NC0000752_Historical_2017-2022

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Mr. Wilbur G. Kessinger Jr.
Kapstone Kraft Paper Corporation
100 Gaston Rd.
Roanoke Rapids, North Carolina 27870
Dear Mr. Kessinger:
NORTH CAROLINA
Environmental Quality
August 10, 2018
Subject: Issuance of NPDES Permit
Permit NC0000752
Roanoke Rapids Mill WWTP
Halifax County
Facility Class IV
The Division of Water Resources is forwarding herewith the Final NPDES Permit for Roanoke
Rapids Mill WWTP. 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 October 15, 2007 (or as subsequently
amended).
This Final Permit contains no significant changes from the Draft Permit.
The Division is unable to grant your request to reduce the instream sampling since it would
make the permit less stringent and it is not allowed by the rules after the Public Notice. Please
submit this request during the next renewal.
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 a demand is made, this permit 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
�9Q�1�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mall Service Center I Raleigh. North Carolina 27699-1611
919.707.9000

the legal requirements to obtain other permits which may be required by the Division of Water
Resources or any other Federal, State, or Local governmental permits that may be required.
If you have any questions on this permit, please contact Sergei Chernikov at 919-807-6386.
Sincerely,
rda Culp,etefim Director
vision of Water Resources
Hardcopy: Central Files,
NPDES Files
Raleigh Regional Office, Water Quality
E-copy: US EPA, Region IV
WSS/Aquatic Toxicology Branch
PERCS
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbwy Street 116U Mail Service center I Raleigh North Carolina 27699-1611
919.707.9000

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-2IS. 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
applicable conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective September 1, 2018.
This permit and authorization to discharge shall expire at midnight on March 31, 2022.
Signed this day August 10, 2018.
LyiFfdallCulpepper, n irector
"ion of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 8

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
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.
Page 2 of 8

Permit NC0000752
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
115A NCAC 02B .0400 et seq., 02B .0500 et seq.]
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 monitored6 by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Avera a
Daily
Maximum
Measurement
Frequency
Sample
a
Sample
Location'
Flow
28.0 MGD
Continuous
Recorder
I or E
BOD, 5 day, 20'C
8,680.0
lbs da
17,361.0
lbs da
Daily5
Composite
E
Total Suspended Solids
18,601.0
lbs da
37,202.0
lbs da
Dailys
Composite
E
Dissolved Oxygen, m L
Dail s
Grab
E, U, D
Temperature, OC
Dail s
Grab
E, U, D
Conductivity, pnihocm
Dail 5
Grab
E, U, D
NH3 as N, m L
Monthly
Composite
E
Total Nitrogen
NO2+NO3+TKN,m L
Monthly
Composite
E
Total Phosphorus, m L
Monthly
Composite
E
Chronic ToXiCity2,3
Quarterly
Composite
E
Total Co era
211.25 µ L
227.36 µ L
Quarterly
Composite
E
H
6.0 — 9.0 standard units
Dail 5
Grab
E
Pentachloro henol4
1.80lbs/day
Weekly
Grab
E
Trichloro henol4
1.64 lbs/day
Weekly
Grab
E
Total Hardness, m L
Monthly
Composite
E, U
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. (3.),
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.
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (6.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 8

Permit NC0000752
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
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 monitored4 by the Permittee as specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Daily
Measurement
Sample
Sample
Average
Maximum
Frequency
a
Location
Flow
Semi-
Estimate
Effluent
annuall
Temperature'C
See note 1
See note 1
Semi-
Grab
Effluent
annually
Semi-
Effluent,
pH
6.0 - 9.0 standard units2
Grab
Upstream,
annually
Downstream3
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. (5.), pH Re -opener.
3. Upstream at NC Highway 48 Bridge, Downstream at NC Highway 158.
4. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (6.).
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. (4), Biocide Condition).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 8

Permit NC0000752
A. (3.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubfa at an effluent concentration of 3.7%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia 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 quarterly test procedure 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 -December 2010) 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,
DWR Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water 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 Water 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. Assessment of toxicity compliance is based
on the toxicity testing month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division -of Water Resources 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.
Page 5 of 8

Permit NC0000752
A. (4.) BIOCIDE CONDITION
[G.S. 143-215.1(b)]
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. (5.) PH REOPEAER
[G.S. 143-215.1(b)]
The Division may re -open this permit to remove pH limitation footnotes at Outfall 002, should new
information indicate water quality problems due to declining pH in this portion of the river.
A. (6.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. 12.1 and Section E. 15.1 lall
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month
and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the
state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,
1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be
submitted to the mailing address above. See "How to Request a Waiver from Electronic
Reporting" section below.
Page 6 of 8

PermitNC0000752
Regardless of the submission method, the first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility, on the last day of the month following
the commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following
compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated
entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on EPA's NPDES
Electronic Reporting Rule is found at:
httt)s: / /www.federalregister. gov / documents / 2015 / 10 / 22 / 2015-24954 / national -pollutant -
discharge -elimination -system -nodes -electronic -reporting -rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request
to the Division. Requests for temporary electronic reporting waivers must be submitted in writing
to the Division for written approval at least sixty (60) days prior to the date the facility would be
required under this permit to begin submitting monitoring data and reports. The duration of a
temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring
data and reports shall be submitted electronically to the Division unless the permittee re -applies
for and is granted a new temporary electronic reporting waiver by the Division. Approved
electronic reporting waivers are not transferrable. Only permittees with an approved reporting
waiver request may submit monitoring data and reports on paper to the Division for the period
that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found
on the following web page:
http: / /deo.nc.gov/about/divisions/water-resources/edmr
Page 7 of 8

Permit NC0000752
4. Signatory Requirements [Supplements Section B 111.1 Ibl and Supersedes Section B (11.)
LIl
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (I I.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority
for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit
the following web page:
http: / /dea.nc.eov/ about/ divisions /water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are sigmficantpenalties for submitting false information,
including the possibility offines and imprisonment for knowing violations."
5. Records Retention [Supplements Section D. 16.11
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from
the date of the report. This period may be extended by request of the Director at any time [40
CFR 122.41].
Page 8 of 8

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Kapstone Kraft Paper Corp.- NC0000752 Facility 0
USGS Quad Number: 628NW Lat.: 36°28'19" Location
Receiving Stream: Roanoke River Long.: 77038'14"
Stream class: C SCALE 1:24 000
Subbasin: Roanoke, 03-02-08 North }

DowSign Envelope ID: 39B4BC91-6F5B-4OE5-6B75-F437CBB29AF6
Notice of Deficiency
Roanoke Rapids Mill WWTP
Page 2 of 2
If you should need any assistance or would like to discuss this non-compliance situation, please contact Alys
Hannum of the Raleigh Regional Office at alys.hannum(a)ncdenr.00v, or by phone at 919-791-4255.
Sincerely,
CDo uftned by:
UaIn t SSA f. kAO At,I.
82916E8AB321"F..
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
cc: WQS Raleigh Regional Office - Enforcement File
Laserfiche

DocuSign Envelope ID: 39B4BC91-8F5B-40E5-8B75-F437CBB29AF6
ROY COOPER
.r.v,
r ;l �I
ELIZABETH S. BISER
S. DANIEL SMITH
�'oRn� c„aoune.
�,...,.,
rnroannrenra Quanry
Certified Mail # 7020 3160 0000 4115 3470
Return Receipt Requested
January 26, 2022
Benjamin P White, General Manager
Westrock Kraft Paper LLC
PO Box 458
Roanoke Rapids, NC 27870-0458
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0012
Permit No. NC0000752
Roanoke Rapids Mill WWTP
Halifax County
Dear Permittee:
A review of the December 2020 Discharge Monitoring Report (DMR) for the subject facility revealed the
deficiency(s) indicated below:
Sample
Location Parameter Date Type of Deficiency
1/31/2021 Outfall 002 Missing
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Raleigh Regional Office encourages
you to take all necessary actions to bring your facility into compliance.

DowSign Envelope ID: 60093DD5-94CE-46F2-9A38-D84803075245
Notice of Deficiency
Roanoke Rapids Mill WWTP
Page 2 of 2
If you should need any assistance or would like to discuss this non-compliance situation, please contact Alys
Hannum of the Raleigh Regional Office at [e-mail], or by phone at 919-791-4255.
Sincerely,
COocuSipnetl by:
VAV t,SS#. f,
e2916RAS321441`
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
cc: WQS Raleigh Regional Office - Enforcement File
Laserfiche
DEQ'

DowSign Envelope ID: 60093DD5-94CE-46F2-9A3B-D84803075245
R_OYCOOPER�
ED2A8ETH S. BfSER
k:rn
S. DANIEL SMITH
- -
m...,,-
1 ,. 1-1.- .. ,
Certified Mail # 7020 3160 0000 4115 3494
Return Receipt Requested
January 26, 2022
Benjamin P White, General Manager
Westrock Kraft Paper LLC
PO Box 458
Roanoke Rapids, NC 27870-0458
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0013
Permit No. NC0000752
Roanoke Rapids Mill WWTP
Halifax County
Dear Permittee:
A review of the August 2020 Discharge Monitoring Report (DMR) for the subject facility revealed the
deficiency(s) indicated below:
Sample
Location Parameter
Date Type of Deficiency
10/1/2020 Outfall 002 Missing
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Raleigh Regional Office encourages
you to take all necessary actions to bring your facility into compliance.

0 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
W61(,SD0704
100 Gaston Rd.
Roanoke Rapids,
NC 27870
NC Dept of Environmental Quality
NOV 1120
Raleigh 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.

16
In the past, on such occurrerr he 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 1OAM 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, notjust 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,
Benjamin
General Manager
Enclosures
Ket
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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ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Direnor
Mr. Benjamin White, General Manager
WestRock Kraft Paper
P.O. Box 458
Roanoke Rapids, NC 27870
NORTH CAROLINA
Environmental Quality
March 25, 2020
Subject: Compliance Evaluation Inspection
Roanoke Rapids Mill WWTP
Permit No. NC0000752
Northampton County
Dear Mr. White:
�m.
On March 11, 2020, Jason Robinson of the Raleigh Regional Office (RRO) conducted a compliance
evaluation inspection of the subject facility. The assistance provided by Mr. Christopher Williams, the
operator in responsible charge (ORC), Mr. Matthew Upton, the backup ORC, Mr. Michael Knudson,
Environmental Manager and Mr. Paul Kinnin, Environmental Technician (laboratory staff) was
appreciated as it facilitated the inspection process. The inspection report is attached. The following
observations were made:
This facility, known as Roanoke Rapids Mill WWTP and owned by Westrock Kraft Paper LLC
(formerly owned by Kapstone Kraft Paper Corporation) 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 pond, and three stabilization ponds. The sludge lagoon, aeration pond and
stabilization ponds and Outfall 001 (and on -site landfill) are located on the opposite side of the
river from the Mill. Outfall 002 discharges non -contact cooling water on the Mill -side of the
river. Both outfalls discharge directly to the Roanoke River, a Class C water in the Roanoke
River basin.
The facility also has sludge -handling facility and onsite landfill that is covered by permit
WQ0000436 (Surface Disposal of Residual Solids (503 exempt).
2. The most recent permit for the new owner was just issued and effective on March 18, 2020. The
permit will expire on April 30, 2021. A renewal application should be submitted at least 180
days prior to expiration.
3. This treatment facility is classified as a WW-4. Mr. Christopher Williams (ORC) is a certified
W W-4 operator, and Mr. Matthew Upton (bORC) is a certified W W-3 operator.
4. The ORCs maintain a detailed daily logbook. Lab results, chain -of -custody forms, and electronic
D E Q North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
s
env 'e� 919.791.4200

Roanoke Rapid W WTP — Wesuock Kraft Pape
Permit No. NC0000752
Discharge Monitoring Reports (eDMRs) were complete and current, kept in good order and
ready for review. August and October 2019 eDMR data was compared to lab bench sheets; no
data transcription errors were noted during the inspection. Parameter analyses are performed by
Meritech (Certificate # 165). Toxicity analysis is done by Environmental Testing Solutions
(Certification #37).
5. Field lab parameter calibration and analysis records were reviewed during the inspection. The
facility analyzes BOD, TSS, pH, conductivity, DO, Suspended Residue and temperature
(Certificate #183). The laboratory was inspected in a cursory manner.
6. The influent bar screens are mechanically cleaned every 8 hours. Untreated wastewater can be
routed to the emergency holding pond prior to the bar screens. All three influent pumps into the
primary clarifier were in operation. The primary clarifier was in good condition.
Sludge from the primary clarifier is pumped via two sludge pumps into a blending tank and is
then dewatered at the sludge handling facility beside the clarifier. Two trains of belt presses,
screw presses, and chemical feed systems are present. Typically train operations are alternated
between the two. Dewatered sludge is disposed at the onsite land fill across the river via truck.
Leachate from the land fill and the old sludge pond flows by gravity into the aeration pond and is
treated along with the effluent from the primary clarifier (WQ0000436).
8. Effluent from the clarifier is transported across the river via gravity and is further treated at the
aeration pond across the river. There are thirty-one 2,135 hp aerators. One was down for
maintenance during the inspection. The number of aerators on-line is controlled by the DO level
in the pond.
9. Effluent from the aeration pond is further treated in the three in -series stabilization ponds before
being discharged to the river. Samples are taken at the discharge point of the final stabilization
pond. A composite sampler was present, and temperature was just below 4 degrees. Flow is
measured and reported just prior to the discharge. The flow meter was last calibrated on July 15,
2019.
10. Outfall 001 was observed. The right of way was 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 observed from across the river (from Outall 001).
(see next page)
2of3

Roanoke Rapid WWTP— Westro A Paper
Permit No. NC0000752
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 Jason Robinson at
[e-mail]
Sincerely,
J Scott Vinson
D Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachments
Compliance Inspection Report
Cc: DWR Laserfiche -31-) as
Raleigh Regional Office w/attachment
Chris Williams, ORC: chris.m.williamsAwestrock.com
3 of 3

United States Environmental Protection Agency
Form Approved.
EPA Washington. D C 20460
OMB No. 204MO57
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 IF I 3 I NC0000752 I11 12 20/03/11 17 18LC] 191 � I 201 I
21111111111111111 11111111111111 IIIIIIUI II r6
Inspection Work Days Facility Self-Monitonng Evaluation Rating B1 CA -Reserved
67
[ ....... . J70 U 71 U 72 L1J u I 731 I 174 7 I I I I I I I I80
I I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
01:OOPM 20103111
18I09I01
Roanoke Rapids MITI WWTP
100 Gaston Rd
Exit Time/Date
Permit Expiration Date
Roanoke Rapids NC 27870
03.o0PM 20103/11
22/03/31
Names) of Onsite Representative(s)/Ttles(s)/Phone and Fax Number(s)
Other Facility Data
Christopher Michael WilliamslORC/252-533-6237/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Benjamin P White,PO Box 458 Ronok Rpd Afs NC 27870/General
Manager/252-533-6335/ Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar N Records/Reports
Sludge Handling Dispo; E 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) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Jason T Robinson, DWR/RRO WO/919-791-0200/
Signature of ManageCmeentt 0 AAReviewer Agency/Office/Phoneand Fax Numbers Date
q�.ze�.t � •`'!�/ 9�9 T %� ill �� /'�/2r l-� 1 ��ZJ
EPA Form 3560.3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NC0000752 I1 1 20/03/11 17 18 1 C 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On March 11, 2020, Jason Robinson of the Raleigh Regional Office (RRO) conducted a compliance
evaluation inspection of the subject facility. The assistance provided by Mr. Christopher Williams, the
operator in responsible charge (ORC), Mr. Matthew Upton, the backup ORC, Mr. Michael Knudson,
Environmental Manager and Mr. Paul Kinnin, Environmental Technician (laboratory staff) was
appreciated as it facilitated the inspection process. The inspection report is attached. The following
observations were made:
1. This facility, known as Roanoke Rapids Mill WWTP and owned by Westrock Kraft Paper LLC
(formerly owned by Kapstone Kraft Paper Corporation) 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 pond, and three stabilization ponds. The sludge lagoon, aeration pond and stabilization ponds
and Outfall 001 (and on -site landfill) are located on the opposite side of the river from the Mill. Outfall
002 discharges non -contact cooling water on the Mill -side of the river. Both outfalls discharge directly tc
the Roanoke River, a Class C water in the Roanoke River basin.
The facility also has sludge -handling facility and onsite landfill that is covered by permit WQ0000436
(Surface Disposal of Residual Solids (503 exempt).
2. The most recent permit for the new owner was just issued and effective on March 18, 2020. The
permit will expire on April 30, 2021. A renewal application should be submitted at least 180 days prior tc
expiration.
3. This treatment facility is classified as a WW-4. Mr. Christopher Williams (ORC) is a certified
WW-4 operator, and Mr. Matthew Upton (bORC) is a certified WW-3 operator.
4. The ORCs maintain a detailed daily logbook. Lab results, chain -of -custody forms, and electronic
Discharge Monitoring Reports (eDMRs) were complete and current, kept in good order and ready for
review. August and October 2019 eDMR data was compared to lab bench sheets: no data transcriptior
errors were noted during the inspection. Parameter analyses are performed by Meritech (Certificate #
165). Toxicity analysis is done by Environmental Testing Solutions (Certification #37).
5. Field lab parameter calibration and analysis records were reviewed during the inspection. The
facility analyzes BOD, TSS, pH, conductivity, DO, Suspended Residue and temperature (Certificate
#183). The laboratory was inspected in a cursory manner.
6. The influent bar screens are mechanically cleaned every 8 hours. Untreated wastewater can be
routed to the emergency holding pond prior to the bar screens. All three influent pumps into the
primary clarifier were in operation. The primary clarifier was in good condition.
7. Sludge from the primary clarifier is pumped via two sludge pumps into a blending tank and is then
dewatered at the sludge handling facility beside the clarifier. Two trains of belt presses, screw
presses, and chemical feed systems are present. Typically train operations are alternated between the
two. Dewatered sludge is disposed at the onsite land fill across the river via truck. Leachate from the
land fill and the old sludge pond flows by gravity into the aeration pond and is treated along with the
effluent from the primary clarifier (WQ0000436).
8. Effluent from the clarifier is transported across the river via gravity and is further treated at the
aeration pond across the river. There are thirty-one 2,135 hp aerators. One was down for maintenance
during the inspection. The number of aerators on-line is controlled by the DO level in the pond.
Page#

Permit: NC0000752
Inspection Date: 03/11/2020
Owner • Facility: Roanoke Rapids MITI WWiP
Inspection Type: Compliance Evaluation
9. Effluent from the aeration pond is further treated in the three in -series stabilization ponds before
being discharged to the river. Samples are taken at the discharge point of the final stabilization pond. f
composite sampler was present, and temperature was just below 4 degrees. Flow is measured and
reported just prior to the discharge. The flow meter was last calibrated on July 15, 2019.
10. Outfall 001 was observed. The right of way was 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 observed from across the river (from Outall 001).
Page#

Permit: NC0000752 Owner -Facility: Roanoke Rapids MITI WWTP
Inspection Date: 0311112020 Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
E
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
E
❑
❑
Is access to the plant site restricted to the general public?
N
❑
❑
❑
Is the inspector granted access to all areas for inspection?
E
❑
❑
❑
Comment
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
E
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
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 24t7 with a certified operatc
E
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
N
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification'
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Comment:
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? E ❑ ❑ ❑
Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑
Page# 4

Permit: NC0000752 Owner - Facility: Roanoke Rapids MITI WWTP
Inspection Date: 03/11/2020 Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
# Is the facility using a contract lab?
E
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
N
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/_ 0.2 degrees?
❑
❑
N
❑
Incubator (BOD) set to 20.0 degrees Celsius +/_ 1.0 degrees?
IN
❑
❑
❑
Comment:
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
0
❑
❑
❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
N
❑
❑
❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
❑
❑
❑
N
Is the basin free of bypass lines or structures to the natural environment?
❑
❑
❑
N
Is the basin free of excessive grease?
❑
❑
❑
Are all pumps present?
❑
❑
❑
0
Are all pumps operable?
❑
❑
❑
0
Are float controls operable?
❑
❑
❑
Are audible and visual alarms operable?
❑
❑
❑
# Is basin size/volume adequate?
❑
❑
❑
Comment: Flow can be diverted to the Emergency Holding Pond prior
to the bar screen.
Page# 5

Permit: NC0000752 Owner -Facility: Roanoke Rapids MIIIWWTP
Inspection Date: 03/11/2020 Inspection Type: Compliance Evaluation
Primary Clarifier
Yes
No
NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
N
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
E
❑
❑
❑
Is the drive unit operational?
E
❑
❑
❑
Is the sludge blanket level acceptable?
❑
❑
❑
E
Is the sludge blanket level acceptable? (Approximately '/. of the sidewall depth)
❑
❑
❑
0
Comment
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
E
❑
❑
❑
Is the chemical feed equipment operational?
E
❑
❑
❑
Is storage adequate?
0
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
N
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
E
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
0
❑
❑
❑
The facility has an approved sludge management plan?
0
❑
❑
❑
Comment: Sludge handling equipment and on -site landfill covered by permit WQ0000436
(Surface
Disposal of Residual Solids (503 exempt))
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
0
❑
❑
❑
Are surface aerators and mixers operational?
0
❑
❑
❑
Are the diffusers operational?
N
❑
❑
❑
Is the foam the proper color for the treatment process?
N
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
E
❑
❑
❑
Is the DO level acceptable?
0
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
0
❑
❑
❑
Page# 6

Permit: NC0000752 Owner - Facility: Roanoke Rapids MITI 1MNTP
Inspection Date: 03111t2020 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Comment:
Lagoons
Yes
No
NA
NE
Type of lagoons?
Facultative
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
# Is a re -circulation line present?
❑
M
❑
❑
Is lagoon free of excessive floating materials?
0
❑
❑
❑
# Are baffles between ponds or effluent baffles adjustable?
0
❑
❑
❑
Are dike slopes clear of woody vegetation?
0
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
0
❑
❑
❑
Are dikes free of seepage?
0
❑
❑
❑
Are dikes free of erosion?
0
❑
❑
❑
Are dikes free of burrowing animals?
M
❑
❑
❑
# 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?
❑
❑
M
❑
Is the lagoon surface free of weeds?
0
❑
❑
❑
Is the lagoon free of short circuiting?
0
❑
❑
❑
Comment: 3 stabilzation ponds in series are located after the aeration basin, and
prior to discharge.
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
M
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment:
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
M
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
M
❑
Comment:
Page# 7

WaterResources
ENVIRONMENTAL QUALITY
April 11, 2018
Mr. Benjamin White
Vice President of Mill Operation
Kapstone — Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: Compliance Evaluation Inspection
Kapstone — Kraft Paper Corporation - Roanoke Rapids Paper Mill
Permit No. NC0000752
Northampton County
Dear Mr. White:
ROY COOPER
cnven,ur
MICHAEL S. REGAN
. Secretary
LINDA CULPEPPER
Interim Director
On November 16, 2016, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a compliance
evaluation inspection of the subject facility. The assistance provided by Mr. Neal Davis, the operator in
responsible charge (ORC), Mr. Chris Williams, 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:
Kapstcme — Kraft Paper Corporation - Roanoke Rapid Paper Mill W WTP 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 pond, and three stabilization ponds. The plant discharges to Roanoke
River, a Class C water in the Roanoke River basin.
1. Current permit expired on March 31, 2017. The facility submitted permit renewal application On
September 23, 2016. A draft permit was sent to the facility for comments.
2. All three influent pumps were in operation. The primary clarifier was in good condition.
3. Sludge from the primary clarifier was dewatered at the sludge handling facility, two trains of belt
presses, screw presses, and chemical feed system were available. One train was in use at the time
of inspection, the other was off line for repair and maintenance. Dewatered sludge was disposed
at the onsite land fill. Leachate from the land fill and the old sludge pond flows by gravity into
the aeration pond and is treated along with the effluent from the primary clarifier.
4. Effluent from the clarifier was further treated at the aeration pond. All 31 aerators were in
operational condition. Numbers of aerators on line was controlled by the DO level in the basin.
Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section http://portal.ncdenr.org/web/wq/aps
1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: [phone]
Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax: [phone]

Kapstone— Kraft Paper Corporation woke Rapids Paper Mill
Permit No. NC0000752
5. Effluent from the aeration pond was further treated in the three stabilization ponds before being
discharged to the river.
6. 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. November 2017 DMR data were compared to lab bench sheets; no data transcription
errors were noted during the inspection.
7. 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.
8. Field lab parameter (Certificate No. 183) calibration and analysis records were reviewed during
the inspection.
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: [phone] (or
email: chenQ.zhang_Ancdenr.gov).
Sinceely,
Danny S ith
Water Quality Regional Supervisor
Raleigh Regional Office
Attachments
Compliance Inspection Report
Cc: Central Files w/attachment
Raleigh Regional Office w/attachment
Neal Davis — ORC w/attachment

United states Environmental Protection Agency
Form Approved.
EPA Washington. D L 20,160
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires B-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
�
IN 1 2 Ib 3 I NC0000752 I11 12 18/03/12 17 18 Li 19 1 g I 20I I
21111111 1111111 11 l l l ll 1111 l l 11111 111111111 11166
I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA Reservetl
67 70 L._.J 71 u 72 I IN I 73 f I I74 75I I I I80
I I 1 I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW also include
Entry Time/Date
Permit Effective Date
POTVV name and NPDES oermit Number)
10:OOAM 18/03/12
12/06/01
Kapstone Kraft Paper Corporation WVVrP
Exit Time/Date
Permit Expiration Date
100 Gaston Rd
Roanoke Rapid INC 27870
12.30PM 18/03/12
17/03131
Names) of Onsite Representabve(s)/Thles(syPhone and Fax Numbers)
Other Facility Data
1/1
Neal R Davis/ORC/252-533-6295/
Name, Address of Responsible OfficiaVTida/Phone and Fax Number
Contacted
Benjamin P White.PO Box 458 Roanoke Rapids INC
278700458//252-533-6335/2525336465 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit E Flow Measurement Operations 8 Maintenanc6 Records/Reports
Self -Monitoring Program E Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
%ame(s) and Signature(s) of Inspector(s) Agency/OfficelPhone and Fax Numbers Date
Chang Zhang PRO WO//919-791-02001
/g-
vyp^r''�• ��-Gt-c• �L �� t r I y0 t
$ignatu of Management A 4IR.e,,e/ Agency/Office/Phone and Fax Numb�rsf Date
EPA Form 60-3 (Rev 9.94) Previous editions are obsolete.
Page#

Permit: NC0000752. Owner • Facility: Kopstone Kraft Paper Corporation VNNrP
Inspection Date: 03/1212018 Inspection Type: Compliance Evaluabon
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? E ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: DO. TSS. pH. and conductitivity,
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
M
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
E
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: Draft permit in review
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
M
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
M
❑
❑
❑
Is the chain -of -custody complete?
E
❑
❑
❑
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?
M
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
E
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
M
❑
❑
❑
Is a copy of the current NPDES permit available on site?
E
❑
❑
❑
Page# 3

Permit: NC0000752 Owner -Facility: Kopstooe Kraft Paper Corporation VAVTP
Inspection Date: 03112i2010 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑
Comment:
Effluent Pipe
Yes No NA NE
Is right of way to the ouffall properly maintained?
N
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: Right of way to both Outfall 001 and 002 was maintained properly.
Flow Measurement - Influent
Yes No NA NE
# Is Flow meter used for reporting?
0
❑
❑
❑
Is Flow meter calibrated annually?
N
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment: Meter was calibrated on August 17 2017
Solids Handling Equipment
Yes No NA NE
Is the equipment operational?
0
❑
❑
❑
Is the chemical feed equipment operational?
E
❑
❑
❑
Is storage adequate?
0
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
0
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
0
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
0
❑
❑
❑
The facility has an approved sludge management plan?
0
❑
❑
❑
Comment: Two rotary screen thickeners and two screw presses. One of each was off line for
maintenance.
Chemical Feed
Yes
No NA NE
Is containment adequate?
0
❑
❑
❑
Is storage adequate?
E
❑
❑
❑
Are backup pumps available?
0
❑
❑
❑
Is the site free of excessive leaking?
E
❑
❑
❑
Comment: Defoamer fed to effluent and aeration basin Surfaric acid (pHl hydrogen peroxide
(hydrogen sulfide control) and polymer fed to primary clarifier sludge
Page# 4

Permit: H00000L2 Owner -Facility: Kapstone Kraft Paper Corporation NMfrP
Inspection Date: 03,12�2018 Inspection Type: Compliance Evaluation
Pump Station - Influent
Yes No NA NE
Is the pump wet well free of bypass lines or structures?
M
❑
❑
❑
Is the wet well free of excessive grease?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
M
❑
❑
❑
Are Float controls operable?
M
❑
❑
❑
Is SCADA telemetry available and operational?
0
❑
❑
❑
Is audible and visual alarm available and operational?
M
❑
❑
❑
Comment: Three pumps controled by SCADA Overflow channel to emergency pond
20.4 acre
emergency pond holds 28 million gallons of waste water under emergency
situations such
as Power failure mechanical problems or high strength waste
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
M
❑
❑
❑
Is the unit in good condition?
M
❑
❑
❑
Comment: Screen runs on timer
Primary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?.
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
M
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
M
❑
❑
❑
Is the sludge blanket level acceptable?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately '/4 of the sidewall depth)
M
❑
❑
❑
Comment
Page# 5

Permit: NC0000752
Inspection Dale: 03/12/2018
Aeration Basins
Mode of operation
Type of aeration system
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 ni
owner - Facility: Kapstone Waft Paper Corporation VJwrP
Inspection Type: Compliance Evaluation
Yes No NA NE
Ext. Air
Surface
■
❑
❑
❑
■
❑
❑
❑
E
❑
❑
❑
■
❑
❑
❑
❑
❑
❑
Comment: All 31 surface aerators were functional Number of aerators online is controlled by
the DO
sensor in the basin DO level at the channel to first stabilization pond ranges from
0.5 to 4
mq/I.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
E
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
N
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
0
❑
❑
❑
Comment:
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
0
❑
❑
Is sample collected below all treatment units?
N
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
E
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
N
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
N
❑
❑
❑
representative)?
Comment: Fixed time fixed volume composite samplin
Influent Sampling Yes No NA NE
Page# 6

Permit: nM0000752 Owner -Facility: Kapstone Kraft Paper Corporation WvViP
Inspection Date: 03, 122018 Inspection Type: Compliance Evaluation
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional?
❑
0
❑
❑
Is sample collected above side streams?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
M
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
Is sampling performed according to the permit?
M
❑
❑
❑
Comment: Fixed time fixed volume composite sampling no influent flow meter.
Lagoons
Yes No NA NE
Type of lagoons?
Facultative
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
# Is a re -circulation line present?
❑
❑
0
❑
Is lagoon free of excessive floating materials?
0
❑
❑
❑
# Are baffles between ponds or effluent baffles adjustable?
❑
❑
0
❑
Are dike slopes clear of woody vegetation?
0
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
M
❑
❑
❑
Are dikes free of seepage?
0
❑
❑
❑
Are dikes free of erosion?
0
❑
❑
❑
Are dikes free of burrowing animals?
0
❑
❑
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
M
❑
❑
❑
locations?
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
0
❑
Is the lagoon surface free of weeds?
0
❑
❑
❑
Is the lagoon free of short circuiting?
M
❑
❑
❑
Comment: 1/5 of the first stabilization pond is dredged every Year
Page# 7

Region;....ispectors' Checklist for Fif __ Parameters
t-acun Name: e_ r 2r // Regional Plant Inspector: Gtid� -ail
NPDES #: c Do0p7 —'2_ Regional Inspector Contact #: q if —7 fr — *is-�
Field Lab Certification #: / Region: �7 ¢ =S. L,
Lab Contact: &j / k,'n ; n Date: 3 / ( Z / J-o IT
I. Check the parameter(s) performed at this site for reporting purposes.
❑ Total Residual Chlorine (TRC) ® Temperature (TEMP) ® Specific Conductivity (SC)
® pH m Dissolved Oxygen (DO) ❑ Settleable Residue (SETT)
II. General Laboratory Innta anv nreantinne in enrfinn Yn
Are instruments, meters, probes, photometric cells, etc. maintained in good condition?
Are standards, reagents and consumables used within manufacturer expiration dates?
RC gel standard is exem t.
I El Yes ❑ No
® Yes ❑ No
Are the following items documented where a licable
Item
TRC
plFL
TEMP
DO
SC
SETT
Date of sample collection*
X
JC
Time of sample collection*
X
pC
X
x
Sample collector's initials or signature
X
Y_
�c
Date of sample analysis*
Time of sample analysis*
)L
Analyst initials or signature
�(
X
Sam le location
yc
y�
X
.... .— I-- `^ .... aI lu of laiysis may Ve me same Tor in siru or on -site measurements.
III. Total Residual Chlorine
Total Residual Chlorine meter make and model:
Is a check standard analyzed each day of use? Circle one: gel or liquid standard
❑ Yes
❑ No
What is the assigned/observed value of the daily check standard?
Is a 5-point calibration verificationperformed? Note date of last verification:
❑ Yes
❑ No
Alternatively, does the lab construct a linear regression, using 5 standards, to calculate
results? Note date of last calibration curve constructed:
❑ Yes
❑ No
True values: ❑ Ng/L ❑ mg/L
Obtained values: ❑ pg/L ❑ mg/L
What program are samples analyzed on?
Are results reported in proper units? Check one: /L ❑ m /L
❑ Yes
❑ No
Are results reported between the facility's permit limit and the compliance limit of 50 pg/L?
If value is less than the low standard, report as "<x", where x=low standard conc.
❑ Yes
❑ No
Are samples analyzed within 15 minutes of collection?
❑ Yes
❑ No
IV. pH
pH meter make and model: OR/ON —STAR H eQ 2-8 /d )
Is the pH meter calibrated with at least 2 buffers per mfg's instructions each day of use?
Note buffers used: q_ 7 , 1 D
M Yes
❑ No
Is the pH meter calibration checked with an additional buffer each day of use? Note check
buffer used: 7
Yes
❑ No
Does the check buffer read within t0.1 S.U. of the known value?
Yes
❑ No
Are the following items documented:
Meter calibration?
Yes
❑ No
Check buffer reading?
® Yes
❑ No
Are samples anal ed within 15 minutes of collection?
® Yes
❑ No
Are sample results reported to 0.1 pH units?
FA Yes
❑ No

V. Temperature
What instrument(s) is used to measure temperature? Check all that apply: ❑ pH meter
❑ DO meter ❑ Conductivity meter ® Digital thermometer ❑ Glass thermometer
Is the instrument/thermometer calibration checked at least annually against a NIST
traceable or NIST certified thermometer? f ural,,6,rcc A04,V /►,a_{a,�a,. -7.4 ill
Yes ❑ No
Are temperature, corrections even if zeroposted on the instrument/thermometer?
® Yes ❑ No
Are samples measured in situ or on -site? [REQUIRED - there is no holding time for
temperature]
M Yes ❑ No
Are sample results reported in degrees C?
91 Yes ❑ No
VI. Dissolved Oxygen
DO meter make and model: V. S :' — r -o
-Is theair-calibration of -the -DO meter rformed-each day -of use? -- -- —
® Yes ❑ No
Are the following items documented:
Meter calibration?
® Yes ❑ No
Are samples analyzed within 15 minutes of collection?
Yes ❑ No
Are results reported in m /L?
© Yes
❑ No
VII. Conductivity
Conductivity meter make and model: OA1,OV I STAR, /3 2 5
Is the meter calibrated daily according to the manufa urer's instructions? Note standard
used this is generallya one -point calibration): o o /brt'rn o,C s /C,„
Yes
❑ No
Is a daily check standard analyzed? Note value: ,_-O J ^»I s / c M
® Yes
❑ No
Are the following items documented:
Meter calibration?
® Yes
❑ No
Are samples anal zed within 28 days of collection?
❑X Yes
❑ No
Are results reported in mhos/cm some meters display equivalent S/cm units)?
Yes
❑ No
Vill. Settleable Residue
Does the laboratory have an Imhoff Cone in good condition?
❑ Yes
❑ No
Is the sample settled for 1 hour?
❑ Yes
❑ No
Is the sample aitated after 45 minutes?
❑ Yes
❑ No
Are the following items documented:
Volume of sample analyzed? Note volume analyzed:
❑
Yes
❑
No
Date and time of sample analysis(settling start time)?
❑
Yes
❑
No
Time of agitation after 45 minutes of settling?
❑
Yes
❑
No
Sample analysis completion(settling end time)?
❑
Yes
❑
No
Are samples analyzed within 48 hours of collection?
❑
Yes
❑
No
Are results reported in ml/L?
❑
Yes
❑
No
IX. Was a paper trail (comparing contract lab and on -site data to DMR)
_ performed? If so, list months reviewed: 11 / so i
® Yes
❑ No
X. Is follow-up by the Laboratory Certification program recommended?
❑ Yes
No
XI. Additional comments:
l3r, laah a- pa-c-e,-'z/ z3 i -,—o I
Please submit a copy of this completed form to the Laboratory Certification program at:
DWQ Lab Certification, Chemistry Lab, Courier # 52-01-01
Electronic copies may be emailed to Iinda.chavis(c�ncdenr.gov.
Revision 04/20/2012

WarerResources
ENVIRONMENTAL QUALITY
January 23, 2018
Mr. Neal Davis
Kapstone Kraft Paper Corp
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: Bioassay Compliance Evaluation Inspection
Whole Effluent Toxicity Test
Kapstone Kraft Paper Corporation WWTP
NPDES Permit No: NC0000752/001
1laiifax County
N PIAA^tvj�r10
Dear Mr. Davis:
kuii ��vrca
Governor
MICHAEL S. REGAN
secretary
LINDA CULPEPPER
Intenm Dmdw
Whole Effluent samples were collected from Kapstone Kraft Paper Corporation W WTP on December 5
and December 7, 2017 by Cheng Zhang of Division of Water Resource (DWR), Raleigh Regional
Office. These samples were for use in a chronic Cer•iodaphnia dubia pass -fail toxicity test, which was
performed by the staff at DWR Aquatic Toxicity Branch. This test passed for the toxicity inspection.
Toxicity test information follows.
Test Type 3-Brood Ceriodaphnia dubia chronic pass fail
Test Concentration 3.7%
Test Result Pass (for Toxicity Inspection)
If you have any questions regarding the attached report or any of the findings, please contact Cheng
Zhang at: [phone] (or email: chene zhangQncdenr.gov).
h
Water Quality Regional Supervisor
Raleigh Regional Office
Attachments: Compliance Inspection Report
Cc: Central Files w/attachment
Raleigh Regional Office w/attachment
Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section http://poilal.nedenr.orwweb!wq/aps
1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: [phone]
Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax: [phone]

Urmed States Enwonmental Protection Agency
Approved.
EPA wasmngton D.0 20e60
No. 204MO57
F'i-PM-PB'-val
Water Compliance Inspection Report
expires 8-31-98
Section A. National Data System Coding (i.e., PCs)
Transaction Code NPDES ynmo/day inspection Type
Inspector Fee Type
1 U 2 15 I 3 I NC0000752 I11 12 171l2/05 17 16 I o I
19 I q J 20I I
211 11 IIIIIII1III I II IIII I II(III IIIIIlUl
l l f6
Inspection Work Days Facility Self -Monitoring Evaluation Rating Bt CA
Reserved
67L I 70 L71 n 72LtiJ 731 I 174 75
I I I I SO
Section 9: Facility Data
Name and Location of Facility Inspected (For Industnal Users discharging to POTW, also include
Entry Time(Date
Permit Effective Dale
POTW name and NPDES oennd Number)
10 30AM 17/12/05
12IG6101
Kapstone Kraft Paper Corporation WWfP
100 Gaston Rd
Exit Time)Date
Permit Expiration Dale
Roanoke Rapid NC 27870
11.00AM 17/12105
17/03/31
Names) of Onsite Representative(syTitles(s)/Phone and Fax Number(s)
Other Facility Data
Neal R Davts/ORC/252-533-6295/
Name, Address of Responsible Official/Titte/Phone and Fax Number
Contacted
Benjamin P White,PO Box 458 Roanoke Rapids NC
278700458//252-533-6335/2525336465 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(a) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
Date
Chang Zhang RRO WOI/919-7914200/
Si nalu of Management Reviewer Ag cy/Office/Phone and Fax N tubers
Date
r
Z��
G✓�
EPA Form 3 -3 (Rev 9-94) Previous editions are ob.olete.
Page#
a

NPDES ynmo/day Inspection Type
31 NCO000762 I11 12 17112/05 17 18 U
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Two 24-hour composite effluent samples were collected on December 5, and December 7,
2017,respectively. Ceriodaphnia dubia chronic pass/fail test was performed at Division of Water
Resources' Aquatic Toxicity Branch, the result of the test was PASS.
Page#