may require separation of waste streams. This section of the report presents the existing wastewater treatment process. Blowdown from the PB Mill WESP discharges directly to Pond 5D. Emergency overflow from the MDF Mill sources is discharges to Pond 5D. Due to greater than typical rainfall in the past year, the quantity of treated wastewater has been greater than the fields can accommodate. As a result, the MDF Mill has been applying wastewater to the hog fuel pile where it is burned with the fuel. Pond 5D has a residence time of approximately 120 days, and facultative treatment occurs during this time to remove five-day biochemical oxygen demand (BODO and chemical oxygen demand (COD). Settling to reduce total suspended solids (TSS) is also accomplished in Pond 5D. From Pond 5D, wastewater is pumped to Pond 4, an unaerated earthen lagoon. Effluent from Pond 4 flows by gravity to Pond 2, where it is aerated, then to Pond 3, which is not aerated. Pond 1 is not aerated and is hydraulically connected to Pond 2; however, there is no circulation between Pond 1 and Pond 2. Treated effluent from Pond 3 is currently pumped to the irrigation fields for disposal. Domestic wastewater from office restrooms is collected in a separate pump station and treated in a small package plant. Treated effluent is conveyed to Pond 3 and is discharged by irrigation with the industrial wastewater effluent. Average annual precipitation for the region is approximately 46 inches and contributes approximately 6 million gallons per year (MGY). This volume is based on 5 acres of area covered by ponds 5D, 1, 2, 3, and 4. It is assumed that rainfall collected in 5C will not be treated. Proposed Improvements to Wastewater Treatment Plant The wastewater treatment plant improvements will vary somewhat based on the discharge alternative selected. In general, the following changes are proposed to the existing wastewater system: Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 4 y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc • Separate domestic wastewater treatment plant effluent and discharge to a drainfield on the Mill site. • Install primary treatment of squeeze water to remove TSS and reduced BOD5 loading on the biological treatment plant. • Install a package biological wastewater treatment plant to treat Pond 3 effluent for reuse, irrigation, and discharge to surface water. • Future plans call for decommissioning the earthen basins, Ponds 5D, 4, 3, 2, and 1. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 5 y:Iprojects12016proj11676008.10_arauco_npdes109_reports-memos19.09_reporAengineering alternativesleaa reportleaa_report-fnal_13sept2016.doc Section 1: Determine if Proposed Discharge will be Allowed The purpose of this section is to determine if the proposed discharge will be allowed. This section considers federal standards, state water quality standards, and basin -specific considerations. Speculative permit limits, and the associated alternatives for surface water discharge that would be required to meet these limits, were developed to demonstrate how the water quality standards could be met. In consideration of the wastewater sources, limits, and discharge viability, Figure 3 presents a schematic of the existing wastewater sources and management approach. 1.1 Federal Standards Arauco's products include Particleboard (PB) and Medium Density Fiberboard (MDF). These products fall under Standard Industrial Code (SIC) 2493 for reconstituted wood products. SIC 2493 includes establishments primarily engaged in manufacturing reconstituted wood products, including: • Board, bagasse • Flakeboard • Hardboard • Insulating siding, board-mitse • Insulation board, cellular fiber or hard pressed (without • Lath, fiber • Medium density fiberboard (MDF) • Particleboard • Reconstituted wood panels • Strandboard, oriented • Wafer -board • Wall tile, fiberboard • Wallboard, wood fiber: cellular fiber or hard pressed-mitse Manufacturing processes for these products vary significantly, and their wastewater generation varies in a similar manner. PB production uses a dry process which does not produce wastewater from conditioning raw materials or forming materials. Wastewater from PB production results from air pollution control devices. MDF production generates wastewater from steaming chips and air pollution control devices. Federal Standards applicable to Arauco's discharge include the following: Effluent Limit Guidelines under 40 Code of Federal Regulations (CFR) 429 Pretreatment Standards 40 CFR 403 Federal rule for EPA administered permit programs under 40 CFR 122.2 defines process wastewater as any water which, during manufacturing or processing, comes into direct contact Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 6 y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc with or results from the production or use of any raw material, intermediate product, finished product, byproduct, or waste product. Effluent guidelines and standards under 40 CFR 429.11 (c) the term "process wastewater" specifically excludes non -contact cooling water, material storage yard runoff (either raw material or processed wood storage), boiler blowdown, and wastewater from washout of thermal oxidizers or catalytic oxidizers, wastewater from biofilters, or wastewater from wet electrostatic precipitators used upstream of thermal oxidizers or catalytic oxidizers installed by facilities covered by subparts B, C, D or M to comply with the national emissions standards for hazardous air pollutants (NESHAP) for plywood and composite wood products (PCWP) facilities (40 CFR part 63, subpart DDDD). For the dry process hardboard, veneer, finishing, particleboard, and sawmills and planing mills subcategories, fire control water is excluded from the definition. 1.1.1 Effluent Limit Guidelines for Surface Water Discharge 1.1.1.1 Particleboard The Particleboard Manufacturing Subcategory under 40 CFR 129, Subpart M indicates best practicable treatment (BPT) technology, Subpart M states (40 CFR 429.141) "there shall be no discharge of process wastewater pollutants into navigable waters". For best available treatment (BAT) technology economically available, Subpart M (40 CFR 429.143) states "there shall be no discharge of process wastewater pollutants into navigable waters." The only source of wastewater from PB production is blowdown from the WESP, which is specifically excluded under 40 CFR 429.11 (c). 1.1.1.2 Medium Density Fiberboard Medium density fiberboard is not listed in the 40 CFR 429 Timber Products Processing category, and employs different production methods from particleboard. MDF production requires process wastewater discharge due to large volumes of water required to refine chips into fiber. No effluent limit guidelines are specific to MDF, therefore, prospective limits for this industry will be water -quality based. 1.1.2 Pretreatment Requirements All wastewater sources discharging to a publicly -owned treatment works (POTW) are subject to 40 CFR Part 403, which generally require the source to prevent upset the treatment works and cause violation of the POTW's permit (including both liquids and solids disposal limitations) as a result of the discharge. POTWs receiving significant contributions of industrial wastewater are required to implement an industrial wastewater pretreatment program, including a rules, inspection programs, limits, and administrative structure. There are no categorical limitations or exclusions for SIC Code 2493 or Reconstituted Wood Products. In the case of the proposed wastewater discharge, the likely pre-treatment limitations would be for BOD/COD, TSS, pH, temperature, and total dissolved solids (TDS). Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 7 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc 1.2 State Water Quality Standards 1.2.1 Water Body Classification The Haw River is in the Cape Fear River Basin, and the location of the discharge is in stream index 16-(42) between the Jordan Lake dam (lower end) and the confluence with the Cape Fear River. These waters are also protected for Class C uses (secondary recreation). WS-IV waters are generally in moderately to highly developed watersheds or Protected Areas. In this reach, the Haw is classified as WS-IV. North Carolina water classifications are described below: Class C: Waters protected for uses such as secondary recreation, fishing, wildlife, fish consumption, aquatic life including propagation, survival and maintenance of biological integrity, and agriculture. Secondary recreation includes wading, boating, and other uses involving human body contact with water where such activities take place in an infrequent, unorganized, or incidental manner. WS-1: Waters protected for all Class C uses plus waters used as sources of water supply for drinking, culinary, or food processing purposes for those users desiring maximum protection for their water supplies. WS-1 waters are those within natural and undeveloped watersheds in public ownership. All WS-1 waters are High Quality Waters (HQW) by supplemental classification. WS-1 is a "high" quality Class C water that is used for water supply as well as for secondary recreation and supporting aquatic life. WS-11: Waters used as sources of water supply for drinking, culinary, or food processing purposes where a WS-1 classification is not feasible. These waters are also protected for Class C uses. WS-11 waters are generally in predominantly undeveloped watersheds. All WS-II waters are HQW by supplemental classification. WS-11 is a considered a "lower" quality water than WS-1. WS-III: Waters used as sources of water supply for drinking, culinary, or food processing purposes where a more protective WS-1 or II classification is not feasible. These waters are also protected for Class C uses. WS-111 waters are generally in low to moderately developed watersheds. HQW: Supplemental classification intended to protect waters which are rated excellent based on biological and physical/chemical characteristics through Division monitoring or special studies, primary nursery areas designated by the Marine Fisheries Commission, and other functional nursery areas designated by the Marine Fisheries Commission. 1.2.2 Special Designations 1.2.2.1 Critical Supply Watershed Special designations for water bodies are typically put in place to protect a drinking water source known as a Critical Supply Watershed as specified in 15A NCAC 2B .0248. The Haw River and Cape Fear River Basin in and downstream of the proposed discharge are not within a designated Critical Supply Watershed specified in 15A NCAC 2B .0248. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 8 y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc 1.2.2.2 Protection of Waters Downstream of Receiving Waters Water quality based effluent limitations or management practices for direct or indirect discharges of waste or for other sources of water pollution will be developed by the Division such that the water quality standards and best usage of receiving waters and all downstream waters will not be impaired. While there are protected waters within the Cape Fear Basin under 15A NCAC 02B .0203, they are in coastal sub basins that would not be directly affected by the proposed discharge. 1.2.2.3 Outstanding Resource Waters The reaches of the Haw River and Cape Fear River basin in the vicinity of the discharge are not subject to a special management strategy specified in 15A NCAC 2B .0225 the Outstanding Resource Waters (ORW) rule. 1.2.3 Applicable Water Quality Standards 1.2.3.1 Statewide Water Quality Standards Statewide Water Quality Standards for Class C Waters applicable to the proposed discharge are summarized in Table 4. Table 4: Applicable State Water Quality Standards Parameter In -Stream WQ Standard Reference Dissolved Oxygen >_5.0 mg/L 15A NCAC 02B .0211 (6) (freshwater aquatic life; non -trout) Temperature No increase more than 2.8 C above ambient; No case more than 32 C 15A NCAC 02B .0211 (18) (lower Piedmont/coastal; non -trout) pH 6.0 to 9.0 standard units 15A NCAC 02B .0211 (14) Chloride 230 mg/L Action level; 15A NCAC 02B .0211 (22) (d) Turbidity <_ 50 NTU 15A NCAC 02B .0211 (21) Nitrate-N :510 mg/L Red Book Nitrate-N <_10 mg/L 15A NCAC 02B .0216 (3) (h) WS-IV water quality standard Abbreviations: >_ = greater than or equal to <_ = less than or equal to North Carolina has no statewide standards for Total Phosphorous or Total Nitrogen. Nutrient limits are determined on the basis of water body status, and are typically covered in Total Maximum Daily Load evaluations (TMDLs). The Cape Fear basin is water quality limited for chlorophyll a, and DEQ is preparing a TMDL update for the Cape Fear Basin to cover phosphorous that contributes to algae blooms. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 9 y1projects\2016proj\1676008.10_arauco_npdes\09_reports-memos\9.09_reporl\engineering allernalives\eaa report\eaa_report-fnal_13sept2016.doc 1.3 Basin -Specific Standards The Haw River and Deep River, which contribute to the Cape Fear River, are water quality limited for turbidity and fecal coliform. The TMDL for the Haw and Deep Rivers was approved by the Environmental Protection Agency (EPA) in 2005. The Cape Fear River is water quality limited for chlorophyll a. 1.3.1 Turbidity The water quality standard states if a water body exceeds the turbidity standard, there shall be no allowable increase in turbidity; therefore, the turbidity would need to be less than 50 NTU at the end of pipe. 1.3.2 Fecal Coliform The domestic wastewater stream will be removed from the industrial treatment plant process, and we propose to discharge through a drain field. For this reason, there would be no domestic wastewater sent to NPDES discharge. For this reason, we do not anticipate fecal coliform will be an issue. 1.3.3 Chlorophyll a in the Cape Fear River There are no statewide standards for Total Phosphorous or Total Nitrogen; nutrient limits are determined on the basis of water body status, and are typically covered in TMDLs. The Cape Fear River above Buckhorn Dam and immediately downstream from the Haw River, is water quality limited for chlorophyll a. DEQ is preparing a TMDL update for the Cape Fear Basin to cover nitrogen and phosphorous that contributes to algae blooms. Arauco's wastewater contains low total phosphorous concentrations and high total nitrogen concentrations. The nitrogen input may be contributing to the algae blooms and resulting high chlorophyll a concentrations. 1.4 Wasteload Allocations in the Cape Fear Basin There are a number of efforts by DEQ currently underway to assess water quality in the Cape Fear River Basin. There is a modeling effort to address nutrients that will lead to nutrient criteria and a nutrient management plan. This effort particularly focuses on the middle Cape Fear River. This effort is expected to be complete in 2020. Because these items are currently in development, DEQ may reserve determination of wasteload allocations for new permits until these efforts are complete. As an alternative to new allocations, two nearby discharges were considered with possible wasteload allocations. The wastewater discharge proposed to the two receiving water bodies near the Moncure facility with physically feasible discharge points: the Haw River and the Cape Fear River. The Haw River is the closer option and would permit Arauco to use an existing pipeline to the river. The Cape Fear River could be reached by constructing a pipeline directly to the river or by connecting to the existing Western Wake Water Reclamation Facility (WWWRF) outfall in cooperation with Chatham County (County). The County owns a volumetric capacity of 6 million Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 10 y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc gallons per day (MGD) in this outfall. The county or another discharger participating in the outfall would need to secure an NPDES Permit and wasteload allocations, as they would be separate from the WWWRF. 1.4.1 Discharge through WWWRF Outfall The WWWRF discharges through an outfall pipeline running approximately 10 miles from the plant to the Cape Fear River just below Buckhorn Dam, as shown on Figure 4. The WWWRF discharges treated wastewater (19 MGD) into the Cape Fear River in the vicinity of and downstream of Buckhorn Dam. The WWWRF effluent limits are listed below in Table 6. Chatham County owns 6 MGD of flow allocation of capacity in this outfall. If Arauco negotiated similar permit limits, its allocation would be as summarized in Table 5. Table 5: WWWRF and Arauco Monthly Average Wasteload Allocations Parameter Monthly Average Limit WWWRF Wasteload Allocation Arauco Possible Wasteload Allocation Flow -- 19 MGD 0.1 MGD BOD5 (Summer) 5.0 mg/L 792 Ib/d 25 Ib/d BOD5 (Winter) 10.0 mg/L 1,585 Ib/d 25 Ib/d TSS 30.0 mg/L 4,754 Ib/d 8 Ib/d Total Nitrogen 5.0 mg/L 792 Ib/d 8 Ib/d Abbreviations: Ib/d = pounds per day This scenario would require Arauco to enter into an agreement with the County to secure approximately 0.1 MGD of the County's capacity allotment, equivalent to 1.7% of the County's total allotment. The discharge would occur under Arauco's NPDES permit and wasteload allocations. 1.4.2 Discharge through Haw River Outfall Performance Fiber operates a wastewater treatment plant near the Mill and discharges treated process and domestic wastewater under an NPDES Permit. Under this permit, Performance Fiber is permitted to 0.244 MGD into the Haw River with the daily maximum effluent limits for TSS and BOD5. Table 6 shows Performance Fiber's wasteload limits with Arauco's maximum limitation added. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 11 y1projects\2016proj\1676008.10_arauco_npdes\09_reports-memos\9.09_reporl\engineering allernalives\eaa report\eaa_report-fnal_13sept2016.doc 101 rwE y_ DEEP RIVER - MWA *CAPEEAR RIVER~` b* - HAW RIVER ARAUCO MILL SITE 4 nNIL X,1 1• ti L (E) OUTFALL N 0 1 2 APPROXIMATE SCALE IN MILES WESTERN WAKE WWTP OUTFALL BUCKHORN DAM Kennedy/Jenks Consultants Arauco Panels USA, LLC Engineering Alternatives Analysis 1676008.10 Outfall Location Plan Figure 4 Table 6: Performance Fiber and Arauco Monthly Average Wasteload Arauco Performance Parameter Speculative Fibers Wasteload Wasteload Flow 0.244 MGD 0.1 MGD pH 6-9 SU 6-9 SU BOD5 10.4lbs/d 15.6lbs/d TSS 10.6lbs/d 3.9lbs/d This scenario would require Arauco to acquire Performance Fiber's NPDES Permit and modify for Arauco's requirement needs. The discharge would occur under Arauco's NPDES permit and wasteload allocations. 1.5 Nutrient Offset for Surface Water Discharge There is currently a lack of clear direction in the determination of an appropriate nutrient allocation for the proposed discharge until the Cape Fear River evaluation and basin management plan are finalized (projected 2020). To provide an opportunity for water quality improvement and enable an NPDES permit to be considered for Arauco's proposed treatment plant, DEQ and EPA suggested Arauco investigate offsetting nutrient inputs from other sources. A technical memorandum titled "Nutrient Offset Justification" (included as Appendix B) provides a supporting argument for eliminating irrigating effluent under the current spray irrigation permit, and allowing discharge of treated effluent under a new NPDES permit to the Haw River. EPA formalized effluent offsets and trading through a policy statement and associated guidance documents. The "Water Quality Trading Policy" (2003) (the Policy) document provides context for the reduction of pollutants under the Clean Water Act and how creative and innovative approaches will be considered to work toward the overall goal of achieving water quality goals. In discussion of offsets, Arauco proposes offsetting nutrients from runoff from agricultural fields by treating wastewater to a higher water quality, thereby, reducing the input of nutrients to the basin. One of the goals of the policy is to achieve early reductions and progress towards water quality standards pending development of TMDLs for impaired waters, thus, an effort to reduce TN input to the basin will achieve this goal. The justification considers estimated rainfall runoff and results of stormwater sampling from 2011 through 2015. The calculations estimate approximately 16,196 pounds of TN entered the Cape Fear River basin on an annual basis in the form of runoff from the irrigation fields for the years listed. The construction of additional treatment for its wastewater will provide a maximum effluent TN concentration of 10 mg/L, which would reduce annual TN discharge to approximately 3,044 pounds. The offset ratio of approximately 5.3:1 will provide improved water quality, meeting objectives of the policy prior to the development of the TMDL and allocations for TN in the basin. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 12 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc Section 2: Provide Reasonable Projections for Population and Flow Arauco prepared a wastewater inventory to meet planned board production needs. The projected wastewater flows are summarized in Table 7. Table 7: Wastewater Flow Rate Projections by Source Source Quantity (gal/day) Keller Scrubber APCD Blowdown 5,000 Wet Scrubber APCD Blowdown 15,000 Biofilter Condensate (future) 4,000 Squeeze Water 55,000 Steam Generators Purge 8,000 Sumps & Oil/Water Separator 5,000 WESP Blowdown 4,000 Net Rainfall -Evaporation 4,000 TOTAL WASTEWATER 100,000 Table 8 provides a summary of average Pond 3 effluent concentrations from historical sampling. For this evaluation, we have assumed these are representative pollutant concentrations in wastewater that will require treatment before discharge under an NPDES permit. Table 8: Average Effluent Concentrations Pond 3 Effluent Parameter Value BOD5 354 mg/L COD (May 2016 sampling) 3,450 mg/L TSS 151 mg/L Total Nitrogen 147 mg/L Chlorides 319 mg/L TDS 2,758 mg/L pH 7.89 SU Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 13 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc Section 3: Evaluate Technologically Feasible Alternatives In this section, technologically feasible alternatives are evaluated. For the purpose of the evaluations, it has been assumed that effluent for Alternatives B, C, D, and E will be treated according to the treatment schematic shown in Figure 5. The effluent characteristics for wastewater from the package wastewater treatment plant are summarized in Table 9. Table 9: Treated Effluent Characteristics Parameter Value pH 6.5 to 8.5 BOD5 <30 mg/L COD <100 mg/L TSS <10 mg/L Total Nitrogen <10 mg/L TDS 2,758 mg/L Abbreviations: < = less than 3.1 Alternative A. Connection to an Existing Wastewater Treatment System The Sanford Big Buffalo Wastewater Treatment Plant (Big Buffalo WWTP) can receive wastewater generated by Arauco's facility. This alternative evaluates connecting the Mill to the Big Buffalo WWTP via a forcemain (FM) and pump station. 3.1.1 Pump Station A new wastewater pump station (WWPS) and FM with a capacity of 0.1 MGD will be required to pump treated effluent from Arauco's facility to the Big Buffalo WWTP. The pump station will be a packaged style system capable of pumping the design peak flow of 70 gpm. 3.1.2 Forcemain 3.1.2.1 Velocity Range The optimal diameter of the new FM was selected based on velocity considerations. A velocity range of 2.0 feet per second (fps) minimum and 8.0 fps maximum was determined from the textbook Hydraulics of Pipelines, Pumps, Valves, Cavitation, Transients. Sedimentation will occur and settle out at velocities less than 2.0 fps. At velocities greater than 8.0 fps, the FM is at an increased risk for excessive transients and head loss. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 14 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc ,AF 5C 5D Keller Scrubber MDF Scrubber MDF Sumps/OWS Wet ESP MDF Mill J (E) IRR. Squeeze , (P) DISK PUMP Water FILTER Fire F RELOCATED Fire \ Pond k%SCREW and 4 y PRESS " (P) PACKAGED — Pond WWTP Pond #4 Pon #3 (P) DOMESTIC Pond #2 WASTEWATER #1 -f DRAINFIELD IRRIGATION (ALTS. B & E (E) DOMESTIC WWTP HAW RIVER DISCHARGE (ALTS. D & E 1h= LEGEND Modified Flow Existing Flow - Pump Packaged Plant . Z 0 10 20 1 /16"=1'-0" Kennedy/Jenks Consultants Arauco Panels USA, LLC Engineering Alternatives Analysis 1676008.10 Treatment Schematic Figure 5 3.1.2.2 Static Head The total static head is the difference in elevation between the lower water level at the new Arauco WWPS wet well and the pipe invert elevation at its highest point located midway between Arauco and the Big Buffalo WWTP. The low water level of the proposed wet well and pump station will be approximately 160 feet (ft) above mean sea level (AMSL). The invert elevation at the FM's highest point will be approximately 294 ft AMSL. Therefore, the static head of the FM will be approximately 134 ft. 3.1.2.3 Total Dynamic Head The maximum total dynamic head (TDH) of the system depends on both static head and friction losses. The TDH is dependent on pipe material, the system curve, and pipe sizes. Assuming a 4-inch DR-17 HDPE pipe, the TDH is approximately 270 ft. Pumping of 70 gpm can be accomplished with a 10 horsepower pump. A duplex pump station is recommended to provide redundancy. 3.1.2.4 Alignment The new forcemain will be approximately 9.1 miles in length. From the new Arauco WWPS wet well, the forcemain will follow Old US Highway 1 for one mile before turning Southwest and following Claude E. Pope Memorial Highway for the remainder of its length. The forcemain will discharge at a manhole just south of the intersection of the Claude E. Pope Memorial Highway and Colon Road. This discharge point feeds the Big Buffalo WWTP through a 12-inch ductile iron pipe. Figure 6 illustrates the proposed alignment to reach the Sanford gravity collection system. This alignment assumes the downstream gravity collection system has capacity to accommodate Arauco's wastewater. 3.1.3 Hauled Wastewater Option A second option would be to haul wastewater generated by Arauco's facility to the Big Buffalo WWTP, if approved by the WWTP. Since hauling wastewater is costly wastewater volume could be reduced through thermal evaporation, membrane filtration, or a combination of the technologies. 3.2 Alternative B. Land Application Treated wastewater is currently land -applied as the sole method of effluent disposal. The effluent is beneficially used to grow row crops. A recent evaluation indicates Arauco is currently at maximum hydraulic loading of the fields. In addition, the high TDS loading in effluent is causing high sodium and potassium loading to the fields. Arauco's Agronomist indicates the salt loading on the fields should be reduced if possible. 3.2.1 Increase Irrigation Area Arauco's current irrigation fields are at their maximum capacity, using a total of 40 acres grow row crops. Arauco owns approximately 35 acres of unused land to the north that could be developed and the irrigation system expanded to provide additional irrigation capacity. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 15 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc --Gunter-Harn& Island: ncli 4 J -.4 it PROPOSED F012QF -016 ;,4 611k� !Sgcoclj -.r xp-," JL Colon-1--i k1ff .4.� I.; P. Y. f ncli 4 J -.4 it PROPOSED F012QF -016 ;,4 611k� !Sgcoclj -.r xp-," JL Colon-1--i k1ff .4.� I.; P. Y. f A iftk own cure- % Unfortunately, due to the poorly draining soils and shallow groundwater, the estimated capacity of the 35 acres is 20,000 gpd. With the existing 24,000 gpd applied, this would total approximately 44,000 gpd. This quantity is less than half of the needed capacity, and is insufficient to meet the projected needs. Arauco has investigated acquiring additional property on all sides of the existing facility and has found no feasible irrigation alternative available in the Moncure area. The one property available for purchase, Performance Fibers to the north, carries high environmental liability that makes this property undesirable. If Arauco could locate and purchase approximately 100 acres of land to irrigate row crops, irrigate the usable portion of the 35 acres it currently owns, and rehabilitate the current 40 acres of land irrigated, there may be enough capacity for 100,000 gpd. For the purposes of this evaluation, a cost estimate for this possibility was prepared and included in Section 4. 3.2.2 Nutrient Limitations Nutrients are limiting with respect to land application of Arauco's wastewater. For the proposed wastewater treatment plant, a 75 acre land application site could accommodate approximately 40,000 gpd if wastewater is treated to the effluent quality in Table 9. 3.2.3 Crop Sensitivity to TDS High TDS in the effluent results in high concentrations of sodium and potassium in irrigation fields. Poorly draining soils allow evaporation of water from the soil surface leaving salt deposits at the surface. When salts accumulate in soils, the soil becomes less permeable, and inhibits plant growth. Conversely, high levels of potassium prevent the uptake of other minerals beneficial to plant growth. Table 10 summarizes sodium sensitivity of crops considered for wastewater land application. Table 10: Crop Sodium Sensitivity Highly Moderately Sensitive Tolerant Tolerant (2.5 g/1) (10 g/1) (5 g/1) Date palm Wheat Red clover Barley Tomato Peas Sugar beet Oats Beans Cotton Alfalfa Sugarcane Asparagus Rice Pear Spinach Maize Apple Bromegrass (hay) Flax Orange Potatoes Prune Carrot Plum Onion Almond Cucumber Apricot Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 16 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc Highly Moderately Sensitive Tolerant Tolerant (2.5 g/1) (10 g/1) (5 g/1) Pomegranate Peach Fig Olive Grape Note: Reference: (United States Department of Agriculture (USDA), 1954 Abbreviations: g/I = grams per liter Table 11 Summarizes potassium sensitivity of crops considered for wastewater land application. Table 11: Crop Potassium Sensitivity Highly Tolerant Moderately Sensitive (10 g/1) Tolerant (2.5 g/1) (5 g/1) Alfalfa Corn silage Corn Red clover Sorghum silage Wheat Bermudagrass Sunflowers Bromegrass (hay) Oats Fescue, tall Soybeans Grain sorghum Note: Reference: (United States Department of Agriculture (USDA), 1954 As shown in Tables 10 and 11, bromegrass is well suited for high levels of sodium and potassium. In addition, bromegrass has a high capacity for nitrogen uptake. Hay combined with alfalfa or grown on its own is the recommended option for liquid application of Arauco's high TDS wastewater. This essentially continues the current operation of the irrigation fields. 3.3 Alternative C. Wastewater Reuse Based on an assumed limiting TDS concentration of 500 mg/L, we estimate the maximum amount of treated effluent that could be recycled is about 4,000 gpd or 3 gpm. This represents approximately 4% of the treated effluent that could be reused. The remainder of the treated effluent will require discharge through one of the other alternatives. Treatment alternatives that could produce reuse -quality effluent include reverse osmosis and vacuum distillation. Both treatment methods are capable of producing effluent with a TDS concentration less than 500 mg/L. Both treatment methods also produce a concentrated residual that must be further treated and disposed. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 17 y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc 3.4 Alternative D. Direct Discharge to Surface Water Alternative D involves direct discharge of Arauco's wastewater to surface water under an NPDES Permit. This would require meeting the effluent quality shown in Table 9. Treatment would include biological treatment and tertiary filtration to obtain the high effluent quality required. Surface water discharge would be through one of the outfall alternatives discussed in Section 1.4. The two outfall options include the existing non -contact cooling water and boiler blowdown outfall from the Arauco facility to the Haw River, and the WWWRF outfall to the Cape Fear River. 3.5 Alternative E. Combination of Alternatives The final alternative involves a combination of water reuse, land application, and surface water discharge. Since all the wastewater needs to be recycled or discharged the wastewater quantity will be 0.1 MGD. Arauco has been able to irrigate only 24,000 gpd due to limitations of the poorly draining soils. Based on a limiting TDS concentration of 500 mg/L, about 4,000 gpd or 3 gpm can be recycled. Therefore, 72,000 gpd or about 50 gpm remains to discharge to surface water under the NPDES permit. A schematic of the proposed wastewater treatment, recycle, and discharge scenario for this alternative is provided in Figure 7. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 18 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc RESIDUAL 2 a N 0 N M a U U U Q W a LU w m O 3 MDF MILL SQUEEZE WATER KELLER SCRUBBER BLOWDOWN WET SCRUBBERS BLOWDOWN BIOFILTER CONDENSATE SUMPS & OIL/WATER SEPARATC COOLING TOWER BLOWDOWNS - SOFTENER BACKWASH - SAND FILTER BACKWASI- STEAM GENERATORS PURGE PARTICLE BOARD MILL WET ESP BLOWDOWN ISUMPS & OIL/WATER SEPARATOI GENERALCLEANUP APCP MAINTENANCE OTHER SOURCES _ WET RAIN/EVAPORATION ON LAGOONS DOMESTIC WASTEWATER — DOMESTIC WWTP DRAIN FIELD Kennedy/Jenks Consultants Arauco Panels USA, LLC Engineering Alternatives Analysis 1676008.10 COMBINATION WASTEWATER TREATMENT AND DISCHARGE SCHEMATIC Figure 7 Section 4: Evaluate Economic Feasibility of Alternatives Economic evaluation of the five alternatives is presented in this section. The assumptions used in the economic analysis are summarized in Table 12. Table 12: Economic Assumptions for Cost Estimates Description Value Year of analysis 2016 Inflation Rate 3.5% Planning Period 20 years Electricity Cost $0.06/KW-hr Labor Cost $60/hr Concrete Cost $1000/CY Earthwork Cost $50/CY Liquid waste hauling (20 miles) $0.05/gal Construction Contingency 30% Abbreviations: CY = cubic yards gal = gallon hr = hour KW-hr = kilowatt per hour For all cost estimates in this section, the wastewater was treated and discharged with a package wastewater treatment plant capable of achieving the effluent quality listed in Table 9. A detailed breakdown of the cost estimates can be found in Appendix C. Assumptions for each alternative are provided in this section. 4.1 Alternative A. Connection to an Existing Wastewater Treatment System The total construction cost estimate for the connection to an existing POTW wastewater treatment system is approximately $6.8 million. The cost estimate was prepared with the following assumptions: • 10 horsepower pump for 70 gpm at 270 feet of TDH. • Approximately 48,000 feet of 4-inch high -density polyethylene (HDPE) forcemain to Sanford's gravity system. • Air release valve stations (5). Table 13 summarizes the capital and annual operations and maintenance (O&M) costs for the connection to POTW. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 19 y1projects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc Table 13: Annual Cost Summary for POTW Discharge Description Cost Capital Cost $6,800,000 Annual O&M Costs Power $4,000/yr Labor $840/yr Motor rewinding $7,000/5-yr Miscellaneous Maintenance $2,600/yr Discharge fees $30,700/yr Total Annual O&M Costs $ 45,100/yr Therefore, the total 20-year net present value (NPV) for Alternative A is approximately $7.9 million, or $0.22 per gallon 4.1.1 Haul Wastewater to the Big Buffalo WWTP The estimated capital cost for hauling all wastewater generated at the Mill to the Big Buffalo WWTP is approximately $60,000. This covers additional piping and tank for equalization of wastewater into the WWTP. The larger hauled waste cost is associated with trucking and disposal. Disposal of this wastewater assumes wastewater equivalent to Pond 3 effluent can be hauled directly to the WWTP. The associated high strength waste charges are included in the disposal cost. Hauling costs assume waste is non -hazardous. Table 14 summarizes the capital and annual costs for hauling wastewater to the POTW. Table 14: Cost Summary for Hauled Waste to POTW Description Cost Capital Cost $60,000 Annual O&M Costs Haul and Dispose at POTW $1,840,000/yr Waste Surcharge $15,000/yr Tank Maintenance $400/yr Total Annual O&M Costs $ 1,855,400/yr Therefore, the total 20-year NPV for hauling wastewater to the Big Buffalo WWTP in Alternative A is approximately $56 million or $1.53 per gallon 4.2 Alternative B. Land Application The total construction cost estimate for land applying effluent wastewater is approximately $6.2 million. This cost includes purchase of an additional 80 acres for land application, as well as piping, center pivot irrigation units, and a new irrigation pump. The cost also includes a new Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 20 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc package wastewater treatment plant. Table 15 summarizes the capital and annual costs for increasing the land application capacity. Table 15: Cost Summary for Land Application Discharge Description Cost Capital Cost $6,200,000 Annual O&M Costs WWTP O&M $42,000/yr Power $5,800/yr Labor $1000/yr Total Annual O&M Costs $ 48,800/yr The total 20-year NPV for increasing the land application capacity in Alternative B is approximately $7.6 million or $0.21 per gallon. 4.3 Alternative C. Wastewater Reuse To reuse all wastewater effluent, the Mill would require treatment of wastewater to reuse quality and disposal of residual concentrate. For this evaluation, we assumed vacuum distillation was selected as the treatment approach. The total construction cost estimate for equipment related to reuse is approximately $7.36 million. In preparation of this estimate, the following assumptions were made: The Mill has steam and cooling tower capacity to operate the vacuum distillation system Residuals are not hazardous waste and can be disposed in a solid waste landfill Table 16 summarizes the capital and annual costs for treating and reusing wastewater in the facility. Table 16: Cost Summary for Wastewater Reuse Description Cost Capital Cost $7,360,000 Annual O&M Costs WWTP O&M $42,000/yr Power & Steam for Evaporator $889,000/yr Maintenance/labor $1,000/yr Sludge disposal $10,000/yr Total Annual O&M Costs $942,000/yr The total 20-year NPV for complete recycle of wastewater in Alternative C is approximately $36 million or $0.97 per gallon. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 21 y1projects\2016proj\1676008.10_arauco_npdes\09_reports-memos\9.09_reporl\engineering allernalives\eaa report\eaa_report-fnal_13sept2016.doc 4.4 Alternative D. Direct Discharge to Surface Water The total construction cost estimate for direct discharge is $3.48 million. Table 22 summarizes the capital and annual O&M costs for the direct discharge alternative under an NPDES permit. Table 17: Cost Summary for Direct Discharge to Surface Water Description Cost Capital Cost Annual O&M Costs $3,480,000 WWTP O&M $ 42,000/yr Power $1,000/yr Labor $2,000/yr Total Annual O&M Costs $ 45,000/yr Therefore, the total 20-year NPV for increasing the land application capacity in Alternative D is approximately $4.8 million or $0.13 per gallon. 4.5 Alternative E. Combination of Alternatives The total construction cost estimate for a combination of alternatives is approximately $4.14 million. The alternative includes continued use of existing irrigation fields, recycling a portion of the effluent to production, and discharge of a portion of the effluent to the existing Arauco- owned outfall. Table 18 summarizes the capital and annual O&M costs for the combination of alternatives. Table 18: Cost Summary for Combination of Alternatives Description Cost Capital Cost Annual O&M Costs $4,140,000 WWTP O&M $42,000/yr Power $1,100/yr Miscellaneous Maintenance $3,000/yr Total Annual O&M Costs $45,100/yr Therefore, the total 20-year NPV for the combination of alternatives under Alternative E is approximately $5.6 million or $0.15 per gallon. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 22 y1projects\2016proj\1676008.10_arauco_npdes\09_reports-memos\9.09_reporl\engineering allernalives\eaa report\eaa_report-fnal_13sept2016.doc References Total Maximum Daily Load for Turbidity and Fecal Coliform for Haw River, Deep River, Third Fork Creek, and Dan River in North Carolina, Final Report, 11 January 2005. Plant Response and Crop Selection for Saline and Alkali Soils; Agriculture Handbook 60, US Department of Agriculture, 1954. NC DENR — Division of Water Qualty `Redbook" Surface Waters and Wetlands Standards, NC Administrative Code 15A NCAC 028 .0100, .0200, .0300, 1 May 2007. Engineering Alternatives Analysis, Arauco Panels USA, LLC Page 23 y:lprojects12016projM76008.10_arauco_npdes109_reports-memos\9.09_reporllengineering allernalives\eaa reportleaa_report-fnal_13sept2016.doc Appendix A: Wastewater Land Application Evaluation - Shaffer Soil Services, Inc. Engineering Alternatives Analysis, Arauco Panels, LLC A-1 yAprojects12016proj11676008.10_arauco_npdes109_reports-memos19.09_repotengineering alternativesleaa reportleaa_report-fnal_13sep@016.doc SHAFFER SOIL SERVICES, INC. 685 SANFORD ROAD PITTSBORO, N.C. 27312 919-244-1984 JUNE 14, 2016 Mr. John Bird Arauco, Inc. Moncure Facility John: this report is designed to offer wastewater application planning considerations based on the proposed wastewater effluent quality you provided and based upon the current and proposed application sites. For the proposed site, both wooded and grassed options are included. The proposed effluent quality is: • pH: 6.5-8.5 • BOD: <100 mg/L • COD: <300 mg/L • TSS: <10 mg/L • NH3: <5 mg/L • Nitrate: <10 mg/L • TKN: 0 mg/L in warm months; 5-10 mg/L cool months The calculations will be based upon allowable hydraulic flow as a starting point. This data comes from 2 sources: current application volumes based on Arauco's records for existing fields; and design flow estimates from the soil study performed in November, 2015. Note that the 2015 design data have the potential for adjustment (only downward) pending the results of a hydrogeologic study. Once upper hydraulic design flow limits are set, the constituent parameters listed above will be assessed to determine if any constituent exceeds an agronomic or environmentally justifiable rate. If so, the parameter with the most limiting restrictions will dictate the flow rate. EXISTING FIELD NO. ACRES CURRENT OR PROPOSED VOLUME (IN/YR) GALLONS/YEAR 2 3.64 12.74 1,259,135 3 2.27 12.74 785,230 4 4.58 12.74 1,584,297 5 4.63 12.74 1,601,593 6 5.67 12.74 1,961,346 7 5.65 12.74 1,954,428 8 2.83 12.74 978,943 9 4.58 12.74 1,584,297 10 5.64 12.74 1,950,969 NEW AREAS A** 7.6 13.28 2,740,397 B** 13.7 24.98 9,292,120 TOTAL 25,692,755 1 *Fields 4 and 5 have a permit limit of 12.74. Fields 2, 3, 6, 7, 8, 9, and 10 have a permit limit of 52. However, Arauco staff has averaged 11-12 inches per year over recent years. **Does not reflect inherent loss of area due to irrigation design/layout. 10-15% losses expected. Individual Parameter Calculations (The highest hydraulic load potential- new field B at 24.98 inches per year, will be the starting basis) 1) pH — NA (see below comments) 2) BOD- recommended maximum 5,000 Ibs BOD/acre/year. At 100 mg/L BOD effluent quality: maximum BOD load is 564 Ibs/acre/year- well below the recommended 5,000 threshold. BOD not limiting at 100 mg/L. 3) COD -recommended maximum 2,000 Ibs COD/acre/year. At 300 mg/L COD effluent quality: maximum COD load is 1693 Ibs/acre/year- below the recommended 2,000 threshold. COD not limiting at 300 mg/L. 4) TSS- not relevant. (see below comments) 5) Plant Available Nitrogen is calculated at 100% nitrate, 50% ammonia, and 30% of organic N which is TKN-ammonia. Organic N is figured at 5mg/L for 7 months and 0 for 5 months for a running average of 3 mg/L. Using the maximum effluent concentrations given, PAN is then 10 + 5 + 3 = 18 mg/L. PAN limits for the crops vary by crop and soil type. For forage crops, corn, and soybeans an average of 140 Ibs PAN/acre/year is budgeted. At 18 mg/L PAN effluent quality the maximum N load is 102 pounds N/acre/year so well within the average target N of 140. Note, individual cropping systems, especially tree crops, will change this rate. Using typical row crops or hay or forages (grazing), N is not limiting at 18 mg/L. Using trees at an annual N maximum recommended of 60 pounds N/acre/year, then N becomes limiting as compared to an effluent rate of 24.98 inches per year. Using the N limit of 60 Ibs N/acre/year, the application is reduced to 14.7 inches per year. Comments: 1) pH- soils under present irrigation presently exhibit high soil pH due to Na additions and subsequent bicarbonate reactions. Options for remedies were discussed in a previous report. The wastewater effluent pH should not significantly change soil pH. Wastewater Na and K should be reduced where practicable. 2) BOD & COD- existing fields appear to be stressed by past Na, K, and organic additions. Future additions to existing fields may continue to reduce permeability, resulting in reduced application rates. 3) TSS- solids are only relevant as they relate to BOD, COD, or a wastewater parameters of significance such as N, P, K, Na. Summary: assumptions include a wastewater quality defined above and application rates per field as described above. New fields are still subject to a hydrogeologic evaluation to determine ultimate application potential. 2 Please advise if any questions arise or more information is needed. Thank you. Sincerely, Karl Shaffer, L.S.S. Shaffer Soil Services, Inc. Attachments: Invoice Appendix B: Technical Memorandum: Nutrient Offset Justification Engineering Alternatives Analysis, Arauco Panels, LLC 8-1 y:lprojects12016proj11676008.10_arauco_npdes109_reports-memos19.09_repotengineering alternativesleaa reportleaa_report-fnal_13sept2016.doc Kennedy/Jenks Consultants Engineers & Scientists, P.C. North Carolina Board of Engineers & Surveyors License No. C-4225 13 September 2016 Technical Memorandum To: Todd Phillips Site Environmental Manager From: Dean Wood and Rob Peacock Reviewed by: Robert Chrobak, North Carolina PE No. 042402 Subject: Nutrient Offset Justification Arauco Panels USA LLC Moncure, NC K/J 1676008*10 Introduction This technical memorandum provides the technical basis for an offset of nutrient loading to the Cape Fear River Basin (Shaddox Creek, Haw River, and Cape Fear River) for the purpose of pursuing a surface water discharge to receiving water impaired for chlorophyll a under the National Pollutant Discharge Elimination System (NPDES) Permit Program. The authority to operate the NPDES permit program was delegated to North Carolina Department of Environmental Quality (DEQ) by the US Environmental Protection Agency (EPA). This memorandum was prepared to support DEQ and EPA in the determination to permit the proposed discharge. Wastewater Sources and Current Management Strategy Arauco Panels USA LLC (Arauco) owns the Moncure Mill (the Mill) located at 985 Corinth Road, Moncure, North Carolina, as shown in Figures 1 and 2. The Mill produces particleboard and medium density fiberboard (MDF). Wastewater is generated from the particleboard facility in the wet electrostatic precipitator (WESP) as part of air emission control. Wastewater from the MDF facility is generated from steaming wood chips and wet emission controls. A site plan showing the facility features is provided in Figure 3. Wastewater from the sources described is first conveyed to Pond 5D where it is detained for approximately 120 days. Wastewater from Pond 5D is pumped to Pond 4, where it flows by gravity to Ponds 1 and 2, and then to Pond 3. Effluent from Pond 3 is pumped to irrigation fields adjacent to the Mill where it is used to grow crops such as corn or sorghum and is authorized via Permit No. WQ0003396. The fields have been in continuous use since 1987 and are being stressed due to prolonged application of wastewater effluent. As a result, the fields cannot uptake sufficient effluent to produce healthy crops. This limitation currently limits the Mill's production. y1projects12016proj\1676008.00_arauco_ww treatment reuse plan109_reports-memosllm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Kennedy/Jenks Consultants Engineers & Scientists, P.C. Technical Memorandum Todd Phillips Site Environmental Manager 13 September 2016 1676008*10 Page 2 Water Quality in the Cape Fear River Basin The Mill is located in the Cape Fear River Basin. Shaddox Creek runs to the east of the Mill and is receiving water for stormwater from the site. The Haw River runs west of the site, approximately 1,000 feet from the Mill's western border. Upstream from the Mill, the Haw flows into the manmade Jordan Lake, then through a dam. The main stem of the Cape Fear River is formed by the merging of the Haw and the Deep Rivers in Chatham County; however, its drainage basin reaches as far upstream as the Greensboro area (Mallin et al., 2011). The main stem of the Cape Fear River is located approximately 0.38 river miles downstream of the Mill on the Haw River. The Cape Fear River basin includes reaches that are water quality limited for chlorophyll a, as shown in Figure 2. Elevated chlorophyll a concentrations indicate potential for algae blooms, which typically occur when several factors are present: shallow stream depth or slow stream velocity, low canopy cover over the stream, and elevated nutrient conditions (Mallin, et al., 2011). Die off of and decay or algae can result in hypoxia and fish kills. Both nitrogen and phosphorous are required for algae growth, and both can be attributed to point source and non -point sources. Arauco's wastewater contains low concentrations of total phosphorous, but higher concentrations of total nitrogen (TN). Still water, as found in a reservoir above a dam, permits stratification and allows algae to form near the surface. These conditions are observed in Jordan Lake (approximately 3.8 river miles upstream from the Mill) and at Buckhorn Dam (approximately 6.4 river miles downstream from the Mill). While it has not been established that the Mill is a significant contributor of nutrients that results in algae blooms in the Cape Fear Basin, this memorandum demonstrates that additional treatment and a new proposed surface water discharge under an NPDES permit will result in a net reduction in TN to the system, and a net improvement in water quality. Nutrient Load to the Cape Fear Basin Arauco discharges stormwater from the Mill under stormwater NPDES Permit No. NCS000151. The Mill encompasses an area of approximately 137 acres, shown on Figure 4. The areas contributing to each outfall are broken down as shown in Table 1. Table 1. Mill Drainage Areas Area (acres) Area Use Outfall 004 Outfall 006 Total Agricultural (pervious) 64 14 78 Paved/Roof (impervious) 6 53 59 Total 70 67 137 y:lprojects12016proj11676008.00_arauco_ww treatment reuse plan109_reports-memosltm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Kennedy/Jenks Consultants Engineers & Scientists, P.C. Technical Memorandum Todd Phillips Site Environmental Manager 13 September 2016 1676008*10 Page 3 Table 2 summarizes benchmarks and average results of sampling of nutrients for calendar years 2011 through 2015. Table 2. Permit Benchmarks and Sample Concentrations Outfall 004 Outfall 006 Parameter > TKN Total N Total P TKN Total N Total P Benchmark (mg/L) > < 20 <30 <2 < 20 <30 <2 Sample Date mg/L mg/L mg/L mg/L mg/L mg/L 10/11 /2011 15 17 0.2 610 610 0.7 11 /17/2011 15 23 0.05 290 290 0.6 1/17/2012 45 -- -- 87 -- -- 1 /27/2012 32 34 0.7 110 110 0.2 3/17/2012 20 21 0.3 51 51 0.5 4/4/2012 150 200 2 71 71 0.3 4/26/2012 32 34 0.4 210 310 0.4 5/9/2012 23 25 0.4 33 38 0.2 8/19/2012 37 37 1 130 130 0.6 11 /14/2012 36 37 0.8 170 170 0.8 7/9/2013 48 48 0.3 25 25 0.3 10/7/2013 86 87 0.3 22 22 0.2 10/29/2014 29 45 0.4 47 47 0.1 11 /7/2015 5 6 0.7 56 58 0.9 Average > 40 47 0.6 129 149 0.4 Notes/Abbreviations: -- ' = Sample not analyzed > = greater than < = less than mg/L = milligrams per liter P = Phosphorus TKN = Total Kjeldahl Nitrogen (Ammonia + Organic Nitrogen) TN = Total Nitrogen (TKN + Nitrate + Nitrite) Proposed Management through Offsets Arauco is proposing to eliminate the irrigation of wastewater on the fields and cease farming the proposed property if an NPDES Permit can be granted for discharge of treated effluent to surface water. The proposed strategy will include installation of a new wastewater treatment system that can produce higher effluent water quality than the current treatment plant. The result will be a significant net reduction in TN to the Cape Fear River Basin. y:lprojects12016proj11676008.00_arauco_ww treatment reuse plan109_reports-memosltm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Kennedy/Jenks Consultants Engineers & Scientists, P.C. Technical Memorandum Todd Phillips Site Environmental Manager 13 September 2016 1676008*10 Page 4 Regulatory Mechanism for Nutrient Offsets EPA formalized effluent offsets and trading through a policy statement and associated guidance documents. The "Water Quality Trading Policy" (2003) (the Policy) document provides context for the reduction of pollutants under the Clean Water Act and how creative and innovative approaches will be considered to work toward the overall goal of achieving water quality goals. In discussion of "offsets" in this memorandum, Arauco proposes offsetting nutrients from runoff from agricultural fields by treating wastewater to a higher water quality, thereby, reducing the input of nutrients to the basin. Because both the existing irrigation and proposed discharge are owned by Arauco, the proposal is to truly offset (and reduce) the net nutrient input from the Arauco facility. Although the terms "trading" and "credits" are used extensively throughout the policy, no trading with other parties is proposed. Instead, we substitute "offset" where it can be appropriately used. The Objectives of offsets, under EPA policy, are summarized in Table 3. Table 3. Pollutant Offset Objectives Proposed Approach Meets Objective Objective Achieves early reductions and progress towards water quality standards Yes pending development of TMDLs for impaired waters. Reduces the cost of implementing TMDLs through greater efficiency and Yes flexible approaches. Establishes economic incentives for voluntary pollutant reductions from N/A point and nonpoint sources within a watershed. Reduces the cost of compliance with water quality -based requirements. N/A Offsets new or increased discharges resulting from growth to maintain Yes levels of water quality that support all designated uses. Achieves greater environmental benefits than those under existing Yes regulatory programs. Secures long-term improvements in water quality through the purchase of N/A retirement of credits by any entity. Combines ecological services to achieve multiple environmental and economic benefits, such as wetland restoration or the implementation of N/A management practices that improve water quality and habitat. Abbreviations: N/A = not applicable TMDL = total maximum daily load In the case of the Cape Fear River Basin where a total maximum daily load (TMDL) is under preparation (projected to be complete in 2020), the policy provides opportunity to begin making y:lprojects12016proj11676008.00_arauco_ww treatment reuse plan109_reports-memosltm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Kennedy/Jenks Consultants Engineers & Scientists, P.C. Technical Memorandum Todd Phillips Site Environmental Manager 13 September 2016 1676008*10 Page 5 improvements in water quality under the NPDES permit program and in accordance with the Clean Water Act. Specifically, the policy summarizes situations where the use of offsets may occur: • Trading to maintain water quality standards • Pre-TMDL trading in impaired waters. The relevant Clean Water Act alignment areas are: • Requirement to obtain permits through the NPDES Permit program • Consistency with standard methods for sampling and monitoring • Protecting designated uses • Antibacksliding on water quality requirements • Antidegradation of receiving waters. The proposed improvement will meet all of the above points. Use of Standard Methods and Information Sources The Policy states that site -specific procedures and protocols used in water quality offsets involving agriculture operations should estimate nutrient load delivery to the water body where the offset occurs. In preparation of the estimated nutrient loadings the EPA Stormwater Calculator, which uses EPA Storm Water Management Model (EPASWMM) as its numerical model, was used to estimate annual runoff from the agricultural areas of the site. Soil data from the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) provided soils information for the estimation of nutrient loading, as was a site -specific soil infiltration study (Shaffer, November 2015, included as Attachment 1). Standard methods were used in the analysis of samples under the Mill's NPDES stormwater permit. Offset Ratios The "Water Quality Trading Toolkit for Permit Writers" (EPA, August 2007/June 2009) provides guidance on uncertainty ratios used for determining acceptability of offsets between a non -point source and a point source. When one point source is used to offset another point source under an NPDES permit, a 1:1 ratio may be justified. However, when a point source offsets a non - point source, the confidence in the estimated flow and representative periodic grab sample is lower than with a closely monitored point source. For this reason, there is an expectation of a ratio of greater than 1:1 for this type of offset. Little guidance on the required value of uncertainty ratios is provided in the EPA policy or tools. Instead the uncertainty ratio is dependent upon many factors. The Virginia Department of y:lprojects12016proj11676008.00_arauco_ww treatment reuse plan109_reports-memosltm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Kennedy/Jenks Consultants Engineers & Scientists, P.C. Technical Memorandum Todd Phillips Site Environmental Manager 13 September 2016 1676008*10 Page 6 Environmental Quality published a document titled "Trading Nutrient Reductions from Nonpoint Source Best Management Practices in the Chesapeake Bay Watershed: Guidance for Agricultural Landowners and Your Potential Trading Partners" recommends a minimum of 2:1 for non -point source pollutant offsets related to Chesapeake Bay nutrient trading. Program Evaluation In the Policy EPA indicates an offset program should be evaluated to confirm its effectiveness. The proposed discharge to surface water will be under an NPDES Permit. Therefore, we expect the permit conditions will include a requirement to evaluate the effectiveness of the offset effort. In most cases, the monitoring requirements and effluent limitations written into the permit will be set to provide sufficient data to verify treatment is effective at reducing nitrogen loading to the basin. Nutrient Load Estimation Stormwater modeling was conducted for the irrigation field areas of the Mill. The purpose of the modeling effort was to estimate runoff volumes to be used in calculation of nutrient loading at the two outfall locations resulting from runoff from the irrigated fields. In estimating runoff, the following assumptions were made: • Irrigation of effluent was not included in the runoff quantities estimated, only estimated rainfall runoff was used. • Stormwater sample results are representative of rainfall runoff from the irrigation fields. • Following cessation of irrigation, the TN concentration in runoff from the fields will be zero. This load estimation was prepared to illustrate the offset reduction in TN being discharged into the Cape Fear River Basin by eliminating irrigation and discharging treated effluent to surface water under an NPDES permit. Rainfall from the irrigated fields will runoff and flow into outfalls 004 and 006 based on the areas shown in Figure 4. For the purposes of this report, only the 78 acres under agricultural use were modeled for runoff to assist in calculation of the total nutrient load. Data Collection Stormwater runoff modeling was conducted using EPASWMM. Soils information was gathered from the USDA Web Soils Survey (WSS) and local soil data from the Shaffer Soil Services y:lprojects12016proj11676008.00_arauco_ww treatment reuse plan109_reports-memosltm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Kennedy/Jenks Consultants Engineers & Scientists, P.C. Technical Memorandum Todd Phillips Site Environmental Manager 13 September 2016 1676008*10 Page 7 Technical Memorandum (November 2015). The Shaffer Soil Services work included the following: • Soil borings to assess site characteristics and develop a site soils map. • Prepare detailed soil descriptions to 7 feet below ground surface. • Saturated hydraulic conductivity evaluation. • Infiltration assessment. The WSS indicates that the soil within Arauco's irrigation area is primarily made up of Mattaponi fine sandy loam (MaB), Peawick fine sandy loam (PeA and PeB), and Udorthents loamy (UdC). Figure 5 illustrates the location of each soil type as indicated by the WSS. The Shaffer Soils study indicated similar hydraulic conductivity values and subsequent runoff coefficients to the WSS. Annual rainfall data was gathered from the Sanford 8 northeast (NE) gauge, as it was the closest to the Mill site and had the most complete data set of the gauges in the area. The TN concentrations were estimated from the historical stormwater sampling data at each outfall from 2011 through 2015. From the rainfall data, soils data, and TN sampling results, the annual runoff from the fields was estimated and the TN load was calculated. Results of Modeling and Nutrient Runoff Estimation Based on stormwater runoff volumes modeled and results of samples collected (Table 2), the estimated nitrogen load contributed to the Cape Fear River basin from Mill stormwater runoff is summarized in Table 4. The nitrogen loads in Table 4 represent an estimate of the contribution to the nitrogen load as a result of irrigation with wastewater as is currently practiced. Table 4. Annual Estimated Nitrogen Load to the Cape Fear Basin Annual Average Nitrogen Load Year Runoff (lb/yr) (Inches) 2011 14.1 44,236 2012 12.5 12,839 2013 19.6 7,277 2014 17.3 7,913 2015 21.1 8,749 Abbreviations: Ib/yr = pounds per year y:lprojects12016proj11676008.00_arauco_ww treatment reuse plan109_reports-memosltm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Kennedy/Jenks Consultants Engineers & Scientists, P.C. Technical Memorandum Todd Phillips Site Environmental Manager 13 September 2016 1676008*10 Page 8 Proposed Treatment Improvements In April 2016, Arauco began the feasibility study and planning process to upgrade the existing wastewater system for improved effluent quality. The original intent was to land apply a portion of the effluent and recycle a portion of the effluent. Arauco has determined it will require discharge of an annual average of 100,000 gallons per day (gpd) to ensure water quality is suitable for production. The selected treatment plant will include biological oxidation of biochemical oxygen demand, chemical oxygen demand, and Total Kjeldahl Nitrogen (TKN), as well as biological nitrification and denitrification, followed by membrane filtration. The treatment process will be capable of reducing TN to less than 10 milligrams per liter (mg/L). The annual TN load resulting from Arauco's discharge of treated effluent with a TN concentration of 10 mg/L to the Haw River and the Cape Fear River basin would be 3,044 pounds per year (lb/yr). Table 5 provides a comparison of estimated TN wasteload from the irrigation fields compared to proposed surface water discharge. Table 5: Offset Between Irrigation Runoff and the Proposed Treated Effluent Runoff TN from Estimated Effluent Year Irrigation Fields TN Load to Surface Offset Ratio (lb/yr) Water (lb/yr) 2011 44,236 3,044 14.5:1 2012 12,839 3,044 4.2:1 2013 7,244 3,044 2.4:1 2014 7,913 3,044 2.6:1 2015 8,749 3,044 2.9:1 Average 16,196 3,044 5.3:1 The estimated impact of discharging treated effluent to the Haw River provides an average offset ratio of 5.3:1 compared to historical sampling. That indicates an estimated average reduction of TN input to the basin of 13,152 Ib/yr or 80 percent (%) of TN load. Conclusion Arauco's proposal to cease irrigation of the fields at the Mill in favor of constructing a new wastewater treatment plant operating under an NPDES permit will provide a significant opportunity to improve water quality in the Cape Fear Basin. An estimated average of 13,152 pounds of TN per year will be permanently removed from the Cape Fear River Basin which reduces potential for algae growth and improve water quality of the Haw River and Cape Fear River. Based on this improvement, the proposed surface water discharge under an NPDES permit will contribute to improved water quality in the basin. y:lprojects12016proj11676008.00_arauco_ww treatment reuse plan109_reports-memosltm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Kennedy/Jenks Consultants Engineers & Scientists, P.C. Technical Memorandum Todd Phillips Site Environmental Manager 13 September 2016 1676008*10 Page 9 References Accounting for Uncertainty in Offset and Trading Programs, EPA (Region III) Technical Memorandum, 12 February 2014. Environmental Assessment of the Lower Cape Fear System, 2011, Mallin, McIver, Merrit, September 2012, Center for Marine Science, UNC Wilmington. Water Quality Trading Policy, EPA Office of Water Quality, 13 January 2003. Water Quality Trading Assessment Handbook, EPA 841-B-04-001, November 2004. Water Quality Trading Toolkit for Permit Writers, EPA 833-R-07-004, August 2007, Updated June 2009. Trading Nutrient Reductions from Nonpoint Source Best Management Practices in the Chesapeake Bay Watershed: Guidance for Agricultural Landowners and Your Potential Trading Partners, Virginia Department of Environmental Quality, September 2007. Soil and Site Evaluation, Arauco-Moncure, NC Facility, Karl Shaffer, 10 November 2015. Attachments y:lprojects12016proj11676008.00_arauco_ww treatment reuse plan109_reports-memosltm-nutrient-memo-13sept2016.doc © Kennedy/Jenks Consultants, Inc. Figures y� ille.• -.Y�. ; Fearrin - �venUe • - - ��' Raleigh s- h Qbrolina 7 2 '"' - pe x s r MIS] 'OUR 1 9' New -Hill Holly Springs A # t ' + " uquay V�arina + �. + a 01 1• �• ii � -�� •�erg i � F Irriaation a ti ` #. _ � f t � 4L . Z 0 150 300 APPROXIMATE SCALE IN FEET r Kennedy/Jenks Consultants Arauco Panels USA LLC Nutrient Offset Justification 1676008.00 September 2016 Site Plan Figure 3 111111111 - t r 64 acres agriculture 0 5.8 acres paved/roof N a0 w Z - U Q U (0 0 Q) r # O F CORINTH ROAD 1 119 Wh � ' w 14 acres agriculture 53 acres paved/roof ,woo, + LEGEND Agricultural Land Paved/Roof/ Impermeable ;. . . E � . � . Z 0 150 300 APPROXIMATE SCALE IN FEET 3 Kennedy/Jenks Consultants Arauco Panels USA LLC Nutrient Offset Justification 1676008.00 September 2016 Runoff Contribution Areas Figure 4 a MaB 0 0 r A FV N M W F Z LU (.) IL U PeA NEW �A a 0 y� LL 0 Z N s UdC ` L UdC' a+ " ! + Gwqw_ MAP UNIT LEGEND PeB UdC a i CORINTH ROAD Chatham County, North Carolina (NC037) Map Unit Symbol Map Unit Name Acres in AOI Percent of AOI MaB Mattaponi fine sandy loam, 13 18% 2 to 8 percent slopes PeA Peawick fine sandy loam, 6 8% 0 to 2 percent slopes PeB Peawick fine sandy loam, 9 12% 2 to 8 percent slopes UdC Udorthents, loamy, 2 to 10 45 62% percent slopes Totals for Area of Interests 73 100% Z 0 150 300 APPROXIMATE SCALE IN FEET Kennedy/Jenks Consultants Arauco Panels USA LLC Nutrient Offset Justification 1676008.00 September 2016 Site Soil Plan Figure 5 Attachment Shaffer Soil Services, Inc. 685 Sanford Road Pittsboro, NC 27312 shaffersoils@gmail.com (919) 244-1984 November 10, 2015 Mr. John Bird Arauco- Moncure Facility 958 Corinth Road Moncure, NC 27559 John: Please find attached 2 copies of the soils and site assessment documentation for this project. Please let me know of any questions or additional information that may be needed. As the design is pursued, some minor modifications may be necessary for the water balance and/or nutrient balances as per the cropping system selected. Thank you for the opportunity to provide this service to your company. Sincerely, Karl Shaffer, L.S.S. Shaffer Soil Services, Inc. 685 Sanford Road Pittsboro, NC 27312 shaffersoils@gmail.com (919) 244-1984 November 10, 2015 Subject: Soil and Site Evaluation Arauco-Moncure, NC Facility Corinth Road and Old U.S. Highway 1 Parcel 0005343 Chatham County, NC Shaffer Soil Services, Inc. was contracted to assess soils on the subject parcel for expansion potential for the wastewater system. This report details the findings of this evaluation. This report satisfies the requirements for the soil evaluation and related guidance documents for the Division of Water Resources as specified in the 2T rules, section .0500 and subsequent guidance policies relating to these rules. The following activities were included in this site assessment: 1. Soil borings to assess site characteristics and develop a site soils map 2. Detailed soil descriptions to 7 feet 3. Soil fertility sampling 4. Saturated hydraulic conductivity evaluation 5. Infiltration rate assessment 6. Hydraulic assessment via water balance calculations 7. Agronomic and constituent loading rate assessment and recommendations INTRODUCTION The Moncure Arauco Fiberboard facility currently irrigates via 9 center pivots process wastewater from the industrial process. Arauco proposes to expand the irrigated acreage for the process wastewater. The company owns land that has not received wastewater north of the existing wastewater application fields. This land was reviewed for potential to apply wastewater to expand the wetted irrigation footprint. Arauco owns parcel 0005343 in Chatham County, NC. GENERAL SITE CONDITIONS The site is presently wooded with little disturbance. Site conditions indicate that the area was once used for row crop land, with a small homestead. The site is traversed by 2 railroad lines, a main line running east -west and a spur to the north serving an adjacent industry. The area is an old river terrace from the Haw and Cape Fear rivers, and it is no longer in a floodplain. Soils are formed from alluvial piedmont materials high in fine sands, silt, and clay. Slopes are gentle and range from 0 to 4 percent. The predominant vegetation is mature pines mixed with hardwoods. SOIL DETAILS Appendix 1 contains detailed soil descriptions for the site. Appendix 2 contains the map depicting the location of all soil boring locations used to delineate specific soil types. The soils range from fine -loamy to clayey and the soil series encountered are the following: Drainage class Soils with clay base Soils with fine loamy base Poorly Drained Roanoke Tomotley Somewhat poorly drained Wahee Augusta Moderately well drained Dogue Altavista Poorly drained soils have a seasonal high water table within 12 inches of the soil surface. These soils are not proposed for irrigation. Somewhat poorly drained soils have a seasonal high water table from 12 to 18 inches. These soils are not proposed for irrigation. Moderately well drained soils have a seasonal high water table from 18 to 36 inches. These soils are proposed for irrigation (Dogue and Altavista). These soils are further subdivided into 2 zones: Zone 1- or Map Unit 1: with depth to seasonal wetness from 18 to 24 inches and Zone 2- or Map Unit 2: with depth to seasonal wetness from 24 to 36 inches. Other than the depth to seasonal wetness, the soils encountered across the tract are very consistent with respect to depth of major horizons, texture, structure, and type of parent material. Clay decrease occurs from 50 to 70 inches over the site. For reference, the USDA official soil series description for Dogue and Altavista soils is included at the end of Appendix 1 behind the soil boring logs. Soil Maps Appendix 2 shows the site aerial photos used as the soil map base. Map 1 shows the general location. Map 2 shows the location of the soil borings by number. Map 3 shows the mapping unit segregations with all setbacks for irrigation and useable acreage applied. No distinction is made between the fine -loamy Altavista soils and the clayey Dogue soils as they are intermixed in a soil complex. Map 4 shows the location, within the mapping units, of the hydraulic conductivity measurements. The water balance (discussed below) is based upon the useable acreage shown on Map 3. 6 soil fertility samples were taken and submitted to the North Carolina Department of Agriculture - Agronomic Division. Results are shown in Appendix 3. The samples were segregated to denote the major soil units encountered. However, the results are very similar and consistent between all 6 samples. The site has had consistent management (trees) for many years. Due to the consistence in major soil chemistry parameters, the following information will not segregate between samples but will focus on the key parameters. Soil pH- Soil pH is very low, ranging from 4.1 to 4.5. This pH is adequate to grow and sustain a forested stand. If vegetation does not change, no lime recommendation will be warranted. If the site is proposed for clearing, higher pH will be recommended and a lime amendment can be calculated from the soil test data. Major soil nutrients N, P, K- N is needed for tree stands in limited quantities. The soil test N recommendation is for high yield biomass, not the goal of a wastewater system. A more prudent recommendation would be 40-80 pounds N/acre/year. P and K are both very low, and a light application of P and K should occur even for tree maintenance. All of these nutrients may be supplied by the wastewater. Calculations will be shown under the agronomic section. Secondary soil nutrients Ca, Mg, S- magnesium is low and an amendment is recommended. This should be applied via dolomitic limestone, if lime is applied. Ca and S are adequate and no amendment is needed. Ca:Mg ratios are in a good range. Micronutrients- no micronutrients are recommended. Other- sodium is low. ESP is 5 or below and shows no current level of concern for sodium. Base saturation is low. This will increase with wastewater additions. A level of 80-90% is ideal, pending nutrient balances and soil pH and CEC. This will be monitored as system operation progresses. SATURATED HYDRAULIC CONDUCTIVITY ASSESSMENT (Ksat) As required, Ksat measurements were made at representative areas on the site. The site is very uniform in its soil conditions, and one soil mapping unit is used to define the entire proposed irrigation area. This mapping unit consists of both Altavista and Dogue soils. While two individual soil series are represented, the soils are quite consistent with a subsoil clay content ranging from 30% to 40%, in other words, these are heavy Altavista soils and light Dogue soils. Because of the size of the site, a large number of Ksat readings were performed to assess the site. Further, both lower Bt and C horizons were measured to determine which was more restrictive. The compact, constant head permeameter (CCHP) method was used, except for one reading with the Aardvark permeameter which is noted in the table below. The following table depicts the key Ksat data recorded. The Ksat test number corresponds with the soil boring number in all cases. 4 Ksat data results Ksat test # Horizon Depth (in) Tubes Steady State Flow Rate (cm/10 min) Calculated Ksat (cm/hr) Ksat (in/hr) 3 Bt 36 1 1.7 0.175 0.071 3 C 60 1 1.8 0.186 0.073 49 Bt 31 1 0.9 0.093 0.04 49 C 56 1 3.2 0.33 0.13 52 Bt 38 1 1.0 0.104 0.04 55 Bt 26 1 0.8 0.083 0.033 55 C 52 1 3.5 0.364 0.14 64 Bt 32 1 5.0 0.516 0.20 64 C 55 1 2.2 0.228 0.09 67 Bt 28 1 0.5 (Aardvark tool) 0.343 0.135 67 Bt 30 1 0.8 0.083 0.033 67 C 48 1 3.3 0.343 0.14 93 Bt 30 1 1.4 0.146 0.057 93 C 51 1 2.7 0.279 0.11 117 Bt 38 1 2.1 0.218 0.086 117 C 46 1 1.8 0.186 0.073 Summary of Ksat data. Bt horizons (in/hour) C horizon (in/hour) Mathematical mean 0.077 0.108 Geometric mean 0.063 0.104 The Ksat data grouping show very high consistence, which supports the visual findings of a very consistent Bt and C material. The Bt horizons on average show a more restrictive conductivity and thus will be used for design purposes and in the water balance. The geometric mean is the preferred tool to use for management of the Ksat data. All data points are used. The geometric mean for the data is 0.063 inches per hour. This is the data point that will be used for the site's water balance assessment, found in the next section. The Ksat field data sheets and calculations are found in Appendix 4. WATER BALANCE AND HYDRAULIC RECOMMENDATIONS The site is divided into 2 irrigation zones and the water balance reflects this as Zone 1 (Map Unit 1) and Zone 2 (Map Unit 2). Zone 1 soils are Dogue and Altavista with a depth to seasonal wetness of 18 to 24 inches, averaging 21 inches. Zone 2 soils are Dogue and Altavista soils with a depth to seasonal wetness of 24 to over 36 inches, averaging 30 inches. The water balance is based on the Ksat results as well as professional judgment on the site. The proposed application site is ideal with respect to topography and surface water drainage. Note that this is strictly a water volume assessment and does not include the nutrient parameters that may apply. This tool is designed to assist with hydraulic loading rates and storage volume calculations. Other assumptions used (note, these may be modified as the system design progresses) : 1) A 0.1-acre surface area storage lagoon, uncovered. The water balance tool requires a storage factor, although this is already covered under the existing design. The use of a storage calculator is not necessary for system expansions such as this. So note that the 0.1 acre lagoon is not intended to reflect either current storage or future requirements. It merely serves as a "place - holder" factor in the water balance software for this system expansion. 2) 32,700 gallons per day design flow (note : at the time of this report, the site usage has not been determined. This site work will support flow up to a given limit based on the field assessment.). 3) Two zones are defined for irrigation. The soil conductivities are very consistent and serve for both irrigation zones. Zone separation is solely for purpose of offering more restrictive design factors for the soils with seasonal wetness from 18 to 24 inches, versus the soils with depth to seasonal wetness from 24 to 36 inches. Both zones will require groundwater mounding modeling to determine the ultimate hydraulic loading factor. 4) The soils with seasonal wetness less than 24 inches have been assigned a drainage factor of 0.05 which is on the very conservative end of the range. The better soils (Zone 2) are assigned a drainage factor of 0.08 due to ideal topography, surface drainage, and good internal soil structure. 5) The wetted area used in the water balance is 7.6 acres for Zone 1 and 13.7 acres for Zone 2. Irrigation design may not be able to wet the entire acreage, and thus this water balance may require adjustment after the irrigation design is complete. 6) The hydraulic loadings defined by the water balance are a hydraulic assessment of the soils only. The loadings may be modified during the design as nutrient loadings dictate. Appendix 5 contains the water balance sheets for this project. 0 INFILTRATION RATES Infiltration measurements were not performed at this site. Estimates and table values are used, however, these are adjusted downward to account for the possibility of long irrigation run times. The soil surface is a deep fine sandy loam underlain by a gradual textural increase. Infiltrative capacity is moderate based on texture, slopes, landscape position, and soil structure. Irrigation design texts would recommend from 0.5 to 0.7 inches per hour. However, it is important to keep these rates conservative for wastewater application. Thus I recommend that the design irrigation rate not exceed 0.4 inches per hour across the entire site, and the design engineer should strive to maintain a rate of 0.25 to 0.30 inches per hour. AGRONOMIC CONSIDERATIONS For purpose of design nutrient loading, the USDA/NCSU realistic table database shall be used. The table for Peawick soils is found in Appendix 6. Peawick soil series is the series correlated in Chatham County, but it is similar in use and management to Dogue soils with subtle differences that only affect soil classification. Recent wastewater analyses have been provided and are used herein to assess nutrient loadings to the site. These must be compared to the hydraulic loadings to determine the more limiting loading factor. Two possible cropping scenarios are presented. Others can be entertained if desired. A summary of recent wastewater analyses for N is found in Appendix 7. The facility does not monitor wastewater effluent for P and K. Nitrogen: recent wastewater analyses show that the average plant available nitrogen, by calculation, of the wastewater is 78.7 mg/L. This correlates to every acre -inch of water applied as having 17.8 pounds plant available nitrogen. For a fescue stand, the nitrogen recommendation rate is 147 pounds per acre per year. At a concentration of 17.8 pounds of N/acre-inch, the total application volume would be 8.25 inches per year (for both Zone 1 and Zone 2). The hydraulic assessment for Zone 1 allows 13.28 inches per year. The hydraulic assessment for Zone 2 allows 24.98 inches per year. For this scenario, N is limiting. For a hybrid bermudagrass alone, the N recommendation is 210 pounds per acre per year. At a concentration of 17.8 pounds of N/acre-inch, the total application volume would be 11.8 inches per year (for both Zone 1 and Zone 2). The hydraulic assessment for Zone 1 allows 13.28 inches per year. The hydraulic assessment for Zone 2 allows 24.98 inches per year. For this scenario, N is limiting. For a hybrid bermudagrass stand overseeded with a winter annual grass, an additional 50 pounds of N per acre per year may be allotted. This is the default maximum used in animal waste systems and is applicable here. It also implies that the winter grass is sowed after the last bermudagrass cutting, and that the grass is harvested before the green -up of bermudagrass, no later than April 15. These are guidelines, and the weather year by year should dictate these dates. For example, a warm spring may require ryegrass harvest by April 1. With the addition of 50 pounds N for ryegrass overseed, the N recommendation increases to 260 pounds N/acre/year. At a concentration of 17.8 pounds of N/acre- inch, the total application volume would be 14.6 inches per year (for both Zone 1 and Zone 2). The hydraulic assessment for Zone 1 allows 13.28 inches per year. The hydraulic assessment for Zone 2 allows 24.98 inches per year. For this scenario, N is limiting in Zone 2 but hydraulics is limiting in Zone 1. 7 For trees, maximum N application rates are 60-80 pounds per acre per year. Using 80; at a concentration of 17.8 pounds of N/acre-inch, the total application volume would be 4.5 inches per year (for both Zone 1 and Zone 2). The hydraulic assessment for Zone 1 allows 13.28 inches per year. The hydraulic assessment for Zone 2 allows 24.98 inches per year. For this scenario, N is limiting. Note: all hydraulic assessments must be reviewed for groundwater mounding, which may further restrict the hydraulic loading. In most cases described above, the hydraulic loading is restricted by the nutrient budget. Also note: while the permit will contain both a hydraulic and nutrient budget, hydraulic gains can be obtained in a nutrient -limiting situation if N concentrations are reduced below what has historically been attained. Additional agronomic recommendations were made earlier in the soil fertility section. This facility would not be required to apply nutrients based on a phosphorus limit. P data is not available. I recommend that wastewater P analyses commence, to assess the amount of P being applied to the crop as the soils are deficient in P. K data is not available. I recommend that wastewater K analyses commence, to assess the amount of K being applied to the crop as the soils are deficient in K. General agronomic comments This site is well -suited to both hybrid bermudagrass and fescue, as well as row crops. If clearing and hay or cropping is chosen, soil amendments as described above will be needed. Calculations can be made to determine the amount of lime, N, P, K, Ca, Mg, and S may be required. Summary agronomic table and loading potential. Zone 1: 7.6 acres, Zone 2: 13.7 acres. CROP SYSTEM APPLICATION ZONE 1 ZONE 1 ZONE 2 ZONE 2 APPLICATION LIMITED BY: APPLICATION HYDRAULIC APPLICATION HYDRAULIC VOLUME (total VOLUME CAPACITY VOLUME CAPACITY gallons based on (in/yr) (in/yr) (in/yr) (in/yr) 100% useable acreage*)for limiting constituent FESCUE N 8.25 13.28 8.25 24.98 4,771,282 BERMUDAGRASS N 11.8 13.28 11.8 24.98 6,824,383 TREES N 4.5 13.28 4.5 24.98 2,602,519 BERMUDAGRASS HYDRAULIC 14.6 13.28 14.6 24.98 8,171,340 WITH WINTER LOAD -Zone 1 OVERSEED N- Zone 2 * 100% useable acreage cannot be obtained unless drip or micro -irrigation systems are used. These are prone to clogging and not recommended for the present wastewater. N SUMMARY COMMENTS FOR THIS PROJECT 1) The maximum irrigation rate is 0.4 inch per hour although I recommend the design engineer strive to maintain less than 0.3 inch/hour. I also recommend that the maximum application depth per event is 1.0 inch. 2) The facility will be limited by nitrogen in all cases except Zone 1 if a combination hybrid bermudagrass/winter overseed cropping system is used. The table in the agronomic section summarizes loading potential. 3) This project does not specify additional storage. Storage will be increased, in terms of days of operation, by adding irrigation zones. 4) The soils with depth to seasonal wetness are not prescribed for irrigation at this time. They are no absolutely prohibitive, however, when groundwater mounding is considered, these areas would likely allow very little irrigation volume per year and are likely not justified to add. 5) The system is mainly N limited based on the past 12 months of effluent N concentrations. If treatment allows for N reductions, then the hydraulic limits may supersede the N limits. It is strongly recommended that you request the permit modification to be open-ended as to N and hydraulic limits. This will allow additional flow, up to the hydraulic limit, if N effluent concentrations are reduced over time. This report and attached maps and appendices represent my professional opinion. The assumptions and calculations are based on accepted scientific principles and data collection and interpretation. Soils and hydraulic conductivities are naturally highly variable, and differing opinions and interpretations may occur. The attached maps and appendices are not to be separated from this report as the use may be misinterpreted. I appreciate the opportunity to perform this service for your company. Please contact me if you have any questions on this report and its addendums. Sincerely, Karl A. Shaffer, L.S.S. President -Shaffer Soil Services, Inc. Attachments: Appendix 1— Soil Descriptions and USDA Official Series Descriptions Appendix 2 — Maps Appendix 3 - Soil Fertility Test Results Appendix 4- Hydraulic Conductivity Field Sheets Appendix 5- Water Balance Appendix 6 — Realistic Yield Tables for Dogue (Peawick) Soils Appendix 7 — Summary N concentrations for effluent 10 Appendix C: Cost Estimate Detail Engineering Alternatives Analysis, Arauco Panels, LLC C-1 y:lprojects12016proj11676008.10_arauco_npdes109_reports-memos19.09_repotengineering alternativesleaa reportleaa_report-fnal_13sept2016.doc Agency: Project/Problem: Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6 Arauco Panels LLC, Moncure, NC Engineering Alternatives Analysis Connection to Sanford Big Buffalo WWTP Land Application Wastewater Reuse/Recycling Discharge to Surface Water Combination of Alternatives Haul Wastewater to POTW Capital Cost 20-year NPV $6,776,390 ($7,939,697) $6,145,100 ($7,622,250) $7,358,000 ($35,796,168) $3,477,500 ($4,839,626) $4,123,600 ($5,519,023) $128,000 ($55,838,966) From Summary Sheet: Risk adjustments (+/- percent): Year of analysis 2016 Benefits Escalation rate 3.50% Capital costs Discount rate Running costs Expressed in 2016 dollars, unescalated -- dollars Expressed in escalated dollars with sensitivity adjustments Capital Outlays 3-inch HDPE Main Grading and Preparation Pump Station ARV Stations Capital outlay 5 Contingency (30%) Total capital outlays Benefits: Benefit 1 Benefit 2 Benefit 3 Total benefits Annual Running Costs: Electricity Pump maintenance Valve maintenance Level Sensorcalibration Flow meter calibration Pump rewinding/reconditioning Discharge fee Running cost 8 Total running costs Life cycle cost analysis PVs in 2016 NPV as of 2016 --------------------- 4,000 4,140 4,285 4,435 4,590 4,751 4,917 5,089 5,267 5,452 5,642 5,840 6,044 6,256 6,475 6,701 6,936 7,179 7,430 7,690 7,959 360 373 386 399 413 428 443 458 474 491 508 526 544 563 583 603 624 646 669 692 716 480 497 514 532 551 570 590 611 632 654 677 701 725 751 777 804 832 861 892 923 955 1,000 1,188 1,411 1,675 1,990 1,000 1,035 1,071 1,109 1,148 1,188 1,229 1,272 1,317 1,363 1,411 1,460 1,511 1,564 1,619 1,675 1,734 1,795 1,857 1,923 1,990 7,000 1 1 8,314 1 9,874 11,727 13,929 30,672 31,746 32,857 34,007 35,197 1 36,429 37,704 39,023 40,389 41,803 43,266 44,780 46,347 47,970 49. 449 51,386 53,185 55,046 56,973 58,967 1 61,031 44,512 37,790 39,113 40,482 41,898 52,866 44,883 46,453 48,079 49,762 62,789 53,306 55,172 57,103 59,102 74,573 63,311 65,527 67,821 70,194 88,569 (6,820,902) (37,790) (39,113) (40,482) (41,898) (52,866) (44,883) (46,453) (48,079) (49,762) (62,789) (53,306) (55,172) (57,103) (59,102) (74,573) (63,311) (65,527) (67,821) (70,194) (88,569) (7,939,697) Appendix A, Page 1 of 1 Alt_1 From Summary Sheet: Risk adjustments (+/- percent): Year of analysis 2016 Benefits Escalation rate 3.50% Capital costs Discount rate Running costs Expressed in 2016 dollars, unescalated -- dollars Expressed in escalated dollars with sensitivity adjustments Capital Outlays Acquire Extra 100 Acres Piping (20,000 feet, 3 inch) Grading/Land Prep, 6 CP Irrigation U Irrigation pump & Controller Wastewater Treatment Plant Contingency (30%) Total capital outlays Annual Running Costs: Electricity (10 hp, 24 hr, $0.09/kwh) Misc Maintenance Total running costs Life cycle cost analysis PVs in 2016 NPV as of 2016 5,800 6,003 6,213 6,431 6,656 6,889 7,130 7,379 7,637 7,905 8,181 8,468 8,764 9,071 9,388 9,717 10,057 10,409 10,773 11,151 11,541 1,000 1,035 1,071 1,109 1,148 1,188 1,229 1,272 1,317 1,363 1,411 1,460 1,511 1,564 1,619 1,675 1,734 1,795 1,857 1,923 1,990 48,800 50,508 52,276 54,105 55,999 57,959 59,988 62,087 64,260 66,509 68,837 71,247 73,740 76,321 78,992 81,757 84,619 87,580 90,645 93,818 1 97,102 (6,193,900) (50,508) (52,276) (54,105) (55,999) (57,959) (59,988) (62,087) (64,260) (66,509) (68,837) (71,247) (73,740) (76,321) (78,992) (81,757) (84,619) (87,580) (90,645) (93,818) (97,102) (7,622,250) Appendix A, Page 1 of 1 Alt_2 From Summary Sheet: Risk adjustments (+/- percent): Year of analysis 2016 Benefits Escalation rate 3.50% Capital costs Discount rate Running costs Expressed in 2016 dollars, unescalated -- dollars Expressed in escalated dollars with sensitivity adjustments Capital Outlays Evaporator Installation Contingency (30%) Total capital outlays Annual Running Costs: Evaporator Operating Cost 30 Hp pump electricity Residual Disposal (Estimate) Life cycle cost analysis 870,000 900,450 931,966 964,585 998,345 1,033,287 1,069,452 1,106,883 1,145,624 1,185,721 1,227,221 1,270,174 1,314,630 1,360,642 1,408,264 1,457,553 1,508,568 1,561,368 1,616,016 1,672,576 1,731,116 17,500 18,113 1 18,746 1 19,403 1 20,082 20,785 1 21,512 1 22,265 1 23,044 23,851 1 24,685 1 25,549 1 26,444 27,369 1 28,327 1 29,319 1 30,345 31,407 1 32,506 1 33,644 34,821 10,000 10,350 1 10,712 1 11,087 1 11,475 11,877 1 12,293 1 12,723 1 13,168 13,629 1 14,106 1 14,600 1 15,111 15,640 1 16,187 1 16,753 1 17,340 17,947 1 18,575 1 19,225 19,898 PVs in 2016 1 (8,297,500) (972,383) (1,006,416) (1,041,640) (1,078,098) (1,115,831) (1,154,885) (1,195,306) (1,237,142) (1,280,442) (1,325,258) (1,371,642) (1,419,649) (1,469,337) (1,520,764) (1,573,990) (1,629,080) (1,686,098) (1,745,111) (1,806,190) (1,869,407) NPV as of 2016 1 (35,796,168) Appendix A, Page 1 of 1 Alt_3 From Summary Sheet: Risk adjustments (+/- percent): Year of analysis 2016 Benefits Escalation rate 3.50% Capital costs Discount rate Running costs Year I 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 Expressed in 2016 dollars, unescalated -- dollars Expressed in escalated dollars with sensitivity adjustments Capital Outlays Misc Piping Valves Contingency (30%) Total capital outlays Annual Running Costs: Electricity Misc Maintenance Life cycle cost analysis PVs in 2016 NPV as of 2016 1,000 1,035 1,071 1,109 1,148 1,188 1,229 1,272 1,317 1,363 1,411 1,460 1,511 1,564 1,619 1,675 1,734 1,795 1,857 1,923 1,990 2,000 2,070 2,142 2,217 2,295 2,375 2,459 2,545 2,634 2,726 2,821 2,920 3,022 3,128 3,237 3,351 3,468 3,589 3,715 3,845 3,980 (3,522,500) (46,575) (48,205) (49,892) (51,639) (53,446) (55,316) (57,253) (59,256) (61,330) (63,477) (65,699) (67,998) (70,378) (72,841) (75,391) (78,029) (80,760) (83,587) (86,513) (89,540) (4,839,626) Appendix A, Page 1 of 1 Alt_4 From Summary Sheet: Risk adjustments (+/- percent): Year of analysis 2016 Benefits Escalation rate 3.50% Capital costs Discount rate Running costs Expressed in 2016 dollars, unescalated -- dollars Expressed in escalated dollars with sensitivity adjustments Capital Outlays Piping Grading/Land Prep Misc Piping & Valves Land Purchase Contingency (30%) Total capital outlays Annual Running Costs: Electricity Misc Maintenance Total running costs Life cycle cost analysis PVs in 2016 NPV as of 2016 1,100 1,139 1,178 1,220 1,262 1,306 1,352 1,400 1,448 1,4991 1,552 1,606 1,662 1,720 1,781 1,843 1,907 1,974 2,043 2,115 2,189 3,000 3,105 3,214 3,326 3,443 3,563 3,688 3,817 3,950 1 4,089 1 4,232 4,380 1 4,533 1 4,692 4,856 1 5,026 1 5,202 5,384 5,572 1 5,768 5,969 46,100 1 47,714 49,383 51,112 52,901 54,752 56,669 58,652 60,705 1 62,830 1 65,029 67,305 1 69,660 1 72,098 1 74,622 1 7 79,937 1 82,735 1 85,630 88,62 91,729 (4,169,700) (47,714) (49,383) (51,112) (52,901) (54,752) (56,669) (58,652) (60,705) (62,830) (65,029) (67,305) (69,660) (72,098) (74,622) (77,234) (79,937) (82,735) (85,630) (88,627) (91,729) (5,519,023) Appendix A, Page 1 of 1 Alt_5 From Summary Sheet: Risk adjustments (+/- percent): Year of analysis 2016 Benefits Escalation rate 3.50% Capital costs Discount rate Running costs Expressed in 2016 dollars, unescalated -- dollars Expressed in escalated dollars with sensitivity adjustments Capital Outlays Storage/Equalization Tank Concrete (4 CY) Tank site prep Contingency (30%) Total capital outlays Annual Running Costs: Haul Wastewater Tank maintenance Discharge Fee Total running costs Life cycle cost analysis PVs in 2016 NPV as of 2016 off 1,825,000 1,888,875 1,954,986 2,023,410 2,094,229 2,167,528 2,243,391 2,321,910 2,403,176 2,487,288 2,574,343 2,664,445 2,757,700 2,854,220 2,954,118 3,057,512 3,164,525 3,275,283 3,389,918 3,508,565 3,631,365 400 414 428 443 459 475 492 509 527 545 564 584 604 626 647 670 694 718 743 769 796 15,120 15,649 16,197 16,764 17,351 17,958 18,586 19,237 19,910 20,607 21,328 22,075 22,847 23,647 24,475 25,331 26,218 27,135 28,085 29,068 30,086 1,840,520 1,904,938 1,971,611 2,040,617 2,112,039 2,185,960 2,262,469 2,341,655 2,423,613 2,508,440 2,596,235 2,687,103 2,781,152 2,878,492 2,979,240 3,083,513 3,191,436 3,303,136 3,418,746 3,538,402 1 3,662,246 (1,967,920) (1,904,938) (1,971,611) (2,040,617) (2,112,039) (2,185,960) (2,262,469) (2,341,655) (2,423,613) (2,508,440) (2,596,235) (2,687,103) (2,781,152) (2,878,492) (2,979,240) (3,083,513) (3,191,436) (3,303,136) (3,418,746) (3,538,402) (3,662,246) (55,838,966) Appendix A, Page 1 of 1 Alt_6