NC0000752_Ownership Change_20191025

ROY COOPER
Governor
MICHAEL S. REGAN
Secreiar�
LINDA CULPEPPER
Director
NORTH CAROLINA
F.nrirovu>'untet Quauty
October 25, 2019
Mr. Benjamin P. White, General Manager
WestRock Kraft Paper, LLC
P.O. Box 458
Roanoke Rapids, NC 27870-0458
Subject: NPDES Permit NC0000752
Transfer of Ownership/Permit Modification
Roanoke Rapids Mill WWTP
Grade IV Biological WPCS
Halifax County
Dear Mr. White:
The Division hereby re -issues permit NC0000752. This action is taken to show the change in ownership
of the subject facility. This permit is issued pursuant to the requirements of North Carolina General Statute 143-
215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection
Agency dated October 15, 2007 (or as subsequently amended).
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty (30)
days after receiving this letter. Your request must take the form of a written petition conforming to Chapter 150B
of North Carolina General Statutes, and you must file it with the Office of Administrative Hearings, 6714 Mail
Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall remain
final and binding.
This permit is not transferable except after notice to the Division. The Division may require modification
or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other
permits which may be required by any other Federal, state, or local government.
If you have any questions concerning this matter, please contact Charles H. Weaver at [phone] or
via e-mail [[e-mail]].
cc: NPDES Unit
Sincerely,
7{i
o Linda Cul r �/
Director, Division of Water Resources
,�-
�A�
North Carolina Department of Environmental Quality I Division of Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-707-3616

Permit NC0000752
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
WestRock Kraft Paper, LLC
is hereby authorized to discharge wastewater from a facility located at the
Roanoke Rapids Mill WWTP
100 Gaston Road
Roanoke Rapids
Halifax County
to receiving waters designated as the Roanoke River in the Roanoke River Basin in accordance with
effluent limitations, monitoring requirements, and other applicable conditions set forth in Parts I, II, III,
and IV hereof.
This permit shall become effective October 25, 2019.
This permit and authorization to discharge shall expire at midnight on March 31, 2022.
Signed this day October 25, 2019.
L' Culpeppe , D t
ision of Wate esources
y Authority of the Environmental Management Commission
Pagel of 8

Permit NC0000752
Grade IV Biological Water Pollution Control System [15A NCAC 08G .03021
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of
this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the
exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements,
terms, and provisions included herein.
WestRock Kraft Paper,- LLC is hereby authorized to:
1. Continue to operate an existing 28.0 MGD wastewater treatment facility (discharging via outfall 001)
that includes the following components:
e Mechanical bar screen
♦ Primary clarifier
♦ Emergency holding pond
♦ Sludge lagoon
♦ Aeration basin
♦ Three stabilization ponds
2. Continue to discharge non -contact cooling water from the B & C evaporator (via outfall 002).
3. Discharge from said treatment works, located at the Roanoke Rapids Mill, off Gaston Rd in Roanoke
Rapids, Halifax County. Effluent from the locations, specified on the attached map will flow into the
Roanoke River, currently classified C waters in the Roanoke River Basin.
Page 2 of 8

Permit NC0000752
Grade IV Biological Water Pollution Control System [15A NCAC 08G .0302]
Part I.
A. (1.) EFFLUENT LEMTATIONS AND MONITORING REQUIREMENTS (001)
[15A NCAC 02B .0400 et seq., 02B �.0500 et seq.] 'I.
During the period beginning on the effective date of the permit and lasting until expiration; the Permittee is
authorized to discharge from outfall 001: process water and stormwater. Such discharges shall be limited and
monitored' by the Permittee as specified below:. ,
EFFLUENT CHARACTERISTICS
, a 'i .. _
[eDMR code]
LIMITS
•1
-sl .,.�..i F,±r .�.i%
MONITORING°REQUIREMENTS "V
f.��1�R '. .' S 15.t2 _ ! •f ti.7C:a..
MwAlrAverage
Daily Maximum
Measurement
uenc
Sample
T
Sample
L:ocation�. ` <,
Flow [50050]
28.0 MGD
Continuous
Recorder
Influent or
Effluent
BOD, 5 day, 200C [QD310]
8,680.0
undild a*y
17,361.0
poundstday
Daily5
Composite
Effluent
Total Suspended Solids [QD530]
18,601.0
pounds/day
37,202.0
pounds/day
Daily5
Composite
Effluent
Dissolved Oxyden, m /L 00300
Dally5
Grab
Effluent, U, D
Temperature, OC 1000101
Daily5'
Grab
Effluent, U, D
ConductWily, prfihblcm 00094 '
Q611y5
Grab
Effluent, U, D
NH3 as N, m /L [CO6101
Monthl•
Comp site
Effluent
Total Nitrogen, mg/L [CO600]
NO2+NO3+TKN ,
Monthly
Composite
Effluent
Total Phosphorus, m /L C0665
Monthly
Composite
Effluent
Chronic Toxic' U GP36
Quarterly
Composite
Effluent
Total Co r3 [910421
211.25 /L
227.36 /L
Quarterly
Composite
Effluent
H 00400
_ _.
> 6.0 and < 9.0
standard units
Dail'
Grab'.
Effluent
Pentachloio henol4 39032 I
T
1.80 pouridilddy
Week
� Grati,' •
' . 'Effluert
Trichlorohenol4 1818481
1.64 pound s/da
veek
Grab
'Effluent
Total Hardness, m /L . 00900 ,
Monthly
Composite.
Effluent, U
Footnotes:
1. U: upstream at NC Highway 48 Bridge. D: downstream at NC Highway 158. All instream samples shall be collected as
grab samples. Stream sampling shall be conducted 3/week during June, July, August, and September and weekly during
the remainder of the year.
2. Chronic Toxicity (Ceriodaphnia) P/F at 3.7%; March, June, September and December; see A. (3.).
3. Monitoring for metals and the whole effluent toxicity test shall be conducted at the same time.
4. Monitoring for pentachlorophenol and trichlorophenol is not required unless chlorophenolic containing biocides are used
at the facility. If chlorophenolic-containing biocides are used at the facility, monitoring for pentachlorophenol and
trichlorophenol shall commence immediately for the duration of the use of the biocides and for a period of not less than
two months after discontinuing use of the biocides.
5. Daily shall mean everyday except Saturdays, Sundays, and legal holidays.
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR system [see A. (6.)].
There shall be no discharge offloating solids or visible foam in other than trace amounts.
Page 3 ofS

Permit NC0000752
Grade IV Biological Water Pollution Control System [15A NCAC 08G .0302]
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (002)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from outfall 002: non -contact cooling water. Such discharges shall be limited and
monitored' by the Permittee'as specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
cfvmcTERISTICS
(eDMR code]
Monfhty
Daliy'
Measurement
S6mple .
Sample�Location
.Avera e {
{.tMaxiMum..:
: Fr uenc t Y.:
T e
Flow 50050
Semi-annually
Estimate
Effluent
Temperature 'C 00010
See note 1
See note 1
Semi-annually
Grab
Effluent
pH [00400]
6.0 — 9.0 standard units2
Semi-annually
Grab
Effluent, Upstream,
Downstream3
Footnotes:
1. The temperature of the effluent will be regulated so that the temperature of the receiving stream does not increase
more than 2.8°C (5.05°F) above the natural water temperature and does not exceed a maximum of 29°C (842°F).
2. The pH shall not be less than 6.0 standard units nor more than 9.0 standard units. In the event that effluent pH shall
be recorded outside this range, any value that falls within the range -of pH measured at the upstream and downstream
points shall be considered compliant. Effluent pH shall be sampled on the same days that stream samples for pH are
taken [see A. (5.)].
3. Upstream: at NC Highway 48 Bridge. Downstream: at NC Highway 158.
4. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR system [see A.
(6.)]•
There shall be no chromium; zinc or copper added to the treatment system except as pre -approved
additives to biocidal compounds; The permittee shall obtain authorization from the Division prior to any
use of biocide in the cooling water [see A. (4.)].
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 8

Permit NC0000752
Grade IV Biological Water Pollution Control System [15A NCAC 08G .0302]
A. (3.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
[I 5A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 3.7%.
The permit holder shall perform at a minimum, quarter monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions
or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or
subsequent versions. The tests will be performed during the months of March, June, September, and
December. These months signify the first month of each three-month toxicity testing quarter assigned to the
facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the fast test of any single quarter results in a failure or a ChV below the permit
limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following
months, as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP313 for the
pass/fail results and THP313 for the Chronic Value. Additionally, DWR Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after
the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the
address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter,
which is the three-month time interval that begins on the first day of the month in which toxicity testing is
required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
Page 5 of 8

Permit NC0000752
Grade IV Biological Water Pollution Control System [15A NCAC 08G .0302]
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
A. (4.) BIOCIDE CONDITION
[G.S. 143­215.1(b)]
The permitted shall not use any biocides except those approved in conjunction with the permit application. The
permitted shall notify the Director in writing at least ninety (90) days prior to instituting use of any additional
biocide in the treatment system, which may be toxic to aquatic life (other than biocides previously reported to the
Division). Such notification shall include completion of Biocide Worksheet Form 101 and a map indicating the
discharge point[s] and receiving stream[s].
A. (5.) , pH REOPENER
[G.S. 143-215.1(b)]
The Division may re -open this permit to remove pH limitation footnotes at Outfall 002, should new information
indicate water quality problems due to declining pH in this portion of the river.
A. (6.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports.
The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Reporting
Records Retention
Monitoring Reports
1. 'Reporting Requirements !Supersedes Section D. (2.) and Section E. (5.) (a)l
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during, the previous month(s) shall be summarized for each month and submitted
electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and
submit DMRs electronically using the internet'. Until such time that the state's eDMR application is
compliant with EPA's Cross -Media Electronic Reporting Regulatiod(CROMERR), permittees will be
required to submit all discharge monitoring data to the state electronically using eDMR and will be required
to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the
computer printed eDMR to the following address:
Page 6 of 8

Permit NC0000752
Grade IV Biological Water Pollution Control System [15A NCAC 08G .0302]
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being
physically located in an area where less than 10 percent of the households have broadband access, then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request
a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver
from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each
electronic submission. The permittee should use the EPA's website resources to identify the initial recipient
for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or
the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving
electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of
electronic submission and for each state. Instructions on how to access and use the appropriate electronic
reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at:
https•//www federaire ig ster.g_ov/documents/2015/10/22/2015-24954/national-pollutant-discharge-elimination-
system-nodes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic
reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division.
Page 7 of 8

Permit NC0000752
Grade IV Biological Water Pollution Control System [15A NCAC 08G .03021
Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty (60) days prior to the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and
shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the
Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved
reporting waiver request may submit monitoring data and reports on paper to the Division for the period that
the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
http://deq.ne.gov/about/divisions/water-resources/edmr
4. minatory Requirements ISupplements Section B. (11.) (b) and Supersedes Section B (11) (d)l
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part I1, Section
B. (11.) (a) or by a duly authorized representative of that person as described in Part 11, Section B. (11.) (b).
A person, and not a position, must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and
login credentials to access the eDMR system. For more information on North Carolina's eDMR system,
registering for eDMR and obtaining an eDMR user account, please visit the following web page:
http//d�,nc.&(�%,/about/div_i-sions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qual fled personnel properly gather and
evaluate the information submitted Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of
my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations. "
5. Records Retention ISupplements Section D. (6.)l
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These
records or copies shall be maintained for a period of at least 3 years from the date of the report. This period
may be extended by request of the Director at any time [40 CFR 122.41 J.
Page 8 of 8

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774
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WestRock Kraft Paper, LLC
Latitude: 362 28' 19" Longitude: -779 38' 14"
Sub -basin: 03-02-08 Stream Class: C
Receiving Stream: Roanoke River
Facility
Location
North NPDES Permit NC0000752
Halifax Count

ROY COOPER
It MICHAEL S. REGAN
co"I' ,
LINDA CULPEPPER
Water Resources Interim Utreom,
ENVIRONMENTAL QUALITY
PERMIT NAME/OWNERSHIP CHANGE FORM
I. CURRENT PERMIT INFORMATION:
Permit Number: NC0000752
1. Facility Name: KapStone Paper and Packaging
II. NEW OWNERMAME INFORMATION: RECEIVED
1. This request for a name change is a result of:
OCT 0 3 1019
_x_a. Change in ownership of property/company
b. Name change only NCDEQ0WNI
c. Other (please explain):
2. New owner's name (name to be put on permit):
WestRock Kraft Paper LLC
3. New owner's or signing official's name and title: Benjamin P. White
(Person legally responsible for permit)
General Manager
(Title)
4. Mailing address: PO BOX 458 City: Roanoke Rapids,
State: NC_ Zip Code: 27870 Phone: ( 252) 533-6335_
E-mail address: ben. white(a�westrock.com
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION UNLESS ALL OF THE
APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
1. This completed application form
2. Legal documentation of the transfer of ownership (such as a property deed, articles of
incorporation, or sales agreement)
[see reverse side of this page for signature requirements]
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, NC 27699-1617
919 807 6300 919-807-6389 FAX
http s: //deq. nc. gov/about/d i vi sions/water-resources/water-resources-permits/wastewater-bran ch/npdes-wastewater-perm its

NPDES Name & Ownership Change
Page 2 of 2
Applicant's Certification:
C'm,4) f A�14,t , attest that this application for a
name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature: / �`'�' /"�C Date.
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING
INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DEQ / DWR / NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 1112017

^^- WestRock
DELEGATION OF AUTHORITY FOR ENVIRONMENTAL MATTERS
CONTAINERBOARD MILLS
As Executive Vice President of Containerboard Mills, I hereby ratify and confirm the authority
of each General Manager (GM) and Designated Representative (DR) listed below to act as
the responsible official and/or the duly authorized representative for the purpose of overseeing
environmental compliance matters at the facility(ies) he manages (Covered Facilities). This
Delegation of Authority includes, without limitation, the authority to execute and submit all
environmental applications, certifications and reports required by the Covered Facilities, as
well as the authority to act with respect to facilities in the U.S. as the "responsible official" as
that term is defined at 40 C.F.R. § 70.2 and corresponding U.S. federal, state and local agency
regulations.
To the extent allowed by applicable law, the GM or DR may re -delegate this authority, in
writing, to any appropriately trained facility manager for the specific purpose of executing any
monthly discharge monitoring or similar wastewater report that may be required under a
National Pollutant Discharge Elimination System (NPDES) or comparable state or local
wastewater discharge permit.
This Delegation of Aut ortty will rem in in effect until revoked or superseded.
Thomas M. Stigers
Executive Vice Pre ident, Containerboard Mills
WestRock
Effective Date: September 9, 2019
COVERED FACILITY STATE GENERAL MANAGER I COVERED FACILITY STATE I GENERAL MANAGER
Cowpens
SC
Steve Leahy
North Charleston
SC
John McCarthy
Dublin
GA
Brian Kinsey
Panama City
FL
Brett Tremblay
Fernandina Beach
FL
Dan Rowland
Pointe-aux-Trembles
QC
Karyne Trudeau
Florence
SC
Devin Nix
Roanoke Rapids
NC
Ben White
Hodge
LA
Eric Taylor
Solvay
NY
Peter Tantalo
Hopewell
VA
James Osborne
Stevenson
AL
Darrell Daubert
Jacksonville (Seminole)
FL
Tom Crockett
Tacoma
WA
John Brandt
La Tuque
QC
Pierre Pacarar
West Point Mill
VA
Chris Broome
Longview
WA
Steve Devlin
CLOSED MILLS
Nina Butler
LvnchburR
VA
Mark Murohv

\ WestRock
V
September 24, 2019
VIA OVERNIGHT FedEx
Mark Powers
Regional Supervisor Raleigh Region
Division of Water Quality, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
100 Gaston Road office: 252-533-6000
Roanoke Rapids, NC
27870
NC Dept of Environmental Quality
OCT v 1 2019
Raleigh Regional Office
Re: Permittee Name Change — KapStone Kraft Paper Corporation
• Permits: NPDES, Distribution of Class A Residuals, Surface Disposal of Industrial
Byproduct Residuals
• Permit Numbers:NC0000752, WQ0021577, W00000436
• Facility Address: 100 Gaston Road, Roanoke, Rapids, NC
Dear Mr. Powers
On November 2, 2018, WestRock Company ("WestRock") acquired KapStone Kraft Paper and Packaging
Corporation ("KapStone"), including its subsidiary, KapStone Kraft Paper Corporation. KapStone Kraft
Paper Corporation holds the above -referenced environmental permits (the "Permits"). To facilitate our
integration and marketing efforts and streamline administrative processes, WestRock plans to convert
KapStone Kraft Paper Corporation from a corporation to a limited liability company ("LLC"). Also, the name
of this entity will be changed to WestRock Kraft Paper, LLC. The conversion to an LLC and accompanying
name change will become effective on or about September 30, 2019.
The upcoming transactions will not have any direct, immediate impact on the permitted facility from an
environmental standpoint. No modification of the manufacturing process at the facility will occur in
connection with the name change, nor will any alteration in the nature, rate or quantity of any environmental
discharges from the facility take place.
We respectfully request that the agency update the Permits to identify WestRock Kraft Paper, LLC as the
permittee. Enclosed are the Ownership Change forms and a letter from Thomas M. Sigers, Executive Vice
President, WestRock, delegating authority for environmental matters for the Roanoke Rapids mill to Ben
White, General Manager (Formerly Mill Manager under KapStone).
The permits for ownership change are NPDES (WQ0021577), Distribution of Class A Residuals
(WQ0021577), Surface Disposal of Industrial Byproducts (W00000436)
If yo,u have questions regarding our request, please contact Mike Knudson at 252-533-6280 or
[e-mail]. Thank you for your cooperation in this matter.
Sincerely,
Benjamin P. White
General Manager
Enclosures
cc: Mike Knudson
Neal Davis