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Home My WebLink AboutNC0000752_Compliance Evaluation Inspection_20211229DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality December 29, 2021 Mr. Benjamin White General Manager Westrock Kraft Paper LLC - Roanoke Rapids Mill 100 Gaston Road Roanoke Rapids, NC 27870 Subject: Compliance Evaluation Inspection Westrock Kraft Paper LLC - Roanoke Rapids Mill WWTP Permit No. NC0000752 Northampton County Dear Mr. White: On November 18, 2021, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a compliance evaluation inspection of the subject facility. The assistance provided by Mr. Chris William, the operator in responsible charge (ORC), Mr. Matt Upton, the backup ORC, and Mr. Paul Kinnin, was appreciated as it facilitated the inspection process. The inspection report is attached. The following observations were made: Westrock Kraft Paper LLC - Roanoke Rapids Mill WWTP is permitted to discharge at a rate of 28.0 MGD and consist of: mechanical bar screen, primary clarifier, emergency holding pond, sludge lagoon, aeration basin, and three stabilization ponds. The plant discharges to Roanoke River, a Class C water in the Roanoke River basin. 1. Current permit expires on March 31, 2022. Renewal application was received by the Division on October 29, 2021. Sludge handling facility is not listed as treatment unit, but covered under landfill permit WQ0000436. 2. All treatment units were found operable, except one of the two sludge screen thickeners (offline for repair) at the time of inspection. The primary clarifier was inspected and maintained during the plant's annual Cold Mill Outrage (scheduled annual maintenance of the entire plant) in October 2021. The traveling porting of the mechanical bar screen was repaired in November 2021 right before the inspection. 3. Process wastewater is pumped to the primary clarifier, where solids settle. 4. Sludge from the primary clarifier is dewatered at the sludge handling facility, two trains NOR�D_E �eeabnenl al EnNrvnmenlel5uelily North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 of screen thickeners and screw presses, and chemical feed system are available. One screen thickener was offline for repair at the time of inspection. Dewatered sludge is disposed at the onsite landfill. Leachate from the landfill and the old sludge pond flows by gravity into the aeration basin and is treated along with the effluent from the primary clarifier. 5. Effluent from the clarifier is further treated at the aeration basin. All 31 aerators were in operational condition. Numbers of aerators on line was controlled by the DO level in the basin. 6. Effluent from the aeration basin is further treated in the three stabilization ponds before being discharged to the river. 7. The ORC maintains a daily logbook. Lab results, chain -of -custody forms, and Discharge Monitoring Reports (DMRs) were complete and current, kept in good order and ready for review. March and August 2021 DMR data were compared to lab bench sheets; no data transcription errors were noted 8. The laboratory on site is certified to analyze most permit parameters (lab cert. no. 183). Toxicity, nutrients, and copper are sent to private labs for analysis. A cursory review of the laboratory noted buffers and standard solutions were within manufacturer expiration dates. The sample storage refrigerator and BOD incubators, were found to be compliant with temperature requirements. Field meter calibration records were reviewed. 9. The right of way to Outfall 001 was well maintained. The effluent was observed to be clear and free of solids. No visible impacts were noted immediately downstream the effluent pipe. Outfall 002 was also maintained and accessible. The overall condition of the facility is compliant with Division standards. If you have any questions regarding the attached reports or any of the findings, please contact Cheng Zhang at: (919) 791-4200 (or email: cheng.zhang@ncdenr.gov). Sincerely, DocuSigned by: FhttA.t,SSA, f. (tt.a tAl a B2916E6AB32144F... Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources Attachments: Compliance Inspection Report Cc: Central Files w/attachment (Laserfiche) Raleigh Regional Office w/attachment Chris Williams, ORC (electronic copy only) North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609 919.791,4200 DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 United States Environmental Protection Agency EPA Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction 1 IN Code I 2 IL I NPDES yr/mo/day Inspection Type Inspector Fac 3 I NC0000752 111 121 21/11/18 117 1810I 19I S I 2011 Type 21IIIIII IIIIIIIIIII IIIIIII I IIIIII IIIIIIIIIII P6 Inspection 671 Work Days Facility Self -Monitoring I 7° I3 Evaluation Rating I 711 B1 I 72 QA I N I 73I I I I Reserved 74 71 I I I I I I 180 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES Dermit Number) Roanoke Rapids MIII WWTP 100 Gaston Rd Roanoke Rapids NC 27870 Entry Time/Date 10:00AM 21/11/18 Permit Effective Date 18/09/01 Exit Time/Date 01:OOPM 21/11/18 Permit Expiration Date 22/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Christopher M Williams//252-533-6237 / Christopher Michael Williams/ORC/252-533-6237/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Benjamin P White,PO Box 458 Roanoke Rapids NC 278700458/General Manager/252-533-6335/ Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran Sludge Handling DispoFacility Site Review Effluent/Receiving Wate Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) Cheng Zhang of Inspector(s) Agency/Office/Phone and Fax Numbers Date �Docusignedby: DWR/RRO WQ/919-791-4200/ oe--# 24....E 12/29/2021 "- D6171508E1 EC41 F... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date r:iDocuSigned by: LtA.t,SSit f. ekl.abuml, 1/7/2022 B2916E6AB32144F. EPA Form 35 (Rev 9-94) Previous editions are obsolete. Page# 1 DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 31 NPDES yr/mo/day NC0000752 I11 121 21 /11 /18 117 Inspection Type 18LI (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Current permit expires on March 31, 2022. Renewal application was received by the Division on October 29, 2021. Sludge handling facility is not listed as treatment unit, but covered under land fill permit WQ0000436. Treatment system consists of influent pump station with bypass line to emergency pond, primary clarifier, aeration basin, three stablization ponds, and sludge lagoon, sludge from clarifier is dewatered with two screen thickeners and two screw presses. Dewatered sludge is disposed of at the onsite landfill. Leachate from the landfill and effluent from the sludge lagoon are treated at the aeration basin. Record keeping was excellent, ORC logbook, flow meter calibratio, and DMR/lab reports were kept at least 5 years back. The laboratory on site is certified to analyze most permit parameters (lab cert. no. 183). Toxicity, nutrients, and copper are sent to private labs for analysis. A cursory review of the laboratory noted buffers and standard solutions were within manufacturer expiration dates. The sample storage refrigerator and BOD incubators, were found to be compliant with temperature requirements. Field meter calibration records were reviewed. Page# 2 DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 Permit: NC0000752 Inspection Date: 11/18/2021 Owner - Facility: Roanoke Rapids MIII WWTP Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? • El El El Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable II ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Facility analyzed pH, conductivity, BOD, DO, temperature for influent, clarifier effluent, and aeration pond for process control on a daily basis. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ■ ❑ ❑ ❑ application? Is the facility as described in the permit? • El El El # Are there any special conditions for the permit? El El • El Is access to the plant site restricted to the general public? • ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? • El El El Comment: Current permit expires on March 31, 2022. Renewal application was received by the Division on October 29, 2021. Sludge handling facility is not listed as treatment unit, but covered under land fill permit WQ0000436. Bar Screens Yes No NA NE Type of bar screen a.Manual ❑ b.Mechanical • Are the bars adequately screening debris? • ❑ El El Is the screen free of excessive debris? • El El El Is disposal of screening in compliance? • El ❑ ❑ Is the unit in good condition? • ❑ El El Comment: Traveling portion was repaired, the bar screen returned to service on November 11, 2021. Pump Station - Influent Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Yes No NA NE ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 3 DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 Permit: NC0000752 Inspection Date: 11/18/2021 Owner - Facility: Roanoke Rapids MIII WWTP Inspection Type: Compliance Evaluation Pump Station - Influent Yes No NA NE Is audible and visual alarm available and operational? ❑ ❑ • ❑ Comment: Bypass channel to emergency holding pond at influent pump station wet well. Primary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the sludge blanket level acceptable? Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • Comment: The primary clarifier was inspected and cleaned in October 2021 during the plant's annual Cold Mill Outrage (scheduled annual maintenance of the entire plant). Skimmer wipes were replaced and scum trough was cleaned while the clarifier was offline. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? • ❑ ❑ ❑ Are surface aerators and mixers operational? • ❑ ❑ ❑ Are the diffusers operational? • ❑ ❑ ❑ Is the foam the proper color for the treatment process? • ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? • ❑ ❑ ❑ Is the DO level acceptable? • ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/I) ■ ❑ ❑ ❑ Comment: DO at the exit of aeration pond was 0.85 mg/L. All aerators were operable. Lagoons Yes No NA NE Type of lagoons? Facultative # Number of lagoons in operation at time of visit? 3 Are lagoons operated in? Series Page# 4 DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 Permit: NC0000752 Inspection Date: 11/18/2021 Owner - Facility: Roanoke Rapids MIII WWTP Inspection Type: Compliance Evaluation Lagoons Yes No NA NE # Is a re -circulation line present? ❑ ❑ • ❑ Is lagoon free of excessive floating materials? • ❑ ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? ❑ ❑ • ❑ Are dike slopes clear of woody vegetation? • ❑ ❑ ❑ Are weeds controlled around the edge of the lagoon? • ❑ ❑ ❑ Are dikes free of seepage? • ❑ ❑ ❑ Are dikes free of erosion? • ❑ ❑ ❑ Are dikes free of burrowing animals? • ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple • ❑ ❑ ❑ locations? # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ ▪ ❑ Is the lagoon surface free of weeds? • ❑ ❑ ❑ Is the lagoon free of short circuiting? • ❑ ❑ ❑ Comment: 1/5 of the first stablization pond is dredged every year. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: Facility has two flow meters, at the time of inspection, one meter was sent to contractor for calibration, the meter in use was calibrated on September 2, 2020. Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 5 DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 Permit: NC0000752 Inspection Date: 11/18/2021 Owner - Facility: Roanoke Rapids MIII WWTP Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Is the chain -of -custody complete? • ❑ ❑ ❑ Dates, times and location of sampling • Name of individual performing the sampling • Results of analysis and calibration • Dates of analysis • Name of person performing analyses • Transported COCs • Are DMRs complete: do they include all permit parameters? • ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ • ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified • ❑ ❑ ❑ operator on each shift? Is the ORC visitation log available and current? • ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? • ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility • ❑ ❑ ❑ classification? Is a copy of the current NPDES permit available on site? • ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ • ❑ Comment: Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Comment: Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ Yes No NA NE ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 6 DocuSign Envelope ID: B2714399-8090-4308-852D-ED959BA31E45 Permit: NC0000752 Inspection Date: 11/18/2021 Owner - Facility: Roanoke Rapids MIII WWTP Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE # Is proper temperature set for sample storage (kept at less than or equal to 6.0 • ❑ ❑ ❑ degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type • ❑ ❑ ❑ representative)? Comment: Time paced composite sample: 100 ml/15 min. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, MODE and sampling location)? Comment: Solids Handling Equipment Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Blend tank was replaced during the Cold Mill Outrage in October 2021. At the time of inspection, one of two rotary screen thickeners was offline for repair. Two screw presses were both in service. Dewatered sludge is disposed of at the onsite landfill. Page# 7