WQCSD0704_NOV-2020-DV-0462 Response_20201110 (2)

WestRock
November 10, 2020
Federal Express Tracking Number: 7720 3715 5921
Jason Robinson, P.E.
Water Quality Regional Operations
Raleigh Regional Office
NCDEQ
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
Subject: Sanitary Sewer Incident September 18, 2020
100 Gaston Rd.
Roanoke Rapids,
NC 27870
�1C ncpt of Environmental Quality
NOV 1 1 2020
Ralcigh Regional Office
This letter/email is in reference to a sanitary sewer backup that occurred on September 18, 2020 at the
WestRock Kraft Paper, LLC. mill in Roanoke Rapids, Halifax County, North Carolina. A Notice of Violation
(NOV) was issued by the Department of Water Quality (DWQ) on October 22, 2020 and received from the
Roanoke Rapids Post Office on November 3, 2020 for this event. Through a series of subsequent telephone
calls and emails, the Department emphasized that, before any action from DWQ to rescind the NOV could be
considered, a written request must be submitted by WestRock. This written correspondence is being submitted
in support of our request to rescind the NOV.
The following discussions provide an overview of the sewer layout at the mill, a description of the September 18
incident and the mill's response, a summary of the subsequent contact with DEQ, and WestRock's position on
the matter.
Waste water collection and treatment activities for the City of Roanoke Rapids are contracted out to the Roanoke
Rapids Sanitary District (RRSD). The RRSD main sanitary sewer line runs through the south edge of the mill
property on its way to a lift pump station and the RRSD waste water treatment plant in Weldon. One of the Mill's
sanitary sewer lines ties into the RRSD sanitary sewer at the SW corner of the mill property. A Google Earth
overhead and a more detailed sewer sketch is included with this letter. Scanned pdf files are attached to the
email. Both drawings identify the mill sanitary sewer manhole that overflowed on September 18, the RRSD
sewer and the tie in point where the mill sewer meets the RRSD sewer. The mill storm water ditch is also
identified.
Heavy rains periodically cause the RRSD sanitary sewer to exceed capacity creating backups on the customer
lines throughout the City. Mill sanitary sewer manholes are subject to these backup situations. One location in
particular that overflowed on September 18, is a manhole located within our property boundaries near our main
truck access gate. That manhole is positioned right in the middle of truck traffic coming in and going out of our
Security Gate 1. A storm water ditch beginning in this area and running around the south and east boundaries of
the mill then discharging directly into the Roanoke River is in close proximity to the manhole. Approximately 70%
of the City's rain water runoff also discharges into that stormwater ditch.
A RRSD sanitary sewer back up is precisely what happened on September 18. The day/night before the event
brought a 4+ inch rain event to the Roanoke Rapids area. Between 8:00 and 8:30 AM on the morning of
September 18, 2020, water was observed to be upwelling from the aforementioned manhole on the Mill's
sanitary sewer. Mill maintenance and the Environmental Department responded and sandbagged the manhole
directing the majority of the sanitary sewer water to nearby Mill process sewers. It was immediately estimated
that up to 3,500 gallons of water came out of the manhole of which an estimated 500 gallons made its way to the
nearby storm water ditch. Other backups likewise occurred throughout the City as a result of the influx of
stormwater to the collection system.

In the past, on such occurrences, the RRSD, recognizing that they were the cause, took responsibility for
making the proper notifications to the agency. Through discussions with RRSD, it is our understanding that a
change in their policy regarding such notifications occurred the first of the year, and they are no longer making
notifications for events that occur on WestRock property to the agency. To prevent the event from going
undetected by the agency, WestRock has voluntarily provided the notification for this event even though the
release was caused solely by issues with the RRSD sewer system. In their defense, when these events have
occurred in the past, RRSD has responded quickly following our notifications to them and assisted with cleanup
and investigation into the cause.
On September 18, an immediate (within 24-hrs) notice was made by WestRock to Mr. Cheng Zhang of the
Raleigh Regional office reporting 3500 gallons of spillage. A follow up report of the incident was completed on
Agency forms and submitted to Mr. Zhang on September 23 via email. In the follow up report, after further
investigations with more accurate information, the total amount of spillage was reported at 3,000 gallons with 500
gallons to surface waters (the storm water ditch).
On November 3, we received notice that we had a certified letter at the post office. That correspondence was
the NOV. There have been several subsequent phone calls and emails relative to the NOV this week, including
the 10AM November 5 call.
The root cause of the release that occurred on September 18 was the lack of RRSD sewer capacity to manage
significant storm events. The mill has evaluated the following potential options for containing sewer overflows
when they occur, keeping in mind that WestRock cannot do anything to eliminate the root cause of the event,
which was the sanitary sewer upset.
1. Raise the manhole covers We would have to raise manhole covers closest to the RRSD sewer three-four
feet in elevation in order to be adequately above the RRSD sanitary sewer and prevent back flows in that
area. Not only would this not prevent the backup moving to other areas in the mill, raising those
manholes would impede log truck and other traffic into and exiting the mill.
2. Sealable manholes also could be installed. This likewise, would not prevent backups from moving to
other locations in the mill.
3. We have had discussions with RRSD about the situation during which, they assured us that they have
hired a consultant to look into the matter, not just only at WestRock, but throughout the City.
As stated, the root cause of the sanitary sewer overflow and the release to the waterway is the lack of sufficient
capacity in the RRSD sewer system and its inability to handle heavy rains. Our sanitary sewer flow has to have
a discharge path. That path is the RRSD sewer. As such, it is hereby requested that the NOV be rescinded.
Maintaining compliance with all environmental regulations is in the core values of WestRock Company. We are
very proud of the near spotless environmental record of the Roanoke Rapids mill. Notices of Violations are of
utmost importance to us and justly deserve immediate attention and action. Please keep us informed of the
progress in the handling of the subject NOV.
Thank you for your attention and reaction to this unfortunate incident. if you have any questions please don't
hesitate to call. We look forward to your response.
Sincerely,
- vV �.
Benjamin .White
General Manager
Enclosures
cc:
Nina Butler, WestRock Chief Environmental Officer and Associate General Council
Brad Justus, WestRock Environmental Services Manager
Mike Knudson, WestRock Environmental Manager
Chris Williams, WestRock waste treatment ORC
Dan Brown, Roanoke Rapids Sanitary District

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