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Home My WebLink AboutNCG210355_COMPLETE FILE - HISTORICAL_20160808STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. aqj c)3c lv DOC TYPE X HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ O' C) 110 0 ? b $ YYYYMMDD Energy Mineral & Land Resources ENVIRONMENTAL QUALITY Roy Hart, EHS Manager P O Box 98 Roaring River, NC 28669 August 08, 2016 Subject Technical Assistance/Compliance Inspection Permit No NCG 210355 Louisiana Pacific Corporation Wilkes County Dear Mr Hart PAT McCRORY Governor DONALD R VAN DER VAART Secretary TRACY DAVIS Director On August 03, 2016 Glen White and Sue White of the North Carolina Department of Environmental Quality, Department of Energy, Minerals, and Land Resources visited the facility located on Abtco Road in Roaring River to conduct a technical assistance inspection at your request This inspection is being conducted as a full Compliance Inspection and consists of review of the Stormwater Pollution Prevention Plan training, monitoring and spills records as well as observation of the general condition of the site Technical Assistance Mr Hart request NCDEQ's assistance to determine the need and required size of a new sediment/skimmer basin to be installed in what will be a landfill area The area is currently pasture It's well vegetated and far upstream from the stormwater discharge location on the Louisiana Pacific (LP) property Inspectors felt that a new basin may not be needed unless a substantial area is exposed by development or landfill activities LP is not required to provide an additional basin at this time If it appears that a new basin will be needed at a later date, NCDEQ will inform LP of that requirement and all ow adequate time to construct the measure Analytical and Qualitative Monitoring will be required downstream of the new facilities The new monitoring location must be determined and the SPPP siteplan must be updated to include its location Permit This facility holds General Stormwater Permit NCG210355 to discharge stormwater from industrial activity associated with Lumber and Wood Products, Except Furniture (SIC 241 under the National Pollutant Discharge Elimination System (NPDES) The permit became effective August 01, 2013 and expires on July 31, 2018 The current permit was available for review and was included in the SPPP State of North Carolina I Environmental Quality I Entrgy Mlntml and Land Resources Winston Salem Regional Office 1450 Hanes Mill Road Suite 300 I Winston Salem NC 27103 336 776 9800 Records/Reports This facility was required to develop and maintain a Stormwater Pollution Prevention Plan (SPPP) in accordance with Part 11, Section A of the permit All qualitative and analytical monitoring records are required to be maintained with the SPPP for a minimum of five (5) years The SPPP has been updated annually by Mr Hart and training is current and provide to all employees Facility Site Review The Roaring River facility manufactures fiberboard Logs are stored onsite, chipped then digested to manufacture product The site has three (3) stormwater outfalls The site is currently in Tier III for monitoring due to consistent exceedances for analytical monitored parameters although the facility has worked hard to provide protective measures Effluent Receiviniz Waters Stormwater from this facility discharges via three outfalls to the adjacent, Class C waters of theYadkin Pee -Dee River Basin Self -Monitoring Program This facility is in an ongoing Tier III Response for consecutive TSS and COD exceedance The Tiered Response is being conducted and reported as required The facility was found to be compliant with its industrial stormwater permit If you have questions or need additional information, please contact Glen White at (336) 776-9660 Sincerely, Matthew E Gantt, P E Regional Engineer Land Quality Section Winston-Salem Regional Office Enclosures Inspection Report cc File Copy Division of Energy, Mineral and Land Resources (WSRO) State of North Carolina I Environmental Quaitty I Energy Mineral and Land Resources Winston-Salem Regional Office 1 450 Hanes Mill Road Suite 300 1 Winston Salem, NC 27103 336 776 9$00 Compliance Inspection Report Permit NCG210355 Effective 0810103 Expiration 07/31/18 Owner Louisiana Pacific Corporation SOC Effective Expiration Facility Louisiana Pacific Corp County Wilkes PO Box 98 Hwy 268 Region Winston Salem Roaring River NC 28669 Contact Person Roy Hart Title Phone 336 696 3464 Directions to Facility System Classifications Primary ORC Certification Phone Secondary ORC(s) On Site Representative(s) Related Permits Inspection Date 08/03/2016 Entry Time 10 OOAM Exit Time 11 15AMi Primary Inspector Glen White Phone 336-776 9800 Secondary Inspector(s) Reason for Inspection Routine Inspection Type Technical Assistance Permit Inspection Type Timber Products Stormwater Discharge COC Facility Status ® Compliant Not Compliant Question Areas Storm Water (See attachment summary) Page 1 Permit NCG210355 Owner Facility Louisiana Pacific Corporation Inspection Date 08/0312016 Inspection Type Technical Assistance Reason for Visit Routine Inspection Summary (See Technical Assistance Letter) This Inspection was conducted at Mr Harts request He wants to make sure that he stays compliant with his permits and wanted to know if he needed to Install a new sediment/skimmer basin Inspectors did not believe a new basin would be needed since most of the area is well established in permanent vegetation and the majority will not be disturbed The monitoring location for this area will need to be determined and the addition made to the SPPP siteplan If it appears at a later date that a basin is needed UP will be notified at that time Page 2 Permit NCG210355 Owner Facility Louisa Pacific Corporation Inspection Date 0810312016 Inspection Type Technical Assistance Reason for Visit Routine Analytical Monitoring - Yes No NA NE Has the facility conducted Its Analytical monitoring? E ❑ ❑ ❑ # Has the facility conducted Its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ E ❑ Comment Monitoring per ttlpermit Facility Is In Tier II due to exceedance of TSS and COD Monitoring as required _ Mr_ Hart has implemented measures to try to reduce TSS and COD and will continue to make improvements Permit and Qutfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? N ❑ ❑ ❑ # Were all outfalls observed during the inspection? E ❑ ❑ ❑ # If the facility has representative outfall status is it properly documented by the Division? ❑ ® ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? S ❑ ❑ ❑ Comment No deficiency noted Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi annually? S ❑ ❑ ❑ Comment Monitoring as required Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? N ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? E ❑ ❑ ❑ # Does the Plan include a Narrative Description of Practices ? ® ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? 0 ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ■ ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ® ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? E ❑ ❑ ❑ # Does the Plan include a t3MP summary? ! ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? S ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ■ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? e ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ® ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑ Page 3 permit NCG210355 Owner Facility Louisiana Pacific Corporation Inspection pate 0810312016 Inspection Type Technical Assistance Reason for Visit Routine Stormwater Pollution Prevention Plan Yes No NA NE Comment SPPP has been updated annually as required and Includes current training records spills records, inspection_ program records, facility and operating procedures No deficiency noted Page 4 r"zv m 4ab"-t zm I ' rra o d f Il M 9 s 3804 Comanche Road Archdale NC 27263 Phone 336-8991760 Fax 3364314972 Email diowe@ornamental com November 13, 2015 F?''CEIt ,SD N C Division of Energy, Mineral and Land Resources NOV 18 2015 Attention Storm Water Permitting Program (Laura Alexander) ,N; i lvo, 1612 Mail Service Center Raleigh, NC 27699-1612 I Re October 27, 2015 Follow Up Stormwater Sampling Event Summary Ornamental Products, LLC Plant 2, Hi oint, No Carolina NPDES Industrial Stormwater Perm t NCG210335 Ms Alexander Per our conversation on 11/12/2015 regarding the most recent Stormwater Sampling at the above named location, please find enclosed a copy of those final results conducted by Phoenix Environmental The attached report references respectively Table 1 (Stormwater Analytical Results) Appendix A (Stormwater Sample Analytical Test Report) Report of Analysis (by Research & Analytical Laboratories, Inc for Phoenix Environmental) Chain of Custody Record (by Research & Analytical Laboratories, Inc) Appendix B (Stormwater Discharge Outfall (SDO) Qualitative Monitoring Report - 2 Pages) Please contact my office at (336) 899-1760 Monday— Friday between 8 OOam — 5 OOpm with any related questions Best regards, Dennis B Lowe, Human Resources Manager Ornamental Mouldings, LLC/Ornamental Products, LLC Phoenix Environmental, Inc. 300 New Hope Road Thomasville, North Carolina 27360 Phone (336) 880-7216 Fax (336) 476-1328 November 6, 2015�� Mr Dennis Lowe Human Resources Manager Ornamental Products, LLC 1 frAr�'illll 2214 Shore Street High Point, North Carolina 27264 Reference October 27, 2015 Stormwater Sampling Event Summary, Ornamental Products, LLC Plant 2, High Point, North Carolina Dear Mr Lowe Ornamental Products LLC (Ornamental) requested Phoenix Environmental, Inc sample stormwater at the above referenced location in accordance with NC General Permit #210000 This report summarizes results of the sampling event On October 27, 2015 a storm system moved through the area and produced sufficient rain to qualify as an event (--- 1' + estimated at the OPI site by 9 am) The rain started intermittently at —4 am and at approximately 8 am heavier rainfall moved into the area and Stormwater from outfall 004 was sampled The total event produced + 64' of rain at the KNCARCHD2 gauging station (Archdale, NC) The recovered samples were immediately placed on ice and shipped to R&A Laboratories, Inc in Kernersville, NC for analysis (BOD & TSS) The sample analytical results are shown in Table I (see Appendix A) The Stormwater Discharge Outfall (SDO) Qualitative Monitoring Report is contained in Appendix B As seen in Table 1, the laboratory results are well within Benchmark Values published for NC General Permit #2l0000 Table I Stormwater Analytical Results Sampling Date Outfall Location pH TSS (m 1) COD (mg/1) 10-27-15 004 70 <5 24 NC Benchmark Values 1 6 0 -- 9 0 100 120 Outfalls 001 — 004 were inspected as part of the SDO monitoring It is noted there is continuing erosion at outfall 003 A joint of the concrete pipe has ei oded out of the bank and Iles in the creek On the sampling date, erosion around the discharging end of the RCP at outfall 003 (in the bank of the drainage system) did not appear to be of concern This is expected to change through time as water discharging from the pipe slowly erodes soil below the pipe until the pipe joint falls off - Phoenix appreciates the opportunity to provide indu;trial hvgiene services for Ornamental Products LLC If we can be of further assistance please don t hesitate to calf me at (336) 880- 7216 Sincerely Phgenia Environmental Inc Mice KBraswell President Appendix A October 27, 2015 Stormwater Sample Analytical Test Report RESEARCh & ANALyTicA[ LA ORAT®RiES,INC* For Phoenix Environmental 300 New Hope Road Thomasville, NC 27360 Attn Bruce Braswell Report of Analysis 1 1/5/201 s ��t�frt�reyr o to NC #34 Z� � « NC431701 �5`�y,,�; sty`. �,. Client Sample ID OR Stormwater Outfall 004 Lab Sample ID 10835 01 Site Phoenix Environmental Collection Date 10/27/2015 8 58 Panin eter Method Result Units Re sR Limit Analyst Analysis Dateaime COD EPA 410 4 24 mg/L 5 KN 10/29/2015 Total Suspended Solids (TSS) SM 2540 D 1997 <5 0 mg/L 5 JB 10/29/2015 NA = not analyzed P O Box 473 106 Short Street Kernersville North Carolina 27284 Tel 335 996 28a1 Fax 336 996 0326 www randalabs com Page 1 ral coo b-isic t1d RESEARCh & ANA1yTICA[ LABORATORIES, INC. Analytical / Process Consultations Phone (3361 996-2641 CHAIN OF CUSTODY RECORD WATER I WASTEWATER I MIsc C ``PANY n �. ,e ni Al�. �—' n v) u Ca L JOB NO cc? & 140 p, ob rZ= � �O' ° fi F Q p Q Q Q c ^v ry qR� ^1' �" �REQUESTED ANALYSIS STREET ADDRESS PROOlJE[/(�T{_ < CITY STATE ZIP 1 SAMPLER NAME (PLEASE PRINT) CONTACT PHONE SIGNATURESAR SAMPLE NUMBER (LAB USE ONLY) DATE TIME C011a GRAB TEMP aC SES ( S FOR. na�l S&UME "TOIX(Savj SAMPLE LOCATION! LD All RELINQUISHED BY DATEMME �� s� RECEIVED BY REMARKS SAMPLE TEMPERATURE AT RECEIPT CI - °C RELINDU[SHED BY DATEITIME RE EI ED Y Appendix B Stormwater Discharge Outfall (SDO) Qualitative Monitoring Report W4 2-10 $65 r'`cr CDENR North Carolina Department of Environment and Natural Resources Division of Energy, Mineral, and Land Resources Land Quality Section Pat McCrory Governor Mr Roy Hart Louisiana Pacific Corporation PO Box 98 Roaring River, NC 28669 Donald R van der Vaart Secretary June 15, 2015 Subject General Stormwater Permit Inspection NPDES Permit No NCG210355 Louisiana-Pacific Corporation, Wilkes County Dear Mr Hart On June 6, 2015, Sue White of this office performed a Stormwater Permit Technical Assistance Visit at the LP Corporation site on ABTCo Road in Roaring River You were present for this visit This encompassed (5) areas to be inspected as designated on the attached EPA inspection form Observations from each area are addressed below 1 Permit This facility holds General Stormwater Permit No NCG210355 to discharge Stormwater from activities associated with Lumber and Wood Products under the National Pollutant Discharge Elimination System (NPDES) The permit became effective August 1, 2013 and expires July 31, 2018 Your permit renewal package must be received in the Central Office in Raleigh no later than 180 days prior to the expiration date of the permit 2 Records/Reports Part II, Section A of the permit requires the development of a Stormwater Pollution Prevention Plan (SPPP) This plan was onsite and complete in a 3 ring binder All 9 sections of the plan were included Please be aware that this plan must be updated once yearly 3 Facility Site Review This site manufactures fiberboard Logs are stored on -site and then chipped and digested to manufacture the product There are 3 outfalls on site Due to the inability to meet monitoring limits, this site is in Tier III for monthly sampling It is recommended that representative outfall status be applied for 4 Effluent/Receiving Waters Stormwater from the site is discharged from three outfall locations on the property into the Yadkin Pee -Dee River, which are class WS-V waters in the Yadkin Pee -Dee River Basin 5_ Self -Monitoring Program Analytical Monitoring This facility is in ongoing Tier III for TSS and COD Tiered response has been conducted and reported as required There have been 3 Technical Assistance visits in the last few years Winston-Salem Regional Office 585 Waughtown Street, Winston-Salem, NC 27101 o Phone 336-771-50001 FAX 336-771 4631 Louisiana Pacific Corporation r 6/15/2015 Page 2 of 2 Qualitative Monitoring All qualitative records do not need to be submitted to DEMLR, however, the records must be kept on file at the facility for a period of five years If you have any questions concerning this letter or the attached inspection report, please contact Sue White at (336) 776-9661 Sincerely, Matthew E Gantt, P E Regional Engineer Land Quality Section Attachments BIMS Inspection Checklist CC _Division of Land Quality — WSRO' r Permit NCG210355 SOc county Wilkes Region Winston Salem Contact Person Roy Hart Directions to Facility System Classifications Primary ORC Secondary ORC(s) On Site Representative(s) Related Permits Inspection Date 06/09/2015 Primary Inspector Sue White Secondary Inspector(s) Compliance Inspection Report Effective 08/01/13 Expiration 07/31/18 Owner Louisiana Pacific Corporation Effective Expiration Facility Louisiana Pacific Corp PO Box 98 Hwy 268 Title Entry Time 09 30AM Certification Roaring River NC 28669 Exit Time 11 30AM Reason for Inspection Routine Inspection Type Permit Inspection Type Timber Products Stormwater Discharge COC Facility Status Compliant ® Not Compliant Question Areas M. Storm Water Phone 336 696 3464 Phone Phone 336 771-5000 Technical Assistance (See attachment summary) • 4 permit NCG210355 Owner Facility Lowsiana Pacific Corporation Inspection Date 0610912015 Inspection Type Technical Assistance Reason for Visit Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? No ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ® ❑ ❑ ❑ # Does the Plan include a Narrative Description of Practices ? ® ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ® ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring dunng the past 3 years? ® ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ® ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ® ❑ ❑ ❑ # Does the Plan Include a BMP summary? ® ❑ ❑ ❑ # Does the Pian Include a Spill Prevention and Response Plan (SPRP)? Is ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® ❑ ❑ ❑ # Does the facility provide and document Employee Training? ® ❑ ❑ ❑ # Does the Plan include a list of Re ponsible Party(s)? ® ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ® ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ® ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ® ❑ ❑ ❑ Comment Qualitative Monitorin4 Yes No NA NE Has the facility conducted its Qualitative Monitoring semi annually? ® ❑ ❑ ❑ Comment Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ® ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ® ❑ Comment Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ® ❑ ❑ ❑ is 17-1 r 1 r-I Permit NGG210355 SOC County Wilkes Region Winston Salem Contact Person Roy Hart Directions to Facility System Classifications Primary ORC Secondary ORC(s) On Site RepresentaUve(s) Related Permits Compliance Inspection Report Effective 08/01/13 Expiration 07/31/18 Owner Louisiana Pacific Corporation Effective Expiration Facility Louisiana Pacific Corp PO Box 98 Hwy 268 Title Inspection Date 09116/2014 Entry Time 09 30AM Primary Inspector Aana Taylor SmEth Secondary Inspector(s) Certification Roaring River NC 28669 Exit Time 10 30AMI Reason for Inspection Routine Inspection Type Permit Inspection Type Timber Products Stormwater Discharge COC Facility Status ® Compliant ❑ Not Compliant Question Areas M Storm Water (See attachment summary) Phone 336 696 3464 Phone Phone 336 771 5000 Technical Assistance Page 1 Roy P Hart LHS Manager ru} Bart Ce, Ilkarp uim 1 336 696 3464 C 336 984 0249 F 336 696 3412 LPCorp tam PQ Box 98 High%%m 268 Roaring Rncr NC 28669 Permit NCG210355 owner Facility E_ouislaAa Pacific Corporation Inspection Date 0911612014 Inspection Type Technical Assistance Reason for Yrsit Routine Inspection Summary Page 2 Permit NCG210355 Owner Facility Louisiana Pacific Corporation Inspection Date 09/1612014 Inspection Type Technical Assistance Reason for Visit Routine Analytical Monitoring Yes No NA NE Has the facility conducted Its Analytical monitoring? M ❑ ❑ ❑ # Has the facility conducted Its Analytical momtonng from Vehicle Maintenance areas? ❑ ❑ ® ❑ Comment Facility is in Tier III for TSS_and COD and has been for many years Tiered response has been conducted as required Joint inspections with WSRO and SPU staff have been conducted in the past to address this issue Monthly monitoring will be reconsidered as investigations continue Permit and Outfalis Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑ # Were all outfalls observed during the inspection? ® ❑ ❑ ❑ # If the facility has representative outfall status is it properly documented by the Division? ❑ ❑ M ❑ # Has the facility evaluated all illicit (non stormwater) discharges? M ❑ ❑ ❑ Comment Outfall 2 is experiencing severe erosion into stream at discharge point Facility will need to speak vAth DWR about whether 401/404 or Army Corps of Engineers permitting will be necessary to repair bank Facility will update SWPPP with any chances Page 3 Taylor -Smith, Aana From Roy Hart <Roy Hart@lpcorp comma Sent Tuesday, September 16, 2014 2 32 PM To Taylor -Smith Aana Subject SW Sampling 2013-2014 xlsx Attachments SW Sampling 2013-2014 xlsx Hi Aana, Last two years outfall data High TSS values for OF 2 and OF 4 are from roadway and gravel lot (OF2) and gravel roads that flow to OF 4 Vegetated swales help, but hard ram for short time overwhelms the vegetation High COD at OF4 is surprising since there is no apparent source, except for rotting vegetation near the spring Pleasure having you visa today, Regards, Roy Roy P Hart EHS Manager Louisiana Pacific - Roaring River Mill Roy hart@Ipcorp com Ph 336 696-3464 Cell 919 357-8441 Taylor -Smith, Aana From Homewood Sue Sent Tuesday September 16, 2014 5 20 PM To Taylor -Smith, Aana Subject RE Louisiana Pacific Roaring River ok Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Resources — Water Quality Programs 585 Waughtown Street Winston-Salem, NC 27107 Voice (336) 771 4964 FAX (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties From Taylor -Smith, Aana Sent Tuesday, September 16, 2014 12 50 PM To Homewood, Sue Subject Louisiana Pacific Roaring River Hi Sue, Hope you are having fun fish shockingi When you get back, would you mind giving Roy Hart at Louisiana Pacific Roaring River a call? He's got an outfall with erosion at the discharge point and they want to do some kind of bank repairs in the next year or two There's no rush — I think he's just looking for information about 404/401/USAGE stuff His phone number is (336) 696-3464 or email is roy hartPlocorp com Thanks so muchi Aana Taylor -Smith Land Quality Section Division of Energy, Mineral, and Land Resources NC DEN Winston-Salem Regional Office Phone (336) 771-SO34 Fax (336) 771-4631 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Charles Wakild P E John Skvarla Governor Director Secretary April 17, 2013 Jimmy Mason Louisiana Pacific Corp PO Box 98 Hwy 268 Roaring River, NC 28669 Subject NPDES General Permit NCG210000 Certificate of Coverage NCG210355 Louisiana Pacific Corp Formerly known as Abtco Wilkes County Dear Mr Mason Division personnel received your request to revise your stormwater permit Certificate of Coverage to accurately reflect your new company and/or facility name Please find enclosed the revised Certificate of Coverage The terms and conditions contained in the General Permit remain unchanged and in full effect This revised Certificate of Coverage is issued under the requirements of North Carolina General Statutes 143-215 1 and the Memorandum of Agreement between North Carolina and the U S Environmental Protection Agency If you have any questions, please contact the Stormwater Permitting Unit at 919-807-6300 Sincerely, ORIGINAL SIGNED 131 KEN PICKLE for Charles Wakild, P E cc Winston-Salem Regional Office Central Files Stormwater Permitting Unit Wetlands and Siormwater Branch 1617 Mad Service Center Raleigh North Carolina 27699 1617 Locabon 512 N Salisbury St Raleigh North Carolina 27604 Phone 91H07 63001 FAX 919-807-6494 % Customer Service 1-877-623-6748 Internet www ncvraterquality org None rthCarohna Naturally An Equal Opportunity 1 Affirmative Action Employer STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO NCG210000 CERTIFICATE OF COVERAGE No NCG210355 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215 1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Louisiana Pacific Corp is hereby authorized to discharge stormwater from a facility located at Louisiana Pacific Corp PO Box 98 Hwy 268 Roaring River Wilkes County to receiving waters designated as the Yadkin Pee -Dee a class WS-V, waters in the Yadkin Pee -Dee River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, IV, V and VI of General Permit No NCG210000 as attached This certificate of coverage shall become effective April 17, 2013 This Certificate of Coverage shall remain in effect for the duration of the General Permit Signed this day April 17, 2013 ORIGINAL SIGNED B) KEN PICKLE for Charles Wakild, P E , Director Division of Water Quality By Authority of the Environmental Management Commission Certified Marl — 70112970 0003 6220 0697 Return Receipt Requested February 18 2013 NCDENR - DWQ 1617 Mail Service Center Raleigh NC 27699-1617 RF Permit No NCG210355 Louisiana-Pacific Corporation To Whom It May Concern LPO BUILDING PRODUCTS Enclosed is a Permit Name/Ownership Change Form that is being filed to correct some erroneous information currently contained in the Department s stormwater database On this Iorm the facility name is being corrected from Abtco — A Louisiana Pacific Company, to Louisiana Pacific Corp The facility address is also being corrected in this change form to P O Box 98, Hwy 268, Roaring River NC 28669 In addition the facility contact person is being changed from Phil Sparks to Roy Hart Thank you for your assistance in getting the data in your system corrected If there are any questions regarding this report, please contact me at (336) 696-3464 S erely Roy P Pan EHS Manager cc File ADDRESS P 0 Box 96 Roaring River NC 28889 TEL 336 696 2751 FAX 336 999 3443 WEB www 1pcorp cam NPDES PERMIT NAME/OWNERSHIP CHANGE FORM Page 2 of 2 IV Permit contact information (if different from the person legally responsible for the permit) Hart Permit contact Roy First M1 Last EHS Manager I itle P O Box 98, Hwy 268 Mailing Address Roaring River NC 28669 City State Zip 336 696-3464 RoX hart a I co com Phone E ail Address V Will the permitted facility continue to conduct the same industrial activities conducted prior to this ownership or name change9 ® Yes _ ❑ No (please e .plain) VI Required Items THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE INCOMPLETE OR MISSING for both name change and/or ownership change ® This completed application is required requests ❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill of sale) is required for an ownership change request Articles of incorporation are not sufficient for an ownership change The certifications below must be completed and signed by both the permit holder prior to the change, and the new applicant in the case of an ownership change request For a natne change request, the signed k Applicant's Certification is sufficient PERMITTEE CERTIFICATION (Permit holder prior to ownership change) 1, , attest that this application for a name/ownership change has been reviewed and is accurate and uired parts is complete to the bat if all rof my enowledge I quired ed supporting information ation is nnd that if lot included, this o application catiionication are not package will be completed and that q returned as incomplete Date Signature APPLICANT CERTIFICATION I, Jimmy Mason, attest that this application for a name/ownership change has been reviewed and is accuratI l required arts of and complete to the be" of �y knowledgedong information is not nderstand that if ncluded, thips application pacis ication kage wiare ll be completed and that if a q pp returned asAcomplete / ie,6 /r , .;PJ13 Date PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO Division of Water Quality Surface Water Protection Section 1617 Mail Service Center Raleigh, North Carolina 27699-1617 r_ NCDENR No [gyp— Der..ATME OF ENVIRONMENT Iwo NRURw� Rrsoimcc. Date Received Year Month Day Division of Water Quality 1 Surface Water Protection FOR AGENCY USE ONLY National Pollutant Discharge Elimination System PERMIT NAME/OWNERSHIP CHANGE FORM I Please enter the permit number for which the change is requested NPDES Permit (or) Certificate of Coverage N 10 1 S 10 1 1 1 1 1 1 1 N 1 G G 2 1 i 1 0 3 1 5 5 II Permit status prior to requested change a Permit issued to (company name) Abtco — A Louisiana Pacific Co b Person legally responsible for permit Jimmy Mason First MI Last Plant Manager Tale _Hwy 268 Permit Holder Mailing Address Roaring River NC 28669 City State Zip (336) 696-2751 (336) 696-3439 Phone Fax c Facility name (discharge) same d Facility address same Address City State Zip e Facility contact person Phil Sparks ( ) First / MI / Last Phone III Please provide the following for the requested change (revised permit) a Request for change isa result of ❑ Change inownership of the facility ® Name change of the facility or owner If other please explain b Permit issued to (company name) c Person legally responsible for permit Q�/;Z� WnR� FEB 2 1 2013 d Facility name (discharge) e Facility address f Facility contact person Louisiana Pacific Corp Jimmy Mason First MI Last Plant Manager Talc, P O Box 98, Hn 268 Permit }-folder Mailing Address Roaring River NC 28669 City (336) 696-2751 State Zip Phone E-mail Address same same Address City State Zip I'lrst MI Last Phone E mail Address Revised 712008 l Revised 2012Ap(13 .. n ..r , i,_ u fr j, ' r a ft 16lc, A t I rr. ..r ChM ILFWA Aja � NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Charles Wakild, P E John Skvarla Governor Director Secretary January 7, 2013 Mr Roy Hart Louisiana-Pacific Corporation P O Box 98 Roaring River, NC 28669 Subject Revision of Permit Monitoring Frequency Louisiana-Pacific Corporation (LP) Permit # NCG210355 Wilkes County Dear Mr Hart a(low tip -fig .I)uP__ it.�': �at� �Ac—rQc> n -#r response to4m4r-Feeeff-Fneet}ng-end/4equest for reduced monitoring frequency for TSS and COD for all three outfalls +he DWQ reviewed your monitoring data, which showed exceedance of benchmark values that required you to perform monthly monitoring for TSS and COD Please refer to the following revisions Outfalls #00t, #002, #003 Beginning February 1, 2013 begin to monitor semi-annually for COD, TSS, and pH as defined in the permit You should continue to monitor semi-annually for these parameters through the current permit cycle, which is July 31, 2013 2 During compliance evaluation inspections the regional office will address best management practices and stormwater characteristics as part of the inspection process If you have any questions please contact George Smith or me at (336) 771-5000 Sincerely, W Corey Basinger Regional Supervisor cc WBSCP Unit Central Files W SRO Files North Carolina Division of Water Quality Winston-Salem Regional Office Location 565 Waughtown Street Winston Salem North Carolina 27107 Phone 336 7715000 1 FAX 336 771-0630 Internet www nwaterauatity ora An Equal Opportunity 1 Affirmative Acton Employer None orthCarolina Naturally NPDES No NCG210355 Louisiana-Pacific Corporation, Roaring River Plant Stormwater Fact Sheet Facile Information Applicant Facility Name Louisiana-Pacific Corporation Roaring River Plant Applicant Address P 0 Box 98, Roaring River, NC 28669 Facility Address Off of Hny 268, West of Roaring River Drainage Area acres 907 Type of Waste Timber Product Primary SIC Code 2493 County Wilkes Miscellaneous Receiving Stream Yadkin River Regional Office. WSRO Stream Classification C Quad C14NE, Roaring River 303 d Listed' No Reviewer George Smith Subbasin 030701 (Yadkin) Date January 7, 2013 1 •'^"T1 t' �s� ,� WE Summer 7Q 10 cfs 228 30Q2 (cfs) Average Flow cfs 976 NPDES Wastewater~-"�' IWC (%) Permitted Q 2 0 MGD 1 3% FACILITY Louisiana Pacific Corporation (LP) — Roaring River site manufactures smooth one-sided hardboard The facility purchases chips (softwood/hardwood) or chips scrap wood on - site, the chips are washed/screened, the chips are digested/pulped, the pulp slurry is then molded, then the resulting product is treated (via temperature/pressure) to make smooth one-sided hardboard The wastewater is discharged into the Yadkin River under the Terms and Conditions listed in the NPDES Permit NCO005266 NPDES Wastewater Permit Limits Parameter Daily max, Lbs/da Monthly avg , Lbs/da BOD5 22,747 11,873 TSS 18,000 12,000 H 6-9 SU Stormwater The facility had numerous benchmark exceedances for COD and TSS at outfalls 001, 002, 003 The facility performed monthly monitoring from October 2010 to present The data revealed benchmark exceedances from 102 mg/ L to 1042 mg/ L for TSS, and from 121 mg/L to 704 mg/L for COD LP Corporation Roaring River Page 1 LP has been manufacturing at this site since the 1970s, and the facility predates the issuance of stormwater permits in North Carolina The site was not originally designed with stormwater controls in mind LP has been proactive prior to stormwater permitting by installing stormwater basins and some basic best management practices to control flow Although the benchmark exceedances for COD and TSS appear to be high, they are actually negligible when compared to the NPDES discharge limits with an IWC of 1 3% in the Yadkin River It is important to recognize that the first flush is the most concentrated, therefore, heavy rain events will not produce high exceedances The NPDES permit is meeting toxicity limits and the Yadkin River does not demonstrate any biological impairment It seems reasonable to assume the stormwater is not endangering the Yadkin River MONITORING The RO feels that the monitoring frequencies for TSS and COD can be reduced to semi-annual monitoring over the life of the permit Upon expiration of the permit LP can request reduced monitoring from the RO During compliance evaluation inspections the RO would evaluate the LP site for BMPs and changes in stormwater characteristics PROPOSED ACTIONS Schedule a meeting with LP to discuss the current representative sampling technique, and any stormwater BMP changes that will be implemented by LP Discuss the RO position to return to semi-annual monitoring for the life of the General Permit The semi-annual monitoring waiver can be evaluated prior to the issuance of the next stormwater permit cycle SCHEDULE Contact LP for meeting Issue letter for semi-annual monitoring General Permit Expiration COMMENTS January 2013 February 1, 2013 (effective) July 31, 2013 NAME DATE � jr2W 16 !3 LP Corporation Roaring River Page 2 Page 1 of 4 Study sheet Louisiana Pacific Roaring River possible further responses to Tier 3 status 9/14/2012 kbp bg Background information a Louisiana Pacific, Roaring River, NC NCG210355 b TSS COD benchmarks routinely exceeded pH benchmark not an issue c LP has a dry detention settling basin on outfall #001, no controls at all on #002, dry detention on #003 Even in subdrainage areas with controls (#001 and #003) some portion of the normal rainfall flows bypasses the controls Data analysis from the three outfalls suggests that the stormwater controls are grossly inadequate for the conditions d Monthly monitoring instituted by WSRO around Oct 2010, yielding partial results from 25 sampling events from Jan 2009 through July 2012 e LP will soon begin sampling a previously unidentified fourth outfall Comparatively low risk industrial activities apparently, are planned for this new subdrainage area f Purpose of this review WSRO has invited SPU consultation on what is a difficult set of circumstances This review is Intended to outline possible paths for regulatory action at LP under NCG21 Data analysis a pH 4 pH exceedances out of 71 measurements By inspection, conclude that pH is not a priority issue at this facility No more consideration of pH in this review b TSS i 36 TSS exceedances out of 68 measurements Benchmark of 100 mg/L ii Exceedances range from 102 mg/L to 1042 mg/L, averaging 316 mg/L The i values below the benchmark averaged 46 5 mg/L Aggregate data averaged 189 mg/L ni Outfalls #001 had 12/24 exceedances, #002 had 16/21 exceedances, #003 had 8/23 exceedances COD i 46 COD exceedances out of 70 measurements Benchmark of 120 mg/L u Exceedances range from 121 mg/L to 704 mg/L, averaging 244 mg/L Values below benchmark averaged 73 mg/L Aggregate data averaged 185 mg/L in Outfalls #001 had 15/25 exceedances, #002 had 14/22 exceedances, #003 had 17/23 exceedances Correlation of COD and TSS Observe that 9 of the 12 TSS exceedances at #001 coincided with COD exceedances at that outfall, 11 of the 14 COD exceedances at #002 coincided with TSS exceedances at that outfall, 8 of the 8 TSS exceedances at e#003 coincided with COD exceedances at that outfall Interpret good correlation between COD and TSS exceedances suggests common source and raises the passFbihty that effective measures to control one parameter might control a J significant portion of the other ; Conclusions of data review Exceptionally good data set compared to what most ' stormwater permittees are able to accumulate in response to performance problems (1) Unlikely that continued monthly monitoring without site changes has much benefit Monthly monitoring maybe beneficial to guickly evaluate subsequent site changes, if site changes are implemented (2) Benchmark exceedances are not } occasional, infrequent, or flukes, and establish a lack of effective control by the plant stormwater controls stems It seems probable that the original stormwater control design has been Inadequate from the beginning Probably fruitless to pursue the question, What in the world did you use as a design basis/design objective for N", I- drs'C FAihk- 1�o Page 2 of 4 your stormwater control system2 It could not possibly have been compliance with your stormwater permit " 3 Significance concerns a Impacts the Yadkin River is the receiving water, and provides substantial dilution for stormwater flows In stream impacts may be minimal — this recognition should figure into our actions, but should not work to eliminate meaningful progress in water quality protection by LP b Costs So far, LP has essentialiyspent nothing to improve pollutant removal from the_stormwater discharges_[However, construction costs in a densely developed - _ _ industrial site can be large It seems an approach that focuses on doing the cheap stuff first and then seeing what works, might be the approach favored by LP However, rLP must be made to understand that they are going to have to spend money on addressing their egregious performance to date+ c Permit requirements We re talking about benchmarks not limits, ie these exceedances are not permit violations, but still, industries are obligated to keep their pollutants on their sites & not discharge them into NC waters, d LP will want to know how we will identify the endpoint of any forward path involving construction of an effective stormwater control system This is a `significance issue in the sense of understanding today the potential future costs they _will _incur as a result ogpoilutant control actions we_require of them 1 -------------------- 4—DWQ objectives in these circumstances a Improve the protection of water quality beyond LP s current poor performance b Preserve the integrity of the permit requirements and the permitting program c Impose reasonable requirements avoid unreasonable burdens on the permittee Be fair d Communicate expectation that company will perform a thorough analysis to demonstrate cost benefit and/or infeasibility of possible solutions and treatment approaches, not just back of the envelope guestimates to dismiss big projects It doesn t have to be perfect, but it has to be solid and persuasive Potential elements of the candidate paths forward for LP a Hire an environmental/civil engineer experienced in large scale industrial site projects to evaluate alternatives and to design new treatment practices Doubtful that this work can be accomplished in house by LP Look at sites in other states b Get a physical features and elevations survey of the whole plant site c Require better control of polluted discharges from LP d Require affirmative action from LP in pursuit of the control of stormwater pollutants e aRequire milestones & interim progress markers set by WSRO and- reviewed/approved -.similar-to a Compliance Order perspectiv f Allow for a protracted time frame where appropriate g Source reduction, if possible? Examples Can boiler fuel storage piles be moved or covered? Can the company evaluate possible collection and reuse of rainwater to supplement raw water for process provided by river? h More effective treatment - any treatment at all would be an improvement in #002 I One outfall and its subdrainage area at a time might help spread out capital costs j DWQ administrative solutions should follow only after LP attempts at site management solutions and engineering solutions However, some accommodation to more frequent monitoring might be considered at this stage if milestones and progress markers are set by WSRO I_�-_ I r 1�� 4-MTeridr 04r- t9+j(4 iS ilt ;[r++l- frArt Inj tyfd f f�tdAT�j —SV 1+ryatr- _ Comment [bll They did spend something to replace the gravel In the parking lot with washed stone right? Didn t nxthe problem and i don t remember the amount but more than nothing I suppose E)ecrJ411g 1(- Wit knr,y y�� o-ds, tonic ✓t!! jr.t �'+� � Comment[b2l DEADoN wv 7 I-ttG D"'t l+�T;v,+rtiin� r pat �r3w jACIIli+rtte � U{r+cr�� f�rwrs� Jd.J ` e4ht IL � j r _ Ba1� s'k"p 4r .04 f- jl/d TV(4VO4"7 6G';~ 04� t-41fe. ipJ56+ti1r Q, rtrf4stel FV4 ).melt It37t Page 3 of 4 k Let LP choose the path forward via a mechanism of they propose a plan, and we approve the plan and they execute the plan and then confirm performance back to us 4 6 Synthesis of all of the above Apparent potential paths forward a QlPath la The trivial no action alternative Keep things as they are today, along with monthly sampling Central Office does not recommend this path b 'Path lb Another form of the trivial no action alternative Revert back to semi annual sampling and keep things the way they are today Central Office does not recommend this path either Neither of these two alternatives addresses the problem of polluted discharges c c-Path 2 A first pass outfall by outfall plan focused on a treatment approach rather than a source reduction approach, subsequent confirmation sampling to determine which outfalls require a second pass i Set up Flow measurement devices on all three outfalls to characterize the flow I rate and volume as a design basis input parameter for the following structural measures Obtain a physical features and elevations survey of the site and i the stormwater system } ii All outfalls where can vegetation and infiltration be improved prior to i 1 discharges I in Outfall #001 Smallest of the three drainage areas with only 17 BA and only 7A impervious Engineering solution approach No significant extra land available Convert existing dry detention basin into gross solids settling basin paired with a wet well for stormwater pumps to convey flow to either of the treatment measures to be constructed in #002 or #003 Re work the creek piping to segregate that Flow from the contaminated stormwater flow as much I as possible iv Outfall #002 Site management and engineering solution approach Portions of the approx 5 5A gravel parking lot to be made available for treatment measures, finished product lay down area to be re configured to accommodate the treatment measures Note that the main discharge line 1 from #002 is —20 deep at the sampling manhole, but the endpoint is 20 above the river according to site personnel This means that at some point along its run, it is at grade we did not see the run of the pipe down to the 1 river well enough to now for sure that existing topo can be modified to accommodate this approach LP to hire a civil engineer to investigate the I feasibility of this approach v Outfall #003 Primarily an engineering solution approach Engineer to i re -design the dry detention basin Instead of one large basin, reconfigure into a treatment train, with pretreatment settling for gross solids removal followed by vegetated or wet detention treatment If a third unit will fit in the train, consider vegetated or infiltration with underdrain collection practices Approximately 2A of land is readily available Evaluate going back up the pipe and segregating the stormwater flows from the creek flow on the north half of the property Rework of the spill containment basin may be required depending on the details of the connections Evaluate localized containment of the boiler fuel storage area vi Outfall #004, new Act now to prevent the perverse action of piping the creek under the plant and dumping contaminated flows into it underground vii This scheme is subject to modification of the details, and the determination that portions of it are infeasible, based on site conditions or costs But, I Page 4 of 4 don t see how LP can address this problem without some capital costs And I don t see how we can administratively let them off the hook for better performance that path might be interpreted as DWQ totally defaulting on our responsibility to pursue the protection of the waters of North Carolina vnl DWQ posture 1We acknowledge the great dilution in the Yadkin by not pressing forward and requiring rigid observation of the benchmark values if LP will commit to installing_BMPs to address the pollutants_as_fai as.is feasible t _ - - _ _ +Path 3 I A hot spot source flow reduction approach that includes both site management and engineering solutions I Outfall #001 Direct wood chip storage pile drains into the WWTP rather than the #001 sediment basin Other portions of DA #001 continue through the sediment basin ii Outfall #002 for TSS - Pave the large gravel truck loading and finished product lay down area For COD - direct wood chip storage pile drains to the WWTP, rather than to the stormwater outfall III Outfall #003 Direct boiler fuel storage areas into the WWTP Spill Basins #1 and #2 and bleed through the WWTP Or dig a new basin adjacent to WWTP Spill Basins #1 & 2 Other portions of #003 continue through the current dry detention basin iv Difficulties with this approach include opening up the wastewater permit for modifications According to WSRO, a difficult approach Further LP reports that the facility is near capacity as is (but not completely at capacity - I guess it may be a question of how much more would this approach add, and how much more can the WWTP take ) Path 4 Stormwater Re use opportunities? Can the company perform an engineering evaluation of possible options and a cost benefit analysis? Path 5 - ??? END - Commmt[b3l lagree This is consistent with our evaluation of the risk to water quality but It i should not alleviate LP's responsibility to make irnpmvemenu to the quality of storrrmater discharges leaving their site .t:a'_ OUTFALL SWO03 Drainage Area: 45.6 acres U ti,7 OUTFALL SW001 Impervious Area: 15.2 acres \ 4`•'• a Drainage Area: 17.8 acres w ti Percentage of Impervious Area: 33% ` 1 Al � ^' � � " ``' "" �' � Impervious Area: 7.0 acres f A NO- IN usm? j Percentage of Impervious Area: 39% Sry _A;� 4� _.?c_NS ` rr -a .maser-w•.sra \ L� w d _ SWO01 SEDIMENT -BASIN (REFER TO FIGURE 213 FOR DETAILS) ti 3 r FENCE 2 r uu►c LP I � f Aa ()eJTFALL S1001 ", T F :`<' E 2 A `F' ? 7_ STORAGE I 11 00 4 \ TANK N AREA o L4 SPILL INTERCWT' POINT'(VN_. CAUS71C TANK 15K GAL 2 GiIAT t j ALUM TANK t 5K GN I (ENCLOSED) ►� h a i HO115 I CO ERi4C�TOR RASH GH LP BOTTLE R'Av M FSTDRAGF3S L7 �:R w.ArE DL ? c �w0 A.r ._- (COVEFtED) TO RECYCLE KX - W(305 C b h 3 , E �yf BIM v �r0A /�' ' - PAPER ',FF p T �_-� r F. 2A ILL �O VEH NT. capc" s . � - \ SLUDGE HANOLJ ASTEWATE f�cvt] C�yTA .�i• tiT 1 POINT I\ (VAL AREA TREATMENTMCi R GHv�A4� 1 G - tic sdar ` o o SEPARATOR (OWS) - �GQv a Y SPILL INTERCEPT ?DINT BISI/ UTLET �. M WWTP - L` CIED AR JN (VALVE) ST A E 9 'PRIMARY EQ DS DAF P. _ \ OUTFALL S` O a • 1 0 BOILER W ,C,;� A FUEL RECLAIM END D AREA, BARK D PIP 5= WL a` >, PHOSPHORIC ACID OUTFALL SWO02 WITH HYD C TANKS (ONE EM CONTAINMENT� i a_�ar�^ i3a�4 i�Aw wATE:R �q A R r.: C BASIN I: 2 9_SS Ni SANiT ATER � % LUDGE PUMP I �� ///w ^ •. w A c R HOUSE PACKAGE AQUA AMMDNIA w t (ABOVE—cRD D) TANKS (2) sP_ 5Asti (CONTAINED) (CONCRETE 2 CONTAINMENn lw \ SIUDGE PUMP HOUSE _ (CONTAINED) OUTFALL SWO02 ✓�'� SECONDARY 0 Drainage Area: 27.3 acres ` cLAmnER ti f :' Impervious Area: 9.8 acres Percentage of Impervious Area: 36% LOUIS MOM -' its �a v i5 r E aRr p�G rJ 6 S nrvn naC, •C a� JWni ry 3 4-SP "" Nek �pIMY11O 7 1 M& #Gk� Cl r :: vt'3c M:'Ai aw6 5 � 3t .��F ,Lr .i w_ [ a � �❑�Se urwo t IN oL srs R ou-r EFl® 0 "A L-, ----I MCDEHR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Waklid, P E Dee Freeman Governor Director Secretary September 5, 2012 Mr Roy Hart Louisiana-Pacific Corporation PO Box98 Roaring River, NC 28669 Subject Compliance Evaluation Inspection Louisiana-Pacific Corporation Permit # NCG210355 Wilkes County Dear Mr Hart On August 29, 2012 a Compliance Evaluation Inspection was performed by George Smith and Corey Basinger, both of this office Cyndi Karoly, Bethany Georgoulias, and Ken Pickle, of the Stormwater Permitting Unit were present in order to evaluate the Tier 2 stormwater measures and Louisiana-Pacific Corporation request for decreased monitoring for COD and TSS The following Louisiana-Pacific Corporation representatives were present Mr Roy Hart, Mr Tim Lanier, and Mr Scotty Mathis The purpose for the inspection was to evaluate the drainage areas that are exceeding the benchmark values for Total Suspended Solids (TSS) and Chemical Oxygen Demand (COD) Permit The NPDES general permit became effective on August 1, 2008 and expires on July 31, 2013 The following Sections of the permit are applicable to this site I Stormwater Pollution Prevention Plan (Part II, Section A) 2 Analytical Monitoring (Part II, Section B, Table 1) 3 Qualitative Monitoring (Part II, Section C, and Table 4) Comments concerning this permit can be made, in wasting, to the N C Department of Environment and Natural Resources, Stormwater Permitting Unit, 1601 Mail Service Center, Raleigh, NC 27699-1601 Records & Reports An excellent site plan was developed, which clearly identified all three (3) sormwater outfalls The plan was kept in a notebook binder All nine items of the Plan were well documented North Carolina Division of Water Quality Winston-Salem Regional Office Location 585 Waughtown St Winston Salem North Carolina 27107 One Phone 336 7715000 1 FAX 336 771-4630 NorthCarollna Internet www ncwaterquality org r/ y 'A'j" atna//y An Equal Opportunity 1 Affirmative Action Employer 6 Louisiana-Pacific Corporation September 5, 2012 Page 2 of 2 Facility Site Review Logs are stored in the yard then chipped, digested, and used to make fiberboard Outfall #001 receives stormwater from timber (logs) in this drainage area Also, Outfall #003 receives a small portion of stormwater from the chipping operation, stormwater in the grassed ditches along of the railroad track, and sawdust piles Per our previous discussion during 2009, the COD may be reduced if the stormwater detention pond was periodically maintained and would dram at a faster rate The basin at the time of this inspection was not effectively draining the water, which may contribute to higher COD values We understand there is a level of maintenance required to keep the stones from clogging with solids I believe that more frequent maintenance is needed, but I do not know how much lower the COD values would be reduced Outfall #002 receives stormwater from storage of large sawdust piles, and drainage from a graveled storage area The periodic exceedence of the benchmark value for TSS is most likely from the fines in the gravel area The TSS may be able to be reduced by making a small pit or weir that would allow the fines to settle just prior to the sampling point Of course, this would have to be periodically maintained Outfall #003 received stormwater from old wood chips and fibers The basin has a grass bottom with little water remaining accumulated The basin drains the stormwater more quickly that outfall 001 Scotty Mathis discussed the possibility of using skimmers At first thought I did not think these would be useful, but my second thought is that these may help drain the water quickly in outfall 001, if sized properly An engineering evaluation of the drainage is needed Self -Monitoring Program The facility had all qualitative monitoring records on -site, as required by the permit The analytical monitoring data was submitted in an excel spreadsheet We would like to thank you and the all the staff for taking the time and interest in resolving the Tier two response for stormwater We do think that a reduced monitoring frequency is warranted, but at this time we are not able to give a reply We will evaluate the site visit with the Stormwater Permitting Unit and get back with you as soon as possible The compliance evaluation inspection is satisfactory If you have any questions please contact George Smith or me at (336) 771-5000 Sincerely, W Corey Basinger Regional Supervisor cc Storniwater Pernutting Umt=Ken Pickle WSRO Files Permit NCG210355 SOC County Wilkes Region Winston-Salem Compliance Inspection Report Effective 08/01/08 Expiration 07/31/13 Owner Louisiana Pacific Corporation Effective Expiration Facility Abtco - A Louisiana Pacific Company Hwy 268 Contact Person Phil Sparks Directions to Facility System Classifications Primary ORC Secondary ORC(s) On Site Representative(s) Related Permits Title Inspection Date 08/29/2012 Entry Time 10 25 AM Primary Inspector George S Smith Secondary Inspector(s) Roaring River NC 28669 Phone Certification Exit Time 12 20 PM Phone Phone 336-771-5000 Reason for Inspection Routine Inspection Type Compliance Evaluation Permit Inspection Type Timber Products Stormwater Discharge COC Facility Status ■ Compliant ❑ Not Compliant Question Areas E Storm Water (See attachment summary) Page 1 Permit NCG210355 Owner Facility Louisiana Pacific Corporation Inspection Date 08/29/2012 Inspection Type Compliance Evaluation Reason for Visit Routine Inspection Summary Page 2 I I Permit NCG210355 Owner Facility Louisiana Pacific Corporation Inspection Date 08/29/2012 Inspection Type Compliance Evaluation Reason for Visit Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ # Does the Plan include a General Location (USGS) map? ■ D n n # Does the Plan include a Narrative Description of Practices ? ■ 0 Q 0 # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ n n n # Does the Plan include a list of significant spills occurring during the past 3 years? ■ n n n # Has the facility evaluated feasible alternatives to current practices? ■ ❑ n n # Does the facility provide all necessary secondary containment? ® n n n # Does the Plan include a BMP summary? ■ n n n # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ n n 0 # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ n n n # Does the facility provide and document Employee Training? ■ n n n # Does the Plan include a list of Responsible Party(s)? to n [1 n # Is the Plan reviewed and updated annually? ■ n p n # Does the Plan include a Stormwater Facility Inspection Program? ■ D D n Has the Stormwater Pollution Prevention Plan been implemented? ■ n n n Comment Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ C] 0 0 Comment Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # if the facility has representative outfall status is It properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment Yes No NA NE ■nnn nnnn Yes No NA NE ■nnn ■nnn nn■n ■D0D Page 3 Certified Mail — 7011 2970 0003 6220 0390 Return Receipt Requested August 29 2012 Ms Margaret Love — District Supervisor NCDENR - Air Quality Division Winston Salem Regional Office 585 Waughtown Street Winston-Salem, NC 27107 Mr Corey Basinger — District Supervisor — 7o11 2970 0003 6220 0406 NCDENR — Water Quality Division Winston Salem Regional Office 585 Waughtown Street Winston-Salem, NC 27107 Subject LP Roaring River Mill Change in Plant Manager Dear Ms Love and Mr Basinger BUILDING PRODUCTS N6Lt2 )a35S This note is to officially notify you that there has been a change in leadership at the Louisiana Pacific Roaring River Plant Mr James K Reavis has chosen to leave the Roaring River Facility effective August 4 2012 I have been named as the Plant Manager effective August 4, 2012 As Plant Manager, I have signatory authority for all documents and reports submitted by this facility to your agency The existing Delegation of Authority (attached) indicates that the person named to the position of Plant Manager is the delegated signatory for the Roaring River Plant If you have any questions, or require additional information, please contact Roy Hart at (336) 696- 3464 Sincerely, Jiiaason Plant Manager cc Mr Donald Van der Vaart — NCDENR Raleigh Mr Jeff Poupart — NCDENR Raleigh Mr Bradley Bennett — NCDENR Raleigh �� SEP - 7 2012 ADDRESS PO Box 98 Hwy 268 Roaring River NC 28669 TEL 336 696 2751 FAX 336 696 3412 WEB www Ipcorp com LP,. I BUILDING PRODUCTS January 27, 2012 Subject LP ENVIRONMENTAL SIGNATORY AUTHORITY To whom it may concern As established by Louisiana-Pacific Corporation Board of Directors resolutions dated November 6, 2004 "RESOLVED that the Chief Executive Officer and the Executive Vice President, Administration, and Chief Financial Officer of Louisiana-Pacific Corporation ("LP") are each hereby authorized to sign, on behalf of LP and its subsidiaries, environmental permit applications and environmental reports to the extent required or permitted by applicable federal, state and local environmental laws, regulations and agency agreements " "RESOLVED that the Chief Executive Officer and the Executive Vice President, Administration, and Chief Financial Officer of LP may delegate the atithority set forth herein to other employees of LP and its subsidiaries to the extent permitted by applicable federal, state and local environmental lazes, regulations and agency agreements, provided that sitch delegations of atithority are set forth in writing and are in accordance with the corporate Signatory Atithority Policy, as such Policy may from time to time be amended " In accordance with these LP Board of Director resolutions, employees occupying the following positions are hereby authorized to sign (for facilities indicated) on behalf of LP and its subsidiaries, environmental permit applications and environmental reports to the extent required or permitted by applicable federal, state and local environmental laws, regulations and agency agreements Executive Vice -Presidents (authorization for all facilities) Vice -President, Environmental, Health, and Safety (authorization for all facilities) ADDRESt, 414 Union Street Ste 2000 Nashville TN 37219 TEL 615 988-8600 FAX 615 086 b606 ueu www Ipeorp com Loulsiana Pacfflc Corporation Signatory Authority Delegation Letter January 27, 2012 Page 2 of 2 • Business Vice -Presidents / General Managers (authorizabon for facilities they are responsible for) • Manufacturing Operations Directors (authorization for facilities they are responsible for) • Regional / Business Operations Managers (authorization for facilities they are responsible for) • Plant Managers (authorization for facilities they are responsible for) c I lei eo �_p 31- Richard W Frost ~ Chief Executive Officer Mark A Fuchs Corporate Secretary Pickle, Ken From Pickle Ken Sent Friday, August 24, 2012 4 22 PM To Georgoulias, Bethany, Karoly Cyndi Cc Smith, George, Bennett Bradley, Basinger Corey Subject RE Stormwater Monitoring Event [Data 2010-2012 As Folks, Clarification I've just exchanged emails with George, and I think I understand the circumstances at Louisiana Pacific a little better now In my note below, I missed or forgot the fact that LP has been sampling monthly as per WSRO direction while they tried to develop an engineering approach to the benchmark exceedances These circumstances are now made more difficult because it appears that engineering alternatives have been evaluated, and the costs involved with engineering responses (BMPs) may be pretty high They are apparently at a dead end Ken Ken Pickle Environmental Engineer NCDENR l DWQ I Stormwater Permitting Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 512 N Salisbury St, Raleigh, NC 27604 Phone (919)807-6376 Fax (919) 807-6494 Email ken pickle@ncdenr aov Webstte htto /loortal ncdenr ora/web/wq/ws/su ** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulations ** From Pickle, Ken Sent Friday, August 24, 2012 2 21 PM To Smith, George Cc Georgoulias, Bethany, Karoly, Cyndi, Bennett, Bradley Subject FW Stormwater Monitoring Event Data 2010-2012 As Hi all, Here are my beginning pre -conceptions on the topics that LP Roaring River wants to discuss next Wednesday, inserted in red in Mr Hart's note below I'll be listening and looking to revise/confirm them kbp Ken Pickle Environmental Engineer NCDENR I DWQ I Stormwater Permitting Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 512 N Salisbury St, Raleigh, NC 27604 Phone (919)807-6376 Fax (919)807-6494 Email ken pickle@ncdenr gov_ Website httc l(portal ncdenr orgLweblwglws su ** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulations ** From Smith, George Sent Thursday, August 23, 2012 7 17 AM To Pickle, Ken, Georgoulias, Bethany Subject FW Stormwater Monitoring Event Data 2010-2012 As Attached you will find LP data George Smith New email george smith@ncdenr gov NC DEN Winston Salem Regional Office Division of Water Quality Water Quality Section 585 Waughtown Street Winston-Salem, NC 27107 Voice (336) 771-4968 FAX (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties From Roy Hart [mailto Roy HartIpcorp com] Sent Wednesday, August 22, 2012 12 27 PM To Smith, George Subject Stormwater Monitoring Event Data 2010-2012 As George I owe you this file I have separated it into individual outfalls for TSS and COD and calculated individual statistics for each in prep for next weeks meeting Topics to discuss Permit Renewal guidance OK, the permit boilerplate is confusing on this point and we will be rectifying that when the permit is renewed next year DWQ SPU will initiate the renewal process — 6 months before the expiration date of the General Permit, 7131113 They only need to respond to our mailer when it comes to them next year Reduction of Tier sampling requirements Yes, I agree We're not going to learn anything more from continuing monthly sampling They have enough data now to support a corrective approach Maybe we want to work in some increased sampling into a BMP requirement, but monthly sampling ad inftnitum seems too much now They could have pulled the trigger on this two years ago, perhaps they were hoping the data would get better Representative Outfall designation Well, #002 is the hottest for TSS, and #003 has the greatest proportion of COD exceedances (17 hits out of 23 data points = 74% exceedances) #001 is not significantly better than the others, however It's much easier to consider ROS when you can just drop the least threatening outfall Let's listen to see if they have a proposal Outfall addition OK, let's see what they are planning, and help them forecast any impact on their permit compliance BMP discussion Yes, this would be a good topic for the meeting After the site tour We need to see the ground conditions in order to advise them Other? Yes Since January 2009, how have you attempted to address the last 44 months of nearly continuous monthly and quarterly exceedances? We need to know what has been tried, and whether they have seen any benefit Also any evidence of in -stream impacts? Are we still expecting 4 (you Corey, two permit writers)? Hope the weather cooperates WA Roy Hart ESH Manager Roaring River Mill Louisiana Pacific Corp 336-696-3464 336-984-0249 cell rov hart(o)lpcorp cam Smith, Geor e From Basinger, Corey Sent Tuesday October 20 2009 2 31 PM To Smith George Cc Tedder, Steve Subject FW NCG210355 Louisiana Pacific - Wilkes County - NCG Attachments NCG210355 SW DMR Data pdf Forwarding this on to you for review, comment and any necessary action CB Corey Basinger, Environmental Engineer Corey Basinger@ncdenr goy NC DENR Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 (336) 771-5000 Fax (336) 771-4630 E mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties From Jones, Jennifer Sent Tuesday, October 20, 2009 2 28 PM To Basinger, Corey Cc Pickle, Ken Subject NCG210355 Louisiana Pacific - Wilkes County - NCG Hey Corey, I was entering the SW DMR data for NCG210355 and saw they had some TS5 and COD exceedences They also had some things wrong with their DMR form — attached —so I called them Billy Thompson at the site seemed pretty concerned and said they had sampled again and had not sent in that data yet but it wasn't looking good either He asked what he could do I talked to Ken about it and called him back but he hasn't called back yet I was going to tell him to contact you to discuss proactive measures He wondered if he would need an individual permit but I don't think that is necessarily necessary —we are already testing for TSS and COD They have a WW permit— but can't take any more water— its already at capacity His name is Billy Thompson — 336-696-3410, email billy thompson@lpcorp com Questions I was going to ask — per conversation with Ken • What industrial activities are you doing at this site? • What is the site layout like? • How long has the mulch pile been there? Where is the spray field? We'd like to be involved in helping them with a solution/identifying their problems, or at least hear what the outcome is I am sure you know this is an evolving part of our program and we'd like to stay on top of it —we've had similar problems with other mulch/bark piles Please feel free to contact him as well and when/if I talk to him I will send him your way Thanks Corey) Jeri On the Louisiana Pacific site there may be a couple of tough issues we will have to confront under their coverage under NCG21 - When are we going to call the stuff from the bottom of a bark pile, 'wastewater"? This site may present an early instance for us to make this determination - If they can contain the leachate from the bark pile on site, perhaps the remaining discharge could be construed as from the general operating area, but not from a bark pile, and we could then go ahead and potentially consider the other flows as stormwater What I'm suggesting is that if possible they should eliminate the discharge from the bark pile Potentially this would go a long way toward reducing TSS and COD exceedences - Let's alert Corey B, or whoever is assigned as WSRO, that we have a pending issue with this NCG21 site - As I understand it, DWM has regulations prohibiting a waste pile So, if the site contact is telling you that the pile has been therefor years, we may want to drop a dime on these guys with WSRO-DWM This guy Chris will be able to tell you if he's the guy, or if someone else needs to be involved - Does the on site spray field deserve closer examination as a potential or partial solution for their circumstances? Jennifer Jones Environmental Engineer NCDENR I DWQ I Stormwater Permitting Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 512 N Salisbury St, Raleigh, NC 27604 Phone (919) 807-6379 Fax (919) 807-6494 Email aennifer]ones(@ncdenr gov Website http //h2o enr state nc us/su **E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties ** N ki NC®ENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H Sullins Governor Director August 13, 2009 Mr Billy 1 hompson Louistana-Pacific Corporation P O Bo\. 98 Roaring River, NC 28669 Subject Compliance Stonnwatet Inspection Permit # NCG210355 N'Vrlkes County Dear Mr I hompson Dee Freeman Secretary On August 6, 2009 a Compliance Stormwater inspection was perfoinned by George Smith, of this office klr Billy ['hompson was present for the inspection I he attached inspection form evaluates fry e (5) areas as noted in Section C of the attached EPA inspection repot t and the obsetvations and comments during the inspection are addressed below Permit The NPDES general permit became, effective on August 1, 2008 and expires on July 31, 2013 Fhe peimit identifies two ateas that apply to this I imbei Products facility 1 Stormwater Pollution Prevention Plan per .Part I1, Section A 2 Storm %atei Discharge Outtall (SDO) Semi-annual qualitative monitoring as required in Part lI Section B Records &. Reports the follon ing stormNA ater records were ex aluated 1 Stormwater Pollution Prevention Plan v,,as developed and implernented per Pait II, Section A An excellent site plan was de%eloped, which clearly identified all Stormwater outfalls The plan was well developed, and kept in a notebook binder All nine items requited if the Plan were deN eloped and well documented North Carolina Division of Water Qualily Winston Salem Regional Office Location 585 Waughtown St Winston Salem North Carolina 27107 Phone 336 771 50001 FAX 336 771-46301 Customer Service 1 877-623 6748 Internet www ncwaterquality org An Equal opportunity 1 Affirmative Action Employer NorthCarol;ina Naturally 11 Louisiana-Pacific Corporation August 13, 2009 Page 2 of 2 1 Stormwater Discharge Outfalls (SDO) shall be inspected and qualitatively monitored semiannually as requited to Part 1I, Section B "I he facility performed and documented the qualitative monitoring, which is required semiannually 2 Analytical monitoring of parameters for stormwater discharges as requited in Part II, Section C are required if 55 gallons of new motor oil are used per month when averaged over the calendar year The vehicle maintenance area does not average, 55-gallons of new motor oil per month, therefore, analytical monitoring is not required Facility Site Review I he facility has a large amount of timber (logs) on site, which is used for to make fiberboard A gene,tal overNiew of the lumberyard did not re,.eal any stormwatet issues that would lead to water quality violations Self -Monitoring Program The facility had all qualitative monitoring records on -site, as required by the permit The analytical monitoring for on -site vehicle maintenance is not required since 55 gallons or greater per month of new motor is not used The stormwater sampling for outfalls 001 & 002 is on Tier 2 for COD Please continue the the steps and outlined in the permit If you have any questions please contact George Smith, at this office (336) 771-4968 Storm Water The site plan addresses all issues for potential stot rnwater discharges the compliance storm�iater inspection is satisfactory If you have any questions please contact George Smith or me at (336) 771-5000 Sincerely, Steve W 1 edder Regional Supervisor cc WSRO Files. Permit NCG210355 sac County Wilkes Region 1rVioston-Salem Compliance Inspection Report Effective 08/01/08 Expiration 07/31/13 Owner Louisiana Pacific Corporation Effective Expiration Facility Abtco A Louisiana Pacific Company Hwy 268 Contact Person Phil Sparks Directions to Facility System Classifications Primary ORC Secondary ORC(s) On Site Representative(s) Related Permits Title Inspection Date 08/0612009 Entry Time C9 00 AM Primary Inspector George S. Smith Secondary Inspector(s) Roaring fever NC 28669 Phone Certification Exit Time 10 10 AM Phone Phone 336 //1 5000 Reason for Inspection Routine inspection Type Storm, Dater Permit Inspection Type Timber Products Stone, paler Discharge COC Facility Status ® Compliant U Not Compliant Question Areas ® Storm Water (See attachment summary) Page 1 Permit NCG210355 Owner Facility Louisiana Pacific Corporation Inspection Date 08l0612009 Inspection Type Stormwater Reason for Visit Routine Inspection Summary Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ® n n n # Does the Plan include a General Location (USGS) map? ® n n n # Does the Plan include a Narrative Description of Practices ? ® n n n # Does the Plan include a detailed site map including eutfall locations and drainage areas? ® n n n # Does the Plan include a list of significant spills occurring during the past 3 years? ® n n n # Has the facility evaluated feasible alternatives to current practices? ® n n n # Does the facility provide all necessary secondary containment? ® n n n # Does the Plan include a BMP summary? ® n n n # Does the Plan include a Spill Prevention and response Plan (SPRP)? ® n n n # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® n n n # Does the facility provide and document Employee Training? ® n n n # Does the Plan include a list of Responsible Party(s)? ® n n n # Is the Plan reviewed and updated annually? ® n n n # Does the Plan include a Stormwater Facility inspection Program? ® n n n Has the Stormwater Pollution Prevention Plan been implemented? ® n n n Comment Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi annually? ® n n n Comment Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ® n n n # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n n ® n Comment Page 2 TSS Outfall1 0utfa112 Outfal13 56 118 80 960 112 28 192 750 104 186 230 236 58 100 122 70 24 94 22 4 400 40 25 40 15 136 1042 172 500 820 198 79 770 102 44 108 50 246 272 676 164 189 606 46 410 732 44 4 55 44 40 254 36 136 38 50 32 14 36 92 150 144 136 362 126 90 38 136 352 Samples 24 21 23 Avg 139 350 95 SD 135 324 83 95% COnf 54 138 34 139 ± 54 350 ± 138 95 ± 34 COD Outfall1 0utfa112 Outfall3 158 159 153 420 67 70 397 326 292 80 128 273 133 167 187 237 148 165 146 0 163 84 22 50 82 110 216 245 479 642 287 66 311 198 77 66 124 105 602 155 160 210 196 251 124 521 704 121 125 46 171 75 290 67 154 48 171 114 58 222 151 168 81 182 152 82 105 81 110 253 25 22 23 Avg 174 220 165 SD 136 195 73 95% Conf 54 81 30 174 ± 54 220 ± 81 165E 30 1500 "� C®ENR North Carolina Department of Environment and Natural Resources Division of Water Quahty Beverly Eaves Perdue Coleen FI Sullins Governor Director December 8, 2009 Mr Billy Thompson Louisiana-Pacific Corporation P O Box 98 Roanng River, NC 28669 Subject Compliance Evaluation Inspection Louisiana-Pacific Corporation — Stormwater Evaluation Permit # NCG210355 Wilkes County Dear Mr Thompson Dee Freernan Secretary On December 3, 2009 a Compliance Evaluation Inspection was performed by George Smith, of this office Mr Billy Thompson was present for the inspection The purpose for the inspection was to evaluate the drainage areas that are exceeding the benchmark values for Total Suspended Solids (TSS) and Chemical Oxygen Demand (COD) Permit The permit identifies the monitoring required for this facility l Part II, Section A - Stonnwater Pollution Prevention Plan 2 Part II, Section B - Analytical Monitonng 3 Part H, Section C - Qualitative Monitoring 4 Part H, Section D - On -Site Vehicle Maintenance Monitoring Records & Reports An excellent site plan was developed, which clearly identified all three (3) stormwater outfalls The plan was kept in a notebook binder All nine items required if the Plan were well documented Facility Site Review Logs are chipped, digested, and used to make fiberboard Outfall 4003 receives stormwater from timber (logs) in this drainage area Also, Outfall #003 receives a small portion of stor nwater from the chipping operation, stormwater in the grassed ditches along of the railroad track, and sawdust piles Per our discussion, the COD may be reduced if the stormwater detention pond was periodically maintained and would drain at a faster rate North Carolina Division of Water Quality Winston-Salem Regional Office Location 585 Waughtown St Winston Salem North Carolina 27107 One Phone 3367716000 1FAX 336771.46301Customer Service 1877-623-6748 NorthCarolina Internet www nmaterquality org Naturally An Equal Opportunity 1 Affirmative Action Employer Louisiana-Pacific Corporation December 8, 2009 Page 2 of 2 Outfall #002 receives stormwater from storage of large sawdust piles, and drainage from a graveled storage area The periodic exceedence of the benchmark value for TSS is most likely from the fines in the gravel area The TSS may be able to be reduced by making a small pit or weir that would allow the fines to settle just prior to the sampling point Of course, this would have to be periodically maintained Outfall #001 received stormwater from a old wood chips and fibers The basin has a grass bottom with little water remaining accumulated The basin drains the stormwater quickly and therefore does not allow time for the COD to develop A rock check dam could be constructed just prior to the sampling point in order to reduce the chance of a TSS benchmark exceedence Self -Monitoring Program The facility had all qualitative monitoring records on -site, as required by the permit The analytical monitoring for on -site vehicle maintenance is performed from Outfall #002 The analytical monitoring for all 3 outfalls is performed Outfall #003 is on Tier Two, and requires monthly monitoring Representative sampling from the following locations is required • Outfall #00I — In the channel downstream of the stormwater basin • Outfall 4002 — In the manhole adjacent to the gravel lot • Outfall #003 --- In the culvert across the railroad track, just prior to entering the property of Certain Teed The compliance evaluation inspection is satisfactory If you have any questions please contact George Smith or me at (336) 771-5000 Sincerely, Steve W Tedder Regional Supervisor cc Stormwater Permitting Unit — Jennifer Jones WSRO Files Michael F Easley Governor o�0� W A r�RQ� >IVWv-`� NMR�1111_1. September 12 2008 Uarames IReavts Louisiana Paclflc Corporation PO Box 98— Roaring River NG 28669 Wtlh im G Ross Jr Secretary North Carolina Department of Environment and Natural Resources Coleen H Sullins Director Division of Water Qualiq Subject NPDES Stormwater Permit Coverage Renewal Abtco = AA Louisiana Pacific Company COC Number NCG210355 WiW-ilk s County Dear Permittee In response to your renewal application for continued coverage under stormwater General Permit NGG210000 the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater General Permit This permit has been reissued pursuant to the requirements of North Carolina General Statute 143-215 1 and the Memorandum of Agreement between the stale of North Carolina and the U S Environmental Protection Agency dated October 15 2007 The following information is included with your permit package • A new Certificate of Coverage • A copy of stormwater General Stormwater Permit NCG210000 • A copy of the Technical Bulletin for the General Permit • Five copies of the Discharge Monitoring Report (DMR) Form • Five copies of the Qualitative Monitoring Report Form The General Permit authorizes discharges of stormwater only and it specifies your obligations with respect to stormwater discharge controls management monitoring and record keeping Please review the new permit to familiarize yourself with all the changes in the reissued permit The more significant changes to the General Permit include the following • Permit cover page second paragraph - The General Permit now may cover activities that DWQ determines to be similar in either the process or in the exposed materials to the Timber Products Industry • Part I Section A - A new provision that facilities draining to 303(d) listed waters or in watersheds with an approved TMDL may not be eligible for continued coverage at the next renewal of the General Permit • Part I Section B second paragraph - A new clanfication that the permit does not authorize discharges that DWQ determines are wastewaters • Part I I Section A -The required contents of the Stormwater Pollution Prevention Plan have been expanded and clarified • Part I I Section B Table 1 - A new requirement to sample stormwater discharges twice per year for those facilities with exposed piles of certain materials remaining on site longer than seven days • Part 11 Section B Tables 2 and 3 and following - For permittees with exposed piles there are new provisions requiring the permittee to execute Tier One and Tier Two response actions based on the first benchmark exceedence (Tier One) and the second consecutive benchmark exceedence (Tier Two) Tier Two requires that the permittee institute monthly monitoring instead of twice per -year monitoring until three consecutive monitoring events show no benchmark exceedences • Part 11 Section B - For permittees with exposed piles a new provlsion'that four exceedences of any particular benchmark will trigger increased DWQ involvement in the permittee s stormwater management and control actions DWQ may direct the permittee to apply for an individual permit or may direct the implementation or installation of specific stormwater control measures • Part 11 Section C - Clarification that under the qualitative monitoring provisions of the permit the permittee is obligated to respond to repeated observations of stormwater pollution DWQ may impose additional stormwater management requirements if the permittee is non responsive or if the responses are ineffective Your coverage under the General Permit is transferable only through the specific action of DWQ NNn hCarolm-k aturally North Carolina Dn ision of Water Quahts 1617 Mail Seri ice Center Raleigh NC 27699 1617 Internet h2o enr state nc uslsulstormwater html 312 N SalisburF St Raleigh NC 27604 An Equal Opportunity/Affirmative Acton Employer— 50% Recycled110% Post Consumer Paper Phone (919) 807 6300 Customer Service FAX (919) 807 6494 l 877 623-6748 NPDES Stormwater Permit Coverage Renewal Permit Number NCG210355 Page 2 This permit does not affect the legal requirements to obtain other permits which may be required by NCDENR nor does it relieve the permittee from responsibility for compliance with any other applicable federal state or local law rule standard ordinance order judgment or decree If you have any questions regarding this permit package please contact Bethany Georgoulias of the Central Office Stormwater Permitting Unit at (919) 807 6376 Sincerely foi Coleen H Sullins cc DWQ Central Files Stormwater Permitting Unit Files WfnsMµ ®�gton-Salem Regional Office STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO NCG210000 CERTIFICATE OF COVERAGE No NCG210355 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215 1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission and the Federal Water Pollution Control Act as amended, Louisiana Pacific Corporation is hereby authorized to discharge stormwater from a facility located at Abtco - A Louisiana Pacific Company Hwy 268 Roaring Rive Wilkes County to receiving waters designated as the Yadkin Pee -Dee River, a class WS-V stream in the Yadkin -Pee Dee River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II III IV V and VI of General Permit No NCG210000 as attached This certificate of coverage shall become effective September 15, 2008 This Certificate of Coverage shall remain in effect for the duration of the General Permit Signed this day September 12 2008 for Coleen H Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission o�0 W A rFq�G > March 24 2008 Mr Billy Thompson Louisiana-Pacific Corporation P O Box 98 Roaring River NC 28669 Subject Compliance Storrnwater Inspection Permit # NCG210355 Wilkes County Dear Mr 1 hompson Michael F Easlev Go%ernor �A illiam G, Ross Ir Secretary \orth Carohna Department of 1=mironment and Natural Resources Coleen H Sullins Director Dl%lsion of Water Quat% On March 17, 2008 a Compliance Storms ater Inspection was performed by George Smith of this office Mr Billy Thompson was present for the inspection The attached inspection form e-* aluates In a (5) areas as noted in Section C of the attached EP -X inspection report, and the observations and comments during the inspection are addressed belo►4 Permit The NPDLS general permit became effective on Inlay 1 2003 and expires on April 30, 2008 This permit is valid past the e\piration date, until the issuance of the next General Permit NCG210000 The permit identifies two areas that apply to this fimbl,r Products facility 1 Stormwater Pollution Prevention Plan per Part 11, Section A 2 Ston-iwater Discharge Outfall (SDO) Semi-annual qualitative monitoring as required in Part 11, Section B Records & Reports The following slormtiNater records wet evaluated I Stormwater Pollution Prevention Plan was developed and implemented per Part 11 Section A An excellent site plan was developed «hick clearly identified all stormwater outfalls The plan ktias «ell developed, and kept in a notebook binder All nine items required if the Plan �Nere developed and Ns ell documented North Carolina Division of W1ter Quality 585 Waughlown Street Phone (336) 771 5000 Customt,r Service Winston Salem Rebronal Office Winston Salem \rC 27107 1-ax (336) 771 4630 1 877 623 6748 Internet wink ncuaterquatrtr Nne octhCarohna ,Aaturally An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper Louisiana Pacific Corporation Nfarch 24 2008 Page 2 oF2 2 Stormwater Discharge Outfalls (SDO) shall be inspected and quahtati-�eK monitored semtannuall) as required to Part II, Section B File factltt) performed and documented the qualitative monitoring, �Nhtch is required semiannual]% 3 Analytical monitoring of parameters for stormy%ater discharges as required to Part II, Section C are required if �5 gallons of new motor oil are used per month when averaged over the calendar vear The vehicle maintenance area does not average 55-gallons of new motor oil per month, therefore analytical monitoring is not required Facility Site Review The facility has a large amount of timber (fogs) on site, which is used for to make fiberboard A general overview of the lumberNard did not reveal any stormwater issues that would lead to water quality violations Self -Monitoring, Program The facility had all qualitative monitoring tecotds on -site, as requited by the permit The analytical monitoring for on -site vehicle maintenance is not required since 55 gallons or greater per month of new motor is not used Storm Water The site plan addILsses all tssucs for potential stormwater discharges The compliance stormwater inspection is satisfactory If you have any questions please contact George Smith or me at (336) 771-5000 Sincerely Steve %NI Tedder Regional Supervisor cc SWP Cenv,il Files WSRO Files, Permit NCG210355 SOC County Wilkes Region Winston Salem Contact Person Bill Baird Directions to Facility System Classifications Primary ORC Secondary ORC(s) On Site Representative(s) Related Permits Compliance Inspection Report Effective 05/01/03 Expiration 04/30/08 Effective Expiration Title Certification Owner Louisiana Pacific Corporation Facility Aotco A Louisiana Pacific Company Navy 268 Roaring River NC 28669 Phone 336 696 3426 Phone Inspection Date 03117/2008 Entry Time 10 03 AM Exit Time 11 45 AM Primary Inspector George S Smith Phone 336 771-5000 Secondary Inspector(s) Reason for Inspection Routine Inspection Type Stormwafer Permit Inspection Type l imber Products Stormwafer Discharge COC Facility Status ® Compliant 0 Not Compliant Question Areas is Storm water (See attachment summary) Page 1 f Permit NCG210355 Owner Facility Louisiana Pacific Corporation Inspection Date 0311712008 Inspection Type Stormwater Inspection Summary Stormwater inspection Is satisfactory Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan? # Does the Plan include a General Location (USGS) map? # Does the Flan Include a Narrative Description of Practices # Does the Plan include a detailed site map including outfall locations and drainage areas? # Does the Plan Include a list of significant spills cccumng during the past 3 years? # Has the facility evaluated feasible alternatives to current practices? # Does the facility provide all necessary secondary containment? # goes the Plan Include a BMP summary? # Does the Plan Include a Spill Prevention and Response Plan (SPRP)? # Does the Plan Include a Preventative Maintenance and Good Housekeeping Plan? # Does the facility provide and document Employee Training? # Does the Plan Include a list of Responsible Party(s)? # Is the Plan reviewed and updated annually? # Does the Plan Include a Stormwater Facility Inspection Prog,am? Has the Stormwater Pollution Prevention Plan been implemented? Comment Qualitative Monitoring Has the facility conducted Its Qualitative Monitoring semi annually? Comment Reason for Visit Routine Yes No NA NE ®nnn ®nnn ®nnn ®nnn ®nnn ®nnn ® n n n ®nnn ®nnn ®nnn ®nnn ®nnn Mnnn ®nnn ®nnn ®nnn Page 2 Michael F Easley Governor William G Ross Jr Secretary North Carolina Department of Environment and Natural Resources Alan W Klimek P E Director Division of Water Quality April 28, 2003 Bill Baird Abtco - A Louisiana Pacific Company PO Box 98 Roaring River, NC 28669 Subject NPDES Stormwater Permit Renewal Abtco - A Louisiana Pacific Company COC Number NCG210355 Wilkes County Dear Permittee In response to your renewal application for continued coverage under general permit NCG210000, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215 1 and the Memorandum of Agreement between the state of North Carolina and the U S Environmental Protection Agency, dated December 6, 1983 The following information is included with your permit package • A new Certificate of Coverage • A copy of General Stormwater Permit NCG210000 • A copy of the Analytical Monitoring Form (DMR) • A copy of the Qualitativel Monitoring Form • A copy of a Technical Bulletin for the general permit Your coverage under this general permit is not transferable except after notice to DWQ The Division may require modification or revocation and reissuance of the Certificate of Coverage This permit does not affect the legal requirements to obtain other permits which may be required by the Department of Environment and Natural Resources, or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree If you have any questions regarding this permit package please contact Bill Mills of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext 548 Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit cc Central Files Stormwater & General Permits Unit Files Winston-Salem Regional Office WX NCDENR N C Division of Water Quality 1617 Mail Service Center Raleigh NC 27699 1617 (919) 733 8053 Customer Service 1 800 623 7748 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO NCG210000 CERTIFICATE OF COVERAGE No NCG210355 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215 1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Louisiana Pacific Corporation is hereby authorized to discharge stormwater from a facility located at Abtco - A Louisiana Pacific Company Hwy 268 Roaring River Wilkes County to receiving waters designated as the Yadkin River, a class WS-V stream, in the Yadkin - Pee Dee River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No NCG210000 as attached This certificate of coverage shall become effective May 1, 2003 This Certificate of Coverage shall remain in effect for the duration of the General Permit Signed this day April 28, 2003 for Alan W Klimek, P E , Director Division of Water Quality By Authority of the Environmental Management Commission Michael F Easley Governor William G Ross Jr Secretary North Carolina Department of Environment and Natural Resources Alan W Klimek P E Director Division of Water Quality Sl-l)iLIllhl-1 4 2002 ERICH BURICE AB I CO A LP CONIPAN) PO BOX 98 ROARING RIVER NC 28669 ',uhlLCt NPDES StoiniA uur PLrnlrt Co\Lr1gt- Ri-nLNN If AbtCo A Lp Coinp-in, COC NLInlbur NCG210;55 DL Ir PLimalLL Your I tLilrty n UII1Lntly UriLrLci for ,tormNk itt t dl,Lh irivl- U11dLr GLnur it Pt-rrnit NCG210000 I Ills permit Lxpnu, on M nCf1 31 200 1 hL DiNision,I Of Is (,urrLntl) in thL proCL„ of rL%krilIll« tilts pL11111t Ind 11, uhLdulLLl to have, till- pLunit ruiSwLd b} L irlv,p€mg of 2001 OnCl- IIIL palnut 1, 1LI„uud Hour I ICIIItN woul(I bL t-hLIblt- kn L011t[nuLd (,ONGT I,'(- undl-r thc, iw„ul-(I ptrmu In ordLr t1) I,sutL your COIl[lnLil-d CoNci wi- undc,r till- 2'�Lnurll pLrmit you ntu,t Ippl\ to the D1'l,1011 01 W ILLI Qu tilt} (DWQ) for rwtuA� it of }our pLrinu u1NLI r«C I m all- 111, tl-nl-u it procC„ l- tvl-r Nkc. 11u Informing Nou In ad, 11UC Ill it }our pLnnit co�Lrak.t- \till b(, uxpiring EIICIoSLd you %%Ill find a Permit Co%cr I;e R(nc�ti 11 Application )Horn I hL apphc. Itton must bL (,omplLILcl and rLlurm d b) OLtohLr 2 2002 in order to a„uIl- Contrnuud Lo%t-ra L undl-r Ihu gLlxi-it purrrnt DuL 10,t Ill and budgLt (-OIV ti IMP, IULt.1, Lonhiming out ILL(.Ipt of thL L01111)10c,d tppltc, Ilion vidl not bl- ,Lnt f uluri- to rLyuL,t rc nLx\ ►I %N [thin the tlmL PLrrod ,pLLII lud In I} rl-,ult rn t LIB It ►„l-„m(,nt of It tL ►,t $250 00 L itgui pLn dw,, In ►} b( as,t-„Ld dq)Lnd[nn on tilt- clLllnyuLnL, of thL iuyuc,t DI,LhargL of ,toriilw itur from vour t Iuh1} vti Ithout Lov Lr 1�,L undLr I x ►hd ,torm(N ItLi NI'DD. p(rmrt Nt ould Constltutt- I (101 Ikon of NCGS 141-215 l tnd Could ILUllt in t„u„nlLnts of Cn 11 pLn 11itL, of up to $ 10 MO pLr d I% PlL t,L nett- th It 1ucu11 tc (It ill 1Lg1,1 ttion 11'1s L ttcndCd tltL no Lxpo,uru LxLlu,lon to Ill opLrltor, of mdw tri it I KAIIuL, In an} of Ihl- l I LatCgoriLS of ,torin w ttLr d1,Ch it4L, a„ol-adtLd with mdu,tl lal It nv (Lxcy)t construLtlon 1LLI\ IttLS) 11 xou furl `our I ILIIIt% c In (oral} t Wndltton (it no Lxprnuru I L thL FILIIIt} rrldu,[ri tI n1 ►turi it, and opLrttions irL not l-xpo,(,d to,totlnwatLI you l- In 1pply for tilt- no Lxpoutrl- uxclumon For additional 111101111 [[]oil L0111 tut OIL CLntr►I (MILL Stormw ate S1 III II1LInhLr hstLd hulow 01 LhUk thL Storw" ttur & Gl-nLi if Pu mat, Unit 1\ t-h Silt- It ht[]) //1120 Lilt ,t itl- nL us/,u/stilt 111N, atLI 11LIIII If thL ,ublLLt (IISLII tr«L to ,, ear, of tilt- st ttL It r, hLLn to mIn Itud PIL nL Lonlplc,tu OIL Lnuluud Res(.ismon RLquCst Form M idling 111,tiuCtion, IIL 11,1ul on IIIL bottom of tilt- loin► l ou will bL notilit d %khLn 1111- rL,Lt„ron proCL„ ha, boon cornplutLd II }ou 111%u In` yuuwons rLI'ar(hM' d1L pC11n1t It-nl-w 11 pIOULIUlu, plu t,u Lont tut Coicti B of [hL Winston-', Henn Ruylon it OIItCL at 3,16-771 4600oi Bill Mtll,of till- CLnn a1 Oflio- StornlwttLi Unit it (919) 7�1 505. Lxt 548 StnuLi t-l} 131 Idl(} BLII(101 ',upLr\ isoi Sto1mv nur ind Cicw rit Put mit, Unit CL Conti al FIIL, ',torn►N4 uLr Ind CtLrIUdI Ptrmtt, Unit Fi]L, Winston-S alum Region it OItiCL NCDENR N C Division of Water Quality 1617 Mart Service Center Raleigh NC 27699 1617 (919) 733 7015 Customer Service 1 800 623 7748 State of North Carolina Department of Environment r and Natural Resources Division of Water Quality Michael F Easley, Governor William G Ross Jr, Secretary Gregory J Thorpe, Ph D , Acting Director November 1 2001 Mr Erich Burke, Environmental Engineer ABTCO, A LP Company P O Box 98 Roaring River, NC 28669 A&V?IWA A •• 2 NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject General Permit No NCG210355 ABTCO, A LP Company COC NCG210355 Wilkes County Dear Mr Burke In accordance with your application for discharge permit for coverage under NCG210000, received on December 20, 2000 and the subsequent information that you submitted at our request, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated May 9, 1994 (or as subsequently amended) Our review of the information that you submitted indicated that the Subject facility is not primarily engaged in wood chip production at this site and that coverage under the General Permit NCG210000 is appropriate If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual penrut application Unless such demand is made, this certificate of coverage shall be final and binding Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage This permit does not affect the legal requirements to obtain other perrmts which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required If you have any questions concerning this permit, please contact Bill Mills at telephone number 919/733-5083 ext 548 Sincerely, ORIGINAL SIGNED BY BRADLEY BENNETT Gregory J Thorpe cc Winston-Salem Regional Office Central Files Stormwater and General Permits Unit Files 1617 Mail Service Center Raleigh North Carolina 27699 1617 Telephone 919-733 5083 FAX 919-733 9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post consumer paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO NCG210000 CERTIFICATE OF COVERAGE No. NCG210355 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143 215 1 other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission and the Federal Water Pollution Control Act as amended ABTCO, A LP Company is hereby authorized to discharge stormwater from a facility located at ABTCO US Hwy 268 Roaring River Wilkes County to receiving waters designated as the Yadkin River in the Yadkin -Pee Dee River Basin in accordance with the effluent limitations monitoring requirements and other conditions set forth in Parts I,11 1I1 IV V VI and VII of General Permit No NCG210000 as attached This certificate of coverage shall become effective November 1 2001 This Certificate of Coverage shall remain in effect for the duration of the General Permit Signed this day November 1 2001 ORIGINAL SIGNED BY BRADLEY BENNET7' Gregory ! Thorpe Ph D Acting Director Division of Waiter Quality By Authority of the Environmental Management Commission rY: rtot 2'30" 1 L 4Q0000 FEET ROARING RIPER QUP�D�AGLF', NORTH CAROLINA-WILKES.,QCO jv 7 5 MINUTE SERIES. (TOP�OGRA?HIC '98 499 ' ."f?,i;rin 1�r0Q'.dlfis / � 4 y 1 .rP,Jlit Y .� _ t 11 291f �'f' 1 r � r �� 1 � �� 1 � 1, _ l � r• � V' � a %P� / .,-� ',�•• � i ) y�� ` �j�� r � j � if � _ �� c , � ., � � • �--]��JJ �� r� � ,� �1 — n4" t� I � OJ} � �� Y f07)% � r u f t rd � \ rit � � U h r� � Yr +2s�ju/1,��lfr� 910 000 FEET IG J aTl NE )rmwater Pollution Prevention Plan Yes No NA yes the site have a Stommater Pollution Prevention Plan? ❑ ❑ ❑ ❑ Does the Plan include a General Locatton (USGS) map? ❑ ❑ ❑ ❑ Does the Plan include a 'Narrative Description of Practices"? ❑ ❑ ❑ ❑ Does the Plan include a detailed site map including ortfall locations and drainage areas? Does the Plan include a list of significant spills occumng during the past 3 years? Has the facility evaluated femble altematrves to current practices? Dues the facility provide all necessary secondary containment? Does the Plan include a BMP summary? Doe, the Plan include a Spill Prevention and Response Plan (SPRP)? Does the Plan include a Preventative Maintenance and Good Hou *eeRng Plan? Does the facility provide and document Employee Training? Does the Plan include a list of Responsible ParMs)? Is the Plan reviewed and updated annually? Does the Plan include a Stornwater Facility Inspection Program? 3S the Stom water Pollution Prevention Plan been implemented? omment talitatiye Monitonng 3s the facility conducted its Qiralitative Monitonng semi-annually? omment alytical Monitonng 3s the facility conducted its Analybcal monitonng? Has the facility conducted ft Analytical monitoring tom Vehicle Marntenartc-- areas? omment mirt and Outfalls Is a copy of the Permit and the Certificate of Coverage available at the site? Were all outfall- observed during the inspection? If the fact Irty has representative outfail status, is it properly documented by the Drvision? Has the facility evaluated all illicit (non story water) discharges? LE ■ I■ Um ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑❑❑❑ Yes No NA NE ❑ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ■ ■ ■ E `rxty TE StAPW S - Ts S, CO D St rM 1 V4 D h Sed bn,;\ S i20S, 4 EGi r� vu �}r i 0 '�Y1 MGLVA V.aVJ ►n10ld Stich VV, age, I V\� (,w \0 v % tt I S- Zo GZGL �S Cb W4 Yf WA 1 S LASUt" JoCJd - 2+nncd pe rry-►%t- +'Cux vulad Out W.A 2 = rou i \j ry V'J, -rt> l v\47 U B r) -F s-p n "T rz tfA,,e - ® in �Youd u 7 e s ,-h'aA"VI , p � iu Yc �r r�nv_.rS d ai} n)Lj st f- 3 o d ovi aw Cycle NC to Loursrana-Pacrfic Colporatron - Google Maps littpsIhvwwgoogic conllnlaps/plan/Louisiana- I'm iic+Corporation/ a36 198634,-81 02944 wa US 421 N slana Pacific Corporation 0 17 min � r � �a �� 1997 n GRoaY'n9 _i er ' L S h _ j� S 231 D� f i xlah , �'- ' l I7j\ Annoc ��i�i n7in1471'Ij 1 � x314 NCalarioe J� uldu s h21 —Ord U s 47j J71 1 UItlU$1g21�� i r1Jd �J of 1 6/1/2015 12 35 I'M z�c Ga ANK 2-2Ct Gn.5 F F,.. ')IL TANKS - E� ;_ovERE❑ N,ND CON'AIN�i '. AND tic..- N vSE OUTFALL SWO03 !� Drainage Area: 45.6 acres s u- RvAd= c tJ OUTFALL SWO01 Impervious Area: 15.2 acres A00w CAL TANK TQRM WA ER �.: _ , Drainage Area: 17.8 acres Percentage of Impervious Area: 33% c._ ati .�F- rr �: _ o LLs "• a _ r a- R s�5 ru 1 impervious Area: 7.0 acres AND NO- IN LtSE} o L 0 K. =01v I J Percentage of Impervious Area: 39 /0 1 �1TTdr�..'i'�erV! TC'-+GEAR uAr Are: .... wER uce SWO01 SEDIMENT . El".\vA" .. c \ ad TOWER �� (REFER T0, FIGURE2B FOR DETAILS) v �I LZ L1 L2 i1+6nC` Y•�drait�3At{! ClL' - FENCE _ TFRLL 7 000 T _ - BULK GE 0 _.. .. c�u i N� hUC: ,( 5WOQ3 SPiL C6NTAIr�ENT BASIN BULK LP � ! 211�3. , swa�I (REFER TO CURE 2A FOR DETAILS) TANK ! ! ! slANL A_. UR NG & ^.N'SI_ v AREA HIP V LL LINE r I i a � ! L4 , SPILL 1MfERCFPr i PDsxr f CONCR rr -LINE S ! CAUSTIC TANK 15K GAL % ��►• r: Ss_'JDvE BASN `, ! ALUM TANK 15K GAL :!4 / 2 G��U 1 ! (ENCLOSED) COVER® TRASH / cr ` I COMPACTOR IPi I v�ArE� , 5 HA3,�Vqn r H LP BOTTLE I� �ra�n Y M STORAGE r aC ysa 2 u FORK UFTS rR t 'E. (COVERED) �{ r YU R' crOr�� E R ECYCLEPAPER �r �liti[bn FUEL I NL6 G� GER CORP. EEC �"- TO SWOOi SEDIMENT BAS1.I _ Ls) s BEN ......... O1M5 (REFER ILi EIGi RE 2A bT VEH MT. �'-6 w �F3E�� C�; Et;nD N3 (RA CARS, FOR DETAILS) j Ss �" r SYS` �n w v. ;Rau_ - POINT SLUDGE HANUL� �y WA•CC�TA Nr�tN' (VAC AREA TREATMENT _ GNU— �«s 4C4SA4 F7 NR (3 'D AIN i 6 V j Q TOR (OWS) v .�/ WAS, . ti,E� . A SPILL INTERCEPT POINT i UTL ET ` T` TO wwrP " C C K E D 1r gj ti ow A . (VALVE) ORA;,E L9q 6 _ _..,_.... C vALl1E ka.. / b PRiwfARr DAF/EC S os DAF , FARE WA ER MP OUTFALLSWO OuSE _.�� 5EL TAjtJ�`4�f FELRRECLAIM (cotirAl END O AREA wavJ....rcR BARK TRU pip �_ SPILL BASIN PHOSPHORIC ACID � � NO. 1 AREA A, BWAR HYD C TANKS (ONE EM AREA CONTAINMENT AERA€10N SASx, RA 4 5VA'•r_R , AERA"-CN SASIN NO. 2 BASN - NO. 1 O BJLK TANKER UNLOADING ARL _�_ _��.. {REFER TO FIGUR 4 >,OR SANfT ATER �� UDGE PUMP f DETAILS) PACKAGE AQUA AMMONIA AASr=wArE-lz HOUSE (ABavr —GRID D) TAWSs SP:I_L 9ASI L: (CONTAINED)�• ( ) , 0- OPEN SFORIMNATER CONVEYANCE (CONCRETE NQ ...._... _ .._�.._...... ..- VCR CI-i OR SWALt CON ��----+--- DIED R0'JP;D �TQRA6'VAT R SLUDGE (CONTAINED) P HOUSE OUTFACE 5Wflfl2 _ — — _ 2nTEc ,RoJNo S RFac: SECONDARY [� Drainage Area: 27.3 acres ;),A N/CATC,4 BASIN CLARIFIER ° Impervious Area: 9.8 acres Percentage of Impervious Area: 36% ,n LOUISIANA-PACIFIC CORPORATION WAI UM rlAlrr /� A A rti1s GR�NT S TIE areo�ER Or LaUiS,"A RACr,c QRRORA"ON i pY111pm 01lIIM„t„ lu ll /dA i IR DRAIKM 6 0-0 IT ,s CCWOENTwt AN0 i5 TC e 5 O'-. .R 112 EXPRIFSS P RPOS: $ 11 • 1w jr� rOR W�^'C' IT :S LCA,tr..^ AN S_OJLP 6E kr.uRNED vFON REOVESr i iN'om I IR OIM �! R ErAIRTR ■romm EI�O.: s Ncir Tc; BE RCIPROOUCEa N AN' roan � 1 1 1m OL � ■!0� ■' {ems �7 MA �M G400IS/a#7a.. PC//;a n/CCY 2163ss' a Jan '09 3 May'09 r. Sept O� ,, Jan '10 4 Apr'10 G July'10 3 Oct'10 S 2 Nov'10 Dec'10 Jan '11 f6 Feb-11 4- Mar-11 ? 3 Apr-11 4 Jul-11 G Aug-11 S Sep-11 6 Oct-11 2 Nov-11 9 4 Dec'11 3 Jan '12 b Feb ' 12 S Mar'12 S Apr'12 May'12 3 July'12 pH OF 1 OF 2 OF 3 733 749 731 651 646 617 809 759 739 777 751 751 834 8041 824 6 37 , _ 629 698 688 725 704 711 71 776 749 844 648 645 636 72 72 691 61 684 68 568 619 624 602 649 656 661 607 649 627 648 613 624 567 697 658 665 56 698 594 72 852 745 691 n 713 706 715 629 655 634 693 651 626 674 6421 695 -MO _TS5_ _ 102,� L_ OF 1 OF 2 OF 3 56 118 80 112 28 192 750 v 104 186 230 236 58 100 122 70 24 94 22 4 400 ✓ 40 25 40 15 136 1042.E 172 500 ✓ 820 198 79 770 v 102 44 108 50 246 272 676 v 164 189 606 46 410 ✓ 732 ✓ 44 4 55 44 40 254 36 136 38 50 32 14 36 L 92 150 144 136 362 v 126 90 3$ 136 352 ✓ 2040 o, 1778 ,� 25 D 22 z z4 Data Coun 24 21 23 6 rz z4 16 2[ 8fZ3 I! �llz�a�rn�, �� 3�,/� r/761csDG6r� JJI r,C00 7�i�. ? r'r 9gerrr� 1✓1a COD_ V20 M:3? L OF1 U l a 3 158 159 153 420 ✓ 67 70 397 ✓ 326 ✓ 292 80 128 273 133 167 187 237 148 165 146 0 163 84 22 50 82 110 216 245 479 ✓ 642 ✓ 287 66 311 ,i 198 77 66 124 105 602 155 160 210 196 251 124 521 ✓ 704 ✓ 121 125 46 171 75 290 67 154 48 171 114 58 222 151 168 81 182 152 82 105 81 110 253 a W 2 a Cop 2 1 ,2O/O- D'o9 r 7SS . eC'D�, T c?r 2 May 09�-Ir TSS' 20/0 ;for T.S'S} ✓ 09 �r CQf�/>7a��i%y .sin? 25 22 23 f5 S I 2z I Z Fti7�14-pair; �z'46/7p w/ T55 -) r3 7�1 C \Documents and Settings\ken_pickle DWQILocal Settings\Temporary Internet Files\Content Outlook\RIMW12TO\Stormwater Monitoring Event Data 2010 2012 xls pH OF 1 OF 2 OF 3 Jan 09 May 09 Sept '09 Jan '10 Apr '10 July'10 Oct' 10 Nov' 10 Dec' 10 Jan 11 Feb-11 Mar-11 Apr-11 Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec'11 Jan'12 Feb '12 Mar'12 Apr'12 May'12 July'12 733 749 731 651 646 617 809 759 739 777 751 751 834 804 824 637 629 698 688 725 704 711 71 776 749 844 648 645 636 72 72 691 61 684 68 568 619 624 602 649 656 661 607 649 627 648 613 624 567 697 658 665 56 698 594 72 852 745 691 713 706 715 6 29 655 634 693 65 626 6 74 6 42 695 TSS OF 1 OF 2 OF 3 56 118 80 112 28 192 750 104 186 230 236 58 100 122 70 24 94 22 4 400 40 25 40 15 136 1042 172 500 820 198 79 770 102 44 108 50 246 272 676 164 189 606 46 410 732 44 4 55 44 40 254 36 136 38 50 32 14 36 92 150 144 136 362 126 90 38 136 352 Data Coun 24 21 23 2040 1778 COD OF 1 OF 2 OF 3 158 159 153 420 67 70 397 326 292 80 128 273 133 167 187 237 148 165 146 0 163 84 22 50 82 110 216 245 479 642 287 66 311 198 77 66 124 105 602 155 160 210 196 251 124 521 704 121 125 46 171 75 290 67 154 48 171 114 58 222 151 168 81 182 152 82 105 81 110 253 25 22 23 3 W 2 a C \Documents and Settings\Bethany_Georgoulias\Local Settings\Temporary Internet Files\Content Outlook\IJDT2TXI\Stormwater Monitoring Event Data 2010-2012 As Page 1 of 4 i Study sheet Louisiana Pacific Roaring River possible further responses to Tier 3 status 9/13/2012 kbp, bg Background information a Louisiana Pacific, Roaring River, NC NCG210355 b TSS, COD benchmarks routinely exceeded pH benchmark not an issue c LP has a dry detention settling basin on outfall #001, no controls at all on #002, dry detention on #003 Even in subdrainage areas with controls (#001 and #003), some portion of the normal rainfall flows bypasses the controls Data analysis from the three outfalls suggests that the stormwater controls are grossly inadequate for the conditions d Monthly monitoring instituted by WSRO around Oct 2010, yielding partial results from 25 sampling events from Jan 2009 through July 2012 e LP will soon begin sampling a previously unidentified fourth outfall Comparatively low risk industrial activities, apparently, are planned for this new subdrainage area f Purpose of this review WSRO has invited SPU consultation on what is a difficult set of circumstances This review is intended to outline possible paths for regulatory action at LP under NCG21 2 Data analysis a pH 4 pH exceedances out of 71 measurements By inspection, conclude that pH is not a priority issue at this facility No more consideration of pH in this review b TSS 1 36 TSS exceedances out of 68 measurements Benchmark of 100 mg/L n Exceedances range from 102 mg/L to 1042 mg/L, averaging 316 mg/L The values below the benchmark averaged 46 5 mg/L Aggregate data averaged 189 mg/L ni Outfalls #001 had 12/24 exceedances, #002 had 16/21 exceedances, #003 had 8/23 exceedances c COD i 46 COD exceedances out of 70 measurements Benchmark of 120 mg/L n Exceedances range from 121 mg/L to 704 mg/L, averaging 244 mg/L Values below benchmark averaged 73 mg/L Aggregate data averaged 185 mg/L ni Outfalls #001 had 15/25 exceedances, #002 had 14/22 exceedances, #003 had 17/23 exceedances d Correlation of COD and TSS Observe that 9 of the 12 TSS exceedances at #001 coincided with COD exceedances at that outfall, 11 of the 14 COD exceedances at #002 coincided with TSS exceedances at that outfall, 8 of the 8 TSS exceedances at #003 coincided with COD exceedances at that outfall Interpret good correlation between COD and TSS exceedances suggests common source, and raises the possibility that effective measures to control one parameter might control a significant portion of the other e Conclusions of data review Exceptionally good data set compared to what most stormwater permittees are able to accumulate In response to performance problems (1) Unlikely that continued monthly monitoring without site changes has much benefit Monthly monitoning may be beneficial to quickly evaluate subsequent site chances, if site changes are implemented (2) Benchmark exceedances are not 'occasional; 'infrequent, or 'flukes , and establish a lack of effective control by the plant stormwater control systems It seems probable that the original stormwater control design has been Inadequate from the beginning Probably fruitless to pursue the question, "What in the world did you use as a design basis/design objective for 4 Page 2 of 4 your stormwater control system? It could not possibly have been compliance with your stormwater permit " 3 Significance concerns a Impacts the Yadkin River is the receiving water, and provides substantial dilution for stormwater flows In -stream impacts may be minimal - this recognition should figure Into our actions, but should not work to eliminate meaningful progress In water quality protection by LP b Costs So far, LP has essentially spent nothing to improve pollutant removal from the stormwater discharges However, construction costs in a densely developed industrial site can be large It seems an approach that focuses on doing the cheap stuff first, and then seeing what works, might be the approach favored by LP However, LP must be made to understand that they are going to have to spend money on addressing their egregious performance to date c Permit requirements We're talking about benchmarks not limits, ie these exceedances are not permit violations, but still, industries are obligated to keep their pollutants on their sites & not discharge them into NC waters, d LP will want to know how we will identify the endpoint of any forward path involving construction of an effective stormwater control system This is a 'significance' issue in the sense of understanding today the potential future costs they will incur as a result of pollutant control actions we require of them 4 DWQ objectives in these circumstances a Improve the protection of water quality beyond LP's current poor performance b Preserve the integrity of the permit requirements and the permitting program c Impose reasonable requirements, avoid unreasonable burdens on the permittee Be fair 5 Potential elements of the candidate paths forward for LP a Hire an environmental/civil engineer experienced in large scale industrial site projects to evaluate alternatives and to design new treatment practices Doubtful that this work can be accomplished in house by LP b Get a physical features and elevations survey of the whole plant site c Require better control of polluted discharges from LP d Require affirmative action from LP in pursuit of the control of stormwater pollutants e Require milestones & interim progress markers set by WSRO and reviewed/approved similar to a Compliance Order perspective f Allow for a protracted time frame where appropriate g Source reduction, if possible'? h More effective treatment --- any treatment at all would be an improvement in #002 i One outfall and its subdrainage area at a time might help spread out capital costs j DWQ administrative solutions should follow only after LP attempts at site management solutions and engineering solutions k Let LP choose the path forward via a mechanism of they propose a plan, and we approve the plan, and they execute the plan, and then confirm performance back to us 6 Synthesis of all of the above Apparent potential paths forward a Path la The trivial no action alternative Keep things as they are today, along with monthly sampling Reject out of hand Page 3 of 4 b Path 1b Another form of the trivial no action alternative Revert back to semi- annual sampling and keep things the way they are today Reject out of hand Neither of these two alternatives addresses the problem of polluted discharges c Path 2 A first pass outfall by outfall plan focused on a treatment approach rather than a source reduction approach, subsequent confirmation sampling to determine which outfalls require a second pass i Set up flow measurement devices on all three outfalls to characterize the flow rate and volume as a design basis input parameter for the following structural measures Obtain a physical features and elevations survey of the site and the stormwater system ii Outfall #001 Smallest of the three drainage areas with only 17 8A and only 7A impervious Engineering solution approach No significant extra land available Convert existing dry detention basin into gross solids settling basin paired with a wet well for stormwater pumps to convey flow to either of the treatment measures to be constructed in #002 or #003 Re -work the creek piping to segregate that flow from the contaminated stormwater flow as much as possible in Outfall #002 Site management and engineering solution approach Portions of the approx 5 5A gravel parking lot to be made available for treatment measures, finished product lay down area to be re -configured to accommodate the treatment measures Note that the main discharge line from #002 is —20' deep at the sampling manhole, but the endpoint is 20' above the river according to site personnel This means that at some point along its run, it is at grade We did not see the run of the pipe down to the aver well enough to know for sure that existing topo can be modified to accommodate this approach LP to hire a civil engineer to Investigate the feasibility of this approach iv Outfall #003 Primarily and engineering solution approach Engineer to re -design the dry detention basin Instead of one large basin, reconfigure into a treatment train, with pretreatment settling for gross solids removal, followed by vegetated or wet detention treatment If a third unit will fit in the train, consider vegetated or infiltration with underdrain collection practices Approximately 2A of land is readily available Evaluate going back up the pipe and segregating the stormwater flows from the creek flow on the north half of the property Rework of the spill containment basin may be required depending on the details of the connections Evaluate localized containment of the boiler fuel storage area v Outfall #004, new Act now to prevent the perverse action of piping the creek under the plant and dumping contaminated flows into it underground vi This scheme is subject to modification of the details, and the determination that portions of it are infeasible, based on site conditions or costs But, I don't see how LP can address this problem without some capital costs And I don't see how we can administratively let them off the hook for better performance that path might be interpreted as DWQ totally defaulting on our responsibility to pursue the protection of the waters of North Carolina vii DWQ posture We acknowledge the great dilution in the Yadkin by not pressing forward and requiring rigid observation of the benchmark values if LP will commit to installing BMPs to address the pollutants as far as is feasible Page 4 of 4 d Path 3 A hot spot source reduction approach that includes both site management and engineering solutions i Outfall #001 Direct wood chip storage pile drains into the WWTP rather than the #001 sediment basin Other portions of DA #001 continue through the sediment basin ii Outfall #002 for TSS - Pave the large gravel truck loading and finished product lay down area, For COD - direct wood chip storage pile drains to the WWTP, rather than to the stormwater outfall in Outfall #003 Direct boiler fuel storage areas into the WWTP Spill Basins #1 and #2, and bleed through the WWTP Or dig a new basin adjacent to WWTP Spill Basins #1 & 2 Other portions of #003 continue through the current dry detention basin iv Difficulties with this approach include opening up the wastewater permit for modifications According to WSRO, a difficult approach Further, LP reports that the facility is near capacity as is (but not completely at capacity - I guess it may be a question of how much more would this approach add, and how much more can the WWTP take ) e Path 4 -?? f Path 5 - 777 END