NC0000752_Compliance Evaluation Inspection_20200325

ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
S. DANIEL SMITH
Director
Mr. Benjamin White, General Manager
WestRock Kraft Paper
P.O. Box 458
Roanoke Rapids, NC 27870
NORTH CAROLINA
Environmentat Quality
March 25, 2020
Subject: Compliance Evaluation Inspection
Roanoke Rapids Mill WWTP
Permit No. NC0000757
Northampton County
Dear Mr. White:
On March 11, 2020, Jason Robinson of the Raleigh Regional Office (RRO) conducted a compliance
evaluation inspection of the subject facility. The assistance provided by Mr. Christopher Williams, the
operator in responsible charge (ORC), Mr. Matthew Upton, the backup ORC, Mr. Michael Knudson,
Environmental Manager and Mr. Paul Kinnin, Environmental Technician (laboratory staff) was
appreciated as it facilitated the inspection process. The inspection report is attached. The following
observations were made:
1. This facility, known as Roanoke Rapids Mill WWTP and owned by Westrock Kraft Paper LLC
(formerly owned by Kapstone Kraft Paper Corporation) is permitted to discharge at a rate of 28.0
MGD and consist of.. mechanical bar screen, primary clarifier, emergency holding pond, sludge
lagoon, aeration pond, and three stabilization ponds. The sludge lagoon, aeration pond and
stabilization ponds and OutfalI 001 (and on -site landfill) are located on the opposite side of the
river from the Mill. Outfall 002 discharges non -contact cooling water on the Mill -side of the
river. Both outfalls discharge directly to the Roanoke River, a Class C water in the Roanoke
River basin.
The facility also has sludge -handling facility and onsite landfill that is covered by permit
WQ0000436 (Surface Disposal of Residual Solids (503 exempt).
2. The most recent permit for the new owner was just issued and effective on March 18, 2020. The
permit will expire on April 30, 2021. A renewal application should be submitted at least 180
days prior to expiration.
3. This treatment facility is classified as a WW-4. Mr. Christopher Williams (ORC) is a certified
WW-4 operator, and Mr. Matthew Upton (bORC) is a certified WW-3 operator.
4. The ORCs maintain a detailed daily logbook. Lab results, chain -of -custody forms, and electronic
E� N North Carolina Department of Environmental Quality 1 Division of Water Resources
IRaleigh Regional Office 13800 Barrett Drive ' Raleigh. North Carolina 27609
htk UIY} Mia
0A1dLmm'ma'Ww" r 919.7914200

Roanoke Rapid WWTI' Westrock Kraft Paper
Permit No, NCO000752
Discharge Monitoring Reports (eDMRs) were complete and current, kept in good order and
ready for review. August and October 2019 eDMR data was compared to lab bench sheets; no
data transcription errors were noted during the inspection. Parameter analyses are performed by
Meritech (Certificate # 165). Toxicity analysis is done by Environmental Testing Solutions
(Certification #37).
5. Field lab parameter calibration and analysis records were reviewed during the inspection. The
facility analyzes BOD, TSS, pH, conductivity, DO, Suspended Residue and temperature
(Certificate 9183). The laboratory was inspected in a cursory manner.
6. The influent bar screens are mechanically cleaned every 8 hours. Untreated wastewater can be
routed to the emergency holding pond prior to the bar screens. All three influent pumps into the
primary clarifier were in operation. The primary clarifier was in good condition.
7. Sludge from the primary clarifier is pumped via two sludge pumps into a blending tank and is
then dewatered at the sludge handling facility beside the clarifier. Two trains of belt presses,
screw presses, and chemical feed systems are present. Typically train operations are alternated
between the two. Dewatered sludge is disposed at the onsite land fill across the river via truck.
Leachate from the land fill and the old sludge pond flows by gravity into the aeration pond and is
treated along with the effluent from the primary clarifier (WQ0000436).
8. Effluent from the clarifier is transported across the river via gravity and is further treated at the
aeration pond across the river. There are thirty-one 2,135 hp aerators. One was down for
maintenance during the inspection. The number of aerators on-line is controlled by the DO level
in the pond.
9. Effluent from the aeration pond is further treated in the three in -series stabilization ponds before
being discharged to the river. Samples are taken at the discharge point of the final stabilization
pond. A composite sampler was present, and temperature was just below 4 degrees. Flow is
measured and reported just prior to the discharge. The flow meter was last calibrated on July 15,
2019.
10. Outfall 001 was observed. The right of way was maintained. The effluent was observed to be
clear and free of solids. No visible impacts were noted immediately downstream the effluent
pipe. Outfall 002 was observed from across the river (from Outali 001).
(see next page)
2of3

Roanoke Rapid WWTP— Westrock Kraft Paper
Permit No. NCO000752
The overall condition of the facility is compliant with Division standards. If you have any questions
regarding the attached reports or any of the findings, please contact Jason Robinson at
[e-mail]
Sincerely,
I,o ScottV inson
Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachments
Compliance Inspection Report
Cc: DWR Laserfiche
Raleigh Regional Office w:`attachment
Chris Williams, ORC: chris.m.williams c�7r.westrock.com
of

United states Environmental Protection Agency Form Approved.
EPA Waahingtcn, D.C. 20460 OMB No. 2040-0057
Water Compliance Inspection Report Approval expires 8.31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
1 1N 1 2 1s 1 3 NCO000752 11 12 20/03/11 17 18I r 1 19I � I 201 I
21 L�J u !J
6
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA Reserved
67 70 U 71 lJ 72 J 73L74 7 L80
Section 8: Facility Data
Name and location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Dale Permit Effective Date
POTW name and NPDES permit Number) 01 OOPM 20/03/11 18/09/01
Roanoke Rapids MITI WWiP
100 Gaston Rd Exit Time/Date Permit Expiration Date
Roanoke Rapids NC 27870 03-OOPM 20/03/11 22/03/31
Name(s) of Ons:te Representative(s)>Titles(s)/Phone and Fax Number(s) Other Facility Data
P/
Christopher Michael Williams/ORC1252-533.6237i
Name. Address of Responsible OfficiailTitlelPhone and Fax Number
Benjamin P While. PO Box 458 Ronok Rpd Afs NC 278701General Contacted
Manager/252-53M3351 Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement 0 Operations & Maintenar N Records/Reports
Sludge Handling DispoE Effluent/Receiving Wate 0 Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Names) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Jason T Robinson DWR/RRO W01919-791-4200/
�i��- -�. 3-041-zo
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yrlmolday Inspection Type (Cont.)
3I NC000!7�11 1 20/03/11 17 18 ICI
LJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On March 11, 2020, Jason Robinson of the Raleigh Regional Office (RRO) conducted a compliance
evaluation inspection of the subject facility. The assistance provided by Mr. Christopher Williams, the
operator in responsible charge (ORC), Mr. Matthew Upton, the backup ORC, Mr. Michael Knudson,
Environmental Manager and Mr. Paul Kinnin, Environmental Technician (laboratory staff) was
appreciated as it facilitated the inspection process. The inspection report is attached. The following
observations were made:
1. This facility, known as Roanoke Rapids Mill WWTP and owned by Westrock Kraft Paper LLC
(formerly owned by Kapstone Kraft Paper Corporation) is permitted to discharge at a rate of 28.0 MGD
and consist of: mechanical bar screen, primary clarifier, emergency holding pond, sludge lagoon,
aeration pond, and three stabilization ponds. The sludge lagoon, aeration pond and stabilization ponds
and Outfall 001 (and on -site landfill) are located on the opposite side of the river from the Mill. Outfall
002 discharges non -contact cooling water on the Mill -side of the river. Both outfalls discharge directly tc
the Roanoke River, a Class C water in the Roanoke River basin.
The facility also has sludge -handling facility and onsite landfill that is covered by permit WQ0000436
(Surface Disposal of Residual Solids (503 exempt).
2. The most recent permit for the new owner was just issued and effective on March 18, 2020. The
permit will expire on April 30, 2021. A renewal application should be submitted at least 180 days prior tc
expiration.
3. This treatment facility is classified as a WW-4. Mr. Christopher Williams (ORC) is a certified
WW-4 operator, and Mr. Matthew Upton (bORC) is a certified WW 3 operator.
4. The ORCs maintain a detailed daily logbook. Lab results, chain -of -custody forms, and electronic
Discharge Monitoring Reports (eDMRs) were complete and current, kept in good order and ready for
review. August and October 2019 eDMR data was compared to lab bench sheets; no data transcriptior
errors were noted during the inspection. Parameter analyses are performed by Meritech (Certificate #
165). Toxicity analysis is done by Environmental Testing Solutions (Certification #37).
5. Field lab parameter calibration and analysis records were reviewed during the inspection. The
facility analyzes BOD, TSS, pH, conductivity, DO, Suspended Residue and temperature (Certificate
#183). The laboratory was inspected in a cursory manner.
6. The influent bar screens are mechanically cleaned every 8 hours. Untreated wastewater can be
routed to the emergency holding pond prior to the bar screens. All three influent pumps into the
primary clarifier were in operation. The primary clarifier was in good condition.
7. Sludge from the primary clarifier is pumped via two sludge pumps into a blending tank and is then
dewatered at the sludge handling facility beside the clarifier. Two trains of belt presses, screw
presses, and chemical feed systems are present. Typically train operations are alternated between the
two. Dewatered sludge is disposed at the onsite land fill across the river via truck. Leachate from the
land fill and the old sludge pond flows by gravity into the aeration pond and is treated along with the
effluent from the primary clarifier (WQ0000436).
8. Effluent from the clarifier is transported across the river via gravity and is further treated at the
aeration pond across the river. There are thirty-one 2,135 hp aerators. One was down for maintenancE
during the inspection. The number of aerators on-line is controlled by the DO level in the pond.
Page# 2

Permit: NCO000752
Inspection Date: 03/11/2020
Owner - Facility: Roanoke Rapids MITI WWSP
Inspection Type: Compliance Evaluation
9. Effluent from the aeration pond is further treated in the three in -series stabilization ponds before
being discharged to the river. Samples are taken at the discharge point of the final stabilization pond.
composite sampler was present, and temperature was just below 4 degrees. Flow is measured and
reported just prior to the discharge. The flow meter was last calibrated on July 15, 2019.
10.Outfall 001 was observed. The right of way was maintained. The effluent was observed to be clear
and free of solids. No visible impacts were noted immediately downstream the effluent pipe. Outfall 002
was observed from across the river (from Outall 001).
Page#

Permit: NC0000752 Owner - Facility: Roanoke Rapids MITI WVVrP
Inspection Date: 03/11/2020 Inspection Type: Compliance Evaluation
Permit
Yes No
NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
■
❑
application?
Is the facility as described in the permit?
N
❑
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
n
❑
❑
❑
Is the inspector granted access to all areas for inspection?
E
❑
❑
❑
Comment:
Record Keeping
Yes
No
NA NE
Are records kept and maintained as required by the permit?
E
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
E
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
E
❑
❑
❑
Is the chain -of -custody complete?
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
8
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
E
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operatc
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
E
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification'
❑
❑
❑
is a copy of the current NPDES permit available on site?
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
0
Comment:
Laboratory[ Yes No NA NE
Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑
Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑
Page# 4

Permit: NC0000752 Owner - Facility: Roanoke Rapids MITI WUVTP
Inspection Date: 03/11/2020 Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
# Is the facility using a contract lab?
N
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
N
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
❑
Incubator (BOD) set to 20.0 degrees Celsius +1-1.0 degrees?
❑
❑
❑
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? E ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable E ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Bar Screens
Yes
No NA
NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
❑
❑
❑
Is the screen free of excessive debris?
N
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
E
❑
❑
❑
Comment:
Equalization Basins
Yes No
NA
NE
Is the basin aerated?
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
❑
❑
❑
■
Is the basin free of excessive grease?
[]
❑
❑
Are all pumps present?
❑
❑
❑
Are all pumps operable?
❑
❑
❑
Are float controls operable?
❑
❑
[]
Are audible and visual alarms operable?
❑
❑
❑
# Is basin size/volume adequate?
❑
❑
❑
Comment: Flow can be diverted to the Emergency Holding Pond prior to the bar screen.
Page# 5

Permit: NC0000752 owner - Facility: Roanoke Rapids MITI VVWrP
Inspection Date: 03/11/2020 Inspection Type: Compliance Evaluation
Primary Clarifier
Yes
No
NA NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
❑
❑
❑
Are weirs level?
■
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
■
❑
❑
❑
Is the site free of excessive floating sludge?
■
❑
❑
❑
Is the drive unit operational?
■
❑
❑
❑
Is the sludge blanket level acceptable?
❑
❑
❑
■
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
❑
❑
❑
■
Comment:
Solids Handling Eciuipment
Yes
No
NA NE
Is the equipment operational?
■
❑
❑
❑
Is the chemical feed equipment operational?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
M
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
■
❑
❑
❑
The facility has an approved sludge management plan?
■
❑
❑
❑
Comment: Sludge handling equipment and on -site landfill covered by permit WQ0000436
(Surface
Disposal of Residual Solids 503 exem t
Aeration Basins
Yes
No
NA NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
■
❑
❑
❑
Are surface aerators and mixers operational?
■
❑
❑
❑
Are the diffusers operational?
■
❑
❑
❑
Is the foam the proper color for the treatment process?
■
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
■
❑
❑
❑
Is the DO level acceptable?
■
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mgll)
■
❑
❑
❑
Page# 6

Permit: NCO000752 owner - Facility: Roanoke Rapids MITI WWrP
Inspection Date: OW11I2020 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Comment:
Lagoons
Yes
No
NA
NE
Type of lagoons?
Facultative
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
# Is a re -circulation line present?
110
❑
❑
Is lagoon free of excessive floating materials?
M
❑
❑
❑
# Are baffles between ponds or effluent baffles adjustable?
❑
❑
❑
Are dike slopes clear of woody vegetation?
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
❑
❑
❑
Are dikes free of seepage?
❑
❑
❑
Are dikes free of erosion?
❑
❑
❑
Are dikes free of burrowing animals?
0
❑
❑
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
❑
❑
❑
locations?
# If excessive algae Is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑
Is the lagoon surface free of weeds? 0 ❑ ❑ ❑
Is the lagoon free of short circuiting? 0 ❑ ❑ ❑
Comment: 3 stabilzation Ponds in series are located after the aeration basin and nrior to discharge.
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
❑
❑
❑
Is flow meter calibrated annually?
❑
❑
❑
Is the flow meter operational?
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
M
❑
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? M ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑
Comment:
Page# 7