NC0000752_Permit (Issuance)_20070706

NPDES DOCYNENT SCANNING% COVER SHEET
NPDES Permit:
NC0000752
Roanoke Rapids Mill WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Permit
History
Document Date:
July 6, 2007
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content on the re'rerse side

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
July 6, 2007
Mr. Chris Puryear
Kapstone Kraft Paper Corporation
100 Gaston Rd.
Roanoke Rapids, North Carolina 27870
Subject: Issuance of NPDES Permit
Permit No. NC0000752
Roanoke Rapids Mill WWTP
Halifax County
Dear Mr. Puryear:
Division personnel have reviewed and approved your application for renewal of the
subject permit. Accordingly, we are forwarding the attached NPDES discharge permit.
This permit is issued pursuant to the requirements of North Carolina General Statute
143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency dated May 9, 1994 (or as subsequently amended).
If any parts, measurement frequencies or sampling requirements contained in this
permit are unacceptable to you, you have the right to an adjudicatory hearing upon
written request within thirty (30) days following receipt of this letter. This request
must be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings (6714
Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is
made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The
Division may require modification or revocation and reissuance of the permit. This
permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local
governmental permit that may be required.
If you have any questions concerning this permit, please contact Teresa Rodriguez at
telephone number [phone], extension 553.
Sincerely,
' Coleen H. Sullins
Cc: NPDES Files
Raleigh Regional Office - Surface Water Protection
Aquatic Toxicology Unit
EPA Region 4
NthCarolina
Naturally
oaturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
KapStone Kraft Paper Corporation
is hereby authorized to discharge wastewater from a facility located at the
KapStone Kraft Paper Corporation WWTP
100 Gaston Road
Roanoke Rapids
Halifax County
to receiving waters designated as the Roanoke River in the Roanoke River Basin
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective August 1, 2007.
This permit and authorization to discharge shall expire at midnight on March 31, 2012.
Signed this day July 6, 2007.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0000752
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked.
As of this permit issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions included herein.
KapStone Kraft Paper Corporation is hereby authorized to:
1. Continue to operate an existing 28.0 MGD wastewater treatment facility (outfall
001) consisting of the following:
• Mechanical bar screen
• Primary clarifier
• Emergency holding pond
♦ Sludge lagoon
• Aeration basin
♦ Three stabilization ponds
2. Continue to discharge non -contact cooling water from the B & C evaporator
(outfall 002) and the turpentine condenser (outfall 003), and
3.:Discharge from said treatment works; located at the KapStone Kraft Paper
.Wastewater Treatment Plant,North Roanoke Avenue, Roanoke Rapids, Halifax
County, at the locations specified on the attached map into the Roanoke River
which is classified C waters in the Roanoke River Basin.
2

Kapstone Kraft Paper Corp.- NC0000752
-_ - ..
Facility
Location
USGS Quad Number: B2BNW
Receiving Stream: Roanoke River
Stream Class: C
Subbasin: Roanoke, 03-02-OB
Lat.: 36°2B'19"
Long.: 77°38'14"
North
SCALE 1:24,000
3

Permit NC0000752
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,
the Permittee is authorized to discharge from outfall serial number 001 - process water
and stormwater. Such discharges shall be limited and monitored by the Permittee as
specified below:
7� ♦.- s 1
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Flow
28.0 MGD
Continuous
Recorder
I or E
BOD, 5 day, 20QC
6,852 lbs/day
13,704 lbs/day
Dail?
Composite
E
Total Suspended Solids
15,576 lbs/day
31,152 Ibs/day
Dail?
Composite
E
Dissolved Oxygen
Dail?
Grab
E, U, D
Temperature
Dail?
Grab
E, U, D
Conductivity
Dail?
Grab
E, U, D
NH3 as N
Monthly
Composite
E
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Chronic Toxicit?4
Quarterly
Composite
E
Total Copper'
Quarterly
Composite
E
pH •
6.0 - 9.0 standard units
Dail?
Grab
E
Pentachlorophenol"
1.51 lbs/day
Weekly
Grab
E
Trichlorophenol"
1.38 lbs/day
Weekly
Grab
E
Footnotes:
1. Sample locations: E - Effluent, I - Influent, U - Upstream at NC Highway 48 Bridge,
D - Downstream at NC Highway 158. All upstream and downstream samples shall
be collected as grab samples. Stream sampling shall be conducted 3/week during
June, July, August and September and weekly during the remainder of the year.
2. Chronic Toxicity (Ceriodaphnia) P/F at 3.7%; March, June, September and
December; see A. (4), Chronic Toxicity Pass/Fail Permit Limit.
3. Monitoring for metals and the whole effluent toxicity test shall be conducted at the
same time.
4. Monitoring for pentachlorophenol and trichlorophenol is not required unless
chlorophenolic containing biocides are used at the facility. If chlorophenolic-
containing biocides are used at the facility, monitoring for pentachlorophenol and
trichlorophenol shall commence immediately for the duration of the use of the
biocides and for a period of not less than two months after discontinuing use of the
biocides.
5. Daily shall mean everyday except Saturdays, Sundays, and legal holidays.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
4

Permit NC0000752
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,
the Permittee is authorized to discharge from outfall(s) serial number 002 - non -contact
cooling water. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Location
Flow
Semi-annually
Estimate
Effluent
Temperature °C
See note 1
See note 1
Semi-annually
Grab
Effluent
pH
6.0 — 9.0 standard units2
Semi-annually
Grab
EfflDownstreamuent, Upstream,
Footnotes:
1. The temperature of the effluent will be regulated so that the temperature of the receiving
stream does not increase more than 2.8°C (5.05°F) above the natural water temperature and
does not exceed a maximum of 29°C (84.2°F).
2. The pH shall not be less than 6.0 standard units nor more than 9.0 standard units.
In the event that effluent pH shall be recorded outside this range, any value that
falls within the range of pH measured at the upstream and downstream points shall
be considered compliant. Effluent pH shall be sampled on the same days that
stream samples for pH are taken. See Condition A(6.), pH Re -opener.
3. Upstream at NC Highway 48 Bridge, Downstream at NC Highway 158.
There shall be no chromium, zinc or copper added to the treatment system except as
pre -approved additives to biocidal compounds. The permittee shall obtain
authorization from the Division prior to any use of biocide in the cooling water (See
A. (5), Biocide Condition).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
5

Permit NC0000752
A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,
the Permittee is authorized to discharge from outfall(s) serial number 003 - non -contact
cooling water. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT f.i_ ),
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'1 jGj�;,y •4.0 "'`' � i.1 ��{ i
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Flow
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_ .
Semi-annually
Estimate
Effluent
Temperature *C
See note 1
See note 1
Semi-annually
Grab
Effluent
pH
6.0 — 9.0 standard units2
Semi-annually
Grab
Effluent, Upstream,
Downstream
Footnotes:
1. The temperature of the effluent will be regulated so that the temperature of the receiving
stream does not increase more than 2.8°C (5.05°F) above the natural water temperature and
does not exceed a maximum of 29°C (84.2°F).
2. The pH shall not be less than 6.0 standard units nor more than 9.0 standard units. In the
event that effluent pH shall be recorded outside this range, any value that falls within the
range of pH measured at the upstream and downstream points shall be considered compliant.
Effluent pH shall be sampled on the same days that stream samples for pH are taken. See
condition A(6.), pH Re -opener.
3. Upstream at NC Highway 48 Bridge, Downstream at•NC Highway 158.
There shall be no chromium, zinc or copper added to the treatment system except as pre -
approved additives to biocidal compounds. The . permittee shall' obtain authorization from the
Division prior to any use of biocide in the cooling water (See A. (5), Biocide Condition).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
6

Permit NC0000752
A. (4) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 3.7%.
The permit holder shall perform at a minimum, auarteriu monitoring using test procedures outlined
in the "North Carolina Cercodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998,
or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of
March, June, September and December. Effluent sampling for this testing shall be performed at
the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the
two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWQ Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no
later than 30 days after'the end of the reporting period for which the report is made.
Test data 'shall be complete, accurate, include all supporting chemical/physical measurements and
all concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the
aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number,
county, and the month/year of the report with the notation of "No Flow" in the comment area
of the form. The report shall be submitted to the Environmental Sciences Section at the
address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate environmental
controls, shall constitute an invalid test and will require immediate follow-up testing to be completed
no later than the last day of the month following the month of the initial monitoring.
7

Permit NC0000752
A. (5) BIOCIDE CONDITION
The permitted shall not use any biocides except those approved in conjunction with the permit
application. The permitted shall notify the Director in writing at least ninety (90) days prior to
instituting use of any additional biocide in the treatment system, which may be toxic to aquatic life
(other than biocides previously reported to the Division). Such notification shall include completion of
Biocide Worksheet Form 101 and a map indicating the discharge point and receiving stream.
A. (6) pH REOPENER
The Division may re -open this permit to remove pH limitation footnotes at Outfall 002 and 003,
should new information indicate water quality problems due to declining pH in this portion of the
river.
8

AMENDMENT TO FACT SHEET
NC0000752
RPA
Mercury — Allowable concentration for mercury based on an IWC of 3 % is 0.38 ug/1. Method 245.1 was used to
sample for the application PPA. The result of the sampling was < 0.2 ug/1. There is no reasonable potential for
mercury. Since the IWC is < 6%, they do not need to use method 1631 for sampling purposes.
Copper - Copper is an action level standard, as such no limit will be implemented. If toxicity failures are
reported the Division can reopen the permit to implement limits.
Fact Sheet
NPDES NC0000752 Renewal
Page 5

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0000752
Facility Information
Applicant/Facility Name:
KapStone Kraft Paper Corporation /Roanoke Rapids Mill
Applicant Address:
North Roanoke Avenue, Roanoke Rapids, NC 27870
Facility Address:
North Roanoke Avenue, Roanoke Rapids, NC 27870
Permitted Flow
28.0 MGD
Type of Waste:
Industrial (100%)
Facility/Permit Status:
Class IV /Active; Renewal
County:
Halifax County
Miscellaneous
Receiving Stream:
Roanoke River
Regional Office:
Raleigh (RRO)
Stream Classification:
C
State Grid/USGS Quad:
B28NW/Roanoke Rapids
303(d) Listed?
Yes
Permit Writer:
Teresa Rodriguez
Subbasin:
03-02-08
Date:
3/30/07
Index No.
23-(26)
Lat. 36° 28' 19" N Long. 77° 38' 14" W
Drainage Area (mi'):
8,384
7Q10 (cfs)
1,120
30Q2 (cfs)
1,120
Average Flow (cfs):
2,400
IWC (%):
3.7%
BACKGROUND
Kapstone Paper Corporation purchased Roanoke Rapids Mill from International Paper in January
2007. A name change was completed to change the name of the facility to KapStone Kraft Paper
Corporation. KapStone operates a mill in Roanoke Rapids producing high quality unbleached
Kraft paper and paperboard. The mill is integrated including power generation, chemical
recovery, pulp production and final paper and paperboard manufacturing. The site operates a
WWTP to treat the wastewaters generated during the process. KapStone is permitted to discharge
28.0 MGD of process water through Outfall 001, non -contact cooling water from the evaporator
cooling tower through Outfall 002 and non -contact cooling water from the turpentine condenser
through Outfall 003. The current permit was issued on December 30, 2004 with an expiration
date of March 31, 2007.
Process wastewaters are conveyed to the WWTP through a concrete lined open channel. The
WWTP consists of a bar screen, 200 foot diameter primary clarifier, 28 million gallon emergency
pond, 21.5 acre aeration pond with 31 aerators, four stabilization ponds with a total of 370 acres,
an effluent defoamer addition system, for solids treatment sludge neutralization tank, two rotary
screen thickeners, two screw presses and a sludge lagoon. The emergency pond is used to divert
process flow in the event they have a power failure, mechanical problems or high strength waste.
The water from the emergency pond is pumped back to the influent channel at a controlled rate.
Condensate collected from the process areas is piped directly to the influent of the aeration basin.
Sludge is landfilled on site under permit WQ0000436.
Fact Sheet
NPDES NC0000752 Renewal
Page !

DMR Data Review/Compliance
Division's records show no violations for the past permit cycle.
Data for the three outfalls were summarized for the period of January 2005 to December 2006.
Flow
(MGD)
BOD
(lb/d)
^ vv+
TSS
(lb/d)
Total
Nitrogen
(mg/l)
Total
Phosphorus
(mg/1)
Ammonia
(mg/1)
Average
14.7
1611
2409
5.6
0.64
1.87
Max
23.4
4402
11980
13.2
1.08
5.6
Table II - Ou
Flow
pH
(SU)
Temp
°C
Average
4.07
6.48
42.81
Max
11.9
7
52
Min
0.3
5.9
30.3
Table III - Outfall
Flow
pH
(SU)
Temp
°C
Average
0.89
6.46
26.28
Max
2.6
7.3
48
Min
0.1
5.4
- 7.8
Stream Monitoring
KapStone monitors -upstream and downstream of the discharge for temperature, pH, dissolved
oxygen, BOD and conductivity. The upstream station is located at the bridge on Highway 48, the
downstream station is at the bridge on Highway 158. Dissolved oxygen was below 5 mg/1 during
August of 2005, with a low value of 4.3 mg/l. The Division has an ambient monitoring station
upstream at the bridge on Highway 48. Results for the ambient monitoring stations are similar to
the facility data.
Table IV - Instream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Temp
°C
Temp
°C
pH
SU
pH
SU
DO
mg/1
DO
mg/1
Average
20.6
20.1
6.8
6.7
8.4
8.1
Max
29
28.8
7.5
7.4
14.1
13.6
Min
5.4
5.1
6.2
6.3
4.3
5.1
303(d)/Basin Plan
This section of the river is listed on the 303(d) as impaired for fish consumption due to mercury
levels in fish.
PERMITTING STRATEGY
Waste Load Allocation (WLA)
The Division prepared the last WLA for the previous permit renewal in 1997. Current limits are
based on guidelines and water quality standards. The current permit includes limits for flow,
BODS, TSS, pH, pentachlorophenol, and trichlorophenol. Monitoring for pentachlorophenol and
Fact Sheet
N PDES NC0000752 Renewal
Page 2

trichlorophenol is not required if the facility doesn't use chlorophenolic-containing biocides.
Based on instream data that the permit holder submitted for the 2001 permit renewal, which
reflect naturally occurring pH at levels occasionally below 6.0 standard units in this portion of
the river, DWQ included a footnote to the pH limit requirements at Outfall 002 and Outfall 003.
(These outfalls discharge non -contact cooling water back into the river a short distance
downstream from where it was drawn.) The footnote states that in the event that the effluent pH
at these outfalls is outside the range of 6.0 — 9.0 standard units, any value that falls within the
range of pH measured at the downstream and upstream points will be considered compliant. It
also requires instream pH to be sampled on the same days that effluent samples are taken. The
footnote will stay in the permit.
Effluent Guidelines
Paper Mill's are regulated under effluent guidelines
unbleached kraft paper production.
The average production for the past three years at the Roanoke Rapids Mill was 1158.9 tons/day.
The limits in Table V were calculated based on the effluent guidelines and average production of
1158.9 tons per day (2596 thousand pounds per day).
Table V — Calculated limits
in 40 CFR 430. Subpart C applies to
Parameter
Daily max limit
Monthly aver limit
BOD''3
14537
lb/day
7268
lb/day
TSS1'3
31152
lb/day
15575
lb/day
pH1'3
6 —9 SU
Penthachlorophenol2
1.51
lb/day
Trichlorophenol2
1.38
lb/day
I. BPT 430.32
2. BAT 430.34
3. BCT 430.33 - same as BPT
Table VI —Proposed Limi
Parameter
Existing limits
Proposed limits
Comments
Daily max
Monthly
aver
Daily max
Monthly
aver
BOD
13704 lb/d
6852 lb/d
13704 lb/d
6852 lb/d
Existing limits are more stringent than the
limits calculated based on actual production.
Limits will not change.
TSS
321101b/d
16055 lb/d
31152 lb/d
15576 lb/d
Proposed EG limits are more stringent than
limits in permit now. Limits will be reduced
accordingly.
Pentachlorophenol
1.55 lb/d
No limit
1.51 lb/d
No limit
Proposed EG limits are more stringent than
limits in permit now. Limits will be reduced
accordingly.
Trichlorophenol
1.421b/d
No limit __
1.38 lb/d
No limit
Proposed EG limits are more stringent than
limits in permit now. Limits will be reduced
accordingly.
Fact Sheet
N PDES NC0000752 Renewal
Page 3

Reasonable Potential Analysis (RPA)
Results for the reasonable potential analysis for arsenic, chloride and copper are shown in Table
VII.
— Reasonable Potential Analysis
Parameter
Allowable
concentration
Maximum predicted
concentration
Reasonable
Potential
Comments
Chronic
Acute
Chronic
Acute
Arsenic
3,359
N/A
21.4
No
N/A
No RP, eliminate monitoring
Chloride
16,796
N/A .
96.5
No
N/A
No RP, eliminate monitoring
Copper
223
7
214.7
No
Yes
Continue monitoring
SUMMARY OF PROPOSED CHANGES
Outfall 001
• Pentachlorophenol, trichlorophenol and TSS limits were reduced to reflect limits
calculated based on effluent guidelines and current production data.
• Monitoring for arsenic and chloride were eliminated. A reasonable potential analysis
showed there is no reasonable potential to exceed the water quality standards.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
NPDES DIVISION CONTACT
May 9,2007
July 2, 2007
If you have questions regarding any of the above information or on the attached permit, please
contact Teresa Rodriguez at [phone] ext. 553.
NAME: DATE:
REGIONAL OFFICE COMMENTS
NAME: DATE:
SUPERVISOR: DATE:
Fact Sheet
NPDES NC0000752 Renewal
Page 4

REASONABLE POTENTIAL ANALYSIS
Kapstone Paper
NC0000752
Time Period 1/1/2005 -12/31/2006
Ow (MGD) 23.4
7010S (cfs) 1120
7010W (cfs) 0
3002 (cfs) 1120
Avg. Stream Flow, OA (cfs) • 2400
Reeving Stream Example Creek
WWTP Class 0
!WC (%) @ 7010S 3.1368
@ 7010W N/A
0 3002 3.1368
0 OA 1.4888
Stream Class C
Outfall 001
Ow =23.4 MGD
PARAMETER
TYPE
It)
STANDARDS &
CRITERIA (2)
POL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC Wos/ 14 FAY/
Chronic Acute
n I DA Nu Pnd Cw Aflowabl. Cw
Arsenic
C
50
uglL
10 0
Note: n<12
Limited data
21.4
set
Acute: NIA
_ _-_ _ __----------------•-----------------
Chronic: 3,359
No RP, eliminate monitoring
Chloride
C
250.0
ug/L
10 10
Note: n<12
Limited data
98.5
set
Acute: WA
_ _ _-_ _ _ _
Chronic: 16,793
No RP. eliminate monitoring
•-------------------------•---•-•—
Cadmium
NC
2 15
ug/L
0 0
WA
Acute: 15
_ _ _---_ _--•---------------------------------
Chronic: 64
Chromium
NC
50 1,022
ugfL
0 0
N/A
Acute: 1,022
Chronic:--1.�4------------------------------------
Copper
NC
7 AL 7.3
ug/L
10 10
Noto: n<12
Limited data
214.7
set
Acute: 7
_ _ _--__ _------------------•---------•—•—•---
Chronic: 223
AL continue monitoring
Cyanide
NC
5 N 22
10
ug/L
0 0
N/A
Acute: 22
_ _ _•— - _ _-_-
Chronic: 159
-------------------------_—•---
Fluoride
NC
1.800
uglL
0 0
N/A
Acute: N/A
_ _-_ _
Chronic: 57,383
b
--------------------------------
Lead
NC
25 N 33.8
ug/L
0 0
N/A
Acute: 34
_ --__ _•�
Chrontc 797
----------------------------------
Mercury
NC
12
2.0000
ngfL
0 0
WA
Acute: WA
_ _ _--__ _----------------
Chronic: 383
_ -----------------
Molybdenum
A
3.500
ug/L
0 0
WA
Acute: N/A
_ _ -_
Chronic: 111,578 —
-------------------------------
Nickel
NC
88 261
ug/L
0 0
WA
Acute: 261
_ Chronic _-_ _ _—•----------
: 2,805
--- --------•---•—•-----
Phenols
A
1 N
uglL
0 0
N/A_
Acute: WA
------------------------•-----•-----
Chronic: 32
Selenium
NC
5.0 56
uglL
0 0
WA
Acute: 56
_ _•—__ _--
Chronic: 159
--------------•-----•---•---------
Silver
NC
0.08 AL 1.23
ugfL
0 0
WA
Acute: 1
_ _ _--- _•-
Chronic: 2
----------------------------------
Zinc
NC
50 AL 67
ug/L
0 0
WA
Acute: 67
_ _ -___ _-----------•-----------------------
Chronic: 1,594
• Legend:
C z Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
Freshwater Discharge
rpa 752.xlt, rpa
4/212007

Re: Fw: EPA comments on draft permit for NC0000752-Kapstone Paper
Subject: Re: Fw: EPA comments on draft permit for NC0000752-Kapstone Paper
From: [e-mail]
Date: Tue, 3 Jul 2007 10:07:31 -0400
To: Teresa Rodriguez <[e-mail]>
CC: [e-mail]
OK, you have cleared up my comments, but can you include this
information in the fact sheet?
Thanks,
Karrie-Jo Robinson -Shell, P.E.
Teresa Rodriguez
<teresa.rodrigue
[e-mail]> To
Karrie-Jo Shell/R4/USEPA/US@EPA
07/03/2007 09:29 cc
AM
Subject
Re: Fw: EPA comments on draft
permit for NC0000752-Kapstone
Paper
Karrie-Joe,
I'm working on the final permit for this facility. You had two comments
regarding mercury and copper.
The criteria we are using to determine if a facility needs to use method
1631 when sampling for mercury is if the instream waste concentration is
6% or above. For Kapstone the IWC is 3% and the allowable concentration
for mercury is 0.38 ug/1. On their application the test results for
mercury was < 0.2 ug/1 which is below the possible limit.
Regarding copper, according to our action levels standard policy,
facilities monitor for copper with no limit and for whole effluent
toxicity. Each month a review is done for compliance. If the WET test
fails notifications are sent. The facility can do a toxicity
identification evaluation or the permit can be reopened to implement a
limit. We usually do not include the reopener in the permits because it
is part of the policy.
Please let me know if this addresses your concerns,
Teresa
[e-mail] wrote:
Teresa,
I forgot to mention that regarding copper, since data indicate that
there is RP, the draft permit should either contain a reopener to
include a limit if data show that one is needed, or the draft permit
should go ahead and include a conditional limit (that could possibly
become effective) if the data show that a limit is needed. For
instance, the draft permit could require that data collected over the
first 12 months would be used to either reopen the permit or have the
conditional limit become effective, if necessary.
Karrie-Jo Robinson -Shell, P.E.
Forwarded by Karrie-Jo Shell/R4/USEPA/US on 05/29/2007 10:11 AM
Karrie-Jo
Shell/R4/USEPA/U
1 of 2 7/3/2007 2:49 PM

Re: Fw: EPA comments on draft permit for NC0000752-Kapstone Paper
S To
05/29/2007 10:09
AM
Teresa,
[e-mail]
cc
Marshall Hyatt/R4/USEPA/US@EPA
Subject
EPA comments on draft permit for
NC0000752-Kapstone Paper
I have completed my review of the draft permit for Kapstone and have
one
comment.
Since the receiving stream is listed for impairment due to mercury. I
suggest the draft permit require the permittee to do one time mercury
sampling using EPA method 1631E, which is a more sensitive method that
used for the application (method 245.1). Use of the more sensitive
method would yield better information for NC to determine if a limit
for
mercury is warranted.
Karrie-Jo Robinson -Shell, P.E.
Teresa Rodriguez, P.E.
Division of Water Quality
EAST NPDES Program
919-733-5083 ext. 553
2 of 2 7/3/2007 2:49 PM

12-\ STATE OF NORTH CAROLINA )
:SS.
AFFIDAVIT OF PUBLICATION
CATHY C. PRUITT
COUNTY OF HALIFAX
PUBLIC NOTICE
STATE OF
NORTH CAROLINA
ENVIRONMENTAL
MANAGEMENT
COMMISSION/
NPDES UNIT
1617 MAIL SERVICE
CENTER
RALEIGH, NC
27699-1617
NOTIFICATION OF
INTENTTO ISSUE A
NPDES
WASTEWATER
PERMIT
On the basis of thor-
ough staff review and
application of NC Gen-
eral Statute 143.21,
Public law 92-500 and
other lawful standards
and regulations, the
North Carolina Envi-
ronmental Manage-
ment Commission pro-
poses to issue a Na-
tional Pollutant Dis-
charge Elimination
System (NPDES)
wastewater discharge
permit to the person(s)
listed below effective
45 days from the pub-
lish date of the notice.
Written comments re-
garding the proposed
permit will be ac-
cepted until 30 days
after the publish date
of this notice. All com-
ments received prior
to that date are con-
sidered in the final de-
terminations regarding
the proposed permit.
The Director of the NC
Division of Water
Quality may decide to
hold a public meeting
for the proposed per-
mit should the Division
receive a significant
degree of public inter-
est.
Copies of the draft
permit and other sup-
porting information on
file used to determine
conditions present in
the draft permit are
available upon request
and payment of the
costs of reproduction.
Mail comments and/oi
requests for informa-
tion to the NC Division
of Water Quality at the
above address or call
Ms. Frances Cande-
laria [phone],
extension 520 at the
Point Source Branch.
Please include the
NPDES permit num-
ber (attached) in any
communication. In-
terested persons may
also visit the Division
of Water Quality at
512 N. Salisbury
Street, Raleigh, NC
27604-1148 between
the hours of 8:00 a.m.
and 5:00 p.m. to re-
view information on
file.
Kapstone Kraft Paper
Corporation at 100
Gaston Road, Ro-
anoke Rapids, NC
27870 has applied for
renewal of NPDES
.permit NC0000752 for
its Roanoke Rapids
Mill WWTP in Halifax
County. This permit-
ted facility discharges
treated process waste-
water through outfall
001 and non -contact
cooling water through
outfalls 002 and 003 to
the Roanoke River in
the Roanoke River Ba-
sin. Currently, BOD is
water quality limited.
This discharge may af-
fect future allocations
in this portion of the
watershed.
May 14; 2007
being first
duly sworn, deposes and says: That (he) (she) is the Agent to the Publisher of the DAILY
HERALD newspapers printed and published six days a week in the County of
Halifax, State of North Carolina, and of general circulation in the cities of Roanoke
Rapids, County of Halifax, State of North Carolina and elsewhere, and thehereto
attached
PUBLIC NOTICE
was printed and published correctly in the
DAILY HERALD for
made on the 14 th day of MAY
and the last publication thereof was made on the 14 th day of
MAY 20 07
was made on each of the following dates, to wit:
05/14/07
Request of
By
regular and entire issue of said
1 issues, that the first was
20 07
that said publication
Herald
Subscribed sworn to before me this 14 t h day of MAY
20
07
Nota Public in and for the County of Halifax, Sate of N.C.
My Commission Expires:
My Commission Expires November 28, 2009;

#l0 36 r (0 r ileum
r�ax� chi And aac
Q eko , Lr 3
2d01- fbin e; p .
( VA- GJ - a4.4.CQ &SA-0 oQA at e
p ec -0- mac.-1 h cpsQF

January 5, 2007
NCDENR DWQ
512 Salisbury Street
Raleigh, North Carolina
27604
Re: Change of Ownership to KapStone Kraft Paper Corporation
Dear Mr. Weaver,
1 JAN 0 2007
•
- WATER QUALITY
„uT SOURCE BRANCH
An application request for change of ownership for the Roanoke Rapids Kraft Paper mill
NPDES Wastewater Operating Permit NC 0000752 from International Paper to KapStone
Kraft Paper Corporation is enclosed. If you have any questions please do not hesitate to
contact me at 252-533-6255.
Sincerely,
Mary Lee- R nsmeier
Environmental Manager
Copy: Anitra Collins, Vice President -Mill Operations
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road, Roanoke Rapids, NC 27870

INTERNATIONAL
Roanoke Rapids Mill
100 Gaston Road
Roanoke Rapids, NC 27870
November 15, 2006
Mr. Alan W. Klimek, Director
NC DENR
Division of Water Quality
512 N. Salisbury Street
Raleigh, NC 27604
PAPER
611
(/5u
0,
11E©lEDWIEN
NOV 212006
DIV. OF WATER QUALITY
DIRECTOR'S OFFICE
Re: International Paper Roanoke Rapids Mill Transfer of Ownership to KapStone-
Environmental Operating Permits
Dear Mr. Klimek,
International Paper has entered into an agreement to sell the Roanoke Rapids Kraft Paper
Mill to a newly formed company, KapStone Kraft Paper and Packaging Corporation.
The mill will continue to manufacture the same products, Kraft paper and light weight
liner board at our integrated Kraft pulp and paper mill without any interruption. We are
currently awaiting final approval by the Securities and Exchange Commission, but
anticipate a closing of December 31, 2006. Therefore, the new permits must be effective
January 1, 2007. Because of a given amount of uncertainty, I wanted to give you as
much advance notice as possible and will confirm the date of closing as soon as we are
informed.
A copy of the ownership change forms are enclosed for the following environmental
permits now held by International Paper:
1. NC000 ES Wastewater Treatment Facility_
2. NCS000106-NPDES Stormwater Permit (revision needed)
3. WQ0021577-Land Application of Flyash
4. WQ013516-Land Application of Residual Solids
5. WQ0000436-Solid Waste Landfill
As soon as approval of the sale finalized, I will be able to notify you and will submit
original signed and dated permit change forms. As noted above, the only permit that
needs revision is the Stormwater Permit. International Paper will retain ownership of an
on site landfill, closed in 1998, which has one stormwater monitoring discharge point
designated as "Lowground."

I look forward to working with you and your staff on this change of ownership as our
mill enters its one hundredth year of manufacturing in Eastern North Carolina. And we
anticipate many more years of continued business in the State. Please contact me if I
you have any questions at 252-533-6255
Sincerely,
'77)( &IV.,..e.e...--'e2-14.70.---77-4-e4--;-<--)
Mary Lee Ransmeier
Environmental Programs Manager
Copy: Anitra Collins, Mill Manager
Chuck Waldld, Regional Supervisor, DWQ
Enclosures

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
SURFACE WATER PROTECTION SECTION
PERMIT NAME/OWNERSHIP CHANGE FORM
I. Please enter the permit number for which the change is requested.
NPDES Permit (or) Certificate of Coverage
N
C
0
0
0
0
7
5
2
II. Permit status prior to status change.
a. Permit issued to (company name):
b. Person legally responsible for permit:
c. Facility name (discharge):
d. Facility address:
e. Facility contact person:
N
C
G
International Paper
Anitra J. Collins
First / MI / Last
Mill Manager
Title
100 Gaston Road
Permit Holder Mailing Address
Roanoke Rapids, NC 27870
City State Zip
( 252) 533-6398 (252 ) 533-6401
Phone
Roanoke Rapids Mill.
100 Gaston Road
Fax
Address
Roanoke Rapids, NC 27870
City State
Zip
Thomas C. Puryear [phone]
First / MI / Last Phone
III. Please provide the following for the requested change (revised permit).
a. Request for change is a result of: I Change in ownership of the facility
O Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
c. Person legally responsible for permit:
d. Facility name (discharge):
e. Facility address:
f. Facility contact person:
KapStone Kraft Paper Corporation
Anitra J. Collins
First / MI / Last
Mill Manager
Title
100 Gaston Road
Permit Holder Mailing Address
Roanoke Rapids, NC 27870
City State
Zip
( 252) 533-6398 [e-mail]
Phone E-mail Address
Roanoke Rapids Mill
100 Gaston Road
Address
Roanoke Rapids, NC 27870
City State
Mary Lee Ransmeier
Zip
First / MI / Last
( 252) 533-6255 [e-mail]
Phone E-mail Address
Rwvic...i 7/7f1f1C

PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
IV. Permit contact information: (if different from the person legally responsible for the permit)
Permit contact:
First / MI / Last
Title
Mailing Address
City
State Zip
Phone E-mail Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior to
this ownership or name change?
12) Yes
❑ No (please explain)
VI. Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE
INCOMPLETE OR MISSING:
❑ This completed application is required for both name change and/or ownership change requests.
❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill
of sale) is required for an ownership change request. Articles of incorporation are not sufficient for
an ownership change.
The certifications below must be completed and signed by both the permit holder prior to the change, and the new
applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification
is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
I, Anitra I. Collins , 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 is not included, this
application p ckage will be returned as incomplete.
4/
tr
Signature Date
APPLICANT CERTIFICATION:
Matt Kaplan , 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 is not included, this
app ication package will be returned as incomplete.
littA---C Li'
Signature Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Water Quality
Surface Water Protection Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Revised 7/2005

STONE ARCADE
ACQUISITION CORP.
FOR IMMEDIATE RELEASE
January 2, 2007
CONTACTS: Media - Kimberly Bracy/252-533-6287
Investors - Roger Stone, Matt Kaplan/847-441-0929
STONE ARCADE ACQUISITION CORPORATION COMPLETES ACQUISITION OF
INTERNATIONAL PAPER'S KRAFT PAPERS BUSINESS
CHICAGO, IL —Jan. 2, 2007—Stone Arcade Acquisition Corporation (OTCBB:SCDE) today
announced it has completed the acquisition of International Paper's kraft papers business and
will change its name to KapStone Paper and Packaging Corporation.
"The acquisition of IP's kraft papers business is an important first step for our company," said
Roger Stone, Chairman and Chief Executive Officer of Stone. "It provides us with a solid
platform from which we hope to expand. We are anxious to continue building on the success of
this business while we simultaneously explore strategic acquisitions."
KapStone Paper and Packaging will continue to be headquartered in Northfield, IL. The newly
acquired kraft papers business will operate as Kapstone Kraft Paper Corporation, and includes
a paper mill in Roanoke Rapids, NC, and Ride Rite®, a dunnage bag plant in Fordyce, AR. The
business employs approximately 700 people.
The company's leadership team has more than a century of combined industry experience. Key
individuals include Roger W. Stone, Chairman and Chief Executive Officer, and Matthew
Kaplan, President and Chief Operating Officer. Tim Keneally will serve as Vice President of
KapStone Paper and Packaging and President of Kapstone Kraft Paper Corporation. Other
Kapstone Kraft officers include Tonie Meyers, Vice President of Mill Sales and Customer'
Service; Anitra Collins, Vice President of Mill Operations; and Tom Bennington, Vice President
of Ride Rite®.
'We are very excited about the acquisition of IP's kraft papers business," added Matt Kaplan.
"The Roanoke Rapids mill and Ride Rite® have been successful in creating strong, long-term
customer relationships resulting from outstanding quality and service. We believe both
businesses are well positioned for the future."
Stone Arcade originally announced plans to purchase International Paper's kraft papers
business in June 2006 for approximately $155 million in cash, subject to certain post -closing
One Northfield Plaza, Suite 480 Northfield, IL 60093
Tel: [phone] Fax: [phone]
NY548657.2
207609-10002

rrn
STONE ARCADE
ACQUISITION CORP.
adjustments, and two payments totaling up to $60 million, payable five years from the close of
the transaction, contingent upon business performance.
About the Company
Headquartered in Northfield, IL, Stone Arcade Acquisition Corporation was formed in 2005 and
is the parent company of Kapstone Kraft Paper Corporation. The business produces
approximately 400,000 tons of kraft paper and lightweight linerboard and approximately 9 million
Ride Rite dunnage bags. The business employs approximately 700 people.
Stone Arcade was formed as a publicly traded special purpose acquisition company, founded in
April 2005, for the purpose of identifying and effecting an asset acquisition or business
combination with an unidentified business in the paper, packaging, forest products, and related
industries. Immediately following consummation of the acquisition of the kraft papers business,
Stone Arcade filed an amendment to its certificate of incorporation to change its name to
KapStone Paper and Packaging Corporation and to remove provisions relating to procedures
governing its first business combination.
This press release may contain forward -looking statements within the meaning of the Private
Securities Litigation Reform Act of 1995. Forward -looking statements are statements that are
not historical facts. Such forward -looking statements are subject to known and unknown risks,
uncertainties and assumptions about Stone Arcade and Kapstone Kraft that may cause actual
results, levels of activity, performance or achievements to be materially different from any future
results, levels of activity, performance or achievements expressed or implied by such forward -
looking statements. Factors that might cause or contribute to such a discrepancy include, but
are not limited to, those described in Stone Arcade's Securities and Exchange Commission
filings. The information set forth herein should be read in light of such risks. Stone Arcade does
not assume any obligation to update the information contained in this press release.
One Northfield Plaza, Suite 480 Northfield, IL 60093
Tel: [phone] Fax: [phone]
NY548657.2
207609-10002

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
(This form is best filled out on computer, rather than hard copy)
Date: 10/19/2006 County: Halifax
To: NPDES Discharge Permitting Unit Permitee: International Paper
Attn. NPDES Reviewer: Teresa Rodriguez Application/ Permit No.: NC0000752
Staff Report Prepared Bv: R. Boone
Project Name: International Paper NPDES Permit Renewal : 1111-
�
SOC Priority Project? (Y/N) N If Yes, SOC No.
A. GENERAL INFORMATION
CT 3 1 2005
1. This application is (check all that apply): ❑ New ® Renewal
❑ Modification
DENR - WATER QUALITY
2. Was a site visit conducted in order to prepare this report? ❑ Yes or ® r GouRce aRANCH
a. Date of site visit:
b. Person contacted and telephone number:
c. Site visit conducted by:
d. Inspection Report Attached: ❑ Yes or ❑ No.
3. Keeping BIMS Accurate: Is the following BIMS information (a. through e. below) correct?
❑ Yes or ® No. If No, please either indicate that it is correct on the current application or the
existing permit or provide the details. If none can be supplied, please explain:
Fill this section only if BIMS or Application Info is incorrect or missing
Facility
a. Location Address: OK on Application ®,
OK on Existing Permit ❑, or provide Location: 100 Gaston Road, Roanoke Rapids, NC 27870.
b. Latitude/Longitude (These are often inaccurate) OK on Application ®, (check at
http://topozone.com ) OK on Existing Permit ®, or provide Latitude: Longitude:
c. Driving Directions OK on Application ❑,
OK on Existing Permit ❑, or provide Driving Directions (please be accurate): 64 bypass east
from Raleigh to I-95. I-95 north to Hwy 46. Hwy 46 west to Gaston, intersection of Hwy 46
(Lawrenceville Road) and Hwy 48 (Roanoke Rapids Road). Left (south) on Hwy 48 (Roanoke
Rapids Road) approximately 1.7 miles. Facility entrance is on the left.
Primary Discharge Point Location
a. USGS Quadrangle Map name and number OK on Application ❑,
OK on Existing Permit ®, or provide USGS Quadrangle Map name and number: Roanoke
Rapids, NC, B28NW
b. Latitude/Longitude of Outfall (These are often inaccurate) OK on Application ❑, (check at
http://topozone.com ) OK on Existing Permit ❑, or provide Latitude: Longitude:

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
For 001, lat/long in application and permit is accurate enough that one could find the
outfall in the field but it does not appear to be exact.
c. Receiving Stream OK on Application ®,
OK on Existing Permit ®, or provide Receiving Stream or affected waters:
a. Stream Classification: C
b. River Basin and Sub basin No.: Roanoke River Basin, 03-02-08
c. Describe receiving stream features and downstream uses: Controlled by Roanoke Rapids
dam. Downstream uses include fishing, secondary recreation and drinking water supply.
For NEW FACILITIES Proceed to Section C, Evaluation and Recommendations
(For renewals or modifications continue to section B)
B. DESCRIPTION OF FACILITIES AND WASTE(S) (renewals and modifications only)
1. Describe the existing treatment facility: Facility is as described in the existing permit.
2. Are there appropriately certified ORCs for the facilities? ® Yes or ❑ No.
Operator in Charge: Chris Puryear Certificate # 8275 (Available in BIMS or Certification Website)
Back- Operator in Charge: Neal Davis Certificate # 6740
3. Does the facility have operational or compliance problems? Please comment: No
Summarize your BIMS review of monitoring data (Notice(s) of violation within the last permit cycle;
Current enforcement action(s)): There are no current NOVs or enforcement actions. There were four
monitoring violations in Mar_ for which no action was taken. There have been no other
violations since last permit reissuance.
Are they currently under SOC, ❑ Currently under JOC, ❑ Currently under moratorium ❑? Have
all compliance dates/conditions in the existing permit, SOC, JOC, etc. been complied with? ❑ Yes
or ❑ No. If no, please explain:
4. Residuals Treatment: PSRP ❑ (Process to Significantly Reduce Pathogens, Class B) or
PFRP ❑ (Process to Further Reduce Pathogens, Class A)? N/A
Are they liquid or dewatered to a cake? Dewatered
Land Applied? Yes ® No ❑ If so, list Non -Discharge Permit No. On site, WQ0013516
Contractor Used:
Landfilled? Yes ® No0 If yes, where? Onsite, WQ0000436
Other?
Adequate Digester Capacity? Yes ❑ No ❑ Sludge Storage Capacity? Yes ❑ No ❑
Please comment on current operational practices: There are no digesters. Sludge is thickened and pH
adjusted and then sent to sludge presses. The sludge from the presses is then sent to either an onsite
FORM: NPDES-RRO 06/03, 9/03 2

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
landfill or land applied. Filtrate from the presses is sent back to the headwords of the plant for
treatment.
5. Are there any issues related to compliance/enforcement that should be resolved before issuing this
permit? ❑ Yes or ® No. If yes, please explain:
C. EVALUATION AND RECOMMENDATIONS
1. Alternative Analysis Evaluation: has the facility evaluated the non -discharge options available? Give
regional perspective for each option evaluated:
Spray Irrigation:
Connect to Regional Sewer System:
Subsurface:
Other Disposal Options: There was no alternatives analysis included with the renewal application.
However, RRO staff feel there are no other practical alternatives primarily due to the high amount of flow
produced at the facility.
2. Provide any additional narrative regarding your review of the application: None
3. List any items that you would like NPDES Unit to obtain through an additional information
request. Make sure that you provide a reason for each item:
Recommended Additional Information
Reason
4. List specific Permit requirements that you recommend to be removed from the permit when
issued. Make sure that you provide a reason for each condition:
Recommended Removal
Reason
5. List specific special requirements or compliance schedules that you recommend to be included in
the permit when issued. Make sure that you provide a reason for each special condition:
FORM: NPDES-RRO 06/03, 9/03 3

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
Recommended Addition
Reason
6. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office;
❑ Hold, pending review and approval of required additional information by NPDES permitting
office; ® Issue; ❑ Deny. If deny, please state reasons:
Reminder: attach inspection report if Yj was checked for 2 d.
7. Signature of report preparer:
Signature of WQS regional supervisor:
Date: ! G I 0 Cr
4-0 A(i/
D. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
If next page is not used, PLEASE set printer for pages 1 through 3 to avoid wasting paper.
Use this page for facilities with more than one Discharge Pipe
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing)
a. Location OK on Application ❑,
OK on Existing Permit ❑, or provide Location: Location lat/long is good. Lat/long for 002 on
application and in BIMS is not exact but is likely good enough for one to find it while in the field.
b. Driving Directions OK on Application ❑,
OK on Existing Permit ❑, or provide Driving Directions (please be accurate): Refer to page 1.
c. USGS Quadrangle Map name and number OK on Application ❑,
OK on Existing Permit ®, or provide USGS Quadrangle Map name and number: Roanoke
Rapids, NC, B28NW
d. Latitude/Longitude OK on Application ❑, (check at http://topozone.com These are often
inaccurate) OK on Existing Permit ❑, or provide Latitude: Longitude:
e. Receiving Stream OK on Application ®,
OK on Existing Permit ®, or provide Receiving Stream or affected waters:
a. Stream Classification: C
b. River Basin and Sub basin No.: Roanoke River Basin, 03-02-08
FORM: NPDES-RRO 06/03, 9/03 4

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
c. Describe receiving stream features and downstream uses: Controlled by Roanoke Rapids
dam. Downstream uses include fishing, secondary recreation and drinking water supply.
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing)
a. Location OK on Application ❑,
OK on Existing Permit ❑, or provide Location: Location lat/long is good. Lat/long for 003 on
application and in BIMS is not exact but is likely good enough for one to find it while in the field.
b. Driving Directions OK on Application ❑,
OK on Existing Permit ❑, or provide Driving Directions (please be accurate): Refer to page 1.
c. USGS Quadrangle Map name and number OK on Application ❑,
OK on Existing Permit El, or provide USGS Quadrangle Map name and number: Roanoke
Rapids, NC, B28NW
d. Latitude/Longitude OK on Application ❑, (check at http://topozone.com These are often
inaccurate) OK on Existing Permit ❑, or provide Latitude: Longitude:
e. Receiving Stream OK on Application ®,
OK on Existing Permit ®, or provide Receiving Stream or affected waters:
a. Stream Classification: C
b. River Basin and Sub basin No.: Roanoke River Basin, 03-02-08
c. Describe receiving stream features and downstream uses: Controlled by Roanoke Rapids
dam. Downstream uses include fishing, secondary recreation and drinking water supply.
FORM: NPDES-RRO 06/03, 9/03 5

INTERNATIONAL
September 25, 2006
PAPER
Mr. Charles Weaver
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, N.C. 27699- 1617
Attn: Carolyn Bryant
re: Renewal Notice
NPDES Permit No. NC0000752
Roanoke Rapids Mill
Halifax County
Dear Mr. Weaver:
ROANOKE RAPIDS MILL
100 GASTON ROAD
ROANOKE RAPIDS, NC 27870
PHONE: [phone]
ECIELIVE
OCT — 2 2006
.J
DENR - WATER QUALITY
SURFACE WATER PROTECTION SECTION
Pursuant to Federal (40 CFR 122.41) and North Carolina (15A NCAC 2H.0105(e))
regulations NPDES permit renewal applications must be submitted at least 180 days
prior to the expiration of the existing permit (March 31, 2007). The Purpose of this
correspondence is to request renewal of NPDES Permit No. 0000752 for the
International Paper mill located in Roanoke Rapids, North Carolina. Enclosed you will
find the following information (one original and two copies):
• EPA Form 3510-1 (General Information Form)
• Topographic Map of Mill Site and Discharge Points
• Application Form 2C — Wastewater Discharge Information
• Mill Water Balance Diagram
• Wastewater Treatment System Diagram
• Wastewater Treatment System Narrative Description
• Sludge Management Plan Narrative Description
• Results of Priority Pollutant Analysis
• Results of Analysis Required under Part V-B and V-C of Form 2C
If you have any questions regarding the permit renewal application please don't
hesitate to call Mary Lee Ransmeier at 252-533-6255 or Chris Puryear at 252-533-
6237.
Sincerely,
-Anitra .>. Collins
Mill Manager
xc: Neal Davis
Mary Lee Ransmeier
Chris Puryear
Paul Kinnin (w/o attachments)

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6W (9.61N1
Outfall 003 N36, 28',41.0" W77, 38',30.4"
Scale 1 : 28,125
1'=2,343.8ft
Data Zoom 12-0

Flow from River
•
24.8 MGD
Mill Water Balance
Paper Mill Influent
Water in Wood
Ir
•
•
•
•
•
•
•
•
.
.
•
365 gpm
Pulpmill Influent
Utility Influent
Non Contact
• Secondary Blow Heat 0.5 MGD
• • •du Primary Turp Cond 0.3 MGD
• ► Sec. Reflux Condensor 0.4 MGD
Paper Mill
Cold Water Tank
8 MGD
Evaporationto Atm
45 gpm I*
Water in Paper
► 12 gpm
Paper Mill Effluent
8 MGD
Pulpmill
•
•
: 1'du
•1
: 1 Condensate Collection
•• ~ •• I•r HPFT
0.7 MGD
•1
. •
• 1 Ou Utility
Pulpmill Effluent 1.2 MGD
►
Condensate Collection Effluent 0.7 MGD
•
: r..
•
• B Evaps Surface Cond 1.2 MGD
• C Evaps Surface Cond 2.1 MGD
:....•Ir Boiler Water Makeup 0.7 MGD
• Slaker Stacks 0.1 MGD
• ► Ash Pond 0.2 MGD
.
.
Utility Effluent 5.3 MGD
• In
• Non Contact Water
Surface Condensor Overflow 8.0 MGD
Sec. Turp Cond 2.0 MGD
•
Waste Flow to River
Water
Treatmen :
15.2 MGD
Recycle • • • • • • • • • •
Recycle inli.am..imp
Non Contact to River 10.0 MGD

Roanoke Rapids
Wastewater Treatment Plant
Stabilization Basil 82
(190 Arm)
Ca.
Pulp Mill
309.5 MG
16 Days Retention
Roanoke River—``
Turpentine
Non -Contact Discharge
•
Iiard�PiP e
Feed Tank
W
Woodyard
S1otmWater
Pond
Siormwater Ditch
Site Plan - Roanoke Rapids
Aerators:
4 - 50 hp Air02 aerators
3 - 75 hp Air02 aerators
11 - 75 hp high speed surface aerators
13 - 60 hp high speed surface aerators
Total — 2030 hp
Landfill
(26 Acres)

INTERNATIONAL PAPER
Roanoke Rapids Mill
NPDES Permit Renewal
Wastewater Treatment System Description
The main sewer that brings the wastewater into the treatment facility is a concrete lined
open channel. Along the channel are a composite sampler, pH and conductivity probes,
and a flow meter. The instruments have local readouts at the channel and in the Sludge
Press operators control room. The sludge press operator monitors the operation of the
sludge press and the wastewater facility from this control room. Operation of the sludge
press and wastewater facility can also monitored from the Lime Kiln operators control
room.
The flow goes through a mechanical bar screen, into a wet well where three lift pumps
carry the flow to a 200 foot diameter primary clarifier. The clarifier has a capacity of 3.8
million gallons. In the event that we have a power failure, mechanical problems or high
strength waste the sludge press operator can divert main sewer flow, by gravity, to the
Surge Pond. The pond is 20.4 acres and holds 28 million gallons of wastewater or about
two days of normal mill wastewater flow. The water from the diversion pond is then
pumped back to the head of the wastewater plant at a rate of 1380 gallons per minute.
The flow from the Primary Clarifier is gravity feed to the aeration pond. Nutrients are
added to the clarified effluent prior to the aeration pond. The aeration pond covers 21.5
acres and has a retention time of four days. There are 31 aerators with a total of 2030
horsepower. The aeration pond also receives approximately 0.6 million gallons per day
from the condensate collection system Hard Pipe Feed Tank (HPFT). (This is not
additional flow to the treatment system but the method of condensate collection and
treatment mandated by the Maximum Achievable Control Technology rules for the Pulp
and Paper industry.) The water then cascades down into the first of four stabilization
ponds. There are 370 acres of stabilization ponds with a retention time of 30-35 days.
The ponds and dikes are clay lined and have a capacity of approximately 480 million
gallons at a normal operating level of 4 feet.
The final stabilization pond discharge has a bar screen and a composite sampler. Effluent
flow is controlled by an electrically operated butterfly valve at the discharge to the river.
Final effluent flow measurement is accomplished by the use of a Marsh Mc Birney multi -
probe velocity type flow meter. We also have the equipment to feed defoamer to the
effluent for foam control if required.
Sludge from the primary clarifier is pumped to a blend tank where sulfuric acid is added
for pH control and polymer is added to promote thickening. The sludge is then pumped
to one of two rotary screen thickeners and gravity feed to one of two Dupps Andritz
screw presses. The presses are 38 feet long and normally produce a sludge cake of 40 %
solids or greater. These solids are deposited into one of four leak proof 28 foot dump
trailers and hauled to the permitted (WQ0000436) onsite landfill.
Dredging from the Stabilization ponds are pumped to the old sludge pond. Leachate
from the old sludge pond, and the onsite landfill, flow by gravity into the aeration pond.
September, 2006

INTERNATIONAL® PAPER
Roanoke Rapids Mill
NPDES Permit Renewal
Sludge Management Plan
The solids that settle to the bottom of the Primary Clarifier are pumped from the center of
the clarifier to a blend tank where sulfuric acid is added to lower the pH and aid the
flocking of the sludge. The sludge is then pumped from the Blend tank to one of two
Rotary Screen Thickeners. While in route to the Rotary Screen Thickeners polymer is
added to flocculate the sludge. Filtrate is released through the screen of the RST and the
solids remain inside and are dumped into a hopper. One of two, 38 foot screw presses
compresses the solids and pushes the filtrate through the screens. The solids are then
dumped into the screw conveyors and conveyed to one of four sealed 28 cubic yard
trailers. The dewatered sludge, which are about 40% solids, is then taken to the mill's
onsite landfill (Permit Number WQ0000436). Periodically the sludge from the sludge
presses are applied to permitted lands under Land Application Permit No. WQ0013516.
All filtrate from the sludge press is returned to the head of the wastewater plant for
treatment.
When ever it is determined that the ponds need to be cleared of solids. The solids that
accumulate in the ponds are pumped by dredge through 8-10 inch fused plastic pipe to
what is referred to as the Old Sludge Pond. The solids decant in the sludge pond and the
filtrate returns to the Aeration Pond for treatment
September, 2006

Paper Mill Influent
Water in Wood
•
365 gpm
r
•
...dt
Flow from River
24.8 MGD
Pulpmill Influent
Utility Influent
rdiP
1
Mill Water Balance
Paper Mill
Cold Water Tank
8 MGD
Pulpmill
Secondary Blow Heat
Primary Turp Cond
Sec. Reflux Condensor
0.5 MGD
0.3 MGD
0.4 MGD
1 Condensate Collection
1-..I. HPFT
1
1 Ou
r
Non Contact
0.7 MGD
Utility
B Evaps Surface Cond
C Evaps Surface Cond
Boiler Water Makeup
Slaker Stacks
Ash Pond
1.2 MGD
2.1 MGD
0.7 MGD
0.1 MGD
0.2 MGD
Ir Non Contact Water
Surface Condensor Overflow 8.0 MGD
► Sec. Turp Cond 2.0 MGD
Evaporation to Atm
45 gpm
Water in Paper
12 gpm
Paper Mill Effluent 8 MGD
Pulpmill Effluent
1.2 MGD
•
Condensate Collection Effluent 0.7 MGD
•
Utility Effluent
5.3 MGD
Non Contact to River 10.0 MGD
•
Waste
Water
Treatment
Flow to River
Recycle
Recycle — . • — •
15.2 MGD

Roanoke Rapids
Wastewater Treatment Plant
Pulp Mill
Stabilizajkn Bum 12
(190 Acres)
3093 MG
16 Days Retention
Roanoke River—�`
Turpentine
Non —Contact Di:charse
Hard Pipe
Feed Tank
C 0-
(A I.
Woodyard
Siortnaalc
10, Pond
Storm water Ditch
Site Plan - Roanoke Rapids
Aerators:
4 - 50 hp Air02 aerators
3 - 75 hp AIr02 aerators
11 - 75 hp high speed surface aerators
13 - 60 hp high speed surface aerators
Total = 2030 hp
Landfill
(26 Acres)