WQ0000461_Staff Report_20200701

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July 1, 2020
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00000461
Attn: Poonam Giri Facility name: Louisiana Pacific Class A Land App. Program
From: Patrick Mitchell
Winston-Salem Regional Office
Note: This form has been adapted from the non-discharee facility staff report to docnment the review ofboth nondlscharee and NPDES permit applications and/or renewals. Pease complete all sections as they are applicable.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
a. Date of most recent site visit: March 12, 2020
b. Site visit conducted by: Justin Henderson
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
Explain anything that may be important for the permit writer to know: Facility operations which generate sludge
have reportedly been shutdown and no more sludge will be produced.
2. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
3. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
4. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
5. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Summary of findings resulting from this review: No compliance issues other than 2L violations of Nitrate at the
Compliance Boundary for the dedicated land application fields.
6. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
7. Check all that apply:
❑ No compliance issues
® Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? An NOV was issued for the 2L violations of
Nitrate and is continued to date. The solution thus far has been to eliminate land application onto the field closest
to the monitorine wells and allow natural attenuation to occur. Preliminary review of some of the data appears to
suggest that Nitrate concentrations have slightly decreased.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
8. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes® No ❑ N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
FORM: WQROSSR 04-14 Page 1 of 2

DocuSign Envelope ID: EB4E90EB-5F22-48F9-B18D-5F5BA5E1 EEA1
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Require a groundwater
remediation plan be
To address Nitrate 2L exceedances at Compliance Boundary and meet permit
submitted within 180 days
requirements/2L requirements.
of permit issuance.
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny p (Please state reasons: )
6. Signature of report preparer:
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Signature of regional supervisor:
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Date: July 1. 2020
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
As described above, the subject facility has changed operations and reportedly will no longer be producing sludge. They
have requested permit rescission. However, due to groundwater limit violations for Nitrate at the compliance boundary
the permit should not be rescinded until either groundwater is returned below 2L limits or an acceptable remediation
plans is received which justifies rescinding the permit. See attached Rescission Request Form for recommendation to
deny the permit rescission at this time.
FORM: WQROSSR 04-14 Page 2 of 2