NC0005266_permit issuance_20070924

NPDES DOCUWENT SCANNIMS COVER SNEET
NPDES Permit:
NC0005266
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Staff Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 24, 2007
This document is printed o m reuse paper - ignore nsiy
conternt on the reverse side

of W a rF9 _
t] �
Joseph R. Hoeflein, P.E.
Plant Environmental Manager
Louisiana-Pacific Corporation -Roaring River
P.O. Box 98
Roaring River, North Carolina 28669
Dear Mr. Hoeflein:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
September 24, 2007
Subject: Issuance of NPDES Permit NCO05266
LP Corporation -Roaring River WWI?
Wilkes County
Division personnel have reviewed and approved your application for renewal of the subject permit
Accordingly, we are forwarding the attached NPDES discharge 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 U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended).
This final permit includes no major changes from the draft permit sent to you on July 18, 2007.
If any parts, measttrement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this
letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be
required. If you have any questions concerning this pert, please contact Sergei Cherikov at telephone number
[phone], extension 594.
Sincerely, �
Coleen H. Sullins
cc: VPDES Files
Winston-Salem Regional Office / Surface Water Protection
Roosevelt Childress, EPA Region IV
Aquatic Toxicology Unit
N. C. Division of Water Quality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center. 1 800 623-7748

Permit NC0005266
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North'Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Water Quality
Commission, and the Federal Water Pollution Control Act, as amended,
Louisiana Pacific Corporation `
is hereby authorized to discharge wastewater from a facility located at the
LP Roaring River Plant
Off NC Highway 268
West of Roaring River
Wilkes County
to receiving waters designated as the Yadldn River in the Yadkin River Basin in accordance with the
discharge limitations, monitoring requirements, and other conditions set forth in Parts I, II, III; and
IV hereof.
This permit shall become effective November 1, 2007.
This permit and the authorization to discharge shall expire at midnight on September 30, 2008.
Signed this day September 24, 2007.
s �
toleen H. Sullins, Director
Division of Water' Quality
By the Authority of the Environmental Management Commission

r.
Permit NC00052g6
v
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge, are hereby
revoked. [The exclusive authority to operate this facility arises under this permit. The authority
to operate the facility under previously issued permits bearing this number is no longer effective.]
The conditions,. requirements, terms and provisions of this permit authorizing discharge under
the NPDES govern discharges from this facility.
Louisiana Pacific Corporation
Roaring River Wastewater Treatment Plant
is hereby authorized to:
1. Continue to operate .a combined wastewater treatment system consisting of: .
➢ 0.03 MGD extended aeration package ' plant with sludge holding tank for
treatment of sanitary wastes
➢ 2.0 MGD industrial waste treatment system with the following components:
• Bar screen and/or in -line grinder
• Influent pump station
• Primary clarifier
• Dissolved air flotation unit
• Pumps
• Sludge holding and mixing tank
• Sludge thickener
• Solids dewatering system consisting of two "Sn roll filter presses & conveyor system
• Two aeration lagoons
• Nutrient addition system
• Secondary clarifier
• Two emergency primary settling basins
• Effluent mixing box
This facility is located at Louisiana Pacific's facility in Roaring River, located
off NC Highway 268 west of Roaring River in Wilkes County.
2. Discharge from said treatment works at the location specified on the attached
map into the Yadkin River, currently classified C waters in the Yadkin -Pee
Dee River Basin.

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Longitude: 81001'5T
Quad#: C14NE
Stream Class: C
Receiving Stream: Yadkin River
Permitted Flow: 1 to 1.5 MGD
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Longitude: 81001'5T
Quad#: C14NE
Stream Class: C
Receiving Stream: Yadkin River
Permitted Flow: 1 to 1.5 MGD

Permit NC0005266
A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from Outfall 001 (combined process and sanitary wastewater).
Such discharges shall be limited and monitored by the Permittee as specified below:
PARAMETER
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Sample
Type
Sample
Locationl
Flow
2.0 MGD
TWeekly
Recording
Influent or
Effluent
BOD-5, 20oC
11,873 pounds/day
22,747 pounds/dayComposite
Effluent
Total Suspended Solids
12,000 pounds/day18,000
pounds/dayComposite
Effluent
Total Phenolics
Grab
Effluent
Total Residual Chlorine
Monthly
Grab
Effluent
COD
3Meek
Composite
Effluent
Temperature
Daily
Grab
Effluent
Temperature
3/Week
See Footnote 1
Grab
U, 1)(1), D(2)
Dissolved Oxygen
Daily
Grab
Effluent
Dissolved Oxygen
3/Week
See Footnote 1
Grab
U, D(1), D(2)
Conductivity
Daily
Grab
Effluent
Conductivity
3Meek
See Footnote 1
Grab
U, D(1), D(2)
Settleable Solids
Daily
Grab
Effluent
Total Nitrogen
(NO2 + NO3 + TKN
Monthly
Composite
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Chronic Toxicity 2
Quarterly
Composite
Effluent
Boron
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
H
>6 and <9 standard units
Daily
Grab
Effluent
Notes:
1. U: upstream at least 100 feet above the outfall. D: downstream (1) approximately 1.7 miles at
NCSR 2327 and (2) approximately 8 miles at NCSR 2303. Instream samples shall grab samples
and shall be conducted three times per week during June, July, August, and September and
weekly during the remaining months of the year.
Instream monitoring is provisionally waived in light of the permittee's participation in the
Yadkin - Pee Dee River Basin Association. Instream monitoring shall be conducted as
stated in this permit should the permittee end its participation in the Association.
2. Chronic Toxicity (Ceriodaphnia) P/F at 1.3%; January, April, July, and October [see Condition A.
(3)]•
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0005266
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (002)
During the period beginning upon expansion above 1.0 MGD (for Outfall 001, which will include
reconfiguration of the sanitary wastewater) and lasting until expiration, the Permittee is authorized
to discharge from internal Outfall 002 (sanitary wastewater) into the junction box for Outfall 001.
Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Daily
Measurement
Sample
Sample
Average
Maximum
Frequency
a
Location
Flow
0.03 MGD
Instantaneous
Influent or
Effluent
BOD-5, 20°C
30.0 (mg/L)
45.0 (mg/L)
Quarterly
Grab
Effluent
Total Suspended
30.0 (mg/L)
45.0 (mg/L)
Quarterly
Grab
Effluent
Solids
pH
>6 and <9 standard units
Quarterly
I Grab
IEffluent
Notes:
1. Effluent = prior to mixing with any other wastestream.
Although minimal monitoring is stipulated through this outfall, the permittee is required, through
proper operation and maintenance, to meet minimum secondary treatment levels for sanitary
wastewater. Should inspection sampling results indicate levels of BOD5 or TSS over the amounts
specified above, enforcement action may be initiated against the permittee.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (3) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of: 1.3% at 2.0 MGD
The permit holder shall perform at a minimum, auarterlu monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998,
or subsequent versions or `North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of
January, April, July, and October. Effluent sampling for this testing shall be performed at the
NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum,
in each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.

Permit NC0005266
A. (3) CHRONIC TOXICITY PERMIT LIMIT (Quarterly), continued
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ
Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no
later than 30.days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and
all concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed -for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Environmental Sciences Branch at the address cited above. . .
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division' of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate environmental
controls, shall constitute an invalid test and will require immediate follow-up testing to be completed
no later than the last day of the month following the month of the initial monitoring.
A. (4) OVERFLOW REPORTING
Any bypass of the measuring box or overflow from the cut in the mixing box should be reported to the
Regional Office within 24 hours.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0005266, Louisiana-Pacific Corporation
Roaring River Plant
Facility Information
Applicant Facility Name:
Louisiana-Pacific Corporation Roaring River Plant
Applicant Address:
P.O. Box 98 Roaring River, NC 28669
Facility Address:
Off of Hwy. 268, West of Roaring River
Permitted Flow
1.5 MGD (current)
2.0 MGD (requested expansion of flow)
Type of Waste:
97% Industrial 3% Domestic
Facility/ Permit Status:
I Major modification - modification to include additional flow
County:
Wilkes
Miscellaneous
Receiving Stream:
Yadkin River
Regional Office:
WSRO
Stream Classification:
C
Quad
C14NE, Roaring River
303 d Listed?:
No
Permit Writer:
Ser ei Chernikov
Subbasin:
030701(Yadkin)
Date:
June 22, 2007
Drainage Area mil :
610
Summer 7 10 cfs
228
30Q2 (cfs):
Average Flow cfs :
976
IWC (%):
1.0 %
(at 1.5 MGD)
1.3%
at 2.0 MGD
Prima SIC Code:
2493
SUMMARY
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. This plant used to manufacture both smooth one-sided hardboard and fiber
cement board (the processing plants are located adjacent to each other). After LP acquired the
plant, it sold the fiber cement board manufacturing portion. However, the fiber cement
manufacturer (now held by Certainteed) discharges its contact cooling water to LP's intake
impoundment.
Recently, LP has applied for a minor modification of the permit to accommodate changes in the
manufacturing process that will introduce Zinc and Boron into wastewater. As a result,
quarterly monitoring for Zn and B was added to the permit on 02/ 12/2007.
This major modification request is submitted due to the need to accommodate a new wet
scrubber blowdown stream. LP has requested an increase in flow from 1.5 MGD to 2.0 MGD.
The facility is not requesting any increase in loading or limits (limits will remain the same, with
the exception of toxicity testing percentage and flow). Various water conservation efforts have
been made at the plant over the years, but current conditions require installation of the wet
scrubber to comply with National Emission Standards for Hazardous Air Pollutants. The mill
will comply with the Maximum Ahievable Control Technology Requirements (MACT) by
removing hazardous air pollutants (HAPs) in a new scrubber at the mill's digesters. The use of
this scrubber can create and additional 0.5 MGD of wastewater flow that contain HAPs,
primarily methanol. The HAPs contained in this flow will be effectively removed by
biodegradation in the aeration basin at the mill's wastewater treatment plant (WWTP). The
LP Corporation Roaring River NC0005266
NPDES Renewal & Modification
Page 1

scrubber blowdown stream will be conveyed directly to the aeration basin in a "hard pipe"
configuration that does not allow loss of HAPs to the atmosphere. The hard pipe will discharge
the new wastewater source below the surface of the aeration basin for immediate mixing and
contact with the biomass in the treatment process. The organic content of the constituents
removed in the scrubber effluent will increase the current BOD loading to the WWTP by only
3%. No changes to the WWTP will be necessary to accommodate this new wastestream.
The current treatment system consists of a lift station for process flow (approximately 0.9028
MGD, 97% of the total flow), flow meter, spill diversion/2 spill ponds, primary clarifier, influent
mixing box, aerated lagoon, secondary clarifier, backup lagoon, effluent mixing box, effluent
flow meter/ sampling, DAF for residuals handling, residuals dewatering presses (land disposal
of residuals). A sanitary package plant handles approximately 0.03 MGD of flow (3% of total
flow). Effluent from the sanitary plant is routed to the aerated lagoon. The existing primary
clarifier has been converted to equalization and a primary DAF unit was added. The sanitary
effluent flow has been diverted to the effluent mixing box (taken out of the aerated lagoon).
Both sanitary and process wastewater streams will be mixed prior to effluent sampling and flow
measurement.
An Engineering Alternatives Analysis was performed and discharge was found to be the most
feasible option for the additional 0.5 MGD of -wastewater flow. The Division of Water Quality
determined that the incremental impact of the increased wastewater flow would not result in
contravention of applicable, water quality standards or loss of the river's designated uses, so
that expansion of the existing treatment plant and continued discharge to the Yadkin River is
the most feasible alternative.
TOXICITY TESTING:
Current Requirement: Chronic P/F at 1.0%, January, April, July, October
Proposed Requirement: Chronic P/F at 1.3%, January, April, July, October.
The facility has been consistently meeting the permit WET limit with one exception. WET
failure occurred in January 2007, subsequent tests passed (see attached).
COMPLIANCE SUMMARY: BASED ON THE PREVIOUS 3 YEARS
There are no outstanding and/or chronic compliance problems related to the NPDES permit.
The Compliance Evaluation Inspection conducted on 4/ 10/2007 was satisfactory with some
areas rated as excellent.
INSTREAM MONITORING:
LP is not required to perform instream monitoring due to its participation in the Yadkin -Pee
Dee River Basin Association. The Association sampling points are on the Yadkin River at
Business Hwy. 421 (upstream of the discharge) and on the Yadkin River at Clingman Road near
Ronda (downstream of the discharge). Review of the coalition data did not indicate obvious
impacts. It is difficult to assess the effect of the discharge on the Yadkin River, especially due to
the high dilution.
PROPOSED CHANGES:
As discussed previously, LP has requested an increase in flow (to 2.0 MGD), but no increase in
load limits. The load limits in this proposed draft permit are well below effluent guideline -
based limits based on current production. The BOD5 and TSS limits will remain the same.
At the request of the Regional Office a special condition was added that requires any bypass of
the measuring box or overflow from the cut in the mixing box should be reportable to the
Regional Office within 24 hours.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: July 3, 2007 (est.)
Permit Scheduled to Issue: August 27, 2007 (est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Sergei Chernikov at [phone] ext. 594.
LP Corporation Roaring River NC0005266
NPDES Renewal & Modification
Page 2

NOTES FOR APPLICATION OF GUIDELINES:
40 CFR 429 TIMBER PRODUCTS PROCESSING POINT SOURCE CATEGORY
(SUBPART E WET PROCESS HARDBOARD SUBCATEGORY, 429.611
This facility falls under Subpart E - Wet Process Hardboard Subcategory, Smooth One -Sided (S1 S)
The parameters and calculated limits presented here are for comparison purposes only. The current
limits are more restrictive than* the guidelines project. The existing limits were based on a negotiated
settlement in 1995. The facility had a history of high effluent solids, which contributed to degradation of
the downstream habitat of the Yadkin River. Significant improvements were made at the plant and this
portion of the Yadkin River is now benthically rated as Good/Fair.
Parameter
Daily max,
m/l
Monthly avg.,
m/1
BOD5
20.5
10.7
TSS
37.3
24.6
PH
6-9 SU
Average production:
1579.57 lbs/ 1000 lbs gross product
Parameter
Daily max,
Lbs/da
Monthly avg.,
Lbs/da
BOD5
32,381
15,796
TSS
58,918
38,857
PH
6-9 SU
LP Corporation Roaring River NC0005266
NPDES Renewal & Modification
Page 4

July 5, 2007
MEMORANDUM
TO: Sergei Chernikov, Ph.D.
NPDES Unit
FROM: George Smith, WSRO
SUBJECT: Louisiana Pacific Corporation — Plant Expansion to 2.0 MGD
NPDES Permit No. NC0005266
Wilkes County
As requested, the following comments and/or recommendations are offered:
In the permit on the "Supplement to Permit Cover Page" it shows: Effluent mixing box (Outfall
001). Outfall 001 should be removed from this treatment component for the following
reasons:
The Effluent Mixing Box is located prior to the effluent flow device. The flow device is
an electromagnetic flow meter used for reporting flow, and for calculating the mass based
limits in the permit.
2. This office interprets Outfall 001 as the pipe and diffuser located in the center of the
channel in the Yadkin River.
During a compliance evaluation inspection performed on November 6, 2003 the effluent mixing
box was illegally discharging -effluent through a channel cut in the top of the wall of the effluent
mixing box. The effluent was discharging onto the ground, thereby, bypassing the effluent flow
meter. It is possible that the effluent mixing box may not be able to contain a permitted flow of
2.0 MGD.
Conclusion
➢ Recommend that Outfall 001 be defined as the pipe and diffuser in the Yadkin River.
➢ The effluent mixing box should not be described as Outfall 001.
➢ Recommend that LP Corporation modify the effluent mixing box, which would include a
safety margin, that it will only discharge through Outfall 001 (outfall 001 defined by this
office).
If you have any questions please contact George Smith at 336-771-4968.
cc: WSRO Files

iniap://sergei.chernikovO/AOdwq.denr. [e-mail]:993/...
Subject: Re: U nixing box
` From: Steve Tedder 6teve.TeddaQnareilnct>
Date: Wed, 11 Jut 2W710:08:36-0400
To: George Smith <Garge. Smith@rnm®il mV, Sean Ohcmdsav <SeBei.Chemkovgncnail.oct>
Sergei,
1 understand then logic for having the emngenry chamal cut tM do not disagree with their logic, I do however think that any bypass of the measuring box or overflow from the cut from the nixing box should be
reponable to the Regional Office within 24 hours. I believe we allowed them to increase the capacity fimn 1.0 MGD to 2 0 MGD using the same W WTP deign some tors: back and the monitoring 1 am suggesting
will just verify that that decision was sound.
Tedder
On 7/I InW79.21 AM, George Smith wrote.
Sergel,
Attached you will find a picture of the effluent nixing box and the chattel cut ix the wall.
Per our discussion, Steve fah that any discharge from the charnel cut in the effluent nixing box most be reporced to DWQ. Pkue add this as a condition in the permit.
Thanks,
GroBe
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Steve Tedder 4 Lev Tcddm4�N( nixl
NC� R
2of2 7/11/2007 10:17 AM

1� imap://[e-mail]:993/...
Subject: re LP Corp, NC0005266
From: [e-mail]
Date: Mon, 30 Jul 2007 13:46:26 -0400
To: [e-mail]
EPA will not be reviewing this draft permit because it does not
discharge to a 303(d) listed stream and there is no TMDL.
1 of 1 7/30/2007 1:54 PM

imap://sergei. [e-mail]:993/...
Subject: Draft NPDES Permit
From: "Joe Hoeflein" <[e-mail]>
Date: Wed, 25 Jul 2007 05:06:51 -0700
To: [e-mail]
I reviewed the draft permit, dated 7/18/07, and we have no comments. Please note the spelling of my last
name for the cover letter. I really appreciate the quick response to our request for a modification and your
assistance with this effort. Thank you.
Joe Hoeflein, PE
Plant Environmental Manager
Louisiana-Pacific Corporation
Roaring River, NC I.
[phone] Office
[phone] Fax
[phone] Cell
1 of 1 7/25/2007 12:57 PM

PUBLIC NOTICE
STATE OF NORTH rAR
SUE A NPDES WASTEWATER
PERMIT
On the basis of thorough staff re-
view and application of N.C. Gen-
eral Statute 143.21, Public law 92-
500 and other lawful standards and
regulations, the North Carolina Envi-
ronmental Management Commis-
sion proposes to issue a National
Pollutant Discharge Elimination
System (NPDES) wastewater dis-
charge permit to the person(s) listed
below effective 45 days from the
publish date of this notice.
Written comments regarding the
proposed permit will be accepted
until 30 days after the publish date
of this notice. All comments re-
ceived prior to that date are con-
sidered in the final determinations
regarding the proposed permit. The
Director of the N.C. Division of Wa-
ter Quality may decide to hold a
public meeting for the proposed
permit should the Division receive a
significant degree of public interest.
Copies of the draft permit and
other supporting information on file
used to determine conditions
present in the draft permit are
available upon request and payment
of the costs of reproduction. Mail
comments and/or requests for
information to the N.C. Division of
Water Quality at the above address
or call Ms. Frances Candelada (919)
733-5083, extension 520 at the
Point Source Branch. Please
include the NPDES permit number
(attached) in any communication.
Interested persons may also visit
the Division of Water Quality at 512
N. Salisbury Street, Raleigh, N.C.
27604-1148 between the hours of
8:00 a.m. and 5:00 p.m., to review
information on file.
Louisiana Pacific Corporation -
Roaring River Plant, P.O. Box 98,
Roaring River, North Carolina
28669, has applied for modification
of its NPDES permit (NCo005266).
The modification includes an
expansion of flow from 1.5 MGD to
2.0 MGD with a continued discharge
of treated sanitary and industrial
wastewater to the Yadkin River in
the Yadkin Pee -Dee River Basin.
There will be no increase in
pollutant loadings. No parameters
are currently water quality limited,
however, this discharge may affect
future discharges in this portion of
the Yadkin River Basin.
7-20-lt(F)
Publisher's Affidavit
State of North Carolina, Wilkes County.
Personally appeared before me the Undersigned JULIUS C. HUBBARD, JR.
and/or JOHN W. HUBBARD Co -Publishers of WILKES JOURNAL-
PATRIOT,
a public newspaper of general circulation, printed and published in North
Wilkesboro, in the county aforesaid who, being duly swom, upon his oath, sayeth
that the notice of which the attached is a true copy, was duly published in said
paper for �_ insertions successively, the first of which publication
was on the day of 20L and the
last on the day of 20
D. MGD`
+3.t
(J(� ,, ^_1,_n_ Co -Publisher of Wilkkes, Joumal-Patriot
Subscribed and swom to before me �4�C�f�(X l y) ) lL 20�
YDieC.4Q,P EM-AJ Public
My Commission expires my COMMISSI00 Bom 10413•2"

^ YLILIJUe,Aides S �� w�..�;J, / f
• SQL t +0 PQ� p �� July ,2Q07 �� 1 w''�ti z�l
o �, l
MEMORANDUM
+i
JUL 7 I J
TO: Sergei Chemikov, Ph.D.
NPDES Unit
DEAR--
Pofn; -J
FROM: George Smith, WSRO ,
SUBJECT: Louisiana Pacific Corporation — Plant Expansion to 2.0 MGD
NPDES Permit No. NC0005266
Wilkes County
As requested, the following comments and/or recommendations are offered:
In the permit on the "Supplement to Permit Cover Page" it shows: Effluent mixing box (Outfall
001). Outfall 001 should be removed from this treatment component for the following
reasons:
The Effluent Mixing Box is located prior to the effluent flow device. The flow device is
an electromagnetic flow meter used for reporting flow, and for calculating the mass based
limits in the permit.
2. This office interprets Outfall 001 as the pipe and diffuser located in the center of the
channel in the Yadkin River.
During a compliance evaluation inspection performed on November 6, 2003 the effluent mixing
box was illegally discharging effluent through a channel cut in the top of the wall of the effluent
mixing box. The effluent was discharging onto the ground, thereby, bypassing the effluent flow
meter. It is possible that the effluent mixing box may not be able to contain a permitted flow of
2.0 MGD.
Conclusion
➢ Recommend that Outfall 001 be defined as the pipe and diffuser in the Yadkin River.
➢ The effluent mixing box should not be described as Outfall 001.
➢ Recommend that LP Corporation modify the effluent mixing box, which would include a
safety margin, that it will only discharge through Outfall 001 (outfall 001 defined by this
office).
If you have any questions please contact George Smith at 336-771-4968.
cc: WSRO Files

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Normal Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
SURFACE WATER PROTECTION SECTION
PERMIT NAME/OWNERSHIP CHANGE FORM
I. Please enter the permit number for which the change is requested.
NPDES Permit
(or) Certificate of Coverage
N I C I D 1 o 1
1 N I C G
❑. Permit status prior to status change.
a. Permit issued to (company name):
i 5 �t n Q — Y uSi'r' ' ✓ d v�
b. Person legally responsible for permit:
Sa- I --eS tK • b \/ - 5
First / MI / Last
�QN J 1/- t0-...a
Title i
✓' a /'a 4 8
P t Holder Mailing Address
20a �,'nal r'✓e.,, /✓G o28G(`�
City State Zip
a7Si ( )
c. Facility name (discharge):
Phone Fax
Lemur S.'o�, t Q - ✓ —aCi �r G� �T+ �"^
d. Facility address:
�T/��6✓Ct.y o2� g
Address
�o�;,•nr 2 ✓e. , A/G
e. Facility contact person:
City State Zip
( 3 34 oZ 7-6
First / MI / Last Phone
III. Please provide the following for the requested change (revised permit).
a. Request for change is a result of:
If other please explain: /G/r
❑ Change in ownership of the facility
❑ Name change of the facility or owner
y �� ��' t �pg✓ L �'� C�/�* . + of G
b. Permit issued to (company name):
.��Xei S.cc-n Q' / G t� +—✓1 m J c�id�^
c. Person legally responsible for permit:
k.
First / MI / Last
�4 /r Title Q �p
i' •y. ] Bx' ( O
Permit Holder Mailing Address
city I State Zip
(33G) G?�- a7Si
d. Facility name (discharge):
Ph Za mail Address
-6 G
e. Facility address:q
tiJa ce o2G 8 ��
Address
e-e'
f. Facility contact person:
City T Sttaatee Zip
g164 `
First / MI / Last
(336 6'74, 3y/o oe. 4oe f/e,H 6
Phone Email 7rdaidress /'0 (�' o rnp e
Revised 72005

PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
IV. Permit contact information: (if different from the person legally responsible for the permit)
Permit contact:
First / MI / Last
Mailing Address
City State Zip
( )
Phone E-mail Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior to
this ownership or name change?
X Yes
❑ No (please explain)
VI. Requiredltems: THISAPPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE
INCOMPLETE OR MISSING:
❑ This completed application is required for both name change and/or ownership change 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 name change request, the signed Applicant's Certification
is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
I, LI ZVL4 e S �ar AJ i S attest that this application for a name/ownership
change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required
parts of this application are not completed and that if all required supporting information is not included, this
application package will be returned as incomplete.
y�< -- A
71FICATION:
nature ate
PLICANT CE QQ
I, �C t �• "Qar_✓ S attest that this application for a name/ownership
change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required
parts of this application are not completed and that if all required supporting information is not included, this
application package will be returned as incomplete.
7
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
Revised 7/2005

June 11, 2007
Sergei Chernikov,
NC DENR, Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
LP
BUILDING PRODUCTS
JUN 19 2DO7D
DENR - WATER QUALITY
POINT SOURCE BRANCH
Subject: Major NPDES Permit Modification — MACT Compliance
Louisiana-Pacific Corporation - Roaring River Facility
Permit No. NC0005266
Dear Sergei,
Enclosed with this letter are three copies of a permit application for future equipment related
to PCWP MACT compliance at the Louisiana-Pacific Roaring River hardboard mill. You
received.3 copies of the EAA related to this project and a check for $860 in January 2007.
As you know, our current permit will expire in September 2008. I'd like to request that this
application also serve as the renewal submittal which is due in March 2008.Our desire is to
receive a permit modification later this year which will allow us to discharge for another 5
years.
Please call me at [phone] or via email at joe.hoeflein(a),lpcorp.com if you have any
questions.
Sincerely,
Jose 7Hoeflein, P. .
Plant Environmental Manager
Attachments: Permit Applications
Copy: George Smith — NC DENR, Winston-Salem
ADDRESS P.O. Box 98
Roaring River, NC 28889
TEL [phone]
FAX [phone]
WEB w .Ipcorp.com

Drowin Name 180201.DWG Operator Name: H.W.C. Scale: 1'-1' Attached Xrefs: LAYOUT
0.65 MGD
EVAPORATIVE/PROCESS
LOSSES
(FUTURE)
MAC SCRUBBER
WELLS (FUTURE)
0.05 . MGD 0 0.5 MGD
MILL BLOWDOWN
1.492 MGD
PROCESS
WASTEWATER
8,000 gpd
PRIMARY
SANITARY TREATMENT
WWTP
CERTAINTEED I OUTFACE
STORAGE 002
0.1 MGD POND
RIVER INTAKE
FUTURE 2.5 MGD
CURRENT 2.0 MGD
ZINC
TREATMENT
SECONDARY
WWTP
CURRENT 1.5 MGD FIGURE 1
FUTURE 2.0 MGD PLANT WATER BALANCE SCHEMATIC
OUTFALL 001 LOUISIANA-PACIFIC CORP.
YADKIN ROARING RIVER, NC.
RIVER
owN. ay. H. CURINGTON
M" AUSTIN APPROVED BY: B.J.T.
DATE: 5 17 07
PROJ. 1 00-06998.02
nLE# 69980201

REASONABLE POTENTIAL ANALYSIS
LP Corporation -Roaring Gap
NC0005266
Time Period
0
Qw (MGD)
1.5
WWTP Class IV
7Q10S (cfs)
228
IWC (Y.) @ 7Q10S 1.0094
7Q10W (cfs)
310
@ 7Q10W 0.7444
30Q2 (cfs)
0
@ 30Q2 N/A
Avg. Stream Flow, QA (cfs)
976
@ QA 0.2377
Rec'ving Stream Yadkin River
Stream Class C
Outfall 001
Qw = 1.5 MGD
PARAMETER
TYPE
(�)
STANDARDS 8,
CRITERIA (2)
PQL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS/ Y FAV/
In # Det Max Pred Cw Allowable Cw
Chronic Acute
Acute: ; N/A
Boron
C
750
ug/L
6 6 308.7
Note: n<12
_
Chronic 315,589
Limited data set
Legend. " Freshwater Discharge
C = Carcinogenic
- NC = Non -carcinogenic
A =Aesthetic
5266-rpa-2007, rpa
1/29/2007

Awe Interoffice Memorandum
Date: January 18, 2007
To: Phil Sparks, Joe Hoeflein - LP
cc: Leo Tramm - RMT
From: Sam White, Ph., D. - RMT
Subject: Potential NPDES Permit Limit for Boron at Louisiana-Pacific Corporation's Roaring
River, NC Mill
During the January 11, 2007 meeting with Dr. Sergei Chernikov of the North Carolina Department of
Environment and Natural Resources (DENR), the potential for establishing an effluent limitation for
boron on the soon-to=be-modified National- Pollutant Discharge Elimination System (NPDES) permit was
discussed. It was stated that since the United States Environmental Protection Agency (USEPA) has
recommended a water quality criterion f 0.75 m /L or boron, based on protecting sensitive crops from
long-term irrigation, it is possible that a numerical limit for boron in the mill's effluent might be included.
in the permit.
When assessing whether or not a permit limit for boron is warranted, the DENR will calculate the
"reasonable potential" for the boron content of LP's effluent to violate the 0.75 mg/L water quality
criterion after mixing in the. Yadkin River. Dr. Chernikov noted that if he were to proceed, with the
limited data available to him at this time, it is likely that a limit would be seen as necessary.
The purpose of this memorandum is to retrieve and document additional data on boron that have
already been developed in previous studies and that can be used to support a finding of "no reasonable
potential" for boron to violate the water quality criterion.
The "No Reasonable'Potential" Calculation Procedure
The Technical Support Document for Water Quality -based Toxics Control (EPA/505/2-90=001, PB91-127415)
issued by USEPA outlines the procedures for assessing the reasonable potential of pollutants to exceed
water quality criteria. The statistical evaluation for "no reasonable potential" requires the following type
of information:
a. The number of data points in the set of effluent values available for the pollutant in question
b. Identification of the highest single value from that data set
c. The statistical coefficient of variation (i.e., the standard deviation divided by the mean value) for
the effluent data set
I:\WPGVL\PJr\00-06998\02\00007\M000699802-001.DCC 1/18/07

Interoffice Memorandum
d. The "multiplying factor" obtained. from either Table '3-1 or Table 3-2 on page 54 of the, USEPA
guidance document cited above. The multiplying factor value is driven by both the number of
data points available and the coefficient of variation derived from those data. A copy of the
tables from the guidance document is attached to this memorandum.
e. The dilution factor calculated from the ratio of Louisiana-Pacific Corporation's (LP) permitted
discharge rate and the appropriate flow rate of -the Yadkin River. Since the water quality
criterion is based on long-term irrigation; the average annual flow rate of the Yadkin River is the
appropriate flow rate for this calculation. The average annual flow rate in the Yadkin River is:
reported to be 630 million gallons per day (mgd) and LP's permitted discharge flow rate is 1.5
mgd. The dilution factor (DF) is calculated from the'following formula:
DF = (LP discharge) / (LP discharge + average annual flow)
DF = (1.5 mgd) / (1.5 mgd + 630 mgd) = 0.00238
With these data available, the following formula is used to calculate the maximum Receiving Water
Concentration (RWC).
RWC = (maximum observed value) x (multiplying factor) x (dilution factor).
If the calculated maximum RWC does not exceed the'EPA water quality criterion, then it is -concluded
that the discharge will have no reasonable .potential to cause violation of the criterion. With that finding,
it is likely that DENR will not establish a numerical limit for boron in the NPDES' permit.
Evaluation of LP Boron Data
DENR has had limited data on the levels. of boron expected in LP's effluent that -could be used for the
statistical evaluation outlined- above. The only value available to DENR prior,to the January 11, 2007
meeting, was from the December 2006 notice of future modifications c e Zinc Borate; ro'ect.
That document cited the mass balance -derived estimate o 172 mg/L boron expected to b�in e 1.5 mgdeffluent from, the Roaring River mill following implementation o t e inc Ora a projec
Because the Zinc Borate project has not yet been implemented, there are no actual effluent measurements
of boron that can be used directly in the statistical evaluation presented above. However, LP conducted
bench -scale wastewater treatability trials that simulated the boron loading to the mill's wastewater
treatment system. Those tests provided several measurements of boron in bench -scale units' treated
effluents that can be used to calculate a coefficient of variation to support the statistical evaluations.
Since the mass balance estimated that 172 mg/t of boron would be present in the effluent, LP conducted
treatability trials that bracketed that concentration. Bench -scale treatability. tests were conducted at
targeted doses of 150 and 300 mg/L to confirm that there would be no detrimental impact of boron on the
activated sludge treatment process. ' Those continuous -flow tests were conducted over` a seven -week
period and yielded six effluent values from each of the two treatability test units. -
I:\WPGVL\PIT\0D-06998\02\00007\M000699802-001.DOC 1/18/07

Interoffice Memorandum
Table 1 presents the two sets of 6 effluent values for boron generated during the seven -week trial. The
standard deviation, mean, and coefficient of variation have been calculated for both sets of data and are
summarized in Table 1.
Determination of Maximum Receiving Water Concentration (RWC)
To be conservative, this calculation will use the higher of the two coefficients of variation calculated from
the boron treatability effluents, which is 0.144, as reported in Table 1. Again, using the more
conservative Table 3-1 (99 percent confidence levels) from the guidance document, a Multiplying Factor
of 1.43 is interpolated for a sample size of 6 and a coefficient of variation of 0.144.
Since the mean effluent boron value from,Data Set Number 1 was 173 mg/L, which is almost identical to
the mass balance estimate of 172 mg/L, RMT has identified the highest boron value in that 6-sample data
set to be 210 mg/L. This highest value will be_used as. the "maximum observed value" for these
calculations.
Using the maximum observed value for the boron content of LP's effluent of 210 mg/L, the Multiplying
Factor of 1.43, and the Dilution Factor of 0.002A-,.Alie maximum RWC is calculated as:
RWC = (210 mg/L) x (1.43) x ,, (0.60238) = 0.71 mg/L
Given the number of conservative assumptions used in these calculations and because the calculated,
maximum RWC is less than the water quality criterion of 0.75 mg/L, these calculations indicate that there
is no reasonable' potential for boron in LP's efflu � to cause an exceedance of the water quality criterion
value in the Yadkin River. Therefore, there shou'lfltbe no numerical limitation on boron derived for the
_NPDES permit.
1:\WPGVL\PJT\00-06998\02\00007\M000699802-001.DCC 1/18/07 •3

Interoffice Memorandum
Table 1
Effluent Boron Concentrations
Zinc Borate Treatability Study
LP Roaring River Mill
SAMPLE NUMBER
SAMPLE SET #1
SAMPLE SET #2
150 mg/L Target Dose
300 mg/L Target Dose
(boron mg/L)
(boron mg/L)
1
130
240
2
170
310
3
160
290
4
190
320
5
210
360
6
180
320
AVERAGE
173
307
STANDARD DEVIATION
24.94
36.36
COEFFICIENT OF VARIATION
0.144
0.119
L\WPGVL\PTf\ao.06"8\02\00007\M000l -ODI.DOC Inavf

Table 3"�._ Reasonaile Potential Multiplying Factors: 99%"Confidence Level and 99% ProbabdLty BasIs;:
Number d
;c6effid6if of Variaffon
`",
Samples
,'0 t 0:2 '
0.3
0.4
0.5
0.6
0.7
0,8.
0.9
1,0
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
2.0
1
1 6
.'2 5�
3.9
6.0
9.0
13.2
18.9
26.5
36.2
48.3
`63.3
81.4'1018 128.0 157.1
100.3 227.8 269.9 316.7 368.3
2
1:4 '"
;`2.Ot
2.9
4.0•
5.5
7.4
918
12.7
16.1
20,2
24.9
30.3
36.3
43.9
50.4
58.4
67.2
76.6
.86.7
97.5
3
1 4 ?
,'-I
2.5
.3:3
4.4
5.6
7.2
8.9
11.0
13.4
16.0
19.0
22.2
25,7
"29l4
33.5
37.7
42.3
47.0
" S2.0
4
Fj'-4(I
Z.3
2.9
3.8
4.7
5.9
7.2
8.7
10.3
12.2
14.2
16.3
1:8.6
21.0
23.6
26.3
29.1
32.1
.35.1
5
1 3 .,"1.7 1
2.1
2.7
3.4
4.2
5.1
6.2
7.3
8.6
10.0
11.5
13.1
14.8
16.6
18.4
20.4
22.4
24.5
26.6
6 l
13
2.0
2.5
3.1
3.8
4.6
5.5
6.4
7.5
8.6
9.8
11.1
12.4
13.8
15.3
16.8
18.3'19.9
21.5
7
1.3
1.6
2.0
2.4
2.9
3.6
4.2
5.0
5.8
6.7
7.7
8.7
9.7
10.8
12.0
13.1
14.4
15.6
16.9
18.2
8
1.2
1.5
1.9
2.3
2.8
3.3
3.9
4.6
5.3
6.1
6:9
7.8
8.7
9.6.
10.6
11.6
12.6
13.6
14.7
15.8
9
1.2
1.5 .
1.8
2.2
2.7
3.2
3.7
4.3
.5.0
5.7
6.4
7.1
7.9
8.7
9.6
10.4
11.3
12.2.
13.1
14.0
10
1.2
1.5
1.8.
2.2 ' 2.6
3.0
3.5'
4.1
4.7
5.3
5.9
6.6
•7.3
8.0
8.8
9.5
10.3
11.0
11.8
12.6
11
1.2
1.5
1.8
2.1
2.5
2.9
3.4
3.9
4.4
5.0
5.6
6.2
6.8
7.4
8.1
8.8
9.4
10.1
10.-8
11 5
12
1.2
1.4
1.7,
2.0
2.4
2.8
3.2
3.7
4.2
4.7
5.2
5.8 .
6.4
7.0
7.5
8.1
8.8
9.4
10.0
1 0.6
13
1.2
1.4
1.7
2:0
2.3
2.7
3.1
3.6
4.0
4.5
5.0
5.5
6.0
6.5
7.1 .
7.6
8.2
8.7
9.3
9.9
-1 4
1.2
1.4
1.7
2.0
2.3
2.6
3.0
3.4
3.9
4.3
4.8
5.2
5.7
6.2
6.7
7.2
7.7
8.2
8.7
9.2
is
1.2
1.4
1.6
1.9
2.2
2.6
2.9
3.3
3.7
4.1
4.6
5 0
5.4
5.9
6.4
6.8
7.3.
7.7
8.2
8.7
16
1.2
1.4
1.6
1.9
2.2
2.5
2.9
3.2
3:6
4.0
4.4
4.8
5.2
5.6
6.'1
6.5
6.9
7.3
7.8
8.2
17
1.2
1.4
1.6
1.9
2.1
23
2.8
3.1
3.5
3.8
4.2
4.6
5.0
5.4
5.8 .
6.2
6.6
7.0 ,
7.4
7.8
18
1.2
1.4
1.6
1.8
2.1
2.4
2.7
3.0
3.4
3.7
4.1
4.4
4.8
5.2
5.6
5.9
6.3
6.7
7.0
7.4
19
1.2
1.4
1.6
1.8
2.1
2.4
2.7
3.0
3.3
3.6
4.0"
4.3
4.6
5.0
5.3
5.7
6.0
6.4
6.7
7.1
20
1.2
1.3
1.6
1.8
2.0
2.3 1.
2.6
19
3.2
3.5
3.8
4.2
4.5
4.8
5.2
5.5
5.8
- 6.1
6.5
6.8
Table 3-2. Reasonable Potential Multiplying Factors:, 95% Confidence Level and 95% Probability'Basis
Number bf
Coefficient of
Varlaiion!
Samples
0.1
0.2.
0.3
0.4-
0.5
0.6
0.7
0.8
0.9
1.0
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
2.0
1
1.4
1.9
2.6
3.6
4.7
6.2
8.6
10.1
12.6
'15.5
18.7
22.3
26.4
30.8
35.6
40.7
46.2
521
58.4
6419'
2
1.3
1.6
2.0
2.5
3.1
3.8
4.6
5.4,
6.4
7.4
8.5
9.7
10.9
12.2
1'16
15.0
16.4
17.9
19.5
21.1
3
1.2
1.5
1.8
2.1
2.5
3.0
3.5
4.0-
4.6
5.2
5.8
6.5
7;2
7.9
8.6
9.3
10.0
10.8
1.1.5
12.3
£4:
1.2
1.4
1.7
1.9
•2.2
2.6
.2.9
3.3
3.7
4.2
4.6
5.0
S.5
6.0
6.4
6.9
7.4
7.8
' 8.3
8.8
5
1.2
1.4
1.6
1.8
2.1
2.3
2.6
2.9
"3.2
3.6
3.9
4.2
4.5
4.9
5.2
5.6
5.9
6.2
6.6
�6.9
.6
1.1
1.3•
1.5
1.7
1.9
2.1
2.4
2 6
2.9
' 3.1
3.4
3.7
3.9
4.2
4.5
4.7
5.0
5.2
5.5
5.7
7
l.1
1.3
1.4
1.6
1.8
2.0
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DEC
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December 4, 2006
Mr. Sergei Chernikov
Environmental Engineer
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Notification of Planned Alterations to the Wastewater Treatment Plant
at the Louisiana-Pacific Roaring River Mill
NPDES Permit NC0005266
Dear Mr. Chemikov:
LP
BUILDING PRODUCTS
Louisiana-Pacific Corporation (LP) has plans to modify the mill's production process to
incorporate zinc borate and boric acid into our hardboard siding product. This process
modification will enhance the value of our product by improving the resistance to rot and
insect attack. As a result of this modification, both zinc and boron will be introduced into the
mill's wastewater. Therefore, LP will design and install additional treatment processes to
remove zinc.
In accordance with our NPDES permit (Condition E.2.), with this letter LP is notifying the
North Carolina Department of Environment and Natural Resources (DENR) about these
planned physical alterations and additions to the permitted facility. Specifically, this
notification identifies the following three issues for DENR's review:
a. The process modification will change the nature of pollutants discharged. After the
modification, both zinc and boron will be present in the wastewater and the
discharge.
b. New physical/chemical treatment units will be designed and installed to remove zinc
from wastewater following the existing primary dissolved air flotation (DAF) process.
These units will involve chemical precipitation, equipment to remove precipitated
metal solids from the waste stream, and new sludge handling and dewatering
equipment.
ADDRESS P.O. Box 98
Roaring River, NC 28669
TEL [phone]
FAX [phone]
WEB www.lpcorp.wm

c. The new wastewater treatment processes will generate a chemical sludge that has not
been previously generated at the mill. This new source of sludge will be managed
and disposed of separately from the currently approved waste activated sludge
disposal program.
LP requests that DENR consider this notification letter as our request to modify the mill's
existing NPDES permit to accommodate these planned alterations. The attached Technical
Memorandum was prepared by our consultant to present more detail on these three issues.
As indicated in the memorandum, LP's design will be based on results of substantial research
and treatability testing.
Those test results provide confidence that the pretreatment system can effectively remove
zinc and that the biological wastewater treatment processes will not be impacted by either the
zinc or boron additions. The memorandum provides a basis for DENWs review of our
request for permit modification.
LP is available to meet with DENR if such a meeting would facilitate the agency's review and
permitting process. We have identified the following three dates that DENR could consider
for such a meeting: December 14 (Thurs), 18 (Monday), or the 2011, (Wednesday). Please call
me if you have any questions concerning this notification or to coordinate a meeting, if
possible at our facility. I can be reached at the mill at [phone].
Sincerely,
Louisiana-Pacific Corporation
Jose'6Hoeflein. P.E.
Plant Environmental Manager
cc: Phil Sparks, LP
George Smith, NC DENR, Winston-Salem
Sam White, RMT
John Bulloch, RMT
Leo Tramm, RMT
Attachment
Certified Mail: 7004 2890 0001 6865 0691 .

Awe Technical Memorandum
Date: December 1, 2006
To: Phil Sparks, Joe Hoeflein - LP
cc: Leo Tramm, John Bulloch - RMT
From: Sam White, Ph. D. - RMT
Project No.: 00-06998.02
Subject: Future Changes in Wastewater Constituents and Modifications to the Wastewater
Treatment Plant, Louisiana-Pacific Mill, Roaring River, North Carolina
The Louisiana-Pacific Corporation (LP) Roaring River hardboard mill is located on Highway 268 in
Roaring River, North Carolina (Wilkes County). The mill includes two production lines, designated as
Manufacturing Lines No. 1 and No. 2, producing embossed hardboard products for use as exterior
siding and trim on residential and commercial buildings. The mill includes a wastewater treatment
plant permitted under National Pollutant Discharge Elimination System (NPDES) Permit No.
NC0005266 issued July 20, 2004.
LP is planning to install a zinc borate addition system to both manufacturing lines in the mill to improve
the rot resistance of hardboard siding products. A zinc borate/boric acid mix and feed system will
provide a continuous, on -demand supply of a zinc borate mixture to two existing forming machines.
During application of the zinc borate, some zinc and boron will not be impregnated into the boards and
will enter the mill's wastewater.
LP plans to install a zinc pretreatment system to remove zinc from the wastewater. The zinc removal
processes will follow the existing primary dissolved air flotation (DAF) solids removal unit and will
precede the activated sludge aeration basin. The pretreatment system will lower the content of zinc in
the wastewater such that the treated discharge will not exceed the North Carolina Department of
Environment and Natural Resources (DENR) action level for zinc. Boron will enter the wastewater
treatment plant (W WTP) and pass through to the effluent without significant removal. Based on the
data presented in this memorandum, boron in the discharge will not cause harm to the aquatic
environment. The Zinc Borate project will not result in increased flow rate or alterations to the other
existing permit limits (i.e., BOD, TSS, or pH) and this project will not increase the production capacity of
the mill.
Subsequent sections of this memorandum provide additional details on the process alterations, expected
effluent concentrations, and Material Safety Data Sheets (MSDS) for the two new constituents that will be
present in the effluent.
1:\WPGVL\P)T\0 998\02\M0006998M2 I.DOC 1211/06

"I
Technical Memorandum
Notification of Alteration Procedure
Condition E.2. of Permit No. NC0005266 requires the following with respect to planned physical
alterations or additions to the permitted facility:
E.2. Planned Changes
The permittee shall give notice to the director as soon as possible of any planned physical alterations or
additions to the permitted facility (40 CFR 122.41(1)1. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b), or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit,
nor to notification requirements under 40 CFR 122.42(a)(1).
c. The alteration or addition results in a significant change in the permittee's sludge use or disposal
practices, and such alteration, addition or change may justify the application of permit conditions that
are different from or absent in the existing permit, including notification of additional use or disposal
sites not reported during the permit application process or not reported pursuant to an approved land
application plan.
Existing Wastewater Treatment Plant Configuration
A schematic for the current Roaring River WWTP is presented in Appendix A. The first process flow
diagram highlights the WWTP upgrades implemented at the Roaring River Mill in 2004. Combined raw
wastewaters are pumped from the mill to the primary clarifier. The overflow from the primary clarifier
is pumped to the primary DAF that was added in the 2004 WWTP modification to improve WWTP
operation by removing wood fibers prior to the aeration basin. The underflow from the primary clarifier
is pumped to the sludge chest and is wasted from the system.
Primary DAF overflow combines with return activated sludge (RAS) at the head end of the 10 million
gallon aeration basin. With 20 aerators providing a total of 1,250 horsepower (hp), the aeration basin is
well mixed and aerated with 125 hp per million gallons. A portion of the mixed liquor leaves the
aeration basin for further treatment in a 55-foot diameter secondary clarifier. The secondary clarifier
overflow is routed directly to the effluent mix box for discharge. The solids settled in the secondary
clarifier are pumped back to the aeration basin as RAS. The remainder of the mixed liquor flow from the
aeration basin is pumped through the secondary DAF unit where polymer is blended with the mixed
liquor solids. The solids "floated" from the stream are transferred to the sludge chest to be wasted from
the system. This solids wastage maintains the mixed liquor suspended solids (MLSS) in the desired
operating range. Water clarified by the secondary DAF unit can either be returned to the aeration basin
or discharged directly to the effluent mix box without passing through the secondary clarifier. Treated
sanitary wastewater is also routed directly to the effluent mixing box.
]:\WPGVL\PJT\00-06998\02\M000699802-001.DOC 12/1/06

Technical Memorandum
Sludges pumped from the primary clarifier underflow are routed into the sludge chest and are combined
with the waste activated sludge (WAS) produced as secondary DAF "float." The combined contents of
the sludge chest are dewatered with belt filter presses. Dewatered sludges are disposed of off -site in
accordance with the Land Application of Wastewater Residuals permit (WQ0000461).
Proposed Zinc Borate Addition System
A zinc borate/boric acid mix and feed system will provide a continuous, on -demand supply of a zinc
borate mixture to two existing forming machines. A Process Flow Diagram for this chemical supply and
feed system is presented in Appendix A. Material Safety Data Sheets for Borogard ZB (zinc borate) and
Optibor® (boric acid) are included in Appendix B. The purpose of the zinc borate is to improve the rot
resistance of hardboard siding products. The purpose of the boric acid solution is to assist in retarding
the rate of hydrolysis (dissolution) of the zinc borate solids. The majority of the zinc and boron will be
retained in the finished board product, however some of the zinc and boron will pass through the board
and become part of the mill wastewater flow.
Treatment of Zinc Borate Impacted Wastewater
As part of the Zinc Borate project, a zinc pretreatment system will be installed to remove zinc from the
wastewater prior to discharge to the existing activated sludge aeration basin. Zinc removal at this point
is needed to: (1) prevent inhibitory effects of zinc on the biological treatment process, (2) discharge an
effluent that will keep zinc below the 50 µg/L Action Level after mixing in the Yadkin River and (3) to
prevent zinc levels in the waste biological sludge that could affect the mill's ability to land -apply the
waste sludge.
Currently, clarified overflow from the Primary DAF Unit flows by gravity to the Aeration Basin Inlet
Box. No valves will be installed. The pipe will be physically reconnected from the primary DAF to the
zinc pretreatment system. LP proposes to install valves to allow that flow to be directed to a proposed
Zinc Pretreatment System, where zinc will be removed through precipitation and settling. A Process
Flow Diagram for the zinc pretreatment system, as well as a Site Location Plan for the modifications, are
included in Appendix A.
In the Zinc Pretreatment System, caustic soda and phosphoric acid will be added in a Mix Tank to
promote precipitation. The wastewater will be pumped from the Mix Tank to a Zinc Removal DAF Unit
where a polymer solution will be metered as a flocculant aid to promote solids removal in the DAF Unit.
After removal of settleable solids and float material, the clarified wastewater would discharge to the
Aeration Basin Inlet Box.
The solids and float material removed from the DAF Unit will be directed to a new Zinc Sludge Sump
that would transfer the sludge to new Belt Filter Presses (BFP) with polymer addition for dewatering.
The filter cake will be transferred from the collection pit to truck trailers by an end -loader, for transport
and disposal at LP's on -site landfill or a commercial industrial waste landfill, as non -hazardous solid
waste. A Process Flow Diagram illustrating the zinc sludge handling system is also included in
Appendix A.
1:\WPGVL\P)T\00-06998\02\M000699802-0O1.DOc 12JI106

Technical Memorandum
The zinc pretreatment system will be designed to consistently remove zinc from the total mill
wastewater flow before discharging wastewater to the aeration basin. Raw wastewater is projected to
contain an average concentration of 138 milligrams per liter (mg/L) at 1.5 mgd, and bench -scale
treatability trials indicate that zinc will be lowered to < 4 mg/L by chemical precipitation with caustic and
phosphoric acid. The removal of zinc to a concentration below 4 mg/L ahead of the aeration basin will
also allow LP to continue current management practices for disposal of the biological sludge in
accordance with the existing land application program.
The raw wastewater, and effluent, concentration of boron is expected to be approximately 172 mg/L at a
wastewater flow rate of 1.5 mgd. The treatment system is not intended to remove boron. That
expectation has been confirmed with laboratory treatability studies.
In bench -scale treatability tests, zinc was added to LP's primary DAF effluent and then treated by
chemical precipitation. Boron was then added to aliquots of the pretreated wastewater at concentrations
that bracketed the concentration of boron expected in the full-scale system. Those aliquots of wastewater
containing different boron concentrations were fed to a number of bench -scale activated sludge units,
seeded from the Roaring River treatment system, that simulated a flow rate of 1.5 mgd of the pretreated
wastewater. Those tests were conducted continuously over a period of 7 weeks to detect impacts from
boron or residual levels of zinc. Those treatability investigations demonstrated that LP's wastewater
treatment system operations would continue to effectively remove BOD and the facility would continue
to meet permit limitations.
Mixing Zone Concentrations of Zinc and Boron
The W WTP effluent discharges through an existing diffuser into the Yadkin River and is readily
dispersed in the mixing zone. After mixing, the concentrations of zinc and boron will be based on the
flow of the effluent, the flow of the Yadkin River, the concentration of constituents in the effluent, and
the background concentration of constituents in the Yadkin River. The process to determine
concentrations of constituents present in the river, after mixing, is presented in the following equation:
Cm = ((Qw)(Ce) + (Qu)(Cu)) / (Qw + Qu)
Where:
Cm is the concentration downstream in the Yadkin after mixing,
Ce is the concentration of the constituent in the discharged effluent,
Cu is the background concentration,
Qw is the maximum permitted waste flow and
Qu is the critical upstream stream flow, generally the summer seven -consecutive -day low flow
rate with a recurrence frequency of ten years -- the 7Q10 flow.
The permitted flow rate of the Roaring River Mill is 1.5 mgd, and the critical low flow rate (7Q10) in the
Yadkin River was 228 cubic feet per second (cfs), or 147 mgd. The average annual flow rate of the
i:\WPGn\PJT\00-06M\02\M000699902-001.DOC 12/1/06

Technical Memorandum
Yadkin River is reported to be 976 cfs, or more than 630 mgd. RMT has sampled the Yadkin River
upstream of the LP discharge to determine background levels for both zinc and boron. Those
background samples results were as follows:
zinc = <0.01 mg/L
boron = <0.01 mg/L
Based on the equation above, the concentrations for zinc and boron downstream at the low flow
criterion, after mixing in the Yadkin River, are as follows:
zinc < 0.05 mg/L
boron = 1.75 mg/L
Substituting the average annual flow rate of 630 mgd in the Yadkin River for the 7Q10 value in the
equation above results in the following long term average concentrations for zinc and boron in the river:
zinc = 0.02 mg/L 1�
boron = 0.42 mg/L
Water Quality Criteria
An Action Level of 50 ug/L (or 0.05 mg/L) has been established for zinc in North Carolina (NCAC 15A
02B.0211[41). Based on the mixing zone calculations described above, LP expects the zinc concentration
in the Yadkin River to remain below 50 ug/L under the critical conditions of the specified low flow
criterion (7Q10) and the maximum permitted discharge flow rate.
There is no water quality standard for boron in the NC DENR Redbook (NCAC 15A O2B). The United
States Environmental Protection Agency's "Gold Book" (Quality Criteria for Water, 1986, EPA 440/5-86-
001) cites no ambient water quality criteria for boron based on protection of human health or protection
of aquatic life. However, it does cite possible injury to sensitive crops (e.g., citrus) from long-term
irrigation with waters containing more than 0.75 mg/L boron. The long-term average concentration of
0.42 mg/L for boron in the Yadkin River is lower than the 0.75 mg/L value that could cause injury if the
river was used as the source of irrigation water and if it was being applied to any "sensitive crops."
1:\WPGV \Prf\0 998\02\M000699802-001.DOC 12/1/06

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2 EWMZA71ON TAM NLET PPE TO BE ERLENDED DOM BELDW LOW WMER LEVEL.
7 & FRIAL'UnAMff FM METER/PPE SECn0N TO BE WC@ FIGURED AND UP-S ZEM
REV. No. WE -Br oLSrJEPBOEE r" Na WE -Br DES
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ROARING RIVER MILL
ROARING RIVER, NC
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1-22-0F
PROCESS FLOW DIAGRAM
WWTP UPGRADE.'`

LP - Roarinci River Wood Furnish
Chips from 31
Roundwood
/ Purchased Chips
o

Oven Market Roundwood Furnish
Mixed
Sweetgum 5%
Ash 5%
_
5%
Maples
5%
Oaks
50%
Popl
30'

Open Market Chip Furnish
Mixed
Oak
25%
Pine
30%
oplar
35%

60
50
40
30
20
10
C
Seasonal Trends - Oak
J F M A M J J A S O N D
Months

------------------------------------------------
Seasonal Trends - Poplar
60
50
40
30
20
10
0
J F M A M J J A S
Months
------------------------------------------------------
----------------
o
n
o

60
50
40
30
20
10
0
Seasonal Trends - Pine
J F M A M
J J
Months
A S O N D

40
35
30
25
ca 20
15
10
5
0
On -Hand Chip Inventory Trends
J F M A M J J A
Months
S O N D
I

Seasonal Wood Furnish Issues
• Winter months offer less round wood and require
more open market chip purchases
• As a result, the wood furnish shifts to higher moisture
contents, less oak, more poplar and pine
- Increased level of fines
- Increased lignin and resin levels
- Increased levels of residual ash content(u
- Fiber length and diameter change
- Creation of fatty acids and mono/poly
saccharides increases
- Longer digester and refiner cycles
• Presence of pinenes and terpenes during winter
months from the higher percentage of pine in the chip
furnish alters process chemistry by affecting pri can create smaller fiber flocs that can easily be
-� 5�, �,- r
ej4 pod,
released from the mill whitewater systems
Summary Conclusion:
There is a definite and distinct difference in the wood
furnish and wood chemistry between LP -Roaring River's
summer and winter operating months --- winter wood
supply will result in higher TSS and TDS discharges from
the mill to the effluent treatment plant
f 6--#, 2

30 Patewood Drive, Suite 100
Greenville, SC 29615.3535
Telephone [phone]
Fax [phone]
a�uu
W-
Engineering Alternatives Analysis
(EAA) for a Proposed Increase in
Discharge Flow
Louisiana-Pacific Corporation
Roaring River Mill
Roaring River, North Carolina
NPDES Permit No. NC0005266
January 2007
t
Sam 4hite\Ph.D.
Senior Consultant
Leo Tramm, P.E.
Project Manager
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow
I:\"Gn\PR\0 998\02\R000999802-001AOC
® 2007 RMT, Inc.
All Rights Resnad

Executive Summary
The Louisiana-Pacific Corporation's (LP) Roaring River Mill in Roaring River, North Carolina,
is requesting that the National Pollutant Discharge Elimination System (NPDES) permit limit on
flow rate be increased from 1.5 to 2.0 million gallons per day (mgd). This increase in flow rate is
not associated with an increase in production and the mill is not requesting increases to any
other permit limits.
The request for additional flow is driven by the need to accommodate a new wet scrubber
blowdown stream resulting from the mill's North Carolina Department of Environment and
Natural Resources (NC DENR)-approved method for compliance with the National Emission
Standards for Hazardous Air Pollutants (NESHAPs): Plywood and Composite Wood Products
(PCWP). The mill will with the PCWP Maximum Achievable Control Technology
(MACT) requirements by removing hazardous air pollutants (HAPs) in a new scrubber at the
mill's digesters. The use of this scrubber can create an additiona10.5 mg of wastewater flow
that contains HAPs, primarily methanol.
The HAPs contained in this flow will be effectively removed by biodegradation in the aeration
basin at the mill's wastewater treatment plant (WWTP). The scrubber blowdown stream will be
conveyed directl to the aeration basin in a "hard pipe" configuration that does not allow loss
of HAPs to the atmosphere. The hard pipe will discharge the new wastewater source below the
surface of the aeration basin for immediate mixing and contact with the biomass in the
treatment process. The organic content of the constituents removed in the scrubber effluent will
increase the current
IC
loading to the WWTP by only 3 percent.
to the WWTP will be necessary to accommodate this new waste stream.
This Engineering Alternatives Analysis (EAA) concludes that the current combination of
extensive in -plant reuse/recycle of water and discharge of the additional 0.5 mgd directly to the
Yadkin River through the existing NPDES permitted outfall are the most technically and
economically feasible options considered. It is both technically and economically infeasible to
pump the mill's 2.0 mgd of wastewater to the North Wilkesboro wastewater collection system
and publicly -owned treatment works (POTW), or to pump treated effluent to a spray irrigation
field for the no -discharge land disposal option. The POTW does not have the treatment
capacity to receive the mill's discharge. LP does not own sufficient land with the characteristics
needed to support the spray irrigation of treated effluent. Both alternatives are very expensive,
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow
IA WPGVL \ PIT \ 00-06998 \ 02 \ R 000699802-001. DO C
January 2007

especially when compared to the "no -cost" alternative of continuing to use the existing surface
water discharge.
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow iv
1.\WPGVL\PIT\00-06998\02\R000699802-001.DOC January 2007

Section 1
General Information
Following the outline presented in the EAA guidance document, this section summarizes basic
information about the facility, explains the history of NPDES limits on flow rate at the Roaring
River Mill, presents a summary of the mill's current practice of in -plant reuse/recycle of water,
and documents the changes that provide the existing facility the capacity to accommodate the
proposed 2.0 mgd flow rate.
1.1 Basic Information
This EAA has been prepared for the following facility:
Louisiana-Pacific Corporation - Roaring River Mill
NPDES Permit Number NC0005266
Wilkes County, North Carolina
Highway 268, west of Roaring River, North Carolina
Telephoner 336-696-2715
The EAA has been prepared on behalf of LP by:
RMT North Carolina, Inc. (RMT)
30 Patewood Drive, Suite 100
Greenville, South Carolina 29615-3535
Telephone: [phone]
1.2 Discharge Flow Rate Limitations at Roaring River
This subsection presents the historical background information on permitted discharge flow
rates at the Roaring River Mill and also discusses the current wastewater operations and
hydraulic capacity.
1.2.1 Historical Background
The WWTP for the Roaring River Mill was built in 1969. According to design drawings
for that facility, the flow rate basis was 1.0 mgd. That design capacity was the basis for
early NPDES permit limitations on discharge flow. That permit limit remained
unchanged for nearly 35 years, even though production had increased dramatically at
the mill and the WWTP was upgraded several times.
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 1
IAWPGVL\PIT\00-06998\02\R000699802-001.DOC January 2007

The original production capacity of the mill in 1969 was 240,000 pounds per day (lb/day)
of raw fiber, according to the 1972 air permit. In 2004, the production capacity was
1,579,570 lb/day of raw fiber. That represents an increase of more than 6.5 times the
original capacity, and yet the treated wastewater discharge rate had remained
unchanged through all of those increases and upgrades.
In 1980, the WWTP received a major upgrade when it was converted to the activated
sludge process and a dissolved air flotation (DAF) system was added to improve
secondary solids wastage and control. In 1995, the DAF itself went though an upgrade
and refurbishment to increase its solids handling capacity.
The 1980 conversion to activated sludge rated the WWTP hydraulic capacity at 1.0 mgd,
which is consistent with the size of the secondary clarifier. However, a DAF for
secondary solids removal was also added in 1980, and the configuration of the system
allowed water clarified by. the DAF to be discharged to the outfall without passing through
or adding any new hydraulic loading to the secondary clarifier. Since the WWTP's secondary
clarifier could already accommodate 1.0 mgd, and the DAF was sized to discharge an
average of approximately 0.63 mgd of clarifier water separately, the WWTP actually had
an effective hydraulic treatment capacity much higher than 1.0 mgd following the 1980
upgrade.
1.2.2 Clear Water Project Upgrade
In 1995, LP executed the Clear Water Project, which included refurbishing and'
upgrading the existing DAF. Following those modifications, the DAF has routinely
operated at average hydraulic capacities between 500 and 600 gallons per minute (gpm)
or approximately 0.75 mgd. One goal of the Clear Water Project was to improve the
WWTP's ability to discharge lower levels of total suspended residuals (TSR). That goal
was achieved partly though continued discharge of DAF clarified effluent routed
directly to the effluent mix box, without passing through or adding hydraulic loads to
the secondary clarifier. Therefore, the WWTP actually had the hydraulic capacity of the
original 1.0 mgd plus the 0.75 mgd capacity added by the DAF discharge. The WWTP
had the capacity to treat a total of 1.75 mgd of wastewater since the 1995 upgrade.
1.2.3 In -Plant Water Reuse/Recycle
The NPDES permit limit of 1.0 mgd remained unchanged for approximately 35 years of
operation, even though production increased by a factor of 6.5 over that period.
Upgrades and additions to the WWTP provided the ability to operate at a hydraulic
loading of 1.75 mgd of wastewater. The mill was able to continue operations at the
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 2
l:\WPGVL\P)T\00-06998\02\R000699802.001.DOC January. 2007

restrictive limit of 1.0 mgd only because of extensive in -plant water conservation steps
and multiple uses/reuses of water within the mill as it transits the production processes.
The mill practices in -plant multiple uses of water, not reuse of treated effluent from the
WWTP.
In both manufacturing lines, press water is reclaimed in the press pit and used as
dilution water in the surge chest. Water from the save all screen is collected in the
scrubber tank and used for makeup water on the No. 3 boiler scrubber, wash water on
the refiners, and wash water on the chip washers. Rich whitewater and lean whitewater
reclaimed from the wet forming operation are used multiple times in the process for
consistency dilution. Approximately 0.7 mgd of water is circulated from the raw water
lagoon and used as non -contact cooling water in several locations throughout the
process.
As production increased, resulting in an increased demand for process water, LP
incrementally implemented these reuse practices. Since the total discharge was limited
to 1.0 mgd, the increased water demands were met by more conservation and increased
multiple uses of water in -plant. In fact, the ratio of fresh water inputted to the mill vs.
process recycled/reclaimed water is approximately 1 to 2. (i.e., 1.5 mgd into the mill,
3.0 mgd continuous recycle, and 1.5 mgd out of the mill).
1.2.4 The 2004 Wastewater Treatment Plant Upgrade
By 2003, the mill was reaching the limit of its ability to conserve water by cascading
multiple reuses within the processes because product quality was being affected. With a
limited "purge rate" of only 1.0 mgd, buildup of wood byproducts, as well as inorganic
and organic additives, had impacted the mill's ability to maintain product quality
criteria. In 2004, LP requested that the NPDES permit discharge limit be increased from
1.0 to 1.5 mgd. That request was not associated with an increase in production, only an
increase in the throughput of water that allowed the mill to meet product quality
demands while still conserving water to the extent possible. Additionally, there was no
request to increase the pollutant loading. (either BOD or TSR) mass limits established in
the NPDES permit. The permitted discharge flow rate was increased from 1.0 to
1.5 mgd simultaneously with a significant upgrade to the mill's WWTP in 2004.
In that upgrade, the old primary clarifier was modified to provide raw wastewater
equalization and a new primary DAF with a 2.0 mgd hydraulic capacity was installed to
improve solids removal from the raw waste stream prior to the biological treatment
process. Another aspect of that upgrade was a reconfiguration of the effluent structure
and an upgrade to the final flow monitoring device. These changes at the effluent
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 3
IAWPGVL\PJT\00-06998\02\R000699802-OOI.DOC January 2007

structure alleviated a "bottleneck" in the system and assured that the hydraulic capacity
of the treatment system would accommodate a discharge rate of more than 2.0 mgd.
1.3 Current Wastewater Treatment Plant Hydraulic Capacity
This EAA addresses the need to accommodate an additional 0.5 mgd of wastewater at the
WWTP. However, to minimize loss of HAPs to the atmosphere, MACT regulations allow waste
streams such as the scrubber blowdown described in this report to be "hard piped" directly into
the aeration basin of the WWTP. The impact of routing this wastewater to the aeration basin is
that the additional flow rate of 0.5 mgd will not impact the hydraulic capacity of the pumps that
transfer the mill's wastewater to the treatment system, the equalization basin, nor the primary
DAF located ahead of the activated sludge basin. The additional flow rate will impact only the
retention time in the aeration basin, the secondary clarifier and/or secondary DAF, the effluent
structure (mix box), the flow measuring device, and the effluent diffuser located in the Yadkin
River.
As noted in Subsection 1.2.4, modifications made during the 2004 upgrade alleviated the
hydraulic bottleneck at the effluent structure. The hydraulic retention time in the activated
sludge aeration basin will be 5 days, and the hydraulic capacity of the secondary clarifier and
secondary DAF have been increased by the improved solids removals from raw wastewater by
the new primary DAF. The existing facility can now accommodate the total flow rate of
2.0 mgd with no further modifications.
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 4
1. \WPGVL\ P/T\00-06998 \ 02 \ R000699802-OOI.DOC
January 2007

Section '2
Basis for Increased Wastewater Flow Rates
This section describes the reason that the Roaring River Mill's wastewater flow rates will
increase in 2007 and describes the source and characteristics of the new wastewater stream, as
well as the treatment to be provided to constituents in that stream.
2.1 Regulatory Compliance Requirement
The Roaring River Mill is subject to the NESHAPs PCWP, otherwise known as the PCWP
MACT rule. One aspect of LP's compliance method for the PCWP MACT includes control of
emissions from the batch digester purge cycles using a wet scrubber.
The mill must achieve compliance with these requirements by September 30, 2008. LP. has
begun the planning and design for the modifications described below.
2.2 Emission Control Equipment
Digester control will involve the installation of a two -stage, packed column scrubber to control
HAP emissions from the batch digesters serving manufacturing lines No. 1 and No. 2. The wet
scrubber will use water to remove HAPs and other volatile organic compounds (VOC) from the
digester purge gas. The scrubbing solution will be routed (hard piped) to discharge below the
surface in the WWTP aeration basin where the collected compounds will be biodegraded. The
digester scrubber will also include installation of a cooling tower to maintain the scrubbing
solution at a temperature necessary for efficient removal of HAP and VOC. At times,
non -contact cooling tower blowdown will be routed to the WWTP as well.
LP is proposing to use a single wet scrubber system to control HAP emissions from the purge
cycle for batch digesters dedicated to Line No. 1 and Line No. 2. Key components of the
proposed scrubber system include the following:
■ A two stage packed bed scrubber design that will allow HAP removal from the digester
purge stream with a high removal efficiency through direct contact and condensation
effects. The removal efficiency is also expected to be high for the HAP specified under the
PCWP MACT due to the moderate boiling points and relatively water-soluble nature of the
HAPs of concern under the PCWP MACT (i.e., methanol, formaldehyde, phenol, etc.).
■ A cooling tower with associated pump, piping, chemical treatment system, valves,
instrumentation, and plate -and -frame heat exchangers will cool recirculated water to the
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 5
L•\WPGVL\PTr\00-06998\02\R000699802-001.DOC January 2007

first stage of the scrubber, and waters discharged to the wastewater treatment system. The
cooling tower consists of three modular stages, each with a variable speed fan to allow
turndown of the cooling tower operation. This will provide operational cost savings when
the full amount of cooling capacity is not needed.
2.3 Wastewater Flow Rate Increases
The proposed scrubber and cooling tower will increase the amount of new fresh water that
enters the mill and will have associated blowdown streams. There will be no increase in
production associated with the modification, only an increase in the throughput of water that
will allow the mill to meet MACT requirements and product quality demands while still
conserving water to the extent possible.
The wet scrubber and cooling tower blowdown will result in an increased flow rate to the
WWTP. LP estimates that these two new wastewater components will add approximately
0.5 mgd to the wastewater currently generated by the mill. The scrubbing solution will result in a
negligible increase in BOD entering the aeration basin (approximately a 3 percent increase over
current WWTP influent) and will not affect other existing discharge limits (i.e., TSR, or pH).
2.4 Projected Wastewater Treatment Plant Performance
The HAPs collected in the scrubber water will be transferred to the WWTP through a closed
piping system, and will be discharged to the aeration basin using a submerged pipe to minimize
volatilization. The WWTP consists of an "enhanced biological treatment system' (i.e., a
thoroughly mixed activated sludge system with mixed liquor suspended solids [MLSS] greater
than 1,000 milligrams per liter), which will result in higher biodegradation rates than a simple
aerated stabilization basin (aerated lagoon) and relative losses to the atmosphere will be low. In
practice, the plant maintains a MLSS concentration of between 3,000 and 4,500 milligrams per
liter (mg/L), which is much higher than the minimum 1,000 mg/L required to qualify as an
"enhanced" system. Therefore, the wastewater treatment system is expected to be very effective
in biodegrading the contaminants from the scrubbing solution. Based on the high
biodegradability of the additional HA -Ps that will enter the WWTP (primarily methanol,
formaldehyde, and acetaldehyde), it is expected that there will be no detectable HAPs in the
outfall.
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 6
IA WPGVL %PIT% 00-06998 \ 02 \RO00699802-OOI.DOC January 2007

Section 3
Disposal Alternatives Evaluation
and Economic Cost Comparison
This section provides an evaluation of disposal alternatives that have been considered for the
Roaring River Mill wastewater discharge. This EAA is not being prepared for a new
wastewater source, but is evaluating alternatives for an existing WWTP that already discharges
up to 1.5 mgd to surface water in accordance with an existing NPDES permit. LP is requesting
that the effluent flow limit be increased from 1.5 to 2.0 mgd, with no increases to any other
NPDES permit limits. This evaluation includes considerations of technical feasibility in addition
to economic feasibility of each option.
3.1 Option 1: Discharge 2.0 mgd to Surface Water through Existing
Outfall
The base case for this evaluation is to continue to discharge treated effluent to the Yadkin River
in accordance with LP's NPDES permit. The Roaring River Mill has maintained a surface water
discharge (Yadkin River) in accordance with an NPDES permit for approximately 38 years.
Continuation of this option is the most technically feasible approach to accommodate the
proposed discharge flow rate of 2.0 mgd.
The "cost" to implement this base case is essentially zero. No changes to the surface water
outfall piping or structure will be needed to implement this increase in discharge flow rate. The
WWTP already has the hydraulic capacity to receive and discharge the 2.0 mgd. The NPDES
permit exists, the outfall and diffuser in the Yadkin River exist, and LP would incur no new
capital costs, nor additional operating costs, when the discharge flow rate is increased from
1.5 mgd to 2.0 mgd. -It should also be noted that the incremental increase of 0.5 mgd will raise
the flow of the Yadkin River by only one-third of one percent over the 7Q10 summer low flow
rate.
3.2 Option 2: Connection to a Sewer -Collection System and Publicly -
owned Treatment Works
The NC DENR's guidance document for evaluating wastewater disposal alternatives
(Engineering Alternatives Analysis; June 2000) cites the goal "to eliminate all surface water point —
source discharges." To accomplish that goal in this case, LP's NPDES discharge would need to be
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 7
1. \WPGVL\PIT\.00-06998\02 \R000699802-002.DOC January 2007

eliminated by routing the wastewater to a POTW. No point -source discharge would be
eliminated if LP continued to discharge 1.5 mgd through the existing NPDES outfall, with the
incremental increase in flow of 0.5 mgd being sent on a 10-mile trip to be discharged through
another NPDES outfall into the same receiving stream. Under that scenario, no discharges
would be eliminated, and no wastewater would be prevented from entering the receiving
stream. Therefore, the entire flow rate of 2.0 mgd from LP must be sent to the POTW to satisfy
the goal of eliminating a point -source discharge.
The Roaring River Mill is located 10.5 miles, by road, from the North Wilkesboro POTW. The
North Wilkesboro sewer collection system extends from the city to within 5 miles of the mill.
Based on discussions with the City of North Wilkesboro, LP would need to pump the effluent
for approximately 5 miles along Highway 268 towards the city before the connection to the
City's collection system can be made. Because of the quantity and quality of LP's wastewater,
the Roaring River Mill would have to continue to operate the existing WWTP to provide an
effluent acceptable to the POTW. LP has assumed that the City's collection system already has
the capacity to convey the additional 2.0 mgd through the existing system to the POTW. If not,
then another large cost component would need to be added to the estimate below. A system to
accomplish this option would include the following elements:
■ Lift station sump and pumps (sized for 2.0 mgd)
■ Five mile force main to convey 2.0 mgd to the City's sewage collection system tie-in point
(12-inch diameter force main)
■ Expansion of the POTW to accommodate this new, large source of wastewater
The North Wilkesboro POTW is permitted to discharge 2.0 mgd, and currently treats an average
of between 0.9 and 1.0 mgd. Therefore, it is technically infeasible for the North Wilkesboro
POTW to accept another 2.0 mgd of wastewater from the Roaring River Mill without a major
upgrade in capacity. The POTW would need to gain an additional capacity of at least 1.0 mgd to
be able to accommodate the addition of LP's 2.0 mgd discharge.
The line diagram presented in Figure 1 illustrates the new components required to convey LP's
2.0 mgd of treated effluent to a point where the discharge can be released into the North
Wilkesboro sewage collection system. After LP's wastewater enters the collection system, it
would be conveyed to the POTW for treatment and subsequent discharge into the Yadkin River.
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 8
1.\WPGVL\PIT\00-06998\02\R000699802-001.DOC January 2007

HIGHWAY 268
-NORTH ROARING�
WILKESBORO RIVER
NORTH
EXISTING WILLKESBORO
POTW POTW
(2.0 mgd CAPACITY)
NEW POTW
EXPANSION
(1.0 mgd)
APPROX. 5 MILES
TIE-IN TO SEWAGE
COLLECTION
SYSTEM
MILLLP 2.0 MGD
WWTP FLWMEIER
c
Iz
d
z
c
m
c SUMP
m
0
YADKIN RIVER
FIGURE 1
OPTION 2: DISCHARGE TO POTW
z
v
v
m
w
Ic
D
F
LIFT STATION
& PUMPS

The United States Environmental Protection Agency (USEPA) technical report, Construction
Costs for Municipal Wastewater Treatment Plants: 1973-1978 (EPA/430/9-80-003), was relied upon
to estimate the cost to expand the POTW by 1.0 mgd. The cost for a 1.0 mgd secondary
treatment plant taken from the report was adjusted for current costs by using the ratio of
Engineering News Record (ENR) indices from 1978 and 2006. The total construction cost of the
new POTW capacity in 2007 would be more than $9 million.
Table 1 summarizes the cost estimates for purchase/installation of each of these components.
Table 1
Option 2: Cost Estimate for Discharge to Publicly -owned Treatment Works
(refer to Figure 1)
COMPONENT
COST BASIS _
ESTIMATED COST
Piping tie-in
12 inch line tap and seal
$8,000
Flow meter and sump
Use existing flow meter and sump
0
Lift station pumps
Duplex pumps at 2.0 mgd
40,000
Force main to sewer tie-in
5 miles of 12 inch high -density polyethylene
(HDPE) $90/LF installed
2,763,000
Add capacity to North
Wilkesboro POTW
1.0 mgd new capacity cost $2.2 million in 1978
ENR index ratio (1978-to-2006) = 2.84 x
6,248,000
Total Estimated Cost
$9,059,000
In addition to the capital costs associated with this option, LP would also be subject to the sewer
use fees (and possibly surcharges) under the City of North Wilkesboro Sewer Use Ordinance,
plus power costs to pump 2.0 mgd through the 5 mile long force main. The present worth of
those operations and maintenance costs would add a considerable additional financial burden
to this option.
3.3 Option 3: Land -based Disposal
The land -based disposal option will be evaluated differently than was Option 2. Because the
Agency's goal is to eliminate surface water point source discharges, Option 2 was based on
routing the entire 2.0 mgd to the North Wilkesboro POTW, since that would be the only way to
eliminate the LP point source discharge. For that evaluation, one point source would be
eliminated by transferring all the wastewater to another point source on the same river. The
approach to evaluating the land -based disposal option could also assume that the entire
2.0 mgd would have to be land applied. That evaluation has been done and it resulted in a
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 10
1.\WPGVL\PR\00-06998\02\Ra00699802-0 1.00C
January 2007

requirement for nearly 600 acres of land, which is totally impractical given the nature of the
soils, the steep slopes along the ridge line near the mill, and the unavailability of land for
purchase in that area. These issues are discussed in more detail below.
However, an alternative evaluation can be made that involves routing only the incremental
increase of 0.5 mgd away from the surface water discharge in favor of land application. While
this approach does not meet the goal of eliminating a surface water discharge, it would allow the
claim that no increase in flow was granted for the existing point source discharge. Therefore,
for the purpose of this EAA, Option 3 will evaluate the land -based disposal of only the
incremental increase of 0.5 mgd of wastewater.
Because of the nature and contents of this new wastewater stream, it must first be treated in the
.ing River Mill's WWTP. To
stream must be treated an the mill's activated
to assure the
r and any alternative, such as land application, would involve capital and operating costs in
addition to the current WWTP expenses.
The September 1997 Soil Survey of Wilkes County, North Carolina, published by the United States
Department of Agriculture (USDA) and the Natural Resources Conservation Service (NRCS),
was reviewed to determine the suitability of soils in the vicinity of LP's mill for land application
of wastewater. The soils map on Sheet #10, plus data from Tables 11 and 15 of that survey, were
relied upon to evaluate the land application option. A copy of the soils map (Sheet #10) is
presented in Appendix A for reference.
According to the soils map, there are very few and very small areas suitable for land application
of wastewater within at least 3 miles of the LP mill, regardless of who owns the property. In
Table 11, under the column for absorption fields, greater than 95 percent of soils in the area
within that radius are described as follows:
■ Pacolet sandy loam
■ Rion fine sandy loam
■ Chewacla loam
■ Pacolet sandy clay loam
severe: 15 to 25 percent slope
severe: 15 to 60 percent slope
severe: frequently flooded
moderate: 15 to 25 percent slope, or 2 to 8 percent slope,
eroded
The severe rating indicates "soil properties or site features so unfavorable or so difficult to
overcome that special design, significant increases in construction costs, and possibly increased
maintenance are required." Furthermore, Table 15 from the survey provides permeability rates
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 11
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Januanj 2007

for these soil types. All six types listed above are limited to a permeability range of only 0.6 to
2.0 inches per hour.
According to the Wilkes County Soil Survey, a very small fraction of the land surrounding the
plant would be suitable for land application of treated wastewater because of permeability,
steep slopes, depth to rock, or flooding potential. Since the county soils survey indicates that
the surrounding property is not suitable for land application of wastewater, a soils scientist
would have to conduct an extensive soils investigation before establishing an appropriately
sized spray application field.
However, to allow a conservative lowest -cost estimate of a hypothetical land application facility
for this EAA, RMT will reference the allowable application rate of a nearby (within 40 miles)
NC DENR-approved land application site for wastewater in North Carolina. The permit for
that site, which is relatively level and has soils acceptable for land application, restricts the
hydraulic loading to 52 inches over a one-year period. That application rate is equivalent to
approximately 1.4 million gallons per acre per year. The volume of treated LP wastewater to be
land -applied would be 0.5 mgd for this hypothetical cost estimate. Therefore, adopting the
hydraulic loading from another nearby facility's site and applying it to LP's requirements
would dictate a land application facility of more than 130 "wetted" acres. That area does not
yet include the 150 foot buffer zones, access roads, and a wet weather storage pond that would
need to hold more than 7 million gallons.
A land application system should have a wet -weather holding pond that will accumulate
treated effluent during inclement weather when land application should not be conducted. If
the pond is sized to hold effluent for a 14-day non -application period, it should hold 7 million
gallons. The pond should also have a synthetic liner to prevent a clay liner from drying out and
cracking during dry periods when the pond remains empty for extended periods of time. The
North Carolina regulations [T15A:02H.02190)(5)U)] also require a 150 foot buffer strip between
the land application site and any property line, as well as access by an all weather road.
Therefore, the total size of the hypothetical land application site would need to be
approximately 165 acres to accommodate the following:
■ Spray field
■ Holding pond
130 acres
2 acres
■ Buffer strips (150 feet wide) and access road 33 acres
Therefore, the land application site for disposal of 0.5 mgd would require an area of at least
165 contiguous acres.
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EAA for a Proposed Increase in Discharge Flow 12
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LP does not own the 165 acres needed for land disposal in the vicinity of the WWTP and mill.
Furthermore, it is highly unlikely that 165 contiguous acres of relatively flat land with
acceptable soils even exits within a reasonable radius of the mill. Because the mill is in a river
valley, most of the adjacent land has a significant slope that would not allow efficient use of
acreage for spray irrigation of treated effluent. The 165 acres certainly would not be contiguous,
but would very likely be several, much smaller tracts of land. Such a configuration greatly
complicates the practicality and escalates the costs for preparing and operating such a disjointed
land application disposal system. When adjacent property has become available in the past, LP
has purchased land but is still far short of the acreage required for this alternative. Therefore, it
is technically infeasible for LP to convert the wastewater disposal system from the existing
surface water discharge to land disposal.
Such a land application system would include the following components:
■ Flow meter and flow control valve
■ Lift station sump and pumps
■ Force main to convey 0.5 mgd to wet -weather holding basin
■ Wet weather holding basin
■ Land application pumps
■ Piping distribution network and spray heads
■ Spray application fields
■ Buffer strips
■ All weather access road to the storage pond and application site
■ Groundwater monitoring wells
The line diagram presented in Figure 2 illustrates the components of a new land application
system for disposal of LP's incremental increase in flow rate of treated wastewater.
Therefore, for the purpose of demonstrating that such a system is not economically feasible, a
hypothetical land application system has been sized simply to allow a cost estimate for this
option. This hypothetical option assumes that a single, contiguous 165 acre tract of land is
available for sale within 2 miles of LP's existing WWTP, and that the hypothetical property is
flat and has already been cleared of trees, brush, etc.
RMT North Carolina, Inc. I Louisiana-Pacific Corporation _
EAA for a Proposed Increase in Discharge Flow 13
1•\WPGVL\PIT\00-06998\02\R000699802-0O1.DOC January 2007

MW-1
I
HEADW I
I
'u�ua•
I
I
®
®MW-4
I c
MW-2
I
c
SPRAY APPLICATION
PUMPS
HOLDING POND
(7 MIL. GAL.)
I e� os
I
L-- -- --
®MW-3 --
II
--J
APPROX.130 ACRES
0.5 MGD
'
LIFT STATION
FLOW
--- MEER
& PUMPS
�
I
I
SUMP
MILL
WWTP
20 MGD
1.5 MGD
MEM
i
y
FIGURE 2
OPTION 3: LAND APPLICATION

According to the Wilkes County Assessors office, open land in the vicinity of Roaring River sells
for at least $3,000 per acre when purchased in tracts of approximately 100 acres. If the
purchases were made on smaller tracts, such as 10 acres at a time, the cost would be greater
than $4,000 per acre. For purposes of this estimate, it is assumed that the entire plot of land
needed for the wet -weather holding pond, spray application field, and buffer strips were all
purchased together for a price of $3,000 per acre.
Table 2 summarizes the cost estimates for purchase/installation of each of these components.
Table 2
Option 3: Land Application Cost Estimate
(refer to Figure 2)
COMPONENT
COST BASIS
ESTIMATED COST.
Piping tie-in
S inch line tee
$5,000
Flow meter and control valve
8 inch lines and 0.5 mgd
7,000
Lift station sump and pumps
Concrete sump and duplex 0.5 mgd pumps
74,000
with power distribution
Holding basin
7 million gallons earthen basin with synthetic
495,000
liner
Spray application pump
Duplex pumps at 0.5 mgd each with remote
77,000
station
power distribution
Land (165 acres)
Sprayfield 130 acres
$495,000
Holding pond 2 acres
Buffer strips 33 acres
$3,000 per acre
Spray application pipes,
8 inch force main (10,000 feet at $71/LF)
$ 710,000
fittings, and spray equipment
8 inch delivery pipe (1,000 feet at $90/LF)
90,000
Distribution header, laterals, and spray heads
$620,000
over 130 acres
Groundwater monitoring
4 wells at 20 feet deep
11,000
wells
Total Estimated Cost
$2,584,000
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 15
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a
3.4 Wastewater Reuse
LP has been using this option for several years. The mill does not recycle treated effluent back
into the production areas, but instead makes multiple uses of fresh water that enters the mill.
This cascading, multiple in -plant water reuse is a very effective water conservation practice that
is necessary for compliance with the current NPDES limit. The addition of the MACT scrubber
and its blowdown discharge stream will not impact the mill's continued internal reuse/recycle
programs.
Therefore, there is no "capacity" within the mill to return treated effluent back into production
processes that already contain concentrated levels of dissolved materials. The mill prefers to
introduce fresh water at the head end of the processes and continue the intense multiple uses of
water internally.
LP's multiple internal reuses of water accomplishes the same goal that is promoted in this
alternative option of recycling treated effluent. LP believes that historical production and
operating data demonstrate that the company has already made maximum use of this
alternative.
3.5 Combination of Disposal Options
The Roaring River Mill has been using a combination of two disposal options for a number of
years. The mill believes that continuing to use these options is the most technically and
economically feasible approach for this situation. As described above, LP has been achieving
the same effect as wastewater recycling by practicing strict water conservation through multiple
in -plant uses of intake water (internal wastewater recycling) through several processes within
the mill. After the maximum use of water has been accomplished within the mill, the WWTP
has used a surface water discharge to the Yadkin River for nearly 38 years. To continue this
practice will result in minimal impact to the Yadkin River with essentially no cost for the
increase in discharge daily flow rate.
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 16
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January 2007

Section 4
Conclusions
The Roaring River Mill WWTP has the hydraulic capacity to increase the wastewater flow rate
from 1.5 to 2.0 mgd. This EAA has demonstrated that the most technically feasible and
economically feasible alternatives for disposal of the treated effluent is to continue the internal
reuse of water in the mill and to continue the use of the NPDES permitted discharge to the
Yadkin River. The cost to implement the base case (Option 1) for continued discharge to the
Yadkin River is essentially zero. The other options are neither technically nor economically
justifiable for implementation.
Option 2, pumping treated effluent from LP to the City of North Wilkesboro POTW, is also not
economically justified. The capital costs alone associated with pumping LP's wastewater to
North Wilkesboro and expanding the POTW's capacity by another 1.0 mgd would total more
than $9,059,000. The same volume of wastewater would still be discharged into the Yadkin
.River, even after eliminating LP's NPDES permit. The ratio of $9,059,000 to implement this
option versus a zero cost is not justifiable.
Option 3, land application of treated effluent, is neither technically nor economically justified
for several reasons:
Even if the land were available, the county soils survey indicates that only a very small
fraction of the land within a reasonable distance of the mill is suitable for land application.
Furthermore, the area of land required is not available as a contiguous site, but would only
be available in many smaller, fragmented properties that would negate the effectiveness of
such a technology.
Even if the soils were suitable for this purpose, after conservatively under -sizing the
property needed for the land application field, the cost of all the components illustrated in
Figure 2 for this option is estimated to be more than $2,584,000.
In addition to not being technically feasible, the ratio of more than $2,584,000 for this alternate
method of handling only 0.5 mgd,. not the entire 2.0 mgd, when compared to a zero cost for
continued discharge to the surface water is not justifiable.
After generating a new wastewater source that is driven by technology needed to comply with
the MACT regulations, the only technically and economically justifiable option to accommodate
the increased flow is believed to be the continued discharge of LP's effluent to the Yadkin River.
RMT North Carolina, Inc. I Louisiana-Pacific Corporation
EAA for a Proposed Increase in Discharge Flow 17
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January 2007