NCG210301_COMPLETE FILE - HISTORICAL_20091113

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
DOC TYPE C3(HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE ❑ ') OL )) 1 3
YYYYMMDD

NCDENR
North Carolina Department of Environment and
Beverly Eaves Perdue
Governor
November 13, 2009
Ms. Kimberely Yates
Louisiana Pacific Corporation
10475 Boston Rd.
Roxboro, NC 27574
Division of Water Quality
Coleen H. Sullins
Director
SUBJECT: Compliance Evaluation Inspection
Louisiana Pacific Corporation- Roxboro
Permit Number — NCG210301
County - Person
Dear Ms. Yates:
Natural Resources
Dee Freeman
Secretary
On September 30, 2009, Autumn Romanski, of the Division of Water Quality (DWQ), Raleigh Regional Office,
performed a stromwater NCG 210000 compliance evaluation inspection of the Louisiana Pacific site in Roxboro.
The assistance and cooperation of Mr. Ross Reed was very helpful and appreciated. Inspection findings are
listed below.
Industry and Site Descripdon
Louisiana Pacific is an Oriented Strand Board (OSB) plant that produces OSB Products/Timber Products (SIC
Code 24). Stonnwater generated at facility is regulated by General Permit NCG210000. DWQ has therefore
issued Louisiana Pacific certificate of coverage, NCG210301, which became effective on August 1, 2008 and
expires July 31, 2013.
Inspection Summary
The facility was in compliance with permit requirements the day of the inspection.
The following items should be addressed:
The SWP3 Plan is currently being updated to incorporate recent physical changes and improvements at the
plant. Upon the next annual inspection all updates to the SWP3 plan should be completed and available for
review
2. Training records were reviewed through July and August of 2008. Please ensure training records are
updated for 2009.

• Page 2
3. A number of spills have been reported in the last 24 months as follows:
a. January 13, 2009- Approx. 1,500-2,000 gallons of Wet Electrostatic Precipitator (WESP)
process water flowed out of a three inch vent pipe of the RTO Vault Sump and ultimately to the
2.5 million gallon fire pond. It was explained in the follow up report that no process water was
released from the site.
A fault alarm was installed on the sump pump, as well as, a back-up alarm on the breaker so
that operators have time to reactivate the pump or shut down the system before causing a
discharge
b. April 10, 2009- Approx. 2500 gallons of a mixture of ash water and city water was spilled and
contained on -site. It was explained in the follow-up report that the plant was in a facility -wide
shutdown the day of the incident when an employee noticed that water was coming from the
bark burner. It was reported that there was no indication that the small amount of tinted water
that was seen in the storm drain (from ash) during this event caused any harm to the
environment or an exceedance of any water quality threshold.
The facility did take preventative measures of providing berms prior to shutdown, which did hold
back the release. The facility should continue to proactively provide preventative measures
especially during shutdowns to protect the environment.
c. April 24, 2009-Approx. 1000 gallons of wash water and wax from the press exhaust ductwork
breached a berm during a clean -out procedure being conducted by a contractor and flowed off
a concrete pad and down a gravel road on -site. It was explained in a follow-up report that
personnel took immediate action to collect and absorb the water and that no discharge entered
the storm drain or reached waters of the state.
To prevent this occurrence in the future, the plant has added a requirement for plant personnel
to oversee the collection and management of process water generated during cleaning
operations to ensure proper procedures are followed.
4. Please review all secondary containment and spill prevention and response.
a. It is requested that the facility lock -out valves by the railroad delivery station due to the nature of
the chemicals. A chemical spill should necessitate authorized personnel only access valves
(with a key to a lock) to open these valves if a release should be needed. The limited access
could provide a preventative measure for accidental releases that could occur during loading
and unloading of chemicals. Accessibility policy to open drains and valves that release to storm
conveyances or outfalls should be reviewed.
b. It is requested that the facility review the conditions at outfall 002 (the outfall that receives both
stormwater and the permitted condensate discharge). Significant signs of erosion and rilling
were observed The installation of a BMP structure to slow runoff should be considered to
prevent further erosion issues at this outfall.
c. It is requested that the facility closely monitor the Ash overflow tank near outfall 002, The
facility should take preventative measures to ensure ash water does not overflow to outfall 002.
The BMP structure discussed above should provide some containment in the event of an ash
overflow.

NCG070075 •
Page 3
d. The facility should consider a careful spill and response plan with regards to the 225,000 gallon
above ground storage tank that contains high BOD process waters for reuse that does not
currently have secondary containment.
5. The facility has two stormwater outfalls not currently identified in the permit that eventually discharge to
outfall 003. It is recommended that the site apply for representative ouffall status (ROS) to cover these two
ouffalls in the permit. Please contact me if you have questions on applying for ROS.
6. Sampling was conducted at outfall 003 and the results indicate the facility is in compliance with all applicable
permit benchmarks. The results are attached. Should you obtain sample results in the future that exceed
the benchmarks set forth in your permit, please note that you are required to follow the tiered responses as
outlined in your permit.
Further details of this inspection can be found in the attached compliance inspection report. A record of the
subsequent October 20, 2009 site visit is also attached for your records
It is our goal to insure the quality of the surface waters of this State.
If I can be assistance to you or your staff, please do not hesitate to contact me at 919-7914200.
Sincerely,
Autumn Romanski
Enclosures
cc: Mr. Ross Reid
Environmental Manager
Louisiana Pacific Corporation
10475 Boston Rd,
Roxboro, NC 27574
Central files
RRO Files -Wastewater
3400 Barrett Drive
Raleigh, North Carolina 27 None hCarolina
Phone: [phone] Fax:x: 919-788-7159
atarallty

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I � s
Permit: NCG210301
SOC:
County: Person
Region: Raleigh
Compliance Inspection Report
Effective: 08/01/08 Expiration: 07/31/13 Owner: Louisiana Pacific Corporation
Effective: Expiration: Facility: Roxboro facility
10475 Boston Rd
Contact Person: Barry McCormick
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Roxboro NC 27574
Title: Phone: [phone]
Certification: Phone:
Inspection Date: 09/30/2009 Entry Time: 12:00 PM Exit Time: 04:00 PM
Primary Inspector: Autumn H Romanski� ,G'_ _ Phone: [phone]
Secondary Inspector(s): ✓`'��
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stonmwater Discharge COC
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page:1

Permit: NCG210301 Owner - Facility: Louisiana Pacific Corporation
Inspection Date: 09/30/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page:2

Permit: NCG210301 Owner - Facility: Louisiana Pacific Corporation
Inspection Date: 09/30/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑
❑
# Does the Plan include a General Location (t1SGS) map?
■
❑
❑
❑
# Does the Plan include a "Narrative Description of Practices'?
■
❑
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑
❑
# Does the facility provide all necessary secondary containment?
■
❑
❑
❑
# Does the Plan include a BMP summary?
■
❑
❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
❑
❑
# Does the facility provide and document Employee Training?
■
❑
❑
❑
# Does the Plan include a list of Responsible Party(s)?
■
❑
❑
❑
# Is the Plan reviewed and updated annually?
■
❑
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment: The SPPP Plan is currently being updated to incorporate recent physical
changes and improvements at the plant. Please see summary for details.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑
Comment: It was explained that qualitative monitoring is completed as required.
However, access to some of the outfalls showed significant erosion and trilling that
should be addressed promptly by the facility at outfalls 001 and 002. The installation of
a BMP structure to slow runoff is being considered (by the outfall that receives SW
runoff, as well as, permitted condensate discharge), 0.4
Analytical Monitoring y Yes No NA NE
Has the facility conducted its Analytical monitoring? ■ ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑
Comment: Sampling was completed on September 23, 2009. Results are not yet
available.
Sampling was also conducted at outfall 003 during this inspection and results will be
reported as soon as they are available
Page: 3

Permit: NCG210301 Owner - Facility: Louisiana Pacific Corporation
Inspection Date: 09/30/2009 Inspection Type: Compliance Evaluation Reason for Vlsit: Routine
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ 0
# Were all outfalls observed during the inspection?
MCI 00
# If the facility has representative outfall status, is it properly documented by the Division? Q Cl ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? M ❑ ❑ f]
Comment: The facility has 4 permitted outfalls. Tefacility has 2 un-named outfalls
that flow to the fire pond, that should be considered outfalls and should fall under
representative outfall status at (final outfall 003).
Page 4

NCG2I010
June 23, 2006 P"O ,S
NC Dept Environment & Natural Resources
Attn: Mr. Myrl Nisely
1628 Mail Service Center
Raleigh, NC 27699-1628
Dear Mr. Nisely,
LP
BUILDING PRODUCTS
q(6
0
This letter is being submitted to you as requested during your June 15, 2006 site visit. Its
purpose is to summarize conditions and activities relating to the reported fish kill that
occurred in the "fire pond" located at the LP Roxboro OSB facility.
The LP Roxboro mill produces Orientated Strand Board (OSB) on an automated production
line. Trees are fed into the mill with a large crane, debarked, then cut into "wafers." The
wafers are dried then transported to dry storage bins. Wafers are fed from the dry bins into
one of the three blenders which coat the wafers with Phenol -Formaldehyde (PF) resin, 4,4-
Methylene Diphenyl Diisocyanate (MDI) resin, and paraffin wax before they are transported
via conveyor to the forming line. The forming line applies layers of wafers to mats that are
then pressed into OSB.
On June 13, at approximately 2:40 A.M. a major fire started in the blenders, and spread to
the forming line and the dry storage bins before being completely extinguished 14 hours
later. The fire was extinguished using a combination of water from the public utility and
water pumped out of a small onsite pond, referred to as the "fire pond." The majority of
water used to fight the fire drained out the south side of the mill and was conveyed by
several storm drains to a small stream which flows into the fire pond. In order to try to
minimize the impact to the environment, absorbent booms were installed around storm
drains receiving firewater runoff.
On June 14, 2006 you were contacted and informed of the event and the precautions LP took
to protect water quality. Mr. Ross Reed contacted you again on June 15, 2006 at
approximately 9:30 A.M. to notify you that LP staff had discovered dead fish in the fire
pond. The cause of their death was originally unknown, but we now believe it was caused
by resin residue washed into the pond by fire fighting water used to extinguish the burning
blenders. This belief is based on the physical characteristics of a reddish sheen that was
ADDRESS 10475 Boston Road
�7Rooxxboro, NC 27574
'I756. 'EI. 599.8080
936 rNx 5".599.5153
Wr'.i+ wv Ipcorp.corn

Mr. Nisely
06/23/06
Page 2 of 2
observed along one bank of the pond. It should be noted that the sheen was only visible
when steady winds forced the residue to accumulate along a bank.
The June 151h verbal notification resulted in a site visit by you later that day. During the
visit, Mr. Reed showed you some of the proactive measures LP had taken to prevent an
incident like this from occurring. As you saw, there was evidence that those measures had
successfully limited the amount of residual materials washed away by the runoff of fire
fighting water. Unfortunately, residues that were carried to the fire pond killed 290 fish
(113 bass, 50 carp, and 127 brim) on June 141h and approximately 50 more on June 151h. No
additional fish have been discovered since June 151h. A visual inspection of the creek the fire
pond discharges into found no indications that it had been impacted by this event or
residues had been washed off LP's property. As requested during your visit, photographs
of the fish collected June 14'h are attached for your review.
The Roxboro LP mill is committed to protecting the environment and truly regrets that
residues carried from the mill by fire fighting water negatively impacted water quality. In
an effort to limit the impact of these residues as quickly as possible an emergency response
contractor, HMHTTC Response, was hired to remove the sheen from the fire pond.
Response equipment was mobilized to our facility on June 14th and cleanup operations
began the following morning. The sheen was collected with booms and removed from the
pond by a vacuum truck. The vacuum truck deposited the removed materials into a frac-
tank that had been delivered to the property the day before. On June 191h, HMHTTC
returned to the site to remove any residual that had appeared on the pond over the
weekend. The removal of the visible sheen and lack of additional dead fish indicate that
these actions have mitigated our negative impact on the lake.
If you have any questions or concerns, please contact me at [phone], ext. 209.
Sincerely,
Ross Reed
Plant Environmental Manager
cc: Wayne Young, Roxboro OSB Plant Manager
Don Sodersten, OSB/EWP Environmental Manager
Attachment

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