NCS000106_NOD and Inspection Report_20201120

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Director
NORTH CAROLINA
Environmental Quality
November 20, 2020
CERTIFIED MAIL: 7013 2630 00018990 4634
RETURN RECEIPT REQUESTED
WestRock Kraft Paper LLC
Attn: Benjamin P. White
P.O. Box 458
Roanoke Rapids, NC 27870
Subject: NOTICE OF DEFICIENCY (NOD-2020-PC-0500)
NPDES Individual Stormwater Permit No. NCS000106
WestRock Kraft Paper LLC
Halifax County, North Carolina
Dear Mr. White:
On November 18, 2020, Aana Gamble from the Central Office of the Division of Energy, Mineral, and
Land Resources (DEMLR) conducted a compliance inspection for the WestRock Kraft Paper LLC
facility located at 100 Gaston Road in Roanoke Rapids. DEMLR would like to thank Environmental
Manager Michael Knudson for his assistance on site during the inspection. A copy of the inspection
report is enclosed for your review.
The subject facility is covered by NPDES Individual Stormwater Permit NCS000106. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as
the Roanoke River, a Class C waterbody in the Roanoke River Basin.
As a result of the file review and compliance inspection, the following deficiencies are noted:
1) Stormwater Pollution Prevention Plan (SWPPPJ
The SWPPP has been incorporated into the facility's Spill Prevention, Control, and
Countermeasures (SPCC) plan. While many required elements of the SWPPP were present, the
following deficiencies were found:
• There was no General Location Map. [Part II, Section A, Item 1a]
• Site maps were included, but were missing required components. [Part II, Section A,
Item 1c]
• There was no list of significant spills or notation that no significant spills have
occurred in the past three years. [Part II, Section A, Items 1d and 7]
• There was no certification that the stormwater outfalls have been evaluated for the
presence of non-stormwater discharges. [Part II, Section A, Item 1e]
• There was no Feasibility Study. [Part II, Section A, Item 2a]
E Q , North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
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• While the SPCC Plan was updated in February 2020, the annual update did not meet
the requirements of the Permit because there was no recertification of non-
stormwater discharge or re-evaluation of Best Management Practice (BMP)
effectiveness. [Part II, Section A, Item 7]
• A facility inspection program was present, but did not meet the Permit
requirements because it only entails monthly inspection of secondary containment
and other SPCC-related BMPs. The inspection program did not include inspection of
other stormwater BMPs/systems, such as the grassy drainage areas observed
during the site inspection. [Part II, Section A, Item 8]
Required Response
The corrected SWPPP components must be submitted to DEMLR for review and approval within 90
calendar days of receipt of this notice.
Thank you for your attention to this matter. This office requires that the deficiencies, as noted
above and detailed in the enclosed inspection report, be properly resolved. Failure to address the
deficiencies could result in the issuance of a Notice of Violation, which could be subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you have any questions or
concerns, please contact Aana Gamble at [phone], or via email at [e-mail].
Sincerely,
Annette Lucas, PE
Stormwater Program Supervisor
Division of Energy, Mineral, and Land Resources
Enclosure: Inspection Report (11-18-2020)
cc: Benjamin P. White, WestRock Kraft Paper LLC, ben.whitePwestrock.com
Chris Williams, WestRock Kraft Paper LLC, chris.m.williamsowestrock.com
Thad Valentine, DEMLR Raleigh Regional Office, thad.valentinePncdenr.gov

Compliance Inspection Report
Permit: NCS000106 Effective: 08/01/09 Expiration: 07/31/14 Owner: Westrock Kraft Paper LLC
SOC: Effective: Expiration: Facility: Roanoke Rapids MITI WWTP
County: Halifax 100 Gaston Rd
Region: Raleigh
Roanoke Rapids NC 27870
Contact Person: Benjamin P White Title: General Manager Phone: [phone]
Directions to Facility:
100 Gaston Rd. - The landfill is located across the river from the paper mill, which is in Halifax County. From Raleigh, take Interstate
64 east to 1-95 north. Take exit 176 and follow Rt. 46 west to Rt. 48 south. Mill is on left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/18/2020 Entry Time 10:45AM
Primary Inspector: Aana C Gamble
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Exit Time: 12:30PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 4

Permit: NCS000106 Owner - Facility: Westrock Kraft Paper LLC
Inspection Date: 11/18/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
See Inspection Letter
Page 2 of 4

Permit: NCS000106 Owner - Facility: Westrock Kraft Paper LLC
Inspection Date: 11/18/2020 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 (USGS) map?
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
❑ 0 ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ 0 ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ 0 ❑ ❑
# Does the facility provide all necessary secondary containment?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
0 ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ 0 ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ 0 ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
E ❑ El ❑
Comment: The SWPPP has been incorporated into _the _SPCC Plan. There is no general location maD (Part
II, Sec. A, Para. 1 a). While site maps are included, they do not meet the requirements of Part II
Section A of the permit (e.g. stormwater outfalls, BMPs, impervious area, etc.). There is no
notation that no spills have occurred (per Part II, Section A. Para. 7). There is no feasibility study
(Part II, Sec. A, Para. 2a). While the plan was updated in February 2020, there is no
recertification of non -SW discharge or re-evaluation of BMP effectiveness (Part II Sec. A Para.
7). While the facility inspection program includes monthly inspection of secondary containment
and other SPCC-related BMPs, there is no stormwater facility inspection of other stormwater
BMPs/systems (Part II, Sec. A, Para. 8).
Despite the above deficiencies, the secondary containment requirements and records, as well
as the spill prevention and response plan, were very detailed, complete, and up-to-date.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? E ❑ ❑ ❑
Comment: Outfall 001 (Tent Outfall) is representative of Outfall 002 (Storeroom Outfall). Qualitative
monitoring was complete for both outfalls.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ❑ ❑
Comment:
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
Yes No NA NE
■❑❑❑
Page 3 of 4

Permit: NCS000106 Owner - Facility: Westrock Kraft Paper LLC
Inspection Date: 11/18/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
# Were all outfalls observed during the inspection? N ❑ M ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ 0 El ❑
Comment: There was no certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges as required by Part II, Sec. A. Para. 1 e of the permit.
Both outfalls were observed and found to be in good condition. There were no solids, sheen or
other signs of contamination at either outfall.
Page 4 of 4