WQ0000461_Compliance Evaluation Inspection_20200316

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Michael Rhea — EHS Manager
Louisiana-Pacific Corporation
P.O. Box 98
Roaring River, NC 28669
NORTH CAROLINA
Environmental Quality
March 16, 2020
Subject: Compliance Evaluation Inspection
Louisiana-Pacific Corporation
LP Roaring River Residuals Distribution & Land Application Program
Permit No. WQ0000461
Wilkes County
Dear Mr. Rhea:
On March 12, 2020, staff of the North Carolina Division of Water Resources Winston-Salem Regional Office
(DWR) performed an announced routine compliance inspection of the subject facility's residuals distribution
and land application program. This inspection was conducted by DWR staff person Mr. Justin Henderson.
Onsite facility records and documents were found to be complete and in good order. The inspection of the
subject facility and the observed land application activities were found to be compliant with Permit No.
WQ0000461.
A separate DWR office file review of the groundwater self -monitoring reports (GW-59) for the reporting
period of Calendar Year (CY) 2019 was also conducted. The GW-59 report for monitoring well MW-5
continues to indicate nitrate concentrations that are in excess of the NC Groundwater Quality Standards [I5A
NCAC 02L .0202(g) (103)], which constitutes a violation of Permit Condition II. 15.
Please refer to the enclosed compliance inspection report form for additional observations and comments. If
you have any questions regarding this letter, please contact Justin Henderson or me at [phone].
Sin bocu4iled by:
LO, -T SMdtr
on'9ftTdF','A%istant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: James Boles, ORC- James.Boleskli2corp.com
Laserfiche Files (Electronic copies)
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NOh �HCARO UHA
^^ •^ �ku^m I u�•i` r 336.776.9800

Compliance Inspection Report
Permit: WQ0000461 Effective: 11/01/15 Expiration: 10/31/20 Owner: Louisiana-Pacific Corporation
SOC: Effective: Expiration: Facility: Roaring River Mill Residuals Land Application F
County: Wilkes 1151 Abtco Rd
Region: Winston-Salem
Roaring River NC 28669
Contact Person: Sharon Wetzel Title: EHS Manager Phone: [phone]
Directions to Facility:
Highway 268
System Classifications: LA,
Primary ORC: James Alfred Boles
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: 987522 Phone: [phone]
NC0005266 Louisiana-Pacific Corporation - LP Roaring River WWTP
Inspection Date: 03/12/2020 Entry Time 01:30PM Exit Time: 03:15PM
Primary Inspector: Justin L Henderson Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
Land Application Site Storage
(See attachment summary)
Inspection Type: Compliance Evaluation
Sampling
Transport
Page 1 of 4

Permit: WQ0000461 Owner - Facility: Louisiana-Pacific Corporation
Inspection Date: 03/12/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On March 12, 2020, staff of the North Carolina Division of Water Resources Winston-Salem Regional Office (DWR)
performed an announced routine compliance inspection of the subject facility's residuals distribution and land application
program. This inspection was conducted by DWR staff person Mr. Justin Henderson. Onsite facility records and documents
were found to be complete and in good order. The inspection of the subject facility and the observed land application
activities were found to be compliant with Permit No. WQ0000461.
A separate DWR office file review of the groundwater self -monitoring reports (GW-59) for the reporting period of Calendar Ye,
(CY) 2019 was also conducted. The GW-59 report for monitoring well MW-5 continues to indicate nitrate concentrations that
are in excess of the NC Groundwater Quality Standards [15A NCAC 02L .0202(g) (103)], which constitutes a violation of
Permit Condition II. 15.
Page 2 of 4

Permit: WQ0000461 Owner - Facility: Louisiana-Pacific Corporation
Inspection Date: 03/12/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Land Application
Distribution and Marketing
Yes No NA NE
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
0
❑ ❑ ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ ❑
Are there any GW quality violations?
❑ ❑ ❑
Is GW-59A certification form completed for facility?
❑ ❑ ❑
Is a copy of current permit on -site?
❑ ❑ ❑
Are current metals and nutrient analysis available?
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
❑ ❑ ❑
a. TCLP analysis?
❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑ ❑ ❑
Are PAN balances being maintained?
❑ ❑ ❑
Are PAN balances within permit limits?
❑ ❑ ❑
Has land application equipment been calibrated?
❑
❑ ❑
Are there pH records for alkaline stabilization?
❑
❑ ❑
Are there pH records for the land application site?
❑
❑ ❑
Are nutrient/crop removal practices in place?
❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ ❑
Are hauling records available?
❑ ❑ ❑
Are hauling records maintained and up-to-date?
❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
0
❑ ❑ ❑
Comment: Monitoring of MW-5 continues to indicate exceedances of Groudwater Standards for Total NitratE
(NO3).
Sampling Yes No NA NE
Describe sampling:
Composite sample collected as residuals are generated.
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? 0 ❑ ❑ ❑
Is a copy of the spill control plan in the vehicle? 0 ❑ ❑ ❑
Page 3 of 4

Permit: WQ0000461 Owner - Facility: Louisiana-Pacific Corporation
Inspection Date: 03/12/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is the spill control plan satisfactory? 0 ❑ ❑ ❑
Does transport vehicle appear to be maintained? 0 ❑ ❑ ❑
Comment:
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? ❑ ❑ ❑
Is the application site in overall good condition? ❑ ❑ ❑
Is the site free of runoff/ponding? ❑ ❑ ❑
If present, is the application equipment in good operating condition? ❑ ❑ ❑
Are buffers being maintained? ❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application
0
❑ ❑ ❑
18% for subsurface application
❑
❑ 0 ❑
Are there access restrictions and/or signs?
❑
❑ ❑
Is the application site free of odors or vectors?
❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑
❑ ❑
For incorporation?
❑
❑ ❑
Does permit require monitoring wells?
❑ ❑ ❑
Have required MWs been installed?
❑ ❑ ❑
Are MWs properly located w/ respect to RB and CB?
❑
❑ ❑
Are MWs properly constructed (including screened interval)?
❑
❑ ❑
Is the surrounding area served by public water?
❑
❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑
❑ ❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑
❑ ❑
Is the water table greater than 173' bls.
❑ ❑ ❑
Is application occurring at the time of the inspection?
0
❑ ❑ ❑
Comment:
Page 4 of 4