WQ0000461_Pilot Study Request_20220216

February 9, 2022
Mr. Nathaniel D. Thornburg
Division of Water Resources
NC Department of Environmental Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Louisiana-Pacific Roaring River
Pilot Study Request — Process Wastewater Non -Discharge Evaporation
Wilkes County
Dear Mr. Thornburg:
Louisiana-Pacific's Roaring River (LP) greatly appreciates you discussing a proposed pilot study to evaluate
treatment and evaporation as a potential non -discharge process wastewater disposal method recently with Mr.
Bob Branch with Branch Residuals and Soils LLC. Based on those conversations, we respectfully request
approval to perform an 18-month pilot study to evaluate evaporation as a disposal method for our process
wastewater.
The proposed study plan is attached. We greatly appreciate your consideration. If you have any questions,
please contact Chad Witherspoon here at the facility, at [phone] or at [e-mail],
Sincerely,
Matt Holcombe
Plant Manager
Attachments
cc:
C:W SERS\ROOP 10129097\APPDATA\LOCAL\MICROSOF LW INOO WS jNETCACHE\CONTENT.OUTLCIOK\F7YM 6DOF\L436069 . LP RR EVAP STU DY_DRAFT(2).DOCX

Wastewater Evaporation Pilot Study
Louisiana-Pacific Roaring River
Wilkes County
Background
LP formerly operated a hardboard siding manufacturing operation in Roaring River, Wilkes County, North
Carolina. In 2020, the facility discontinued major manufacturing operations and now only performs finishing
operations. As part of current operations, LP generates sanitary wastewater and approximately 3,000 gallons
per day (gpd) of process wastewater. The sanitary wastewater is collected and treated separately in a package
plant and discharged to the Yadkin River in accordance with National Pollutant Discharge Elimination System
(NPDES) Permit No. NC0005266.
Prior to discontinuing major manufacturing operations, the process wastewater generated from those operations
was treated in an onsite process wastewater treatment system and discharged to the Yadkin River along with the
sanitary wastewater. With the facility now only performing finishing operations, the process wastewater from the
finishing operations is subject to regulation by Subpart L— Finishing Subcategory of the Timber Products
Processing Point Source Category (40 CFR Part 429). That regulation prohibits the discharge to navigable waters of
process wastewater subject to regulation by Subpart L. Currently, LP collects and ships the wastewater offsite to a
commercial wastewater disposal service in accordance with approval dated February 5, 2021, from NC DEQ.
With the pump and haul approval set to expire on February 5, 2026, the understanding that NC DEQ prefers not
to approve permanent pump and haul applications, and no public sewer access available located near the
facility, LP would like to evaluate treatment utilizing a portion of the existing onsite process wastewater
treatment system and evaporation. LP worked with the National Council of Air and Stream Improvement
(NCASI) as part of a desk -top, engineering evaluation of the potential for evaporation for the site. The results of
that evaluation determined that on an annual basis, treated wastewater would be evaporated at more than
double the generation rate. NCASI's evaporation modeling appears to match up very closely with our own field
measurements of water level and influent flow when wastewater was being discharged to the aeration basins.
Therefore, LP would like to pursue a field pilot study to further validate the evaporation results through multiple
seasons. The proposed pilot study plan described below will also consider the effectiveness of the treatment
steps to meet potential spray irrigation requirements in the event that the pilot study indicates evaporation may
not be sufficient for disposal.
Pilot Study Plan
LP proposes to perform the pilot study for six quarters to validate evaporation rates during different seasons
throughout the year. The six quarters will allow the study to extend through Winter of 2023 to gain addition
evaporation field data during the typical low evaporation period of the year. The six quarters will also enable LP
to submit quarterly progress reports with ongoing results.
C:\USERS\ROOP10129097\APPDATA\LOCAL\MICROSOFI'\WINDOWS\INETCACHE\CONTENT.OUTLOOK\F7YM600F\L436069 - LP RR EVAP STUDY_DRAF (2).DOCX

Wastewater Evaporation Pilot Study
Louisiana-Pacific Roaring River
Wilkes County
During the study, LP will perform a physical/chemical primary treatment to precipitate and remove solids on the
3,000 gpd finishing wastewater stream and then send the wastewater to the existing three -acre aeration basin
for biological treatment/stabilization and evaporation. Based on the oxygen demand and in line with LP's long-
term operating strategy to be evaluated with the study, LP proposes to operate one or more 75-horsepower
surface mechanical aerators as needed during the study to provide mixing for the basin and to determine their
effect on evaporation. Records will be kept during the study of aerator operation.
During the study, process parameters will be monitored on the raw and treated wastewater streams as well as
within the basin itself at various frequencies in accordance with the attached sampling plan. Sampling
frequencies may be modified, and monitoring parameters adjusted during the study as an understanding of the
trends and variability of the data is gained. Site rainfall and basin water level will also be measured daily.
Solids from the primary treatment system will be dewatered and disposed at a municipal landfill. LP does not
anticipate the generation of substantial solids within the aeration basin during the study. If a permanent
evaporation program is implemented, LP will perform long-term management of solids in the basin as needed,
such as maintenance dredging and landfill disposal.
LP will maintain a running log of monitored parameters and evaluate the results to determine if adjustments to
the study plan would be warranted, such as operating additional aerators, adjusting treatment chemicals in the
primary treatment system, and adjusting sampling frequencies/parameters monitored. At the conclusion of the
study, LP will prepare an engineering report presenting the findings of the study. Based on the results, LP will
discuss the applicable permitting application process with your office regarding the favorable disposal method.
LP requests approval for the pilot study for at least six quarters but allows for additional time to continue the
study while a final disposal method is determined and permitted.
C\USERS\R00P10129097\APPDATA\ LOCAL \MICROSOFT \W INDOW S\INETCAd1E\CONTENT.0UTLO0K\F7YM6DOF\L436069 - LP RR EVAP STUDY_DRAFr(2).D00(

Evaporation Pilot Study Monitoring Plan
LP Roaring River
Baseline Raw Wastewater Monitoring (Prior to Primary Treatment)
Monitoring Frequency
Parameter
Daily
Weekly
Monthly
Quarterly
BOD5
X
TSS & Total solids
X
pH
X
Temperature
X
Flow, gpd
X
X (monthly avg)
Primary Treated Wastewater
Monitoring Frequency
Parameter
Daily
Weekly
Monthly
Quarterly
BOD5
X
TSS & Total solids
X
NH3 — N
X
Turbidity
X
pH
X
Temperature
X
Flow, gpd
X
X (Monthly Avg)
Aeration/Stabilization Basin and Site
Monitoring Frequency
Parameter
Daily
Weekly
Monthly
Quarterly
Rainfall
X
-
-
-
Basin Water Level
X
-
-
-
BOD5
X
TSS & Total solids
X
NH3 -- N
X
Turbidity
X
E. Coli (or similar
pathogen test)
X
D.O.
X
pH
X
Temperature
X
C:\USERS\ROOP16129697\APPDATA\LOCAL\MICROSOFT\WINDOWS\INETCACHE\CONTENT.OUTLOOK\F7YM6DOF\L436669-LP RR EVAP STUDY_DRAFT(21.0O0(

Wastewater Evaporation Pilot Study
Louisiana-Pacific Roaring River
Wilkes County
C:\USERAROOP10129097\APPDATALOCALWICROSOFT\WINDOWS\INETCACNE\CONTENT.OUTLOOIC\F7YM6DOF\LA96069 - LP RR EVAP STUDY DRAFTM.DOCX