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Home My WebLink AboutNCS000106_Facility Review_20190927WestRock September 24, 2019 Ms. Lauren Garcia DEMLR Stormwater Division Division of Energy, Mineral and Land Resources 100 Gaston Road Roanoke Rapids, NC 27870 office: 252.533.6295 neal.davis@ westrock.com FI F— r".171V E D 512 North Salisbury St. o a L AN11D QUALITY 1612 Mail Service Center �'RiN1�NATe �'�RPlIiTTIhG Raleigh, NC 27699-1612 :: fC?r;iv1 Subject: KapStone Kraft Paper Corp. / WestRock Kraft Paper LLC Stormwater Permit NCS000106 Dear Ms. Garcia; Please note below, comments from KapStone Kraft Paper Corporation/WestRock Kraft Paper, LLC on the Draft Stormwater Permit dated August 27, 2019, Permit No. NCS000106. 1. In November of 2018, WestRock acquired KapStone Kraft Paper Corporation. WestRock is in the process of converting KapStone Kraft Paper Corporation from a corporation to a Limited Liability Company (LLC) and changing the name of the entity to WestRock Kraft Paper, LLC. The electronic form from the edos.deq.nc.gov website will be submitted for the storm water permit ownership change. Please change KapStone Kraft Paper Corporation on the title page of the permit to WestRock Kraft Paper, LLC. Enclosed is a letter from Thomas M. Sigers, Executive Vice President, WestRock, which delegates authority for environmental matters for the Roanoke Rapids mill to Ben White, General Manager (Formerly Mill Manager under KapStone). 2. Page 8 of 29 Footnote 3: We have an email from Ken Pickle dated June 11, 2009, granting ROS status to a stormwater outfall on the site which is behind our storeroom. A copy of the email is enclosed with this letter. 3. Page 10 of 29: This is a stipulation about Impaired Waters. In the old permit, page 8 of 11, it is stated that the reason for Roanoke River impaired waters is a mercury Fish Advisory. In the new permit it declares that "This site discharges to impaired waters experiencing problems with turbidity, fluoride, nickel, fecal coliform, arsenic, water temperature, chloride, copper, pH, fish tissue mercury, lead, dissolved oxygen, cadmium, iron and zinc. WestRock takes issue with this. At the ncdenr.maps website that you referenced in your September 20, 2019, email, "Impaired" is not mentioned. The Roanoke River, downstream of the Roanoke River Dam, is classified Gray and states: "There are only data inclusive assessments or at least one pathogen assessment is data inconclusive (except. for Mercury in Fish 'Tissue). The website map shows that the Roanoke River continues Gray all the way to the Albermarie Sound. WestRock objects to labeling the Roanoke River as impaired in the permit for all these parameters when the official NCDENR website does not. Please only note mercury in this stipulation, which is consistent with the old permit as well as State and EPA determinations. If there are any question or concerns please contact Neal Davis at neal.davisAwestrock.com or 252-533-6295 Sincerely, Benjamin P. White, General Manager WestRock Kraft Paper I,I,C 100 Gaston Road Roanoke Rapids, NC 27850 Enclosure Copies: Neal Davis Danny Smith (RRO) -' WestRock DELEGATION OF AUTHORITY FOR ENVIRONMENTAL MATTERS CONTAINERBOARD MILLS As Executive Vice President of Contalnerboard 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 y will rem in in effect until revoked or superseded. Thomas M. Stigers Executive Vice Pr ident, Containerboard Mills WestRock 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 . 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 Neal From: Pickle, Ken [ken.pickle ®ncdenr.gov] Sent: Thursday, June 11, 2009 4:36 PM To: Ransmeier, MARY Cc: myrl.nisely*ncmail.net; Davis, Neal; Bennett, Bradley; Lowther, Brian Subject: RE: KapStone Kraft NCS000106 Dear Ms. Ransmeier, Thanks for being available on such short notice for our unscheduled visit. It really helps the permitters when we can see the site conditions. Based on your note, we are in agreement as to the Storeroom Outfall and as to the sample point for the Tent Outfall. I've re -stated below your points just to confirm our agreement on them; please contact us if I have missed any minor point. I have relayed our conversation and my observations at Kapstone to your permit writer, Brian Lowther, and to our supervisor, Bradley Bennett. Please take this note as written confirmation of certain comments I made while on your site. Specifically, as to your current coverage under the expired individual permit, NCS000106, you are authorized for Representative Outfall Status from this time forward. DWQ will consider the Tent Outfall representative of the stormwater discharges from both the Tent Outfall and the Storeroom Outfall, until and unless significant changes in on - site activities suggest that the Representative Outfall Status is no longer appropriate. Scheduled analytical samples need only be taken for the Tent Outfall. Visual monitoring is to be continued at both outfalls. Further, we are in agreement with the relocation of the sample point for flows from the Tent Outfall to a location further downstream than previously located. As you note and as we discussed, the new location will be close to, but still upstream of the junction with the large flows from off site, i.e. the city stormwater flows. As to provisions in the pending renewed permit, we intend that the Representative Outfall Status will continue for the Tent Outfall, and we will so note in the transmittal letter that will accompany the renewed permit. Administratively it has been our practice to address the granting of Representative Oufall Status by separate letter outside of the permit text, and we propose to continue that practice if you do not object. Similarly, on large and complicated sites we typically do not direct the exact location of stormwater sampling, unless we see a need to. We are in agreement with the current proposed location further downstream, and are agreeable for that location to be continued under the renewed permit. Please contact us for concurrence if you subsequently judge that another location might be more representative of the stormwater flows from your site. Ken Pickle DWQ Stormwater Permitting Unit 11