WQ0021577_Renewal Application_20200203

Initial Review
INITIAL REVIEW
Reviewer Thornburg, Nathaniel
Is this submital an
application?*
r Yes r No
Is this a complete
application?* Complete App Date
r Yes r No 02/03/2020
Project Number* WQ0021577
Applicant/Permittee WestRock Kraft Paper, LLC
Applicant/Permittee 100 Gaston Road, Roanoke Rapids, NC 27870
Address
Is the owner in BIMS?
r Yes r No
Owner Type
Facility Name
County
Organization
WestRock Kraft Paper DCAR
Halifax
Fee Category
Minor
Signature Authority
Signature Authority Title
Signature Authority Email
Document Type (if
non -application)
Email Notifications
Does this need O Yes
review by the r No
hydrogeologist? *
Regional Office Raleigh
Is the facility in BIMS?
r Yes r No
Fee Amount
0

CO Reviewer Ranveer Katyal: eads\rkatyal
Admin Reviewer
Below list any additional email address that need notification about a new project.
Email Address
Comments to be added to email notification
Comments for Kendall
Comments for RO
This renewal application supersedes the Change of Ownership application received October 3, 2019. The Change of
Ownership application will be returned.
Comments for Reviewer
This renewal application supersedes the Change of Ownership application received October 3, 2019. The Change of
Ownership application will be returned.
Comments for Applicant

Submitted Form
Project Contact Information
Rease provide information on the person to be contacted by MB Staff regarding electronic subnittal, confirmation of receipt, and other issues.
.......................................................................................................................................................................................................................................................................................................................................................................................................
Name * Robert Branch
Email Address*
[e-mail]
Project Information
Submittal Type* r New Permit Application
r Renewal
r Annual Report
Permit Type * r Wastewater Irrigation
r Other Wastewater
r Closed -Loop Recycle
r Single -Family Residence
Wastewater Irrigation
Is a paper copy of the application being submitted?*
r Yes r Nor N/A
Permit Number WQ0021577
currently has project
Applicant\Permittee * Mr. Benjamin WHite
Phone Number*
336.510-0340
r Modification (Major or Minor)
r Additional Information
r Other
r High -Rate Infiltration
r Reclaimed Water
r Residuals
r Other
Applicant/Permittee 100 Gaston Road, Roanoke Rapids, NC 27870
Address*
Facility Name * WestRock Kraft Paper, LLC
Please provide comments/notes on your current submittal below.
Please attach all information required or requested for this submittal to be review here.
Application Form Engineering Rans, Specifications, Calculations, Etc.)
WestRock WQ0021577 Final pdf.pdf 4.24MB
upload only 1 R7F document. NL@iple documents must be combined into one R7F file.

For new and modification permit applications, a paper copy may be required. If you have any questions
about what is required, please contactthe reviewer or Tessa Monday. If a paper --polka*-ion is required,
be advised, applications accepted' far pre -review until both the paper and eIect-c-,i_ co1)ies nave been
received. The paper copy shall include the following:
o Application Form
o All relevant attachments (calcs, soils report, specs, etc.)
o One full-size engineering plan set
o One 11x17" engineering plan set
o One extra set of specifications
o Fee (if required)
MallinE address:
❑iuision of Water Resources1 Division of Water Resources
Non -Discharge Branch I Non -Discharge Branch
1617 Mail Service Center 1 Aft: Nathaniel Thornburg, 91° Floor, Cfice #942W
----------------------------------------------------------- -----------------------------------------
Raleih, NC 27699-1617 512 N. Salisbury St.
Far questions or problems contact Tessa Monday [e-mail] or 919.707.3560.
* W By checking this box I acknowledge that I understand the application will not be accepted
for pre -review until the paper copy (if required) and fee (if required) have been received by
the Non -Discharge Branch. I also confirm that the uploaded document is a single PDF with
all parts of the application in correct order (as specified by the application).
Signature
Submission Date 1/30/2020

PERMIT RENEWAL
DISTRIBUTION OF RESIDUAL SOLIDS
WQ0021577
WESTROCK KRAFT PAPER, LLC.
ROANOKE RAPIDS, NC FACILITY FLYASH AND PRIMARY
CLARIFIER SOLIDS
Prepared For:
West Rock Kraft Paper, LLC.
100 Gaston Road
Roanoke Rapids, NC 27870
Prepared By:
Branch Residuals & Soils, LLC
1735 Heckle Blvd. Suite 103-291
Rock Hill, SC 29732
January 2020

BRANCHRESIDUALS & SOILS, LLC
8646 W. Market St. —Suite 111 • Greensboro, NC 27409
PHONE [phone] • Fax [phone]
January 28, 2020
North Carolina Department of Environment and Natural Resources
Division of Water Resources/Non-Discharge Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attention: Mr. Nathaniel Thornburg
Reference: PERMIT RENEWAL OF RESIDUAL SOLIDS
Permit WQ0021577
WestRock Kraft Paper, LLC.
Roanoke Rapids, North Carolina
BR&S Job No. 2007-68
Dear Mr. Thornburg:
Branch Residuals & Soils, LLC is under contract with WestRock Kraft Paper, LLC (formerly
Kapstone Kraft Paper Corporation) to renew permit WQ0021577. This permit has two sources:
• Flyash (that is a combination of coal ash and wood ash) and
• Primary Clarifier Solids (PCS) that contain a small amount of domestic waste.
These materials are planned to be utilized as defined in the attached management plan. Since
WestRock has undergone a recent name change and we have had discussions on this in the past, I am
sure you are familiar with this project.
Meritech, Inc. (the laboratory that performed analytical testing for Kapstone and WestRock) informed
WestRock recently that they would no longer be able to provide Class A fecals values either directly
or through subcontract. WestRock concluded that they and/or their subcontractor had lost
certification or was unable to meet holding time criteria. WestRock has provided the last, most recent
certified lab values which are from July and are included in their respective Residual Source
Certification sections for the two sources.
On December 30, 2019, an additional information request was sent to Mr. White regarding this permit
renewal for WQ0021577 (Attachment A). A copy of this letter immediately follows and is found in
Attachment A. These items will be addressed in the order they appear in the letter.
A. Response to Draft Comments
1. Domestic Contribution - WestRock does not operate a biological wastewater treatment system,
it has a primary clarifier. A small amount (0.058%) of domestic that is part of the Primary

Permit Renewal of Residual Solids — WestRock Kraft Paper, LLC BR&S Job No. 2007-68
Division of Water Resources — Non -Discharge Branch January 28, 2020
Clarifier Solids (PCS). This has previously been permitted a Class A product in the past and
should remain so. Tests that have been performed indicate that Class A pathogen levels have
been met.
2. Flyash residuals allow to be removed from the landfill Permit WQ00000436 — This was allow
in previous permits and as long as the materials that are placed in the landfill are kept separate,
this should be continued. This will allow the distribution permit to have a store of materials
on hand and distribute based on not just current production but previous production.
3. Utilization Agreements — Not required.
4. Annual Soil Sampling - Not Required.
5. Attachment A — The Attachment A should include two sources, Flyash and Primary Clarified
Solids (PCS). Each of these sources are included in the following permit submittal and have
a separate section for their respective Residual Source Certification.
6. Attachment A footnotes — Please review the old footnotes to determine the inclusion of these
notes as they are important to our program.
B. Application Renewal
The permit was not submitted within 6 months of expiration. It is submitted now
could not have submitted it any earlier. I apologize for it's lateness.
2. Contribution of Domestic Wastewater - WestRock does not operate a biological
wastewater treatment system, it has a primary clarifier. A small amount (0.058%) of
domestic that is part of the Primary Clarifier Solids (PCS). This has previously been
permitted a Class A product in the past and should remain so. Tests that have been
performed indicate that Class A pathogen levels have been met.
C. Recommendations
1. Withdrawal of name change — The documentation of name change has been included as
provided on September 28, 2019. The inclusion of this to be in compliance with the current
NC statues that the permit be issued to a company that is authorized to do business in the
state and not a previous company that is not.
Please contact me immediately if you require additional information or have questions in the review
process.
Sincerely,
1
Y'
Robert T. Branch, L. S. S.
Project Manager
cc: Mr. Chris Williams — WestRock Kraft Paper, LLC.
Attachment A — December 30, 2019 Additional Information Request WQ0021577
2

Attachment A
December 30, 2019 Additional Information Request WQ0021577

ROY COOPER
Gm ernot
Iti1ICHAEL S. REGAN
Secrermy
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
December 30, 2019
BENJAMIN P. WHITE — GENERAL MANAGER
WESTROCK KRAFT PAPER, LLC
POST OFFICE BOX 458
ROANOKE RAPIDS, NORTH CAROLINA 27870
Subject: Application No. WQ0021577
Additional Information Request
WestRock Kraft Paper DCAR
Residuals Management System
Halifax County
Dear Mr. White:
Division of Water Resources' Central and Regional staff has reviewed the application package
received October 3, 2019. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on January
29, 2019.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Section B, or failure to provide the additional information on or before the above requested date may
result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with hvo paper
copies and one electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3661 or Ram ecr.l:ah al c ncdenl .�To� . Thank you for your cooperation.
Sincerely,
Ranveer Katyal, Environmental Engineer
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Mike Knudson — WestRock Kraft Paper (Electronic Copy)
Permit Application File WQ0021577
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7� North Carolina Department of Enoironmental Qualit} Dicislon of W iter Resources
512.North S,disbur� Street 1 I317 Mall Ser\,ice Center I Raleigh, North Carolina 2769Q loll
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Mr. Benjamin P. White
December 30, 2019
Page 2 of 3
A. Response to draft permit comments:
1. Schedules (page 1 of 9): We request the language from our current permit that alloivs distribution to
second parties for approved uses to remain intact. (Our requested revisions will be included in an
electronic attachment in red text.)
The very small quantity of domestic wastewater changes the rule under which it is regulated from 40
CFR Part 257 to 40 CFR Part 503, which regulates residuals generated during treatment of biological
wastewater.
2. Operation and Maintenance (page S of 9): YVe wish to request the inclusion of a numbered item
containing language from our current permit that alloivs fly ash residuals to be stored in the surface
storage unit at the fly ash pond (Our requested revisions will be included in an electronic attachment
in red text.)
Will be added based on the additional information provided.
3. The draft permit does not appear to contain language with respect to establishing a Utilization
Agreement for the distribution of residuals. (Items I 1 and 12 on page 6 of 12 in our current permit)
We ivould like to request clarification that this agreement is no longer required
Utilization Agreements are no longer required for Class A residual permits.
4. The draft permit does not appear to contain language tivith respect to peuforming an annual soils
analysis. (Item S on page 9 of 12 in our current permit) We would like to request clarification that this
analysis is no longer required
Annual soils analyses are not required for Class A residual permits.
Attachment A of the draft permit does not include Fly ash in the table. Also it appears the mineralization
rate of 0.4 needs to be associated tivith the WWTP residuals and not the Fly ash. (An approved
mineralization rate has not been established for Fly ash)
Attachment A has been updated to add Fly ash to the residual source table.
6. Attachment A is also missing Items 6-9 from the current permit. We would like to request the language
from the current permit be included in the draft perinit. (Our requested revisions will be included in an
electronic attachment in red text.)
These conditions would most likely be changed based on the additional information required below.
B. Application Renewal:
1. The current permit was effective from the date of issuance till April 30, 2020. Pursuant to 15A
NCAC 02T .0109 and as per permit condition I.1. the permittee shall request renewal of the permit
on official Division forms no later than six months prior to the expiration of this permit. Please
fill out the DCAR 06-16 form, RSC form 06-16 (both attached below) and the renewal application
and submit it to the Division.
2. Contribution of domestic wastewater: In the RSC form 06-16, fill out section I.5 to include the
contribution of domestic wastewater. Residuals generated from the treatment of biological
wastewater are qualified under 40 CFR 503, and not 40 CFR 257. Please provide additional
information to include the domestic wastewater quantity, percent/quantity of domestic wastewater
contribution, source of the domestic wastewater and the Fecal lab results to show compliance with
Class A standards as per 15A NCAC 02T .1106(a).

Mr. Benjamin P. White
December 30, 2019
Page 3 of 3
C. Recommendations:
1. It is recommended that the subject Change of Ownership application be withdrawn, and
incorporated into the renewal application noted in Section B, Item 1 above. This will allow the
permit undergo a Change of Ownership, and to have a permit length of up to 8 years.

TABLE OF CONTENTS
Section No. Title
DISTRIBUTION OF RESIDUAL SOLIDS APPLICATION FORM
II RESIDUALS SOURCE CERTIFICATION ATTACHMENT — FLYASH
Vicinity Map
Process Flow Diagram and Narrative
Justification of Residuals Production Rate
Sampling Plan
Residual Analytical Reports
III RESIDUALS SOURCE CERTIFICATION ATTACHMENT — PRIMARY
CLARIFIER SOLIDS (PCS)
Vicinity Map
Process Flow Diagram and Narrative
Justification of Residuals Production Rate
Sampling Plan
Residual Analytical Reports
IV MANAGEMENT PLAN
Overview of Process and Residual Solids Handling
Distribution Methods for Reuse
Transportation and Logistics
Monitoring and Recordkeeping
Leachate Collection
V LABEL AND PRODUCT INFORMATION SHEET
WestRock Roanoke Rapids Flyash
WestRock Roanoke Rapids Primary Clarifier Solids
VI RESIDUALS RECEIPT FORM
WestRock Roanoke Rapids Flyash
WestRock Roanoke Rapids Primary Clarifier Solids
VII SPILL CONTROL PLAN
VIII APPLICATION RATES
IX CHANGE OF OWNERSHIP FORM

SECTION I
DISTRIBUTION OF RESIDUAL SOLIDS APPLCATION FORM

State of North Carolina
DWR
Department of Environmental Quality
Division of Water Resources
Division of Water Resources 15A NCAC 02T .1100 — DISTRIBUTION OF CLASS A RESIDUALS
INSTRUCTIONS FOR FORM: DCAR 06-16 & SUPPORTING DOCUMENTATION
Please use the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these
instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of additional
information requested. Failure to submit all of the required items will lead to additional processing and review time for the
permit application. Unless otherwise noted, the Applicant shall submit one original and two copies of the application and
supporting documentation
For more information, visit the iVater Quality Permitting Section's Non -Discharge Permitting Unit website
General — This application is for treatment, storage, transport, distribution, land application, and/or marketing of Class A (or Equivalent)
residuals under 15A NCAC 02T .1 100.
Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed
below.
A. Distribution of Class A Residuals (FORM: DCAR 06-16):
® Submit the completed and appropriately executed Distribution of Class A Residuals (FORM: DCAR 06-16) form. Please do
not make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachments to
the application may be made, as long as the attachments are numbered to correspond to the section and item to which they
refer.
® The project name should be consistent on the plans, specifications, etc.
® The Applicant's Certification on Page 3 of this form shall be signed in accordance with 15A NCAC 02T .0I06(b). An alternate
person may be designated as the signing official if a delegation letter is provided from a person who meets the criteria in 15A
NCAC 02T .0106(b).
❑ If this project is for a modification of an existing permit, submit one copy of the existing permit.
❑ Please submit this application form at least 180 days prior to the expiration date on the existing permit, or 90 days prior to
operation of proposed facility(ies) for application packages involving new or changes to treatment and storage units.
B. Application Fee (New and Major Modification Application Packages)
® Submit a check, money order or electronic funds transfer made payable to: North Carolina Department of Environmental
Quality (NCDEQ).
Facility Classification
New Permit I Major Modification'
Major (residuals permitted for distribution >:3,000 dry tons/year) F$1,310 [— $395
Minor (residuals permitted for distribution < 3,000 dry tons/year) 1 $810
$245
- A major modification shall be defined as any permit modification that: increases the generating facility's residuals dry tonnage;
adds additional residuals sources; or includes the addition of new treatment or storage units/processes not previously permitted.
There is no fee for minor permit modifications.
C. Cover Letter (All Application Packages)
® List all items included in the application package, as well as a brief description of the requested permitting action.
INSTRUCTIONS FOR FORM: DCAR 06-16 Page 1 of 3

D. Program Information (All Application Packages)
® Provide a narrative explaining the following:
® How the materials will be handled and transported from where the residuals were produced to where it will be treated.
® How the residuals will be processed/treated (attach process flow diagram).
® How leachate collection will be handled.
® Where the residuals will be stored until processed.
® How the final product will be distributed (packaging, bulk, etc.)
® What nutrients or other constituents (i.e. nitrogen, phosphorous, aluminum, calcium, etc.) are used or recommended as the
limiting parameter for determination of residuals loading rate to ensure that it does not overload the soil and cause
contravention of surface water or groundwater standards, limit crop growth, or adversely impact soil quality.
® Attach a marketability statement detailing destinations and approximate amounts of the final product to be distributed.
® Provide either a label that shall be affixed to the bagged processed residual or an information sheet that shall be provided to the
person who receives the processed residual. The label or information sheet shall contain, at a minimum, the following
information:
® Name and address of the person who prepared the residual that is sold or given away.
® A statement that application of the residuals to the land shall be in accordance with the instructions on the label or
information sheet.
® A statement that the residuals shall not be applied to any site that is flooded, frozen or snow-covered.
® A statement that adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored
residuals into any surface waters.
® Information on all applicable setbacks in accordance with 15A NCAC 02T .l 108(b).
®A statement that the residuals shall be applied at agronomic or recommended rates for intended uses.
E. Detailed Plans and Specifications (Application Involving New or Changes to Treatment or Storage Units)
❑ Submit detailed plans and specifications that have been signed, sealed, and dated by a NC Professional Engineer per 15A
NCAC 02T .l 101(a). Specifications for standard equipment may only be omitted for municipalities with approved standard
specifications, but use of the standard specifications must be noted on each sheet of the plans.
❑ Plans must include the following minimum items: a general location map, a topographic map, plan and profile view of the
residuals treatment and storage units as well as the proximity of the residuals treatment and storage units to other utilities and
natural features within 500 feet of all treatment and storage facilities, and detail drawings of all items pertinent to the residuals
treatment and storage units. Depict minimum separations required in 15A NCAC 02T .1108(a) on the plans.
❑ Specifications must include, at a minimum, the following for all items pertinent to residuals treatment and storage units:
description of materials to be used, methods of construction, quality of construction testing procedures to ensure the integrity
of the final product in accordance with 15A NCAC 02T .l 104(a)(2)(B), including leakage and pressure testing as appropriate.
❑ Plans and specifications must not be labeled with preliminary phrases (e.g., FOR REVIEW ONLY, NOT FOR
CONSTRUCTION, etc.) that indicate that they are anything other than final plans and specifications. However, the plans and
specifications may be labeled with the phrase: FINAL DESIGN — NOT RELEASED FOR CONSTRUCTION.
F. Engineering Calculations (Application Involving New or Changes to Treatment or Storage Units)
❑ Submit all design calculations that have been signed, sealed, and dated by a NC Professional Engineer per 15A NCAC 02T
.1 104(a).
G. Environmental Assessments (May be Required — See 15A NCAC 1 C .0300)
❑ Submit a copy of the Findings of No Significant Impact (FONSI) or Environmental Impact Statement (EIS). Also, include
information on any mitigating factor(s) from the Environmental Assessment (EA) that impact the construction of the residuals
treatment and storage facilities. An EA may also be required for private systems if any public funds and/or lands are used for
the construction of the subject facilities.
INSTRUCTIONS FOR FORM: DCAR 06-16 Page 2 of 3

H. Operation and Maintenance Plan (New and Renewal Application Packages)
® For Modification Application, if there are any changes to the existing plan, submit an updated O&M plan.
® Submit the O&M Plan in accordance with 15A NCAC 02T .l 110 and include at a minimum:
® Operational functions; describe the operation of the program to show what operations are necessary for the program to function
and by whom the functions are to be conducted.
® Maintenance schedules; may include equipments calibration, maintenance of signs, etc.
® Safety measures; may include safety training program, manuals, signs, etc.
® Spill response plan; including control, containment, remediation, emergency contact information, etc.
® Inspection plan including the following information;
® Names and titles of personnel responsible for conducting the inspections.
® Frequency and location of inspections, including those to be conducted by the ORC, and procedures to assure that the selected
location(s) and inspection frequency are representative of the residuals management program.
® Detailed description of inspection procedures including record keeping and actions to be taken by the inspector in the event
that noncompliance is observed.
® Sampling and monitoring plan including the following information;
® Names and titles of personnel responsible for conducting the sampling and monitoring.
® Detailed description of monitoring procedures including parameters to be monitored.
® Sampling frequency and procedures to assure that representative samples are being collected. Fluctuation in temperature, flow,
and other operating conditions can affect the quality of the residuals gathered during a particular sampling event. The sampling
plan shall account for any foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to meet
pathogen and vector attraction reduction requirements (e.g. facilities that land apply multiple times per year but have an annual
sampling frequency, may need to sample during winter months when pathogen reduction is most likely to be negatively affected
by cold temperatures.
ONE ORIGINAL AND TWO COPIES OF THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION AND MATERIALS, SHALL BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service:
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
TELEPHONE NUMBER: [phone]
By Courier/Special Delivery:
512 N. SALISBURY STREET
RALEIGH, NORTH CAROLINA 27604
FAX NUMBER: [phone]
INSTRUCTIONS FOR FORM: DCAR 06-16
Page 3 of 3

DWR
State of North Carolina
Department of Environmental Quality
Division of Water Resources
Division of Water Resources 15A NCAC 02T .1100 — DISTRIBUTION OF CLASS A RESIDUALS
FORM: DCAR 06-16
I. APPLICANT INFORMATION:
1. Applicant's name: WestRock Kraft Paper, LLC.
Applicant type: ❑ Individual ® Corporation ❑ General Partnership ❑ Privately -Owned Public Utility
❑ Federal ❑ State ❑ Municipal ❑ County
Signature authority's name per 15A NCAC 02T .0106: Mr. Benjamin P. White
Applicant's mailing address: 100 Gaston Road
City: Roanoke Rapids State: NC Zip: 27870
Telephone number: [phone] Email Address: [e-mail]
2. Consultant's name: Branch Residuals & Soils. LLC. License Number (for P.E.):
Affiliation: ❑ On Staff ® Retained (Firm: )
Consultant's mailing address: 1735 Heckle Blvd. Suite 103-291
City: Rock Hill State: SC Zip: 29732
Telephone number: [phone] Email Address: [e-mail]
3. Fee submitted: 0.00 (See Instruction B)
II. PERMIT INFORMATION:
1. Application is for (check all that apply): ❑ new, ❑ modified, ® renewed permit
2. If this application is being submitted to renew or modify an existing permit, provide the following:
Permit number: W00021577
Date of most -recently issued permit: June 15.2015
Date of most -recently certified Attachment A (if different than the permit):
III. FACILITY INFORMATION:
1. Name of residuals processing facility: WestRock Kraft Paper, LLC.
City: Roanoke Rapids State: NC Zip: 27870-
Coordinates: Latitude: 36' 28' 33.24"N Longitude: 77' 38' 37.28"W
Datum: NAD 1983 UTM 18N Level of accuracy: I"
Method of measurement: Map
Title: General Manager
County where facility is located: Halifax
2. Facility contact (person familiar with residuals preparation):
Name: Chris Williams Title: Environmental Engineer
Mailing address: 100 Gaston Road
City: Roanoke Rapids State: NC Zip: 27870-
Telephone number: [phone] E-mail address: [e-mail]
FORM: DCAR 06-16 Page 1 of 3

3. Is the residual process facility also the generator? ® Yes; ❑ No
If No, please specify delivery frequency and quantity of residual to be processed: 1
4. Length of residuals storage at facility: 365+ days (Note: the Division requires minimum 30 days storage in units that are separate
from treatment system, i.e. not in clarifiers, aeration basins, etc.)
IV. RESIDUALS QUALITY INFORMATION:
1. Specify how these residuals will be distributed:
❑ sold or given away in bags or other containers; ❑ lawn (bulk); ❑ home garden (bulk);
® other (explain); See Attached Management Plan
Note: Bulk residuals shall mean residuals that are transported and not sold or giving away in a bag or other receptacles with a
load capacity of one metric ton or less.
2. Complete the following if residuals are to be mixed with other materials:
Type of Materials Amounts to be added
oer 1.0 dry ton of residuals (dry ton)
3. Approximate amounts of the residuals received and processed at the facility: 15,000 dry tons per year Flyash
15,000 dry tons per year Primary Clarifier Solids
4. Approximate amounts of the final product (processed residuals) to be distributed: 3.298 dry tons per year.
5. Provide a description of the onsite storage management plan for the treated residuals (including estimated average and
maximum storage times prior to distribution): Residuals can be stored in monofil under NCDEO Permit W000000436
6. Does the facility have a stormwater management plan? ® Yes; ❑ No
Explain whether the treatment and storage areas are under roof or how stormwater runoff will be handled: See Attached
Management Pan.
V. RESIDUALS SOURCE INFORMATION: (Required for all new, renewed, or modified residuals source)
Complete and submit the attached Residuals Source Certification and all associated documentation.
RSC 06-16.doc
FORM: DCAR 06-16 Page 2 of 3

Professional Engineer's Certification: (Application Involving New or Changes to Treatment or Storage Units)
attest that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I further attest that to the best of my knowledge
the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package
may have been developed by other professionals, inclusion of these materials under my signature and seal signifies that I have reviewed
this material and have judged it to be consistent with the proposed design.
North Carolina Professional Engineer's Seal, Signature, and Date:
Applicant's Certification:
The applicant or any affiliate has not been convicted of an environmental crime, has not abandoned a wastewater facility without proper
closure, does not have an outstanding civil penalty where all appeals have been exhausted or abandoned, are compliant with any active
compliance schedule, and do not have any overdue annual fees under Rule 15A NCAC 02T .0105.
® Yes ❑ No, Explain;
I, Beniamin P. White General Manager
(Signature Authority's Name — PLEASE PRINT) (Title)
attest that this application for WestRock Kraft Paper, LLC. Class A Distribution Program
(Facility Name)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that the Division of Water Resources
may not conduct a technical review of this program and approval does not constitute a variance to any rules or statutes unless specifically
granted in the permit. Further, any discharge of residuals to surface waters or the land will result in an immediate enforcement action,
which may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the Division of Water
Resources should a condition of this permit be violated. I also 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 to me as
incomplete.
Note: In accordance with North Carolina General Statutes § 143-215.6A and § 143-215.6B, any person who knowingly makes any false
statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up to $25,000 per violation.
Signature: Date:
FORM: DCAR 06-16 Page 3 of 3

SECTION II
RESIDUALS SOURCE CERTIFICATION ATTACHMENT - FLYASH

DWt,;
State of North Carolina
Department of Environmental Quality
Division of Water Resources
Division of Water Resources RESIDUALS SOURCE CERTIFICATION
INSTRUCTIONS FOR FORM: RSC 06-16
Please use the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these
instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of additional
information requested. Failure to submit all of the required items will lead to additional processing and review time for the
permit application. Unless otherwise noted, the Applicant shall submit one original and two copies of the application and
supporting documentation
For more information, visit the Water Quality Pennitting Section's Non -Discharge Permitting Unit
General — This certification provides detailed information of residuals source generating facility and its residuals quality for land
application, distribution, or disposal in accordance with 15A NCAC 02T .l 100. Do not submit this certification for review without
a corresponding application form (FORM: RLAP 11-15, FORM: DCAR 11-15, or FORM: SDR 11-15).
Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed
below.
A. Residuals Source Certification (FORM: RSC 11-15):
® Submit the completed and appropriately executed Residuals Source Certification (FORM: RSC 11-15) form. Please do not
make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachments to the
application may be made, as long as the attachments are numbered to correspond to the section and item to which they refer.
® For new or renewed permits, submit a separate certification for each source facility.
❑ For modified permits, submit a separate certification for only those facilities that are affected by the proposed modification.
® Complete the residuals source facility summary page. List all new, renewed, or modified facilities.
B. Residuals Source -Generating Facility Information:
® For each source facility, attach the following:
® Vicinity map - A vicinity map that shows the location of the facility and meets all of the criteria in the "Map GUIdanCe for
Residuals Land Application Permits".
® Process flow diagram and/or narrative - A detailed narrative and/or process flow diagram that describes how the residuals
are to be generated, treated, processed, and stored at the facility.
® Quantitative justification for residuals production rate - A quantitative justification for the value provided in Item I. 8.
Ensure that the amount of residuals listed is the maximum amount expected to be generated by the facility for the life of
the permit. In addition, ensure that this amount is equivalent to that which is actually to be land applied, distributed,
and/or disposed, including any chemicals, amendments, or other additives that are added to the residuals during
processing.
® Sampling plan - A detailed sampling plan for the residuals source -generating facility. Ensure that the plan identifies
sampling points, sampling frequency, sample type, as well as the Division -certified laboratory to be used. In addition,
ensure that the plan details how the facility and/or the residuals are monitored for any applicable pathogen reduction and
vector attraction reduction requirements. Note that all sampling and monitoring must be completed on the residuals as
they are to be land applied, distributed, and/or disposed.
C. Residuals Quality Information:
® For each source facility, attach the following:
® Laboratory analytical reports and operational data - reports for all laboratory analyses used to complete this certification.
® Documentation that the facility complies and/or the residuals comply with any applicable pathogen reduction and vector
attraction reduction requirements.
❑ For new facility that may have not yet been constructed and analytical results of residuals cannot be obtained, please
attach analytical results of residuals generated from a similar facility along with the description of similarities of the two
facilities.
INSTRUCTIONS FOR FORM: RSC 06-16 Page I of 1

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Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
RESIDUALS SOURCE CERTIFICATION
FORM: RSC 06-16
1. RESIDUALS SOURCE -GENERATING FACILITY INFORMATION (See Instruction B.):
1. Facility Name: WestRock Kraft Paper, LLC.
2. Facility permit holder is: ❑ Federal, ❑ State, ❑ Local Government, or ® Private.
Facility permit issued by: ❑ Div. of Water Resources, ® Div. of Environmental Health,
or ❑ Other (explain: . ).
3. Facility contact person and title: Mr. Chris Williams Environmental Engineer
Complete mailing address: 100 Gaston Road
City: Roanoke Rapids State: NC Zip: 27870-!7- i
Telephone number: [phone] E-mail address: [e-mail]
4. Facility physical address: 100 Gaston Road
City: Roanoke Rapids State: NC Zip: 27870-
Coordinates: Latitude: 36' 28' 33.24" N Longitude: 77' 38' 37.28" W
Datum: NAD 1983 UTM 18N Level of accuracy: 1"
Method of measurement: Man
5. Purpose of the facility:
❑ treatment of municipal wastewater, 0 treatment of 100% domestic wastewater,
treatment of potable water, Q treatment of 100% industrial wastewater,
❑ treatment of industrial wastewater mixed with domestic wastewater,
(approximate percentages: % industrial and _ % domestic)
® other (explain: Flyash derived from Coal and Wood Products ).
6. Does the facility have an approved pretreatment program: 0 Yes ® No
7. Facility permitted/design flow: NA MGD and facility average daily flow: NA MGD
8. Average amount of residuals being generated at this facility 1,649 dry tons per year.
9. Specify the following regarding treatment and storage volumes available at the facility:
Type and volume of residuals treatment: NA for treatment: monofil for storage
Type and volume of residuals storage (i.e., outside of residuals treatment units): None.
II. RESIDUALS QUALITY INFORMATION (See Instruction C.):
1. Specify if residuals are regulated under:
❑ 40 CFR Part 503 or ® 40 CFR Part 257.
Note: Only residuals that are generated during domestic/municipal wastewater treatment processes are regulated under 40
CFR Part 503, otherwise, the residuals are regulated under 40 CFR Part 257.
2. Specify if residuals are defined under 15A NCAC 02T. l 102(6) as:
Biological ® Non -Biological
Note: Biological residuals are residuals that have been generated during the treatment of domestic wastewater, animal
processing wastewater, or the biological treatment of industrial wastewater (biological treatment is a system that utilizes
biological processes including lagoons, activated sludge systems, extended aeration systems, and fixed film systems).
FORM: RSC 06-16 Page 1 of 5

3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non -hazardous under
RCRA: (Note - this item does not have to be completed for facilities that are less than 0.5 MGD in design flow that treat
100% non -municipal, domestic wastewater only)
a. Are the residuals listed in 40 CFR §261.31-§261.33: ❑ yes no.
If yes, list the number(s): "'_l
b. Specify whether or not the residuals exhibit any of the characteristics defined by 40 CFR §261.21-
261.24: ❑ yes ® no.
Fill in the following tables with the results of the latest toxicity characteristic leaching procedure (TCLP) analysis as
well as those for corrosivity, ignitability, and reactivity:
Laboratory: Meritech. Inc and Date of analysis: 8/23/19
Passed corrosivity test: ® yes ❑ no. pH: s.u. (2 < pH < 12.5)
Passed ignitability test: ® yes ❑ no. Flashpoint: WNI IF (> 140°F)
Passed reactivity test: ® yes ❑no. HCN: <0.50 mg/l:g (<250) & H,S: <10 mg/kg (<500)
TCLP Parameter
Limit
(ntg/l)
Result
(mg/l)
TCLP Parameter
Limit
(mg/l)
Result
(mg/l)
Arsenic
5.0
<0.010
Hexachlorobenzene
0.13
<0.10
Barium
100.0
0.819
Hexachloro-1,3-Butadiene
0.5
<0.10
Benzene
0.5
<0.01
Hexachloroethane
3.0
<0.10
Cadmium
1.0
<0.02
Lead
5.0
<0.10
Carbon Tetrachloride
0.5
<0.01
Lindane
0.4
<0.04
Chlordane
0.03
<0.003
Mercury
0.2
<0.02
Chlorobenzene
100.0
<0.0I
Methoxychlor
10.0
<1.0
Chloroform
6.0
<0.01
Methyl Ethyl Ketone
200.0
<0.10
Chromium
5.0
<0.05
Nitrobenzene
2.0
<0.10
m-Cresol
200.0
<0.20
Pentachlorophenol
100.0
<0.50
o-Cresol
200.0
<0.10
Pyridine
5.0
<0.10
p-Cresol
200.0
<0.20
Selenium
1.0
<0.10
Cresol
200.0
<0.30
Silver
5.0
<0.05
2,4-D
10.0
<1.00
Tetrachloroethylene
0.7
<0.01
1,4-Dichlorobenzene
7.5
<0.10
Toxaphene
0.5
<0.05
1,2-Dichloroethane
0.5
<0.01
Trichloroethylene
0.5
<0.01
1,1-Dichloroethylene
0.7
<0.01
2,4,5-Trichlorophenol
400.0
<0.10
2,4-Dinitrotoluene
0.13
<0.10
2,4,6-Trichlorophenol
2.0
<0.10
Endrin
0.02
<0.002
2,4,5-TP (Silvex)
1.0
<0.10
Heptachlor and its Hydroxide
0.008
<0.0008
Vinyl Chloride
0.2
<0.02
FORM: RSC 06-16 Page 2 of 5

4. Metals Determination: Complete one of the following tables (i.e., as applicable) to demonstrate that the residuals do not
violate the ceiling concentrations for metals regulated under 15A NCAC 02T .1105.
a. For Distribution/Land Application: Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: Meritech. Inc. and Date of analysis: 8/5/19
Parameter
Ceiling
Monthly Average
Result
Concentration Limits
Concentration Limits
(ClassA & ClassB)
(Class A Only)
(nlglkg)
(ntglkg)
(niglkg)
Arsenic
75
41
14.40
Cadmium
85
39
0.63
Copper
4,300
1,500
68.20
Lead
840
300
21.40
Mercury
57
17
0.09
Molybdenum
75
n/a
1.35
Nickel
420
420
37.20
Selenium
100
100
<0.912
Zinc
7,500
2,800
57.30
b. For Surface Disposal Unit (landrill): Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: : `� and Date of analysis: F7. 71
Distance from Disposal
Unit to Boundary to
Closest Property Line
(meters, check one)
Arsenic
(mg/kg)
Chromium
(nzg/kg)
Nickel
(mglkg)
❑ > 0 but < 25
30
200
210
❑ > 25 but < 50
34
220
240
❑ > 50 but < 75
39
260
270
❑ > 75 but < 100
46
300
320
0 > 100 but < 125
53
360
390
❑ > 125
62
450
420
Result (nzg/kg)
FORM: RSC 06-16 Page 3 of 5

5. Nutrient/Micronutrient Determination: Complete the following:
a. Total solids: 54.8 %.
b. Fill in the following table with the results of the latest analyses (i.e., on a dry weight basis) for the following nutrient and
micronutrient parameters:
Laboratory: Meritech. Inc. and Date of analysis: 8/5/19
Parameter
Result
(mglk-g)
Aluminum
15,500.00
Ammonia -Nitrogen
<18.20
Calcium
9,820.00
Magnesium
2,040.00
Nitrate -Nitrite Nitrogen
<18.20
pH (Standard Unit)
9.00
Phosphorus
1,200.00
Potassium
5,110.00
Sodium
2,810.00
Total Kjeldahl Nitrogen
737.00
c. Using the results listed in Item II. 5b. above, calculate the sodium adsorption ration (SAR): 4.97
[Note: If residuals contain SAR of 10 or higher, the applicant shall obtain recommendations from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, a
North Carolina Licensed Soil Scientist, or an agronomist, prior to land application of residuals. The recommendations shall
address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a mechanism for maintaining site integrity
and conditions conducive to crop growth].
d. Specify the mineralization rate to be used in calculating the plant available nitrogen (PAN) of the residuals: 40 %. This
rate is a (check one): ® default value, or actually established.
If the residuals are not generated from the treatment of municipal or domestic wastewater, explain or provide technical
justification as to why the selected default value is appropriate to be applied to these residuals:
e. Calculate the PAN for the residuals (i.e., on a dry weight basis) and fill the results in the following table:
Application Method
First (151) Year PAN
Five -Year
Maximum Adjusted PAN
(ntglkg)
(nig/kg)
Surface
315
458
Injection/Incorporation
324
468
6. Other Pollutants Determination: Specify whether or not there are any other pollutants of concern in the residuals and provide
the results of the latest analyses:
FORM: RSC 06-16 Page 4 of 5

7. Pathogen Reduction: Per 15A NCAC 02T.1 106, specify how residuals will meet the pathogen reduction requirements:
a. For Distribution/Land Application of Class A or Equivalent:
® A fecal coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry solids,
or
❑ A salmonella sp. density that is demonstration to be less than 3 MPN per 4 grams of total dry solids.
AND one of the followings (except for non -biological residuals):
kE Alternative 1 [15A NCAC 02T.1106(b)(3)(A)] - Time/Temperature Compliance.
Alternative 2 [15A NCAC 02T.1106(b)(3)(B)] -Alkaline Treatment.
Alternative 3 [15A NCAC 02T.1106(b)(3)(C)] -Prior Testing for Enteric VirusNiable Helminth Ova.
Eg Alternative 4 [15A NCAC 02T.]106(b)(3)(D)] -No Prior Testing for Enteric Virus/Viable Helminth Ova.
Alternative 5 [15A NCAC 02T. 1106(b)(3)(E)-(K)] - Process to Further Reduce Pathogens (PFRP).
Specify one: ❑ composting, 0 heat drying, � heat treatment,
❑ thermophilic aerobic digestion, ❑ beta ray irradiation,
❑ gamma ray irradiation, or ❑ pasteurization.
b. For Land Application of Class B:
0 Alternative 1 [15A NCAC 02T.I 106(c)(1)] - Fecal Coliform Density Demonstration.
Q Alternative 2 [15A NCAC 02T.1106(c)(2)] -Process to Significantly Reduce Pathogens (PSRP).
Specify one: ❑ aerobic digestion, ❑ air drying, 0 anaerobic digestion,
❑ composting, or El lime stabilization.
c. For Surface Disposal:
❑ Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item II. 7a. above.
❑ Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item 11. 7b. above.
❑ Exempt -If Daily Cover Alternative is chosen in Item I1.8. below [15A NCAC 02T.1106(a)(2)].
El Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
8. Vector Attraction Reduction (VAR): Per 15A NCAC 02T.1 107, specify how residuals will meet the VAR requirements:
❑ Alternative 1 [ 15A NCAC 02T.I 107(a)(1)] - 38% Volatile Solids Reduction (Aerobic/Anaerobic Digestion).
❑ Alternative 2 [15A NCAC 02T.I 107(a)(2)] - 40-Day Bench Scale Test (Anaerobic Digestion).
Alternative 3 [15A NCAC 02T.I 107(a)(3)] - 30-Day Bench Scale Test (Aerobic Digestion).
❑ Alternative 4 [15A NCAC 02T. 1107(a)(4)] - Specific Oxygen Uptake Rate Test (Aerobic Digestion).
❑ Alternative 5 [15A NCAC 02T. 1107(a)(5)] - 14-Day Aerobic Processes.
❑ Alternative 6 [15A NCAC 02T.1 107(a)(6)] -Alkaline Stabilization.
❑ Alternative 7 [15A NCAC 02T.I 107(a)(7)] - Drying of Stabilized Residuals.
❑ Alternative 8 [15A NCAC 02T. I 107(a)(8)] - Drying of Unstabilized Residuals.
❑ Alternative 9 [15A NCAC 02T.1 107(a)(9)] - Injection.
❑ Alternative 10 [ 15A NCAC 02T. 1107(a)(10)] - Incorporation.
❑ Alternative for Surface Disposal Units Only - Soil/Other Material Cover [15A NCAC 02T.1107(b)(2)].
® Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
Note: For animal processing residuals, only alternatives 9 or 10 may be chosen due to the nuisance conditions that typically
occur when these residuals are applied and left on the land surface.
FORM: RSC 06-16 Page 5 of 5

Vicinity Map

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Residual Solids Distribution Site
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Process Flow Diagram and Narrative

FLYASH PROCESS NARRATIVE
Coal, sawdust, and bark are burned in #1 Power Boiler at 2000' F. Any unburned material
collects at the bottom of the boiler. This area is called the ash hopper. Untreated river water is
used to carry the ash from the ash hopper through a pipe to the Ash Pond.
Particulates that become air -borne with the smoke are captured by water showers, called Scrubbers
in the smokestacks. The particulates washed down from the scrubbers are collected in Scrubber
tanks and pumped to the Ash Pond.
At the Ash Pond, the solids settle to the bottom. As solids settle, the clear liquid is decanted and
flows to the head of the Wastewater Plant. The solids are dipped from the Ash Pond weekly.
After they dry at the edge of the pond, the Flyash is hauled to the WestRock Kraft Paper, L L C .
Landfill Permit #WQ0000436. The past several years the amount of coal used as fuel has been
less than 50% by weight.

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Justification of Residuals Production Rate

JUSTIFICATION OF RESIDUALS PRODUCTION RATE
WestRock Kraft Paper produces approximately 15,000 dry tons of the flyash annually. Based on
recent year's distribution, less than 1,600 dry tons of flyash have been distributed annually.
WestRock requests the limit remain at 1,649 dry tons.

Sampling Plan

FLYASH SAMPLING PLAN
WestRock Flyash will be transported from the ash pond to the landfill in sealed sludge trailers.
The flyash will be kept separate from primary clarifier solids and time mud that are also placed
into the landfill for disposal. The area that contains the flyash solids will be maintained
separately to allow the sampling of newly generated flyash as well as stockpiled flyash.
Each quarter that residual solids are to be land applied, WestRock Flyash will be sampled from the
landfill or from dipped solids from the Ash pond; to insure the beneficial utilization for agricultural
production, when application activities are due to occur, or when requested by the soil amendment
manufacturer. Representative samples of the WestRock Flyash will be sent to a qualified
laboratory and analyzed for nutrient and metals and 7 fecal samples. Once a permit
cycle, a residuals solid sample will be analyzed for TCLP. TCLP parameters are listed below:
Arsenic
Cadmium
Chlorobenzene
o-Cresol
Cresol
1,2-Dichloroethane
Endrin
Hexachloroethane
Lindane
Methyl ethyl ketone
Pyridine
Tetrachloroethylene
2,4,5-Trichlorophenol
Vinyl chloride
Barium
Benzene
Carbon tetrachloride
Clilordane
Chloroform
Chromium
nrCresol
p-Cresol
2, 4-D
l ,4-Dichlorobenzene
1, 1 -Dichloroethylene
2,4-Dinitrotoluene
Hexachlorobenzene
Heptachlor (and its hydroxide)
Lead
Hexachloro-1,3-butadiene
Mercury
Methoxychlor
Nitrobenzene
Pentachlorophenol
Selenium
Silver
Toxaphene
Trichloroethylene
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)
Each quarter that residual solids are to be distributed, the residual solids will be analyzed
for: Cadmium, Copper, Lead, Nickel, Zinc, Aluminum, Ammonia- Nitrogen, Nitrate -Nitrite,
Nitrogen, r/o Total Solids, pH, Phosphorus, Potassium, TKN, and Calcium Carbonate
Equivalency (CCE). From this information, the Plant Available Nitrogen (PAN) will be
calculated.

Residual Analytical Reports

Meritech, Inc.
Environmental Laboratory
.�. Laboratory Certification No. 165
Contact: Neal Davis
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870
Report Date:
NPDES#:
Project:
Date Sample Rcvd:
8/5/2019
WQ0021577
WQ0000436
Monthly
7/11/2019
Meritech Work Order #
071119112 Sample: Flyash Grab
7/11/19
Parameters
Results
Analysis Date
Analyst
Reporting Limit
Method
% Total Solids
54.8 %
7/12/19
JM
0-100 %
SM2540B
Ammonia, Nitrogen
<18.2 mg/kg
7/16/19
LH
18.2 mg/kg
EPA 350.1
TKN
737 mg/kg
8/2/19
NW
20 mg/kg
EPA 351.1
Nitrate/Nitrite Nitrogen
<18.2 mg/kg
7/17/19
LH
18.2 mg/kg
EPA 353.2
Nitrogen, total
737 mg/kg
8/5/19
NW
20 mg/kg
EPA 353.2
Aluminum, total
15,500 mg/kg
7/17/19
ED
5.00 mg/kg
EPA 200.7
Arsenic, total
14.4 mg/kg
7/17/19
ED
1.00 mg/kg
EPA 200.7
Barium, total
453 mg/kg
7/17/19
ED
0.500 mg/kg
EPA 200.7
Cadmium, total
0.633 mg/kg
7/17/19
ED
0.200 mg/kg
EPA 200.7
Calcium, total
9,820 mg/kg
7/17/19
ED
10.0 mg/kg
EPA 200.7
Chromium, total
27.6 mg/kg
7/17/19
ED
0.100 mg/kg
EPA 200.7
Copper, total
68.2 mg/kg
7/17/19
ED
1.00 mg/kg
EPA 200.7
Lead, total
21.4 mg/kg
7/17/19
ED
0.50 mg/kg
EPA 200.7
Magnesium, total
2040 mg/kg
7/17/19
ED
10.0 mg/kg
EPA 200.7
Mercury, total
0.091 mg/kg
7/16/19
MR
0.02 mg/kg
EPA 245.1
Molybdenum, total
1.35 mg/kg
7/17/19
ED
0.500 mg/kg
EPA 200.7
Nickel, total
37.2 mg/kg
7/17/19
ED
1.00 mg/kg
EPA 200.7
Phosphorous, total
1200 mg/kg
7/17/19
ED
2.00 mg/kg
EPA 200.7
Potassium, total
53:110 rag/kg
7/ 17 119
ED
2Q.0 ►17gji-
EPA 200.7
Selenium, total
<0.912 mg/kg
7/17/19
ED
0.912 mg/kg
EPA 200.7
Sodium, total
2810 mg/kg
7/17/19
ED
20.0 mg/kg
EPA 200.7
Zinc, total
57.3 mg/kg
7/17/19
ED
1.0 mg/kg
EPA 200.7
SAR
4.99 -
7/17/19
ED
-
-
pH
9.0 S.U.
7/12/19
JM
1.0 - 14.0 S.U.
SM 4500 H B
CCE*
<1 %
7/29/19
LH
1 %
AOAC 955.01
* Results not for regulatory purposes
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

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Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Page 1
Contact: Neal Davis Report Date: 8/23/2019
Client: Kapstone Paper & Packaging NPDES#: WQ0021577
100 Gaston Rd. WQ0000436
Roanoke Rapids, NC 27870 Date Sample Rcvd: 8/8/2019
Meritech Work Orderit 080819190 Sample: Flyash Grab 8/8/2019
1311- TCLP Metals
Parameter
Results
Analysis Date
Analyst
Det. Limit
Reg. Limit
Method
Arsenic
<0.010 mg/L
8/19/2019
ED
0.100
5.0
EPA 200.7
Barium
0.819 mg/L
8/19/2019
ED
0.050
100.0
EPA 200.7
Cadmium
<0.020 mg/L
8/19/2019
ED
0.020
1.0
EPA 200.7
Chromium
<0.050 mg/L
8/19/2019
ED
0.050
5.0
EPA 200.7
Lead
<0.100 mg/L
8/19/2019
ED
0.100
5.0
EPA 200.7
Mercury
<0.02 mg/L
8/13/2019
MR
0.02
0.2
EPA 245.1
Selenium
<0.100 mg/L
8/19/2019
ED
0.100
1.0
EPA 200.7
Silver
<0.050 mg/L
8/19/2019
ED
0.050
5.0
EPA 200.7
TCLP Organics
Parameter
Results
Analysis Date
Analyst
Reporting Limit
Method
Volatiles 8260
Attached
8/14/2019
VV
-
8260
Semi Vol. 8270
Attached
8/20/2019
PM
-
8270
Other Tests
Parameter
Results
Analysis Date
Analyst
Reporting Limit
Method
Cyanide, total
<0.500 mg/kg
8/16/2019
LH
0.500 mg/kg
EPA 335.4
Sulfide
<10 mg/kg
8/14/2019
LH
10 mg/kg
SW 846 9038
Ignitability
Will Not Ignite
8/19/2019
NW
-
EPA 1030
Corrositivity (pH)
7.9 S.U.
8/12/2019
JM
1.0 - 14.0 S.U.
SM 4500 HB
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Page 2
Contact: Neal Davis Report Date: 8/23/2019
Client: Kapstone Paper & Packaging NPDES#: WQ0021577
100 Gaston Rd. WQ0000436
Roanoke Rapids, NC 27870 Date Sample Rcvd: 8/8/2019
Meritech Work Order # 080819150 Sample: Flyash Grab 8/8/2019
1311- TCLP Pesticides & Herbicides
Pesticide - SW-846 8081A
Parameter Results Analysis Date Analyst Det. Limit Reg. Limit Dilution Factor
Endrin
Attached - - - -
Chlordane
Attached - - - -
Toxaphene
Attached - - - -
Methoxychlor
Attached - - - -
Heptachlor
Attached - - - -
Lindane
Attached - - - -
Herbicides - SW-846 8151A
Parameter Results Analysis Date Analyst Det. Limit Reg. Limit Dilution Factor
2,4-D Attached - - - -
2,4,5-TP (Silvex) Attached - - - -
I hereby certify that I have reviewed and approve these data. ( -
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

MERITECH, INC.
- Environmental Laboratories
Laboratory Certificate #165
Client: Kapstone Kraft Paper Corp
Project: TCLP
Client Sample ID: Flyash
Sample Collection: 08/08/19
Meritech Sample ID: 080819150
1311 - TCLP Organics
Volatiles: SW-846 8260
Analysis: 08/14/19
Extraction:
08/12/19
Analyst: VWV
Report Date:
08/20/19
Parameter
Result
Units
Det. Limit
Ree. Limit
Dilution Factor
Benzene
< 0.0100
mg/L
0.0100
0.50
10
Carbon Tetrachloride
< 0.0100
mg/L
0.0100
0.50
IO
Chlorobenzene
< 0.0100
mg/L
0.0100
100
10
Chloroform
< 0.0100
mg/L
0.0100
6.0
I0
1,2-Dichloroethane
< 0.0100
mg/L
0.0100
0.50
l0
l,l-Dichloroethene
< 0.0100
mg/L
0.0100
0.70
10
Methyl Ethyl Ketone
< 0.100
mg/L
0.100
200
10
Tetrachloroethylene
< 0.0100
mg/L
0.0100
0.70
t0
Trichloroethene
< 0.0100
mg/L
0.0100
0.50
10
Vinyl Chloride
< 0.0200
mg/L
0.020
0.20
10
Semi-Volatiles: SW-846 8270
Analysis: 08/20/19
Extraction:
08/12/19
Analyst: PM
Report Date:
08/20/19
Parameter
Result
'Units
!let. Limit
Ree. Limit
Dilution Factor
1,4-Dichlorobenzene
<0.100
mg/L
0.100
7.5
10
Hexachlorobenzene
<0.100
mg/L
0.100
0.13
10
Hexachloro-1,3-butadiene
<0.100
mg/L
0.100
0.5
10
Hexachloroethane
<0.100
mg/L
0.100
3.00
10
o-cresol
<0.100
mg/L
0.100
200
10
m&p-cresol
<0.200
mg/L
0.200
200
10
Total cresols
<0.300
mg/L
0.300
200
10
Nitrobenzene
<0.100
mg/L
0.100
2.00
10
Pentachlorophenol
<0.500
mg/L
0.500
100
10
Pyridine
<0.100
mg/L
0.100
5.0
10
2,4,5-Trichlorophenol
<0.100
mg/L
0.100
400
10
2,4,6-Trichlorophenol
<0.100
mg/L
0.100
2.00
10
2,4-Dinitrotoluene
<0.100
mg/L
0.100
0.13
10
1 hereby certify that I have reviewed and approve
these data.
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] * [e-mail]

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Meritech, Inc.
y Environmental Laboratory
Laboratory Certification No. 165
Page 1
Contact: Neal Davis Report Date: 7/23/2019
Client: Kapstone Paper & Packaging NPDES#: WQ0021577
100 Gaston Rd. WQ0000436
Roanoke Rapids, NC 27870 Date Sample Rcvd: 7/11/2019
Meritech Work Order # 07111975 Sample: Flyash 0 7-19 Grab 7/11/19
Parameters Results Analysis Date Analyst Reporting Limit Method
% Total Solids 54.1 % 7/12/19 JM 0-100 % SM 2540B
Fecal Coliform <168 col/ g dry 7/11/19 CD 168 col/ g dry SM 9222 D
Meritech Work Order # 07111976 Sample: Flyash P 7-19 Grab 7/11/19
Parameters Results Analysis Date Analyst Reporting Limit Method
% Total Solids
52.1 %
7/12/19
JM
0-100 %
SM 2540B
Fecal Coliform
<174 col/ g dry
7/11/19
CD
174 col/ g dry
SM 9222 D
Meritech Work Order # 07111977 Sample: Flyash Q 7-19 Grab
Parameters Results Analysis Date Analyst
7/11/19
Reporting Limit Method
% Total Solids
54.3 %
7/12/19
JM
0-100 %
SM 2540B
Fecal Coliform
<167 col/ g dry
7/11/19
CD
167 col/ g dry
SM 9222 D
Meritech Work Order # 07111978 Sample: Flyash R 7-19 Grab
7/11/19
Parameters Results Analysis Date Analyst Reporting imit Method
% Total Solids
53.6 %
7/12/19
JM
0-100 %
SM 2540B
Fecal Coliform
<170 col/ g dry
7/11/19
CD
170 col/ g dry
SM 9222 D
Meritech Work Order # 07111979 Sample: Flyash S 7-19 Grab
7/11/19
Parameters Results Analysis Date Analyst Reporting Limit Method
% Total Solids
52.4 %
7/12/19
JM
0-100 %
SM 2540E
Fecal Coliform
<173 col/ g dry
7/11/19
CD
173 col/ g dry
SM 9222 D
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: Neal Davis
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870
Page 2
Report Date: 7/23/2019
NPDES#: WQ0021577
WQ0000436
Date Sample Rcvd: 7/11/2019
Meritech Work Order # 07111980 Sample: Flyash T 7-19 Grab 7/11/19
Paramgters Results Analysis Date Analyst Reporting Limit Method
% Total Solids 53.7 % 7/12/19 JM 0-100 % SM 2540B
Fecal Coliform <169 col/ g dry 7/11/19 CD 169 col/ g dry SM 9222 D
Meritech Work Order # 07111981 Sample: Flyash U 7-19 Grab 7/11/19
Parameter Results Analysis Date Analyst Reporting Limit Method
% Total Solids 54.4 % 7/12/19 JM 0-100 % SM 2540B
Fecal Coliform <167 col/ g dry 7/11/19 CD 167 col/ g dry SM 9222 D
I hereby certify that I have reviewed and approve these data. eo- �.L a
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

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SECTION III
RESIDUALS SOURCE CERTIFICATION ATTACHMENT -
PRIMARY CLARIFER SOLIDS

State of North Carolina
DWR
Department of Environmental Quality
Division of Water Resources
Division of Water Resources RESIDUALS SOURCE CERTIFICATION
INSTRUCTIONS FOR FORM: RSC 06-16
Please use the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these
instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of additional
information requested. Failure to submit all of the required items will lead to additional processing and review time for the
permit application. Unless otherwise noted, the Applicant shall submit one original and two conies of the application and
supporting documentation
For more information, visit the Water Quality Permitting Section's Nat -Discharge Permitting Unit
General — This certification provides detailed information of residuals source generating facility and its residuals quality for land
application, distribution, or disposal in accordance with 15A NCAC 02T .1 100. Do not submit this certification for review without
a corresponding application form (FORM: RLAP 11-15, FORM: DCAR 11-15, or FORM: SDR 11-15).
Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed
below.
A. Residuals Source Certification (FORM: RSC 11-15):
® Submit the completed and appropriately executed Residuals Source Certification (FORM: RSC 11-15) form. Please do not
make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachments to the
application may be made, as long as the attachments are numbered to correspond to the section and item to which they refer.
® For new or renewed permits, submit a separate certification for each source facility.
❑ For modified permits, submit a separate certification for only those facilities that are affected by the proposed modification.
® Complete the residuals source facility summary page. List all new, renewed, or modified facilities.
B. Residuals Source -Generating Facility Information:
® For each source facility, attach the following:
® Vicinity map - A vicinity map that shows the location of the facility and meets all of the criteria in the "Map Guidance for
Residuals Land Application Permits".
® Process flow diagram and/or narrative - A detailed narrative and/or process flow diagram that describes how the residuals
are to be generated, treated, processed, and stored at the facility.
® Quantitative justification for residuals production rate - A quantitative justification for the value provided in Item I. 8.
Ensure that the amount of residuals listed is the maximum amount expected to be generated by the facility for the life of
the permit. In addition, ensure that this amount is equivalent to that which is actually to be land applied, distributed,
and/or disposed, including any chemicals, amendments, or other additives that are added to the residuals during
processing.
® Sampling plan - A detailed sampling plan for the residuals source -generating facility. Ensure that the plan identifies
sampling points, sampling frequency, sample type, as well as the Division -certified laboratory to be used. In addition,
ensure that the plan details how the facility and/or the residuals are monitored for any applicable pathogen reduction and
vector attraction reduction requirements. Note that all sampling and monitoring must be completed on the residuals as
they are to be land applied, distributed, and/or disposed.
C. Residuals Quality Information:
® For each source facility, attach the following:
® Laboratory analytical reports and operational data - reports for all laboratory analyses used to complete this certification.
® Documentation that the facility complies and/or the residuals comply with any applicable pathogen reduction and vector
attraction reduction requirements.
❑ For new facility that may have not yet been constructed and analytical results of residuals cannot be obtained, please
attach analytical results of residuals generated from a similar facility along with the description of similarities of the two
facilities.
INSTRUCTIONS FOR FORM: RSC 06-16 Page 1 of I

EN
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!' )lWR
Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
RESIDUALS SOURCE CERTIFICATION
FORM: RSC 06-16
I. RESIDUALS SOURCE -GENERATING FACILITY INFORMATION (See Instruction B.):
1. Facility Name: WestRock Kraft Paper, LLC.
2. Facility permit holder is: ❑ Federal, [D State, E] Local Government, or ® Private.
Facility permit issued by: Div. of Water Resources, ® Div. of Environmental Health,
or Other (explain: ).
3. Facility contact person and title: Mr. Chris Williams Environmental Engineer
Complete mailing address: 100 Gaston Road
City: Roanoke Rapids State: NC Zip: 27870-17-71 number: [phone] E-mail address: [e-mail]
4. Facility physical address: 100 Gaston Road
City: Roanoke Rapids State: NC Zip: 27870-
Coordinates: Latitude: 36' 28' 33.24" N Longitude: 77' 38' 37 28" W
Datum: NAD 1983 UTM 18N Level of accuracy: 1I"
Method of measurement: Man
5. Purpose of the facility:
❑ treatment of municipal wastewater, Q treatment of 100% domestic wastewater,
❑ treatment of potable water, 0 treatment of 100% industrial wastewater,
® treatment of industrial wastewater mixed with domestic wastewater,
(approximate percentages: 99.942% industrial and 0.058 % domestic)
❑ other (explain: ).
6. Does the facility have an approved pretreatment program: 0 Yes ® No
7. Facility permitted/design flow: NA MGD and facility average daily flow: NA MGD
8. Average amount of residuals being generated at this facility 1,649 dry tons per year.
9. Specify the following regarding treatment and storage volumes available at the facility:
Type and volume of residuals treatment: NA for treatment: monofil for storage
Type and volume of residuals storage (i.e., outside of residuals treatment units): None.
II. RESIDUALS QUALITY INFORMATION (See Instruction C.):
1. Specify if residuals are regulated under:
R 40 CFR Part 503 or ® 40 CFR Part 257.
Note: Only residuals that are generated during domestic/municipal wastewater treatment processes are regulated under 40
CFR Part 503, otherwise, the residuals are regulated under 40 CFR Part 257.
2. Specify if residuals are defined under 15A NCAC 02T.1102(6) as:
❑ Biological ® Non -Biological
Note: Biological residuals are residuals that have been generated during the treatment of domestic wastewater, animal
processing wastewater, or the biological treatment of industrial wastewater (biological treatment is a system that utilizes
biological processes including lagoons, activated sludge systems, extended aeration systems, and fixed film systems).
FORM: RSC 06-16 Page 1 of 5

3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non -hazardous under
RCRA: (Note - this item does not have to be completed for facilities that are less than 0.5 MGD in design flow that treat
100% non -municipal, domestic wastewater only)
a. Are the residuals listed in 40 CFR §261.31-§261.33: ❑ yes ® no.
If yes, list the number(s):
b. Specify whether or not the residuals exhibit any of the characteristics defined by 40 CFR §261.21-
261.24: 9 yes ® no.
Fill in the following tables with the results of the latest toxicity characteristic leaching procedure (TCLP) analysis as
well as those for corrosivity, ignitability, and reactivity:
Laboratory: Meritech. Inc and Date of analysis: 8/23/19
Passed corrosivity test: ® yes ❑ no. pH: s.u. (2 < pH < 12.5)
Passed ignitability test: ® yes 0 no. Flashpoint: WNI IF (> 140°F)
Passed reactivity test: ® yes ❑no. HCN: <0.50 mg/kg (<250) & H2S: <10 mg/kg (<500)
TCLP Parameter
Limit
(ntg/1)
Result
(mg/1)
TCLP Parameter
Limit
(mg/1)
Result
(171g/1)
Arsenic
5.0
<0.010
Hexachlorobenzene
0.13
<0.10
Barium
100.0
0.642
Hexachloro-1,3-Butadiene
0.5
<0.10
Benzene
0.5
<0.01
Hexachloroethane
3.0
<0.10
Cadmium
1.0
<0.02
Lead
5.0
<0.10
Carbon Tetrachloride
0.5
<0.01
Lindane
0.4
<0.04
Chlordane
0.03
<0.003
Mercury
0.2
<0.02
Chlorobenzene
100.0
<0.01
Methoxychlor
10.0
<1.0
Chloroform
6.0
<0.01
Methyl Ethyl Ketone
200.0
<0.10
Chromium
5.0
<0.05
Nitrobenzene
2.0
<0.10
m-Cresol
200.0
<0.20
Pentachlorophenol
100.0
<0.50
o-Cresol
200.0
<0.10
Pyridine
5.0
<0.10
p-Cresol
200.0
<0.20
Selenium
1.0
<0.10
Cresol
200.0
<0.30
Silver
5.0
<0.05
2,4-D
10.0
<1.00
Tetrachloroethylene
0.7
<0.01
1,4-Dichlorobenzene
7.5
<0.10
Toxaphene
0.5
<0.05
1,2-Dichloroethane
0.5
<0.01
Trichloroethylene
0.5
<0.01
1, 1 -Dichloroethylene
0.7
<0.01
2,4,5-Trichlorophenol
400.0
<0.10
2,4-Dinitrotoluene
0.13
<0.10
2,4,6-Trichlorophenol
2.0
<0.10
Endrin
0.02
<0.002
2,4,5-TP (Silvex)
1.0
<0.10
Heptachlor and its Hydroxide
0.008
<0.0008
Vinyl Chloride
0.2
<0.02
FORM: RSC 06-16 Page 2 of 5

4. Metals Determination: Complete one of the following tables (i.e., as applicable) to demonstrate that the residuals do not
violate the ceiling concentrations for metals regulated under 15A NCAC 02T .1 105.
a. For Distribution/Land Application: Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: Meritech. Inc. and Date of analysis: 8/5/19
Parameter
Ceiling
Monthly Average
Result
Concentration Limits
Concentration Limits
(ClassA & ClassB)
(Class A Only)
(nlg1kg)
(mg1kg)
(mgAg)
Arsenic
75
41
2.27
Cadmium
85
39
4.30
Copper
4,300
1,500
100.00
Lead
840
300
7.91
Mercury
57
17
0.05
Molybdenum
75
n/a
<0.516
Nickel
420
420
30.20
Selenium
100
100
2.38
Zinc
7,500
2,800
533.00
b. For Surface Disposal Unit (landfill): Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: f and Date of analysis:
Distance from Disposal
Unit to Boundary to
Closest Property Line
(meters, check one)
Arsenic
(nig/kg)
Chromium
(ntg/kg)
Nickel
(nig/kg)
❑ > 0 but < 25
30
200
210
E > 25 but < 50
34
220
240
> 50 but < 75
39
260
270
❑ > 75 but < 100
46
300
320
❑ > 100 but < 125
53
360
390
❑ > 125
62
450
420
Result (mg/kg)
FORM: RSC 06-16 Page 3 of 5

5. Nutrient/Micronutrient Determination: Complete the following:
a. Total solids: 48.4 %.
b. Fill in the following table with the results of the latest analyses (i.e., on a dry weight basis) for the following nutrient and
micronutrient parameters:
Laboratory: Meritech. Inc. and Date of analysis: 8/5/19
Parameter
Result
(mg1kg)
Aluminum
6,880.00
Ammonia -Nitrogen
<20.70
Calcium
146,700.00
Magnesium
8,100.00
Nitrate -Nitrite Nitrogen
<20.70
pH (Standard Unit)
8.00
Phosphorus
2,230.00
Potassium
1,230.00
Sodium
4,480.00
Total Kjeldahl Nitrogen
349.00
c. Using the results listed in Item 1I. 5b. above, calculate the sodium adsorption ration (SAR): 2.14
[Note: If residuals contain SAR of 10 or higher, the applicant shall obtain recommendations from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, a
North Carolina Licensed Soil Scientist, or an agronomist, prior to land application of residuals. The recommendations shall
address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a mechanism for maintaining site integrity
and conditions conducive to crop growth].
d. Specify the mineralization rate to be used in calculating the plant available nitrogen (PAN) of the residuals: 40 %. This
rate is a (check one): ® default value, or ❑ actually established.
If the residuals are not generated from the treatment of municipal or domestic wastewater, explain or provide technical
justification as to why the selected default value is appropriate to be applied to these residuals:
e. Calculate the PAN for the residuals (i.e., on a dry weight basis) and fill the results in the following table:
Application Method
First (I") Year PAN
Five -Year
Maximum Adjusted PAN
(mg/kg)
(nig/kg)
Surface
162
228
Injection/Incorporation
173
238
6. Other Pollutants Determination: Specify whether or not there are any other pollutants of concern in the residuals and provide
the results of the latest analyses: L�t;L___J
FORM: RSC 06-16 Page 4 of 5

7. Pathoeen Reduction: Per 15A NCAC 02T.1 106, specify how residuals will meet the pathogen reduction requirements:
a. For Distribution/Land Application of Class A or Eauivalent:
® A fecal coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry solids,
or
❑ A sabnonella sp. density that is demonstration to be less than 3 MPN per 4 grams of total dry solids.
AND one of the followings (except for non -biological residuals):
❑ Alternative 1 [15A NCAC 02T.1 106(b)(3)(A)] - Time/Temperature Compliance.
❑ Alternative 2 [15A NCAC 02T.1106(b)(3)(B)] - Alkaline Treatment.
0 Alternative 3 [15A NCAC 02T. 1106(b)(3)(C)] - Prior Testing for Enteric VirusNiable Helminth Ova.
0 Alternative 4 [15A NCAC 02T.I 106(b)(3)(D)] - No Prior Testing for Enteric VirusNiable Helminth Ova.
Alternative 5 [15A NCAC 02T.I 106(b)(3)(E)-(K)] - Process to Further Reduce Pathogens (PFRP).
Specify one: composting, ❑ heat drying, ❑ heat treatment,
® thermophilic aerobic digestion, ❑ beta ray irradiation,
❑� gamma ray irradiation, or ❑ pasteurization.
b. For Land Application of Class B:
❑ Alternative 1 [15A NCAC 02T.I 106(c)(1)] - Fecal Coliform Density Demonstration.
0 Alternative 2 [15A NCAC 02T.I 106(c)(2)] - Process to Significantly Reduce Pathogens (PSRP).
Specify one: D aerobic digestion, ❑ air drying, ❑ anaerobic digestion,
12
composting, or Ellime stabilization.
c. For Surface Disposal:
❑ Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item II.7a. above.
❑ Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item II. 7b. above.
Q Exempt -If Daily Cover Alternative is chosen in Item II.8. below [15A NCAC 02T.1106(a)(2)].
Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
8. Vector Attraction Reduction (VAR): Per 15A NCAC 02T.1 107, specify how residuals will meet the VAR requirements:
Alternative I [15A NCAC 02T.1 107(a)(1)] - 38% Volatile Solids Reduction (Aerobic/Anaerobic Digestion).
❑ Alternative 2 [15A NCAC 02T.I 107(a)(2)] - 40-Day Bench Scale Test (Anaerobic Digestion).
❑ Alternative 3 [15A NCAC 02T.1 107(a)(3)] - 30-Day Bench Scale Test (Aerobic Digestion).
❑ Alternative 4 [15A NCAC 02T.1 107(a)(4)] -Specific Oxygen Uptake Rate Test (Aerobic Digestion).
❑ Alternative 5 [15A NCAC 02T.I 107(a)(5)] - 14-Day Aerobic Processes.
❑ Alternative 6 [15A NCAC 02T.1 107(a)(6)] -Alkaline Stabilization.
❑ Alternative 7 [15A NCAC 02T.I 107(a)(7)] - Drying of Stabilized Residuals.
Alternative 8 [15A NCAC 02T.1107(a)(8)] - Drying of Unstabilized Residuals.
❑ Alternative 9 [15A NCAC 02T. 1107(a)(9)] - Injection.
❑ Alternative 10 [15A NCAC 02T.I 107(a)(10)] - Incorporation.
❑ Alternative for Surface Disposal Units Only - Soil/Other Material Cover [15A NCAC 02T.1107(b)(2)].
® Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
Note: For animal processing residuals, only alternatives 9 or 10 may be chosen due to the nuisance conditions that typically
occur when these residuals are applied and left on the land surface.
FORM: RSC 06-16 Page 5 of 5

Vicinity Map

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NRCan, Esri Japan, METI, Esri China (Hong Kong), EsritKorea, Esn
�o (Thailand), Mapmylndia, NGCC, © OpenStreetMap contributors, and the
o` RO GIS User Community
SCALE: 1 " = 1,500 ft WestRock Kraft Paper, LLC
Residual Solids Distribution Site
CHECKED BY: RTB Flaysh and Primary Clarifier Solids Vicinity
RESIDUALS DRAWN BY: RTB+8L
BRANCH Roanoke Rapids, NC Map
DATE: 1/11/2020 OILS, LLC P.J.tN.. 2007-68

Process Flow Diagram and Narrative

PRIMARY CLARIFIER SOLIDS PROCESS NARRATIVE
All process and stormwater contributions enter the open ditch or channel. Near the head of the
channel, baffles have been installed to aid mixing and provide a representative sample of what is
going to the wastewater treatment plant concerning solids, BOD, COD, TSS, pH, and
conductivity. There is a small work area suspended above the main sewer. This area is equipped
with an influent sampler. The walking bridge is equipped with a flow meter, pH probe,
conductivity probe, and temperature probe. These readings, conductivity, pH, and flow are sent
to the sludge press provox. These readings are used to determine if, when, and how long bypass
should be engaged to the surge pond to avoid causing any harm to the treatment plant.
Typically, wastewater flows through the bar screen that removes large pieces of debris such as
wood knots, large strips of paper, rocks, etc. After the bar screen, the flow goes into the wet well
where the three lift pumps send the flow to the clarifier center well. Each lift pump is rated at
7,500 gpm (10 mgd). Based on recent calculations, WestRock has 0.058% domestic contribution
and 99.942% industrial. The domestic contribution is handled within the same process that the
industrial Primary Clarifier Solids are processed. Other domestic contributions are sent to the city
of Roanoke Rapids. The domestic contributions noted can not be excluded from the industrial
Primary Clarified Solids.
Mixed wastewater (industrial and domestic) is pumped up through a pipe to the center well where
the flow goes out the top. The flow velocity is reduced and forced down by a metal retaining
ring. This metal retaining ring is 24-feet in diameter, and extends down the clarifier 8-feet below
the surface of the water. The retaining ring serves two purposes: it prevents the flow from short-
circuiting the clarifier, which could prevent the solids in the wastewater from settling out in the
clarifier and place more solids loading on the other parts of the treatment plant and it helps
to distribute solids equally throughout the clarifier. The settleable solids drift to the bottom of
the clarifier, where they are pushed toward the center well by the plows on the rake system.
These solids are then pumped to the blend tank using the sludge pumps. The non -settleable
solids, or floaters, are pushed to the collector by the skimmer. The water goes over the outside
weirs and into the launder trough and across the river by the 36-inch pipe and to the aeration
basin.
The clarifier sludge is pumped to the blend tank where sulfuric acid is added to lower the pH that
aids in the flocculation process. The sludge is pumped from the blend tank to either of two
Rotary Screen Thickeners (RST}. While in route to the RST, polymer is added to flocculate the
sludge. Solids from the BST's are sent to one of two 38-foot Dupps Andritz screw presses where
the solids content is pressed to 40% - 45%. The solids are then discharged into a screw
conveyor and transferred into sealed sludge trailers. The primary clarifier solids are taken either
to the mill's on site permitted landfill (NCDEQ Permit No. WQ0000436) for distribution under
this permit.
See following for the diagrams for process flow schematics for the water and solids for the
WestRock Kraft Paper Corporation Roanoke Rapids Water Treatment Plant.

stabm.a[ioo n.an s 2
309.5 MG
16 Days Retention
Roanoke Rapids
Waste«aterTreatment Plant
Aerators
4 - 50 lip Aero 2 Aerators
3- 75 hp Aero 2 Aerators
l 1 - 75 hp Aerators
13 - 60 hp Aerators
2030 hp Total
Stdairativt
Landfill Leachate
(26 cres)
97.73 MO
/ Aaatioa Buie \
set>rr.�tan (21s Aorta)
Uda 0 3
(1 t0 Aar") 73A Ma
1931 MO
la1 Mr Raarmt Stu* 1. SOM
mj A=_)
Roanoke River
Turpentine
Non-Conuet Dischame C
a"
Pull) Mia Udfi
FlyAth Pond
I.l MO
pgxr Mal Naq
Dpea Duch 1 • u Moo
_ r
Emergency Pond
Woodyard (20.4 Acres)
Scorme�� t.er
1'on�
CA wt It Suwmwater Ditch
1 MOD
6
Site Plan - Roanoke Rapids
a j

Justification of Residuals Production Rate

Justification of Residuals Production Rate
WestRock Kraft Paper LLC. produces approximately 15,000 dry tons of the primary clarifier solids
annually. Based on previous history, WestRock requests the limit remain at 1,649 dry tons.

Sampling Plan

PRIMARY CLARIFIER SOLIDS SAMPLING PLAN
WestRock Primary Clarifier Solids (PCS) will be transported from the screw presses to either
distribution points, non-specific receiver sites, or the landfill in sealed sludge trailers. The PCS will
be kept separate from the flyash and lime mud that are also placed into the landfill for disposal.
The area that contains the clarifier solids will be maintained separately to allow the sampling of
newly generated PCS as well as stockpiled PCS.
Each quarter that residual solids are to be land applied, WestRock PCS will be sampled from the
landfill or from the screw press; to insure the beneficial utilization for agricultural production,
when application activities are due to occur, or when requested by the soil amendment
manufacturer. Representative samples of the WestRock PCS will be collected and composited prior
to being sent to a qualified laboratory that is familiar with routine environmental sample preparation
and standards. Once a permit cycle, a residuals solid sample will be analyzed for TCLP. TCLP
parameters are listed below:
Arsenic
Cadmium
Chlorobenzene
o-Cresol
Cresol
1,2-Dichloroethane
Endrin
Hexachloroethane
Lindane
Methyl ethyl ketone
Pyridine
Tetrachloroethylene
2,4,5-Trichlorophenol
Vinyl chloride
Barium
Benzene
Carbon tetrachloride
Chlordane
Chloroform
Chromium
m-Cresol
p-Cresol
2, 4-D
1,4-Dichlorobenzene
1, 1 -Dichloroethylene
2,4-Dinitrotoluene
Hexachlorobenzene
Heptachlor (and its hydroxide)
Lead
Hexachloro-1,3-butadiene
Mercury
Methoxychlor
Nitrobenzene
Pentachlorophenol
Selenium
Silver
Toxaphene
Trichloroethylene
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)

Each quarter that residual solids are to be land applied, the residual solids will be analyzed for:
Cadmium, Copper, Lead, Nickel, Zinc, Aluminum, Ammonia -Nitrogen, Nitrate -Nitrite, Nitrogen,
% Total Solids, pH, Phosphorus, Potassium, TKN, and Calcium Carbonate Equivalency (CCE).
From this information, the Plant Available Nitrogen (PAN) will be calculated and seven fecal
samples or appropriate pathogen testing will be collected and sent to a qualified laboratory.

Residual Analytical Reports

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Contact: Neal Davis
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870
Meritech Work Order # 071119113
Parameters Results
Sample: Primary Clarifier Residuals Grab
Analysis Date Analyst
% Total Solids
48.4 %
7/12/19
JM
Ammonia, Nitrogen
<20.7 mg/kg
7/16/19
LH
TKN
349 mg/kg
8/2/19
NW
Nitrate/Nitrite Nitrogen
<20.7 mg/kg
7/14/19
LH
Nitrogen, total
349 mg/kg
8/5/19
NW
Aluminum, total
6,880 mg/kg
7/17/19
ED
Arsenic, total
2.27 mg/kg
7/17/19
ED
Barium, total
382 mg/kg
7/17/19
ED
Cadmium, total
4.30 mg/kg
7/17/19
ED
Calcium, total
146,700 mg/kg
7/17/19
ED
Chromium, total
33.9 mg/kg
7/17/19
ED
Copper, total
100 mg/kg
7/17/19
ED
Lead, total
7.91 mg/kg
7/17/19
ED
Magnesium, total
8100 mg/kg
7/17/19
ED
Mercury, total
0.052 mg/kg
7/16/19
MR
Molybdenum, total
<0.516 mg/kg
7/17/19
ED
Nickel, total
30.2 mg/kg
7/17/19
ED
Phosphorous, total
2230 mg/kg
7/17/19
ED
Potassium, Lucai
i230 mg/'kg
7/17/19
EL
Selenium, total
2.38 mg/kg
7/17/19
ED
Sodium, total
4480 mg/kg
7/17/19
ED
Zinc, total
533 mg/kg
7/17/19
ED
SAR
2.15 -
7/23/19
ED
pH
8.0 S.U.
7/12/19
JM
CCE*
34.9 %
7/29/19
LH
* Results not for regulatory purposes
Report Date:
8/5/2019
NPDES#:
WQ0021577
WQ0000436
Project:
Monthly
Date Sample Rcvd:
7/11/2019
Reporting Limit
0-100 %
20.7 mg/kg
20 mg/kg
20.7 mg/kg
20 mg/kg
5.00 mg/kg
1.00 mg/kg
0.500 mg/kg
0.200 mg/kg
10.0 mg/kg
0.100 mg/kg
1.00 mg/kg
0.50 mg/kg
10.0 mg/kg
0.02 mg/kg
0.516 mg/kg
1.00 mg/kg
2.00 mg/kg
20.0 nig/ 1•:g
0.50 mg/kg
20.0 mg/kg
1.0 mg/kg
1.0 - 14.0 S.0
1 %
7/11/19
Method
SM2540B
EPA 350.1
EPA 351.1
EPA 353.2
EPA 353.2
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 245.1
EPA 200.7
EPA 200.7
EPA 200.7
EPA 2Q0.7
EPA 200.7
EPA 200.7
EPA 200.7
SM 4500 H B
AOAC 955.01
I hereby certify that I have reviewed and approve these data. Am� � "
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

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Meritech, Inc.
Environmental Laboratory
w Laboratory Certification No.165
Contact: Neal Davis
Report Date:
Page 1
8/23/2019
Client: Kapstone Paper & Packaging
NPDES#:
WQ0021577
100 Gaston Rd.
WQ0000436
Roanoke Rapids, NC 27870
Date Sample Rcvd:
8/8/2019
Meritech Work Order # 080819149 Sample: Primary Clarifier Residuals Grab
8/8/2019
1311- TCLP Metals
Parameter
Results
Analysis Date
Analyst
Det. Limit
Reg. Limit
Method
Arsenic
<0.010 mg/L
8/19/2019
ED
0.100
5.0
EPA 200.7
Barium
0.642 mg/L
8/19/2019
ED
0.050
100.0
EPA 200.7
Cadmium
<0.020 mg/L
8/19/2019
ED
0.020
1.0
EPA 200.7
Chromium
<0.050 mg/L
8/19/2019
ED
0.050
5.0
EPA 200.7
Lead
<0.100 mg/L
8/19/2019
ED
0.100
5.0
EPA 200.7
Mercury
<0.02 mg/L
8/13/2019
MR
0.02
0.2
EPA 245.1
Selenium
<0.100 mg/L
8/19/2019
ED
0.100
1.0
EPA 200.7
Silver
<0.050 mg/L
8/19/2019
ED
0.050
5.0
EPA 200.7
TCLP Organics
Parameter
Results
Analysis Date Analyst
Reporting Limit
Method
Volatiles 8260
Attached
8/14/2019 VV
-
8260
Semi Vol. 8270
Attached
8/20/2019 PM
-
8270
Other Tests
Parameter
Results
Analysis Date Analyst
Reporting Limit
Method
Cyanide, total
<0.500 mg/kg
8/16/2019 LH
0.500 mg/kg
EPA 335.4
Sulfide
<10 mg/kg
8/14/2019 LH
10 mg/kg
SW 846 9038
Ignitability
Will Not Ignite
8/19/2019 NW
-
EPA 1030
Corrositivity (pH)
9.0 S.U.
8/12/2019 JM
1.0 - 14.0 S.U.
SM 4500 HB
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

Meritech, Inc.
Environmental Laboratory
i-k Laboratory Certification No. 165
Page 2
Contact: Neal Davis Report Date: 8/23/2019
Client: Kapstone Paper & Packaging NPDES#: WQ0021577
100 Gaston Rd. WQ0000436
Roanoke Rapids, NC 27870 Date Sample Rcvd: 8/8/2019
Meritech Work Order # 080819149 Sample: Primary Clarifier Residuals Grab 8/8/2019
13 11 - TCLP Pesticides & Herbicides
Pesticide - SW-846 8081A
Parameter Results Analysis Date Analyst Det. Limit Reg. Limit Dilution Factor
Endrin Attached - - - _
Chlordane Attached - - - _
Toxaphene Attached - - - _
Methoxychlor Attached - - - _
Heptachlor Attached - - - _
Lindane Attached - - - _
Herbicides - SW-846 8151A
Parameter
2,4-D
2,4,5-TP (Silvex)
Results Analysis Date Analyst Det. Limit Reg. Limit Dilution Factor
Attached
Attached
1 hereby certify that 1 have reviewed and approve these data. Ama
La oratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

MERITECH, INC.
'em;i--Environmental Laboratories
Laboratory Certificate #165
Client: Kapstone Kraft Paper Corp
Project: TCLP
Client Sample ID: Primary Clarifier Residuals
Sample Collection: 08/08/19
Meritech Sample ID: 080819149
1311 - TCLP Organics
Volatiles: SW-846 8260
Analysis: 08/14/19
Extraction:
08/12/19
Analyst: VWV
Report Date:
08/20/19
Parameter
Result
Units
Det. Limit
Reg. Limit
Dilution Factor
Benzene
< 0.0100
mg/L
0.0100
0.50
10
Carbon Tetrachloride
< 0.0100
mg/L
0.0100
0.50
10
Chlorobenzene
< 0.0100
mg/L
0.0100
100
10
Chloroform
< 0.0100
mg/L
0.0100
6.0
10
1,2-Dichloroethane
< 0.0100
mg/L
0.0100
0.50
10
1, 1 -Dichloroethene
< 0.0100
mg/L
0.0100
0.70
10
Methyl Ethyl Ketone
< 0.100
mg/L
0.100
200
10
Tetrachloroethylene
< 0.0100
mg/L
0.0100
0.70
10
Trichloroethene
< 0.0I00
mg/L
0.0100
0.50
10
Vinyl Chloride
< 0.0200
mg/L
0.020
0.20
10
Semi-Volatiles: SW-846 8270
Analysis: 08/20/19
Extraction:
08/12/19
Analyst: PM
Report Date:
08/20/19
Parameter
Result
Units
net. Limit
Reg. Limit
Dilution Factor
1,4-Dichlorobenzene
<). 100
mg/L
0.100
7.5
10
Hexachlorobenzene
<0.100
mg/L
0.100
0.13
10
Hexachloro-1,3-butadiene
<0.100
mg/L
0.100
0.5
10
Hexachloroethane
<0.100
mg/L
0.100
3.00
10
o-cresol
<0.100
mg/L
0.100
200
10
m&p-cresol
<0.200
mg/L
0.200
200
10
Total cresols
<0.300
mg/L
0.300
200
10
Nitrobenzene
<0.100
mg/L
0.100
2.00
10
Pentachlorophenol
<0.500
mg/L
0.500
100
10
Pyridine
<0.100
mg/L
0.100
5.0
10
2,4,5-Trichlorophenol
<0.100
mg/L
0.100
400
10
2,4,6-Trichlorophenol
<0.100
mg/L
0.100
2.00
10
2,4-Dinitrotoluene
<0.100
mg/L
0.100
0.13
10
I hereby certify that 1 have reviewed and approve
these data.
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] * [e-mail]

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Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Page 1
Contact: Neal Davis Report Date: 7/23/2019
Client: Kapstone Paper & Packaging NPDES#: WQ0021577
100 Gaston Rd. WQ0000436
Roanoke Rapids, NC 27870 Date Sample Rcvd: 7/11/2019
Meritech Work Order # 07111982 Sample: PCR-15-7-19 Grab 7/11/19
Parameters Results Analysis Date Analyst Reporting Limit Method
% Total Solids 46.3 % 7/12/19 JM 0-100 % SM 2540B
Fecal Coliform 196 col/ g dry 7/11/19 CD 153 col/ g dry SM 9222 D
Meritech Work Order # 07111983 Sample: PCR-16-7-19 Grab 7/11/19
Parameters Results Analysis Date Analyst Reporting Limit Method
% Total Solids
46.1 %
7/12/19
JM
0-100 %
SM 2540B
Fecal Coliform
197 col/ g dry
7/11/19
CD
158 col/ g dry
SM 9222 D
Meritech Work Order # 07111984 Sample: PCR-17-7-19 Grab
7/11/19
Parameters Results Analysis Date Analyst Reporting Limit Method
% Total Solids
46.6 %
7/12/19
JM
0-100 %
SM 2540B
Fecal Coliform
<195 col/ g dry
7/11/19
CD
195 col/ g dry
SM 9222 D
Meritech Work Order # 07111985 Sample: PCR-18-7-19 Grab
7/11/19
Parameters Results Analysis Date Analyst Reporting Limit Method
% Total Solids
47.0 %
7/12/19
JM
0-100 %
SM 2540B
Fecal Coliform
387 col/ g dry
7/11/19
CD
158 col/ g dry
SM 9222 D
Meritech Work Order # 07111986 Sample: PCR-19-7-19 Grab
7/11/19
Parameters Results Analysis Date Analy s Reporting Limit Method
% Total Solids
47.7 %
7/12/19
JM
0-100 %
SM 2540B
Fecal Coliform
384 col/ g dry
7/11/19
CD
158 col/ g dry
SM 9222 D
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Contact: Neal Davis
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870
Page 2
ReportDate: 7/23/2019
NPDES#: WQ0021577
WQ0000436
Date Sample Rcvd: 7/11/2019
Meritech Work Order #
07111987 Sample: PCR-21-7-19 Grab
7/11/19
Parameters
Results Analysis Date Analyst
Reporting Limit
Method
% Total Solids
47.8 % 7/12/19 JM
0-100 %
SM 2540B
Fecal Coliform
190 col/ g dry 7/11/19 CD
158 col/ g dry
SM 9222 D
Meritech Work Order #
07111988 Sample: PCR-21-7-19 Grab
7/11/19
Parameters
Results Analysis Date Analyst
Reporting Limit
Method
% Total Solids
47.0 % 7/12/19 JM
0-100 %
SM 2540B
Fecal Coliform
387 col/ g dry 7/11/19 CD
158 col/ g dry
SM 9222 D
I hereby certify that I have reviewed and approve these data. 4fMfr& 0anwIL
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

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Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Page 1
Contact: Neal Davis Report Date: 4/26/2019
Client: Kapstone Paper & Packaging NPDES#: WQ0021577
100 Gaston Rd. WQ0000436
Roanoke Rapids, NC 27870 Date Sample Rcvd: 4/11/2019
Meritech Work Order # 04111962 Sample: PCR 8-4-19 Grab 4/11/19
Parameters Resumes Analysis Date Analy,Ft Reporting Limit Method
% Total Solids 59.3 % 4/12/19 JM 0-100 % SM 2540B
Fecal Coliform <153 col/ g dry 4/11/19 CD 153 col/ g dry SM 9222 D
Meritech Work Order # 04111963 Sample: PCR 9-4-19 Grab 4/11/19
Parameters Results Analysis Date Analyst Reporting Lim! Method
% Total Solids 57.6 % 4/12/19 JM 0-100 % SM 2540B
Fecal Coliform <158 col/ g dry 4/11/19 CD 158 col/ g dry SM 9222 D
Meritech Work Order # 04111964 Sample: PCR 10-4-19 Grab 4/11/19
Parameters
% Total Solids
Fecal Coliform
Results Analysis Date Analyst Reporting Limit Method
57.8 % 4/12/19 JM 0-100 % SM 2540B
629 col/ g dry 4/11/19 CD 235 col/ g dry SM 9222 D
Meritech Work Order # 04111965 Sample: PCR 11-4-19 6fab
Parameters Results Analysis Date Analyst
% Total Solids 58.7 % 4/12/19 JM
Fecal Coliform <155 col/ g dry 4/11/19 CD
Meritech Work Order # 04111966 Sample: PCR 12-4-19 Grab
Parameters Results Analysis Date Analyst
4/11/19
Reporting Limit Method
0-100 % SM 2540B
155 col/ g dry SM 9222 D
4/11/19
Reporting Limit Method
% Total Solids
58.7 %
4/12/19
JM
0-100 %
SM 2540B
Fecal Coliform
310 col/ g dry
4/11/19
CD
235 col/ g dry
SM 9222 D
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

SECTION IV
MANAGEMENT PLAN

MANAGEMENT PLAN
WestRock Kraft Paper, LLC. produces Primary Clarifier Solids (PCS) from its Roanoke Rapids,
North Carolina Wastewater Treatment Plant facility as a byproduct of Kraft paper production.
These residual solids are produced by non -biological processes following primary clarifier
separation. These residuals have a very small amount of domestic contribution. This facility
also operates under authority of WQ0000436 for these same residual solids and it has been riled that
pathogen testing should be required (for the Primary Clarifier Solids, but not for the Flyash), but
based on the treatment process being deemed non -biological, vector attraction reduction testing is
not required.
This same facility produces Flyash that is a mixture of coal, sawdust and bark that are burned
for power. The past several years the amount of coal used as fuel has been less than
50% by weight.
Several entities have approached WestRock with the intent of using its residuals (both Flyash
and PCS) in a variety of ways. These include:
• Sorptive media for hazardous waste,
• Sorptive media for hydrocarbon impacted media,
• Use as a landfill daily cover,
• Admixture for composts, soil amendments, and potting soils, and
• As a replacement for sawdust in the manufacture of bricks.
These uses are in addition to the direct application of these residuals to nonspecific receiver
sites.
For direct application, WestRock Kraft Paper, LLC. or it's assigned representative will identify
local landowners and/or other property as receiver sites. Application made to all sites will be
based on the ability of the crop and the land to properly assimilate the residual solids. Application
rate (equating to the thickness of application), percent solids of the
residuals applied, and the type and thickness of the vegetative cover will be the determining

factors. These materials have very little nitrogen value so application will be based on:
• application thickness,
• lime needs of the soil, or
• nitrogen needs of the crop
whichever of these three criteria accounts for the most restrictive application rate.
For uses of these residuals in other processes other than direct application, WestRock makes no
claim for their consistency or properties. Use by other entities will be without their
responsibility to determine and accept as is, with no liability or other implication to WestRock.

Overview of Process and Residual Solids Handling

Overview of Process and Residual Solids Handling
WestRock Kraft Paper LLC Roanoke Rapids facility is located at 100 Gaston Road in Halifax
County, North Carolina. This facility has a 28 million gallon per day (MGD) wastewater treatment
plant that serves the production of Kraft paper. Primary Clarifier Solids (PCS) are produced by
non -biological processes following primary clarifier separation. These residuals have a very small
amount of domestic contribution. This same facility produces Flyash that is a mixture of coal, sawdust
and bark that are burned for power.
Both PCS and Flyash will be placed in sealed trucks for one of three intended destinations:
• on -site landfill operated under permit (NCDENR Permit No. WQ0000436) and disposed,
• can be taken to nonspecific land application receiver sites under the distribution permit
(NCDENR Permit No. WQ0021577), or
• sent to one of various points of distribution under distribution permit (NCDENR Permit No.
WQ0021577) to include:
+ Sorptive media for hazardous waste,
+ Sorptive media for hydrocarbon impacted media,
+ Use as a landfill daily cover,
+ Admixture for composts, soil amendments, and potting soils, and
+ As a replacement for sawdust in the manufacture of bricks.
The purpose of this permit is to extend the life of the landfill currently permitted for the facility.
Each of the landfill cells will have small separate staging areas of each of the materials that go into
the landfill (Flyash, PCS, and lime mud). Once any of these separate solids become mixed with the
others, a separate staging area will begin and materials from the mixed area will not be
distributed.

Distribution Methods for Reuse

Distribution Methods for Reuse
The Primary Clarifier Solids (PCS) or Flyash may be distributed in the following
manner:
• can be taken for direct application to nonspecific receiver sites under distribution permit
(NCDEQ Permit No. WQ0021577), or
• sent to one of various points of distribution under distribution permit (NCDEQ Permit No.
WQ0021577) to include:
+ Sorptive media for hazardous waste,
+ Sorptive media for hydrocarbon impacted media,
+ Use as a landfill daily cover,
+ Admixture for composts, soil amendments, and potting soils, and
+ As a replacement for sawdust in the manufacture of bricks.
For direct application to nonspecific receiver sites, WestRock Kraft Paper, LLC. or its assigned
representative will identify local landowners and/or other property as receiver sites. Application made
to all sites will be based on the ability of the crop and the land to properly assimilate the residual
solids. Application thickness of the application rate, percent solids of the residuals applied, and the
type and thickness of the vegetative cover will be the determining factors. These materials have very
little nitrogen value so application will be based on:
• application thickness,
• lime needs of the soil, or
• nitrogen needs of the crop
whichever of the three accounts for the most restrictive application rate.
For other distribution points regarding the use of this residual in other processes or as admixtures,
WestRock makes no claim for their consistency or properties. Use by other entities will be without
their responsibility to determine and accept as is with no implication to WestRock.

Transportation and Logistics

Transportation and Logistics
WestRock Kraft Paper, LLC. Roanoke Rapids Primary Clarifier Solids (PCS) and Flyash will be
placed in sludge trailers separately. These trailers will be routed to various points for distribution,
land application to nonspecific receiver sites, or sent to the on -site landfill (Permit No, WQ0000436).
Trucks will travel on major traffic routes to the application and or distribution sites.
Individuals, agencies, or companies wishing to receive either of the WestRock PCS or Flyash will be
issued a product information sheet, the most recent copy of the analytical information, and Product
Receipt Form for the product requested. The product information sheet will specify the buffer
requirements of either of the WestRock PCS or Flyash as well as application restrictions. Each
Product Receipt Form will document:
• Amount of PCS or Flyash received,
• The name, address and telephone number of the person who prepared either the PCS or
the Flyash,
• The name, address and telephone number of the person distributing/land applying the
residuals (this will be kept separately for the two sources),
• A description of the source or process by which either of the residuals are generated,
• A summary of the results from the most recent residuals sampling event for either of the
products,
• A summary of the type and volume of residuals distributed/land applied per acre,
• A summary of the nutrients land applied per acre, and
• A list of recommendations to the recipient of the residual regarding field use, soil testing,
pH adjustment, and other relevant agronomic information.
Both the Product Label and the Product Receipt Form will be required to ensure receipt of this
information and for the removal volume. Copies of this information will be retained by WestRock
Roanoke Rapids and will be available for review upon request

The distribution receiver, the land applier, and the site receiver will be instructed as to the proper
use of this material as listed below:
• Applications should be made in accordance with approved application standards.
• Application shall not be made to land that is flooded, frozen, or snow covered.
• Application and storage must be performed to prevent runoff from the application or
storage site to any surface water.
• Buffer or "no application" zones as described in the approved permit and Product
Information Sheet.
• Applications must not be applied so thick as to cover existing vegetation.

Monitoring and Recordkeeping

Monitoring and Recordkeeping
The WestRock Kraft Paper, LLC Roanoke Rapids facility requests that the Primary Clarifier Solids
(PCS) and Flyash be monitored each quarter that residual solids are to be land applied. If no
distributions occur during the quarterly period, then no monitoring will be conducted. A set of
seven (7) fecal analyses o r a p p r o p r i a t e p a t h o g e n t e s t i n g will be performed prior
to each distribution event that occurs within each quarter for each source. A TCLP analysis will
be performed once per permit cycle. The WestRock Kraft Paper, LLC. Roanoke Rapids PCS and
Flyash samples will be collected and delivered to a laboratory qualified to analyze residual solids
and that is familiar with routine environmental sample preparation and standards.
Records pertinent to the successful management of the land applications program will be maintained
for the benefit of the farm operator, DWR, land applicator, and permittee. These records will
contain at a minimum:
• Source of the residuals,
• Type of the residuals,
• Date of the residual application/ distribution receiver,
• Information regarding the location of the residual application / distribution receiver ( i.e.
field owner name, address, and telephone number, approximate field location, and field
number)
• Method of application /intended distribution,
• Weather conditions (if applicable),
• Soil conditions (if applicable),
• Type of crop or crops to be grown on the field or type of distribution receiver and intended
use,
• Volume or weight of residuals applied to the field or provided to distribution receiver,
• Annual totals of dry tons per acre of residuals, annual pounds of plant available nitrogen,
and annual pounds of phosphorus applied to the field or annual total of dry tons given to
distribution receiver if distributed as a non -land application alternative.

Each year an annual summary of the activities of the program will be prepared and delivered to the
appropriate agencies and participants on or before the I st of March. Separate records will be kept
for each of the PCS and Flyash distribution products. The annual summary will include:
A) Summary of the WestRock PCS and Flyash,
B) Volume/Weight of the distributed amount of WestRock PCS and Flyash,
C) Name of the receiver of the distributed WestRock PCS and Flyash,
D) Intended use(s) of the WestRock PCS and Flyash,
E) Volume/Weight of other Amendments or Bulking Agents,
F) Annual totals of dry tons/acre of the WestRock PCS and Flyash and,
G) pounds of plant available nitrogen (PAN), phosphorus, and lime applied from
the WestRock PCS and Flyash if distributed to non-specific receiver sites.
2. Quarterly (provided a distribution event has occurred during the quarter) -
nutrients and metals will be analyzed of: Aluminum, Ammonia, Arsenic, Cadmium,
Calcium, Copper, Lead, Magnesium, Mercury, Molybdenum, Nickel, Nitrate -Nitrite,
Zinc,% Total Solids, pH, Phosphorus, Potassium, TKN, Selenium, and Sodium will be
collected and analyzed by a qualified laboratory. From this information, the Plant
Available Nitrogen (PAN) will be calculated.
3. Once a permit cycle a Toxicity Characteristics Leaching Procedure (TCLP) analysis
with ignitability, reactivity, and corrosivity of the WestRock PCS and Flyash will be
collected and analyzed by a qualified laboratory. If land application occurs at a
frequency of less than annually, a TCLP analysis with ignitability, reactivity, and
corrosivity will be required for each distribution event.

Leachate Collection
No provision is made for leachate collection since the residuals are not designed to undergo
any mixing with other productions on -site. Leachate collection will be the responsibility of
the distribution sites that receive these residuals. These residuals that are to be distributed, either
as to distributions sites or land applied to nonspecific sites, will remain in -place and not be
removed until the time of application.
Onsite storage locations will be selected to allow good smooth unloading surfaces that will neither
collect surface water nor enhance the potential for surface water to be impacted by the staging.
If staging is necessary on nonspecific sites, the staging will be limited to 30 days in the field
without cover. If application does not occur with thirty days, cover will be placed over stockpiled
areas.
Leachate collection and treatment occurs while material is stored in the landfill cells.
If these sources are kept separate in the land fill cells (PCS, Flyash, or Lime Mud), WestRock
requests that this material be allowed to be mined from the landfill cell and sent to various
approved distribution methods as approved by NCDEQ.

SECTION V
LABEL AND PRODUCT INFORMATION SHEET
WestRock Roanoke Rapids Flyash
WestRock Roanoke Rapids Primary Clarifier Solids

The WestRock Kraft Paper, LLC. Roanoke Rapids
Flyash Label
Produced BY Preparer
WestRock Kraft Paper, LLC. Chris Williams [phone]
100 Gaston Road 100 Gaston Road
Roanoke Rapids, North Carolina 27870 Roanoke Rapids, North Carolina 27870
For information on this product contact WestRock Kraft Paper
Corporation Roanoke Rapids facility at [phone]
The WestRock Kraft Paper, LLC. Roanoke Rapids Flyash is a generated product of the burning of coal and wood
products in the #1 Power Boiler. The venerated residuals are based on 100% industrial production and are an
exceptional quality residual solid that is permitted for bulk distribution under WQ0021577.
Approved used for WestRock Flyash:
• Amendment for creation of soil mixture to he further distributed to the public,
• Amendment for compost to he further distributed to the public,
• Use as it sorptive media. Must be disposed of properly in a regulatory approved facility based on the media
sorted.
• Use as an amendment for the manufacturing of brick, concrete, and asphalt,
• Use as a daily landfill cover,
• Application to potential receiver sites for use as a soil amendment or replacement for agricultural lime.
Provisions for application are listed below.
Provisions for Application
Application of WestRock Flyash is prohibited except in accordance with the provisions specified in the Application
Information Sheet. Application must conform to Standards identified in Permit IVQ0021577 and include but are not
limited to:
Maxinumt slope for the land application of these residuals is 10 %forstuface applications and 18% fr subsutf ice
applications
Distance
Buffer Items (feet)
Public or private water supply source, seaters classified as SA or SB, and any Class I or Class II impounded
reservoir used as a source of drinking water for both surface and subsurface methods 100
Streams classified as WS or B. any other stream, canal. marsh or coastal slaters, and any other lake or impoundment
for surface application 100
Streams classified as WS or B. any other stream, canal. marsh or coastal waters. and any other lake or impoundment
for subsurface application 50
Property lines (both surface and subsurface applications) 50
Public right of ways (both surface and subsurface applications) s0
Upslope interceptor drains and surface water diversions (both surface and subsurface applications) 10
Downslope interceptordrains, surface svaterdisersion. groundwaterdrainage systems. and surface water drainage
ditches (both surface and subsurface applications) 25

Application Information Sheet WestRock
Flyash
WestRock Flyash shall not be applied to flooded, frozen, or snow-covered areas.
2. Application and storage of WestRock Flyash must be conducted in such a way as to prevent runoff or erosion
from the application or storage site to any surface water.
3. Applications of WestRock Flyash must not be applied so thick as to cover existing vegetation. Application
that is made to sites with less than 50 percent ground cover should be incorporated unless incorporation will
result in violation of other federal program.
=4. Application to receiver sites of WestRock Flyash shall be applied uniformly at a rate equal to amount that can
be adequately assimilated into the soil through incorporation, will not smother any current living crop on the
surface of the soil if material will not be incorporated, or the agronomic rate of the crop as specified by the
permit and the most recent residual analysis, or the time requirement of the soil and most recent residuals
analysis; whichever is most limiting.
5. An acceptable soil pH (greater than 6.0) for proper crop growth shall be maintained on the receiver site. The
soil pH should be verified annually with a soil sample with recommendations. These recommendations should
be followed as they relate to optimal crop growth, monitoring and adjustment of the exchangeable sodium
percentage, potential for calcium and magnesium deficiency, as well as other relevant agronomic information.
Additional fertilizer, time, or other nutrients may need to be added as directed by the soil sample results.
6. Applications and loading rates of WestRock Flyash shall be applied at rates that comply %with realistic yield
expectations based on the soil series and crops found at: http://nutricnts.soil.ncsu.edu/yields/
WestRock Kraft Paper, LLC. Roanoke Rapids Flyash
Approximately Contains:
54.8 % Solids
0.63 lbs. Plant Available Nitrogen IDry Ton (Surface application)
0.65 lbs. Plant Available Nitrogen IDry Ton (Incorporation application)
5.51 lbs. Phosphate (P20s) I Dry Ton
12.31 lbs. Potash (K20) IDry Ton
1.00 % Lime (calcium carbonate equivalency)
Average pH of 9.0 standard units
See WestRock Kraft Paper, LLC. Roanoke Rapids WWTP for a copy of the most recent
residuals analysis and loading rates.

The WestRock Kraft Paper, LLC. Roanoke Rapids
Primary Clarifier Solids Label
Produced Bs•
WestRock Kraft Paper, LLC.
100 Gaston Road
Roanoke Rapids, North Carolina 27870
Preparer
Chris Williams [phone]
100 Gaston Road
Roanoke Rapids, North Carolina 27870
For information on this product contact WestRock Kraft Paper
Corporation Roanoke Rapids facility at [phone]
The WestRock Kraft Paper, I,IX. Roanoke Rapids Priinar3, Clarifier Solids (PCS) are the solids from the
primary clarifier generated during Kraft paper production. The generated residuals are 99.942% industrial production
and 0.058% domestic production WestRock PCS are an exceptional quality residual solid that is permitted for bulk
distribution under permit WQ0021577.
Approved used for WestRock PCS:
- Amendment for creation of soil mixture to be further distributed to the public,
- Amendment for compost to be further distributed to the public,
- Use as a sorptive media. Must be disposed of properly in a rc_ulatory approved facility based on the media
sorbed.
- Use as an amendment for the manufacturing of brick, concrete. and asphalt.
- Use as a daily landfill cover.
- Application to potential receiver sites for use as a soil amendment or replacement for agricultural lime.
Provisions for application are listed below.
Provisions for Application
Application of WestRock PCS are prohibited except in accordance frith the provisions specifted in the Application
Information Sheet. Application must conform to standards identified in Permit IVQ0021577 and include but are not
limited to:
Maximum slope .for the land application of these residuals is 10 %for stofitce applications and 18% for subsutfctce
applications
Distance
Buffer Items (feet)
Public or private water Supply source, waters classified as SA or SB, and any Class I or Class Il impounded
reservoir used as a source of drinking water for both surface and subsurface methods 100
Streams classified as WS or 13. any other stream, canal, marsh or coastal waters, and any other lake or impoundment
for surface application 100
Streams classified as WS or B, any other stream, canal, marsh or coastal waters, and any other lake or impoundment
for subsurface application 50
Property lines (.both surface and subsurface applications) 50
Public right of ways (both surface and subsurface applications) 50
Upslope interceptor drains and surface water diversions (both surface and subsurface applications) 10
Downslope interceptor drains. surface water diversion, groundwater drainage systems. and surface water drainage
ditches (both surface and Subsurface applications) 25

Application Information Sheet WestRock PCS
I . WestRock PCS shall not be applied to flooded, frozen. or snow-covered areas.
2. Application and storage of WestRock PCS must be conducted in such a way as to prevent runoff or erosion
from the application or storage site to any surface water.
3. Applications of WestRock PCS must not be applied so thick as to cover existing vegetation. Application that
is made to sites with less than 50 percent ground cover should be incorporated unless incorporation will result in
violation of other federal program.
4. Applications of WestRock PCS shall be applied uniformly at a rate equal to amount that can be adequately
assimilates( into the soil through incorporation, will not smother any current living crop on the surface of the
soil if material will not be incorporated, or the agronomic rate of the crop as specified by the permit and the
most recent residual analysis, or the time requirement of the soil and most recent residuals analysis: whichever is
most limiting.
5. An acceptable soil pH (greater than 6.0) for proper crop growth shall be maintained on the receiver site. The
soil pH should be verified annually with a soil sample with recommendations. These recommendations should be
followed as they relate to optimal crop growth, monitoring and adjustment of the exchangeable sodium
percentage, potential for calcium and magnesium deficiency, as well as other relevant agronomic information.
Additional fertilizer, time, or other nutrients may need to be added as directed by the soil sample results.
6. Applications and loading rates of WestRock PCS shall be applied at rates that comply with realistic yield
expectations based on the soil series and crops found at: littp://nutrients.soiLncsu.edu/yields/
WestRock Kraft Paper, LLC. Roanoke Rapids Primary Clarifier Solids
Approximately Contains:
48.4 % Solids
0.33 lbs. Plant Available Nitrogen /Dry Ton (Surface application)
0.35 lbs. Plant Available Nitrogen / Dry Ton (Incorporation application)
10.24 lbs. Phosphate (P20s) / Dry Ton
2.96 lbs. Potash (K20) /Dry Ton
34.9 % Lime (calcium carbonate equivalency)
Average pH of 8.00 standard units
See WestRock Kraft Paper, LLC. Roanoke Rapids WWTP for a copy of the most recent
residuals analysis and loading rates.

SECTION VI
RESIDUALS RECEIPT FORM
WestRock Roanoke Rapids Flyash
WestRock Roanoke Rapids Primary Clarifier Solids

Flyash

WESTROCK KRAFT PAPER, LLC. ROANOKE RAPIDS
FLYASH RECEIPT FORM
I . (printed name) have received wet
tons of WestRock Kraft Paper, LLC. Roanoke Rapids Flyash, WestRock Flyash product label,
and a copy of the most recent analysis of the product. I have read these documents and agree
to adhere to the directions specified on the Application Information Sheet and the Product
Label. My intended use of this product is :
Signature of Receiver
Date of Receipt

Primary Clarifier Solids

WESTROCK KRAFT PAPER, LLC. ROANOKE RAPIDS
PRIMARY CLARIFIER SOLIDS RECEIPT FORM
I , (printed name) have received wet
tons of WestRock Kraft Paper, LLC. Roanoke Rapids Primary Clarifier Solids (PCS),
WestRock PCS product label, and a copy of the most recent analysis of the product. I
have read these documents and agree to adhere to the directions specified on the
Application Information Sheet and the Product Label. My intended use of this product
is:
Signature of Receiver Date of Receipt

SECTION VII
SPILL CONTROL PLAN

SPILL CONTROL PLAN
WESTROCK KRAFT PAPER, LLC. ROANOKE RAPIDS PRIlt1ARY
CLARIFIER SOLIDS AND FLYASH ROANOKE RAPIDS, NORTH
CAROLINA
In the case of a spill, the following actions shall be taken immediately:
1. Halt the source of the spill: Damaged truck or trailer tank unit.
2. Contain spill: Use straw bales to form a barrier. Straw hay bales can be obtained from
several sources for this purpose. Soil near the site can also be used to form a barrier for
containment.
3. Clean up: Use residual solids application equipment to recover as much of the material
as possible. After the application equipment has recovered as much material as possible, it
will be land applied as per operation plan.
4. Final Clean up: Any unrecoverable material will be scraped and swept from the road
surface and incorporated into an adjacent tillable area.
5. Notification: As soon as possible after a spill occurs notify:
A. WestRock Kraft Paper Corporation Wastewater Treatment Plant- ORC (252)
533-6237
B. Department of Environmental Quality
Raleigh Regional Office at [phone]
C. The Halifax or Northampton County Sheriff's Department
D. Fire Department if assistance is required for washdown
6. Management of clean-up efforts: The ORC or applicator shall take immediate charge
of the clean-up activities. Additional labor will be requested from the treatment plant and
other departments as needed.
7. Reporting: Within 5 days of notifications, a written report will be prepared detailing the
cause of the spill, all actions taken in response to the spill, and proposed actions to be
taken to ensure spill does not recur.

SECTION VIII
APPLICATION RATES

APPLICATION RATES
Prior to a distribution event, a private landowner will contact WestRock Kraft Paper, LLC.
Roanoke Rapids to initiate an application. This landowner will indicate the type of crop to be
grown and the size of the field to have the residuals distributed. A recent soil sample will be
needed to determine lime requirements.
A composite sample of either the Primary Clarifier Solids (PCS or Flyash) generated from WestRock
Kraft Paper, LLC. Roanoke Rapids will be collected prior to a distribution event to non- specific
receiver sites so that application rates for the crops can be set. Prior to the distribution event, the
potential receiver sites will be reviewed to ensure the crop has been identified correctly and the
field size is correct. Soils data will be checked at that time. Application rates will be determined
based on the solids content of the residuals, the height of the crop on the receiver site, smothering
potential of the crop, the lime requirement of the soil, lime requirements of the soils analysis, and
nitrogen needs of the crop to be grown.
Application rates will be limited based on either: application thickness, lime needs of the soil, or
nitrogen needs of the crop; whichever of the three accounts for the most restrictive application rate.
Based on my experience as a licensed soil scientist, application thickness on
potential receiver sites should be no more than 25 wet tons per acreif it is to be spread
on the surface of the soil with an actively growing crop and no more than 40 wet tons per acre if the
residual is to be incorporated, depending on the percent solids of the residuals. The incorporated
amount may be further reduced if the incorporation equipment fail to properly turn the residual
under depending on slope, cover, soil assimilation. Application should not occur at a rate that the
residuals may experience runoff or erosion from the receiver site. Re -application of sites will be
based on these same factors. If there are questions concerning an individual application rate for a
receiver site, consult a licensed soil scientist.

SECTION IX
CHANGE OF OWNERSHIP FORM

CHANGE OF OWNERSHIP FORM
Following is the change of ownership form that was submitted on September 24, 2019.

r
WestRock
September 24, 2019
VIA OVERNIGHT FedEx
Rick Bolich
Assistant 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
Re: Permittee Name Change — KapStone Kraft Paper Corporation
• Permits: NPDES, Distribution of Class A Residuals, Surface Disposal of Industrial
Byproduct Residuals
• Permit Numbers:NC0000752, W00021577, WQ0000436
• Facility Address:100 Gaston Road, Roanoke, Rapids, NC
Dear Mr. Bolich
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 (W00021577),Distdbution of Class A Residuals
(W00021577), Surface Disposal of Industrial Byproducts (W00000436)
If you have questions regarding our request, please contact Mike Knudson at 252-533-6280 or
mike. [e-mail]. Thank you for your cooperation in this matter.
Sincerely,
ZWP
minPhite
General Manager
Enclosures
cc: Mike Knudson
Neal Davis

Brad Justice
Ray Stewart (RRO)

r.`'
W
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Water Resources Interim Director
ENVIRONMENTAL QUALITY
PERMIT NAME/OWNERSHIP CHANGE FORM
CURRENT PERMIT INFORMATION:
Permit Number: NC0000762
1. Facility Name: KapStone Paper and Packaging
II. NEW OWNER/NAME INFORMATION:
1. This request for a name change is a result of:
_x a. Change in ownership of property/company
b. Name change only
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: Beniamin 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 ,)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
https://deq.nc.govlaboutldivisionstwater-resources/water-resources-permits/wastewater-bmnchlnpdes-wastewater-pernats

r.
NPDES Name & Ownership Change
Page 2 of 2
Applicant's Certification:
attest that this application for a
name/ow ership 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: / Date: 1/
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

M
4
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 Autor*4111 re6NIn in effect until revoked or superseded.
Thomas M. Stigers
Executive Vice Pre
WestRock
Containerboard Mills
Effective Date: September 9, 2019
COVERED FACILITY
STATE
GENERAL MANAGER
COVERED FACILITY
STATE
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
_flopewell
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
Lynchburg
VA
Mark Murphy_

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Water Resources Interim Director
ENVIRONMENTAL QUALITY
PERMIT NAME/OWNERSHIP CHANGE FORM
I. CURRENT PERMIT INFORMATION:
Permit Number: WQ0021577
1. Facility Name: KapStone Paper and Packaging
NEW OWNERINAME INFORMATION:
1. This request for a name change is a result of:
_x a. Change in ownership of property/company
b. Name change only
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: Beniamin 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 .whiteDwestrock.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
https://deq.nc.govlabouttdivisionslwater-resources/water-resources-permitslwastewater-branchlnpdes-wastewater-permits

NPDES Name & Ownership Change
Page 2 of 2
Applicant's Certification:
I, AJA.7- , 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: ri- ' A JAA — 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 will rem in In effect until revoked or superseded.
Thomas M. Stigers
Executive Vice Pre
WestRock
Containerboard Mills
Effective Date: September 9, 2019
COVERED FACILITY
STATE
GENERAL MANAGER
COVERED FACILITY
ISTATEJGENERAL
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
opewell
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
Lynchburg
VA
Mark Murphy

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Water Resources LINDA CULPEPPERInterim Director
ENVIRONMENTAL QUALITY
PERMIT NAME/OWNERSHIP CHANGE FORM
I. CURRENT PERMIT INFORMATION:
Permit Number: W00000436
1. Facility Name: KapStone Paper and Packaging
II. NEW OWNER/NAME INFORMATION:
1. This request for a name change is a result of.
_x a. Change in ownership of property/company
b. Name change only
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: [phone]_
E-mail address: ben.whitAO)westrock com i
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
https://deq.nc.gov/about/divisions/water-resourcestwater-resources-permits/wastewater-branchlnpdes-wastewater-permits

NPDES Name & Ownership Change
Page 2 of 2
Applicant's Certification:
I, ; a ►�, d, [� �E'— , 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: �J� Date: � ZW /
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
t:l ew1-k
Thomas M. Stigers
Executive Vice Pre
WestRock
In effect until revoked or superseded.
Containerboard Mills
Effective Date: September 9, 2019
COVERED FACILITY I STATE I GENERAL MANAGER I COVERED FACILITY ISTATE 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
Popewell
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
Lynchburg
VA
Mark Murnhv

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