WQ0028749_NOV-2019-PC-0698 Response_20191112

No Pc -mil 9C)
November 12, 2019
NC Division of Environmental Quality
Division of Water Resources, Water Quality
Attn: Mr. Rick Bolich
3800 Barrett Drive
1628 Mail Service Center
Raleigh, NC 27699-1628
Dear Mr. Bolich,
Lp
SUILDING PRODUCTS
NC Dept of Environmental Quality
NOV 15 2019
Raleigh Regional Office
This letter is in response to the Notice of Violation (NOV) issued to the Louisiana-Pacific
(LP) Orientated Strand Board facility located in Roxboro North Carolina dated October 18,
20I9. The NOV was issued in response to observations made during an inspection by Mr.
Ray MiIosh on October 16, 2019. The NOV states, "On the day of the inspection, the
sandfilter had ponded water that was overflowing and running down into the treated water
holding pond. The sand filter must be repaired or replaced immediately." It also stated "This
system is losing water. The source of the leak must be determined and corrected."
Louisiana-Pacific has operated the onsite domestic waste water system in accordance with
the conditions set forth in permit WQ0028749 since 2006. In 2018 weekly inspections
identified that the sand filter was not draining as expected, although still in compliance with
the permit. Historically, when we identified this type of change, chlorine treatments and
cleaning the drain Iines, both considered normal maintenance activities, returned flow to a
normal range. In 2018 these actions became ineffective. As a result, LP contacted Mr.
Kevin Davidson with Agri -Waste Technology to evaluate the system. It was determined that
the sandfilter was at the end of its useful life and either needed to be rebuilt or replaced. Mr.
Davidson provided a cost evaluation of both options. Once received, LP choose the higher
upfront cost option and allocated $149,000. Purchase orders were issued to both consulting
and construction contractors. Your office acknowledged receipt of the application on
September I3, 2019, with Mr. Milosh conducting a site visit to verify site conditions on
October 16, 2019. We received the permit to begin the project on November 8, 2019. We
have already made arrangement for the work to begin and expect the project to be completed
by the end of January 2020. We believe our actions clearly demonstrate that we were
committed and well into the process of replacing the sandfilter prior to the issuance of an
NOV.
ADDRESS 10475 Boston Road
Roxboro, NC 27574
TEL [phone]
FAX 366 599, 5153
WEB www Ipcorp corn

Mr. Rick Bolich
11/12/19
Page 2 of 2
The NOV states, "The irrigation pond receives roughly 1000 gallons per day of treated
water, but no irrigation has occurred since June 2018... This system is losing water. The
source of the leak must be determined and corrected." These statements are not accurate.
The system has averaged 917 gpd from May 2017 through September 2019, and 20,800
gallons were irrigated in August 2018, with an additional 39,000 gallons in November 2018.
We agree the system is losing water, but do not believe it is through a leak. This was
discussed with Mr. Milosh in December 2018. As discussed, the potential of a leak has been
investigated extensively since the installation of the system. We believe the water "loss" is
within the design of the system. In accordance with the rules in place in 2005 the system was
designed and permitted with a clay liner that allows "...a hydraulic conductivity of no greater
than 1 x 10-6 centimeters per second when compacted, or a synthetic liner of sufficient
thickness to exhibit structural integrity and an effective hydraulic conductivity no greater
than that of the natural material liner, according to 15A NCAC 2H .0219(f)." (Please note
the current rifles went into effect on September 1, 2006, after the original permit for the
system was issued.) Based on the permitted design AWT has evaluated the seepage rate and
provided a preliminary calculated allowable rate of 530-690 gpd. When we receive their
finalized evaluation it will be forwarded. Some additional seepage, per the originally
permitted design, also occurs through the sandfilter. This seems to account for the water loss
in the system that was identified in the NOV as a leak. Once the new system is installed we
anticipate a reduction in the seepage rate thru the new filter and an increased rate of
irrigation.
I certify, under penalty of law, that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information including the possibility of fines and imprisonment for
knowing violations.
If you have any questions or concerns, please contact Mr. Ross Reed at [phone], ext.
3166.
Sincerely,
Mike Sarder
Plant Manager