NC0000752_correspondence_20230914

DocuSign Envelope ID: C010A699-7593-4F49-9D4D-B9A78C7EB424
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Benjamin P. White, General Manager
WestRock Kraft Paper
100 Gaston Road
Roanoke Rapids, NC 27870
Dear Mr. White:
NORTH CAROLINA
Environmental Quality
September 14, 2023
Subject: NC0000752 WestRock/Kraft Paper 001 and 002
Investigative Monitoring
Roanoke Rapids Mill WWTP
Halifax County (RRO) Facility Class IV
Recent concerns about elevated water temperatures in the Roanoke River have been brought to the attention of
the Division of Water Resources (DWR). Follow-up by DWR staff, along with communications with facility
personnel, indicates the WestRock facility is likely the source of the elevated instream water temperatures.
WestRock's January 20, 2023, permit renewal included temperature requirements that addressed instream
temperature monitoring. For specific details, refer to the permit at page 3 Condition A. (1) in the table related to
"Temperature" and at footnote number 8; and at page 4 Condition A. (2) in the table related to "Temperature" and
at footnote number 1.
Based on the above, DWR is requesting expedited investigative monitoring and completion of the temperature
modeling study as described below. The authority for such additional investigative actions can be found in 15A
NCAC 02B .0508 (b)(2) and G.S. 143-215.66.
REQUIRED ACTIONS
Based upon the forgoing issue and regulatory authority, beginning within thirty (30) days of the date of this letter,
the Permittee shall implement the following additional investigative requirements:
1. Investigative Monitoring Map: Prior to implementation, the Permittee shall submit a map to DWR for
review and possible approval. The map shall include at a minimum the following: (1) Aerial/Site location
map; (2) Facility location; (3) Location of outfall(s) (latitude and longitude); (4) Sampling and monitoring
location(s) (latitude and longitude); (5) Map scale (e.g. 1" = 500' or USGS Map); (6) Distance in feet
from outfall(s) (latitude and longitude) to sampling location(s); (7) Upstream and downstream monitoring
locations (latitude and longitude); (8) Waterbody name; and (9) Major roads. Once approved, Permittee
shall implement the monitoring, sampling and reporting below.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORrH cARCLINA ^ �/
919.707.9000

DocuSign Envelope ID: C010A699-7593-4F49-9D4D-B9A78C7EB424
a. Effluent shall be sampled for temperature prior to discharge, three (3) times per week for each
Outfall (i.e., 001 and 002).
b. Instream water temperature sampling shall occur upstream of the discharge points and shall be
sampled three (3) times per week. The sampling locations shall be approximately 1,000 feet above
the facility discharge points.
c. Instream water temperature sampling shall occur downstream from the discharges and shall be
sampled within 100 feet and within 1,000 feet of the discharge points three (3) times per week.
2. The Permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system per Special Condition A. (6) (G.S. 143-215.1(b)) of the Permit.
In addition to reporting the monthly results on the facility's eDMR, send a copy of all results to the
DWR NPDES Industrial Permitting Unit within thirty (30) days of the end of each calendar month
to: sergei.chemikovgdeq.nc.gov. Please include your NPDES permit number and reporting period in
the subject heading.
3. The facility shall provide a schedule for conducting and completing the temperature modeling study as
specified in the NPDES permit at page 3 footnote number 8.
The sampling and reporting protocols specified herein shall remain in effect until rescinded by DWR in letter
form. If necessary, NPDES staff will contact you to develop additional corrective actions based upon the results
of the data.
The Department looks forward to working closely with you on this important issue. Please contact any of the
following DWR NPDES Industrial Permitting Unit staff members if you have any questions or concerns: Douglas
Dowden at: 919-707-3605 or via email at [e-mail], or Sergei Chernikov, Ph.D. at 919-707-3606
or via email at sergei.chernikovndeq.nc..ov.
Sincerely,
Ev
DocuSigned by:
b+S NWAU,
CE9CD2D3C45B4D4...
Douglas Dowden
Environmental Program Supervisor II
Industrial Permitting Unit
Division of Water Resources, NCDEQ
Cc: NPDES Regional Office Files
e.c. Sergei Chernikov, Ph.D., Environmental Engineer III at: sergei.chemikovndeq.nc.gov
Michael Montebello, NPDES Program Branch Chief at: michael.montebellogdeq.nc.gov
Julie Gryzb, Deputy Director, Division of Water Resources at: Julie. g nz bkdeq.nc.gov
John Hennessy, Environmental Program Supervisor II at: john.hennessykdeq.nc.gov
Vanessa Manuel, Assistant Regional Supervisor at: vanessa.manuel(kdeq.nc.gov
Scott Vinson, Regional Supervisor at: scott.vinsongdeq.nc.gov.
Charles Weaver, Environmental Specialist II at: Charles.weaver(kdeq.nc.gov
Mike Knudson, Environmental Manager Westrock at: mike.knudson(kwestrock.com
Benjamin White, General Manager at Westrock at: ben.white&westrock.com
D � � North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
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