WQ0042203_Notice of Deficiency_20240417

North Carolina Department of Environmental Quality | Division of Water Resources
Winston-Salem Regional Office | 450 W. Hanes Mill Rd, Suite 300 | Winston-Salem, North Carolina 27105
336.776.9800

April 17, 2024

Delivered via email to: [e-mail]

Mr. Steve Kobelak, Plant Manager
Weyerhaeuser NR Company
524 Pride Way
Elkin, NC 28621

SUBJECT: NOTICE OF DEFICIENCY (NOD-2024-PC-0071)
2023 Residuals Annual Report Review
Weyerhaeuser Distribution of Class A Residuals
Permit No. WQ0042203
Surry County

Dear Mr. Kobelak:

On April 15, 2024, Division of Water Resources staff Kristen Potwora completed a
review of the 2023 Annual Report for WQ0042203. This review reflects non-compliance
with the subject permit.

The following item of deficiency was noted:

1. Records show that the Annual Report was received on 03/14/2024. Per Permit
Condition IV.7, “an annual report shall be submitted on or before March 1st.”
Please ensure that all annual reports are submitted according to permit
requirements.

The following items of concern were noted:

 Lab analysis reports for Residuals Analysis and TCLP were not included in
the final 2023 Annual Report. Additional information was requested on
4/3/2024, and lab results were forwarded to DWR staff on that same day.
 The Plant Available Nitrogen (PAN) rate for the 11/21/23 sample was
reported incorrectly. An incorrect nitrate value was used in the calculation.
DWR staff calculated PAN to be 6166.14 mg/kg. Please ensure all
calculations are correct.

North Carolina Department of Environmental Quality | Division of Water Resources
Winston-Salem Regional Office | 450 W. Hanes Mill Rd, Suite 300 | Raleigh, North Carolina 27105
336.776.9800

 All the PAN rates were reported with incorrect units (lbs/acre) on the Annual
Residual Sampling Summary Form. The PAN Surface rate in mg/k should
be used moving forward.
 pH was not recorded on the Annual Residual Sampling Summary Form for
the sample taken on 09/12/23. The Lab results sent on 4/3/2024 didn’t show
the pH value for that sample.

Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact me or Kristen Potwora at the letterhead address
and phone number 336-776-9697, or by email at [e-mail] or
[e-mail]

Sincerely,

Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO

Enc: Inspection Report
Cc: Dennis Atkinson, ORC (electronic copy)
Surry County Department of Environmental Health (electronic copy)
Compliance Inspection Report
Permit:WQ0042203 Effective:04/05/21 Expiration:01/31/28 Owner :Weyerhaeuser Nr Company
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Surry
Winston-Salem
Dennis Atkinson
Effective:Expiration:Facility:Weyerhaeuser NR Company DCAR
524 Pride Way
Elkin NC 28621
Title:Phone:[phone]Environmental Manager
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
WQ0005555 Weyerhaeuser Nr Company - Weyerhaeuser – Elkin OSB Mill WWTF
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
04/03/2024 08:00AM 09:00AM
Kristen Potwora 336-776-9800
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503 Exempt)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Sampling
(See attachment summary)
Page 1 of 3
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0042203
04/03/2024 Annual Report Review
Weyerhaeuser Nr Company
Routine
Inspection Summary:
Page 2 of 3
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0042203
04/03/2024 Annual Report Review
Weyerhaeuser Nr Company
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
Record Keeping Yes No NA NE
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:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate?
Is sampling representative?
Comment:
Page 3 of 3