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HomeMy WebLinkAboutWQ0000461_2021 ARR NOD-2022-PC-0047_20220411ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Matt Holcombe, Plant Manager Louisiana-Pacific Corporation 1068 ABTco Road North Wilkesboro, NC 28659 NORTH CAROLINA Environmental Quality April 11, 2022 SUBJECT: Notice of Deficiency (NOD-2022-PC-0047) 2021 Residuals Annual Report Review LP Roaring River Mill, Distribution/Land Application of Class A Residuals Permit No. WQ0000461 Wilkes County Dear Mr. Holcombe: Division of Water Resources staff person Caitlin Caudle completed a review of the 2021 Residuals Annual Report. A site visit was completed as part of this review. This review was non -compliant with the subject permit. The following deficiency was noted: 1. Per Permit Condition IV.7 all monitoring wells shall be sampled at the frequencies and for parameters specified in Attachment C. The annual report review showed that all monitoring wells were not sampled for Total Phosphorus in the 2021 calendar year. This is a violation of the subject permit. Moving forward be sure to sample all wells for Total Phosphorus. Please review the enclosed inspection report for additional comments and observations. If you have any questions regarding this letter, please contact Caitlin Caudle at the letterhead address or phone number, or by email at caitlin.caudle@ncdenr.gov. Sincerely, DocuSigned by: "-0D2D3CE3F1 B7456... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: James Boles, ORC — LP Corp (electronic copy) Chad Witherspoon — LP Corp (electronic copy) Laserfiche File WQ0000461 WSRO Electronic Files GDE NORTH C OLI JA ' omm m�� ep..of o�.i North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQ0000461 Effective: 11/16/20 Expiration: 07/31/27 Owner : Louisiana-Pacific Corporation SOC: Effective: Expiration: Facility: Louisiana-Pacific - Roaring River Mill DCAR County: Wilkes 1151 Abtco Rd Region: Winston-Salem Contact Person: Chad Witherspoon Roaring River NC 28669 Title: Phone: 336-696-3448 Directions to Facility: Highway 268 System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0005266 Louisiana-Pacific Corporation - LP Roaring River WWTP Inspection Date: 04/04/2022 Entry Time 03:OOPM Exit Time: 04:30PM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Annual Report Review Permit Inspection Type: Distribution of Residual Solids (503) Facility Status: ❑ Compliant Not Compliant Question Areas: ▪ Miscellaneous Questions Record Keeping Sampling ▪ Wells (See attachment summary) Page 1 of 3 Permit: WQ0000461 Owner - Facility: Louisiana-Pacific Corporation Inspection Date: 04/04/2022 Inspection Type : Annual Report Review Reason for Visit: Routine Inspection Summary: Division of Water Resources staff person Caitlin Caudle completed a review of the 2021 Residuals Annual Report. This reviev was non -compliant with the subject permit. The following deficiency was noted: 1. Per Permit Condition IV.7 all monitoring wells shall be sampled at the frequencies and for parameters specified in Attachment C. The annual report review showed that all monitoring wells were not sampled for Total Phosphorus in the 2021 calendar year. This is a violation of the subject permit. Moving forward be sure to sample all wells for Total Phosphorus. Other observations: • The signature of the Permittee on the Distribution and Marketing/Surface Disposal Certification Summary Form did not match what was on record. Chad Witherspoon provided updated information for the most recent Plant Manager. Page 2 of 3 Permit: WQ0000461 Owner - Facility: Louisiana-Pacific Corporation Inspection Date: 04/04/2022 Inspection Type : Annual Report Review Reason for Visit: Routine Type Land Application Distribution and Marketing Record Keeping Is GW monitoring being conducted, if required? Are GW samples from all MWs sampled for all required parameters? Are there any GW quality violations? Is GW-59A certification form completed for facility? Is a copy of current permit on -site? Are current metals and nutrient analysis available? Are nutrient and metal loading calculating most limiting parameters? a. TCLP analysis? b. SSFA (Standard Soil Fertility Analysis)? Are PAN balances being maintained? Are PAN balances within permit limits? Has land application equipment been calibrated? Are there pH records for alkaline stabilization? Are there pH records for the land application site? Are nutrient/crop removal practices in place? Do lab sheets support data reported on Residual Analysis Summary? Are hauling records available? Are hauling records maintained and up-to-date? # Has permittee been free of public complaints in last 12 months? Has application occurred during Seasonal Restriction window? Comment: Nitrate exceedances in MW1, MW5, MW9. Total calendar year. Sampling Describe sampling: Is sampling adequate? Is sampling representative? Comment: TP was missed in all monitoring wells. Yes No NA NE Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Phosphorus was not sampled for in the 2021 Yes No NA NE Page 3 of 3