The URL can be used to link to this page

Home My WebLink AboutNC0000752_correspondence_20231010ROY 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 October 10, 2023 Subject: NC0000752 WestRock/Kraft Paper 001 and 002 Investigative Monitoring — Followup Time Adjusted Roanoke Rapids Mill WWTP Halifax County (RRO) Facility Class IV As follow-up to the meeting on October 5, 2023, and request of October 8, 2023 (Attachment 1) DWR NPDES Industrial Permitting Unit is adjusting the time schedule established in its September 14, 2023 Investigative Monitoring letter (Attachment 2) to Westrock as follows. The implementation schedule for additional investigative monitoring will be revised from the original start date of October 14, 2023, to December 1, 2023. This change is based upon the information provided during the meeting, the attached email and in anticipation of receiving the temperature modeling study / report by the end of October 2023. The adjusted schedule will allow NCDEQ staff time to review the report and provide questions and/or concerns before implementation of additional monitoring requirements. In addition, the identified upstream and downstream sampling locations may be revised to be more reflective of the proposed mixing analysis. The Department looks forward to working closely with Westrock 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 doug.dowdenkdeq.nc.gov, or Sergei Chernikov, Ph.D. at 919-707-3606 or via email at sergei.chernikovngdeq.nc.gov. Sincerely, DocuSigned by'. `,, �'n.'' ` u6d AukV t "ttth Micliael� ontZello NPDES Program Branch Chief Division of Water Resources, NCDEQ Cc: NPDES Regional Office Files e.c. Sergei Chernikov, Ph.D., Environmental Engineer III at: sergei.chernikovngdeq.nc.gov Michael Montebello, NPDES Program Branch Chief at: michael.montebellokc eq.nc.gov Julie Gryzb, Deputy Director, Division of Water Resources at: Julie.grz b deq.nc.gov John Hennessy, Environmental Program Supervisor II at: john.hennessygdeq.nc.gov Vanessa Manuel, Assistant Regional Supervisor at: vanes sa.manuelkdeq.nc.gov Charles Weaver, Environmental Specialist II at: Charles.weaverkdeq.nc.gov Mike Knudson, Environmental Manager Westrock at: mike.knudson(Lwestrock.com Attachments: 1 — Westrock Email of 10/8/23; 2 — Investigative Letter of 9/14/23 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 cAROLINA ^ �/ 919.707.9000 ATTACHMENT 1 Michael Knudson <mike.knudson@westrock.com> To: Dowden, Doug Cc: Brad Justus <brad.justus@westrock.com>; Benjamin White <ben.white@westrock.com>; Nina -Mary Butler <nina. butler@westrock.com> Sun 10/8/2023 2:09 PM CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Dear Doug — I am following up on our earlier conversation regarding the September 14 letter that NC DEQ sent to the Roanoke Rapids mill requesting effluent temperature information. As you know, the mill's NPDES permit contains a requirement for WestRock to perform temperature modeling by 2025 to determine the boundaries of its non -contact cooling water (NCCW) thermal plume. Rather than utilizing all the time provided by the permit, WestRock retained third -party experts, HDR, several months ago to model its NCCW discharge for temperature using the CORMIX model, which is recommended by NC DEQ's guidance on effluent mixing zones. The flow, temperature and other inputs used in the CORMIX modeling effort were derived from robust, existing data sets that include site -specific sampling data, USGS data, NC DEQ temperature data, and data from the Dominion Energy facility upstream of the Roanoke Rapids Dam. We expect to finalize the report of our mixing zone study and submit it to the State no later than October 31, 2023. At this point, WestRock has substantially completed the study required by our NPDES permit, passing the stage where the data requested in NC DEQ's September 14 letter would be useful. For this reason, WestRock respectfully requests that the State suspend its data request until the mill has submitted its mixing zone study and NC DEQ has had the opportunity to review this work. If you have any questions about our request, please feel free to contact me. Sincerely, Mike Knudson Environmental Manager Michael E. Knudson Environmental Manager WestRock P.O. Box 4581 Roanoke Rapids, NC 27870 T 252.533.6280 1 M 252.326.5288 Mike.Knudson(cDwestrock.com I www.westrock.com This electronic message contains information from WestRock Company (www.westrock.com) or its subsidiaries, which may be confidential, privileged or otherwise protected from disclosure. The information is intended to be disclosed to and used by only the named recipient(s). If you are not the intended recipient, then your review, use, disclosure, printing, copying, or distribution of this message or its contents is prohibited. If you have received this message in error, please notify WestRock immediately at postmaster@westrock.com, and delete the message from your system. For information about WestRock's privacy practices, including how WestRock collects, processes, transfers, and stores Personally Identifiable Information shared with us, please visit WestRock Privacy Policy. Unless previously authorized in writing, this message does not constitute an offer, acceptance, or agreement of any kind. Sender is not liable for damage, errors or omissions related to or caused by transmission of this message. (c) WestRock Company. 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 CARCLINA 919.707.9000 gaparhneM of EmironmanW quay ATTACHMENT 2 September 14, 2023 Mr. Benjamin P. White, General Manager WestRock Kraft Paper 100 Gaston Road Roanoke Rapids, NC 27870 Subject: NC0000752 WestRock/Kraft Paper 001 and 002 Investigative Monitoring Roanoke Rapids Mill WWTP Halifax County (RRO) Facility Class IV Dear Mr. White: 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: 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. a. Effluent shall be sampled for temperature prior to discharge, three (3) times per week for each Outfall (i.e., 001 and 002). 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 gaparhneM of EmironmanW quay 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 doug.dowdengdeq.nc.gov, or Sergei Chernikov, Ph.D. at 919-707-3606 or via email at sergei.chemikov@deq.nc.gov. Sincerely, 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.chernikovkdeq.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 bgdeq.nc.gov John Hennessy, Environmental Program Supervisor 11 at: john.hennessykdeq.nc.gov Vanessa Manuel, Assistant Regional Supervisor at: vanessa.manuel(c-r�,deq.nc.gov Scott Vinson, Regional Supervisor at: scott.vinson(c�r�,deq.nc.gov. Charles Weaver, Environmental Specialist II at: Charles.weaver(gdeq.nc.gov Mike Knudson, Environmental Manager Westrock at: mike.knudsongwestrock.com Benjamin White, General Manager at Westrock at: ben.whitegwestrock.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 gaparhneM of EmironmanW quay