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Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Colleen 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:
A117-;r/
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,
Z�I-j
Coleen H. Sullins
Cc: NPDES Files
Raleigh Regional Office - Surface Water Protection
Aquatic Toxicology Unit
EPA Region 4
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Internet h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Alfimutive Action Employer-50 % Recyc"10% Post Consumer Paper
tCmlina
rldy
Customer Service
1-877-623-6748

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, 11, 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.
Z i Z� -4 2 �--
Coleen H. Su-
llins, Dir for
Division of Water Quality
By Authority of the Environmental Management Commission

i.���LKIZ�PI�TiF�S+a
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 aY 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.
7

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Kapstone Kraft Paper Corp.- NC0000752
Facility
Location &,
USGS Quad Number: B28NW
Lat.: 36028'19"
Receiving Stream: Roanoke River
Long.: 77038'14"
Stream Class: C
Subbasin: Roanoke, 03-02-08
SCALE 1:24,000
North
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:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REOUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
28.0 MGD
Continuous
Recorder
I or E
BOD, 5 day, 202C
6,852 lbs/day
13,704 lbs/day
Dail
Composite
E
Total Suspended Solids
15,576 lbs/day
31,152 Ibs/da
Dail
E
Dissolved O en
Dail
-Composite
Grab
E, U, D
Temperature
Dail
Grab
E, U, D
ConductivityDail
Grab
E, U, D
N113 as N
Monthly
Composite
E
Total Nitrogen NO2+NO3+TKN
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Chronic Toxici
Quarterly
Composite
E
Total Copper'
Quarterly
Composite
E
H
6.0 - 9.0 standard units
Dail
Grab
E
Pentachloro heno
1.51 l6s/day
Weekly
Grab
E
Trichlorophenol
1.38lbs/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.
0

rermit NC0000752
A. (2) EFFLUENT LIMIT, ..*jNS 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
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 uisible foam in other than trace amounts.

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
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
a
Daily
Maximum
Measurement
Fre uenc
Sample
T e
Sample Location
Flow
jAvera
Semi-annual)
Estimate
Effluent
Tem erature `C
ee note 1
See note 1
Semi-annually
Grab
Effluent
pH
6.0 - 9.0 standard units'
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.

. ermit 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 dubfa at an effluent concentration of 3.7%.
The permit holder shall perform at a minimum,guarterlu 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 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 THP313 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 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.

"S Permit Standard Conditions
Page 1 of 16
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events.
3/Week
Samples are collected three times per week on three separate calendar days.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC 1251, et. seq.
Annual AvereQe
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
colifonn, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
13 as
The known diversion of waste streams from any portion of a treatment facility including the collection system, which
is not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the nest day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 ml in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time
interval between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically.
Composite samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour
period of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period
with the time intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow recorder and
totalizer, and the preset gallon interval between sample collection fixed at no greater than 1/24 of the
expected total daily flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at
a constant time interval. This method may only be used in situations where effluent flow rates vary
less than 15 percent. The grab samples shall be taken at intervals of no greater than 20 minutes apart
during any 24-hour period and must be of equal size and of no less than 100 milliliters. Use of this method
requires prior approval by the Director.

NPDES Permit Standard Conditions
Page 2 of 16
In accordance with (4) above, influent grab samples shall not be collected more than once per hour.
Effluent grab samples shall not be collected more than once per hour except at wastewater treatment systems
having a detention time of greater than 24 hours. In such cases, effluent grab samples may be collected at
intervals evenly spaced over the 24-hour period that are equal in number of hours to the detention time of the
system in number of days. However, the interval between effluent grab samples may not exceed six hours nor
the number of samples less than four during a 24-hour sampling period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. The "daily discharge" concentration comprises the mean
concentration for a 24-hour sampling period as either a composite sample concentration or the arithmetic mean of all
grab samples collected during that period. (40 CFR 122.2)
Daily Maximum
The highest "daily discharge" for conventional and other non -toxicant parameters. NOTE: Permittees may not
submit a "daily average" calculation [for determining compliance with permit limits] for toxicants. See the relevant
Federal effluent guideline[s] for the appropriate calculation interval.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit The Division expects that sampling shall be conducted on weekdays except where holidays or other
disruptions of normal operations prevent weekday sampling. If sampling is required for all seven days of the week
for any permit parameter(s), that requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWO or "the Division"
The Division of Water Quality, Department of Environment and Natural Resources.
EMC
The North Carolina Environmental Management Commission.
Facility Closure
The cessation of wastewater treatment at a permitted facility, or the cessation of all activities that require coverage
under the NPDES. Completion of facility closure will allow this permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level)') shall be considered = L
Grab Sample
Individual samples of at least 100 ml collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
Instantaneous flow measurement
A measure of flow taken at the time of sampling, when both the sample and flow will be representative of the total
discharge.
Version 6/l/2006

Permit Standard Conditions
Page 3 of 16
Monthly Av,Me (concentration limit
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration limit)
The average of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable,
or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Averagg(concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week In the case of fecal
coliform, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Pennittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation
of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under
section 405(d) of the Clean Water Act within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet been
modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates section 301, 302, 306, 307, 308, 318 or 405 of the
Act, or any permit condition or limitation implementing any such sections in a pemut issued under section
402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8)
of the Act, is subject to a civil penalty not to exceed $25,000 per day for each violation. [40 CFR 122.41 (a)
(2)]
c. The Clean Water Act provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or
405 of the Act, or any condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, or any requirement imposed in a pretreatment program approved under section
402(a)(3) or 402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a
negligent violation, a person shall be subject to criminal penalties of not more than $50,000 per day of
violation, or by imprisonment of not more than 2 years, or both. [40 CFR 122.41 (a) (2)]

NPDES Permit Standard Conditions
Page 4 of 16
d. Any person who knorame violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In
the case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[40 CFR 122.41 (a) (2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act,
and who knows at that time that he thereby places another person in imminent danger of death or serious
bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not
more than 15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment
violation, a person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than
30 years, or both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction
of violating the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined
up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41 (a) (2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such
sections in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are
not to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$25,000. Penalties for Class II violations are not to exceed $10,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $125,000. [40 CFR
122.41 (a) (3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to mi imie or prevent any discharge or sludge use or disposal in
violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment
[40 CFR 122.41 (d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on 'Bypassing" (Part H. C. 4), "Upsets" (Part II. C. 5) and "Power
Failures" (Part II. C. 7), nothing in this permit shall be construed to relieve the Permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309
of the Federal Act, 33 USC 1319. Furthermore, the Permittee is responsible for consequential damages, such as
fish kills, even though the responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor
any infringement of Federal, State or local laws or regulations [40 CFR 122.41 (g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
7. Severability
Version 8i12006

1 mermit Standard Conditions
Page 5 of 16
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS 150B-23].
8. Duty to Provide Information
The Permittee shall famish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit The Permittee shall also furnish to the
Permit Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41 (b)].
9. Duty to Reapnly
I£ the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41 (b)].
10. E_px mta Lon of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Permittee shall submit such information, forms, and
fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date.
Any Permittee that has not requested renewal at least 180 days prior to expiration, or any Permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will subject
the Permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et seq.
11. Simmatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified
[40 CFR 122.41 (k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in
charge of a principal business function, or any other person who performs similar policy or decision
making functions for the corporation, or (b) the manager of one or more manufacturing, production, or
operating facilities, provided, the manager is authorized to make management decisions which govern the
operation of the regulated facility including having the explicit or implicit duty of making major capital
investment recommendations, and initiating and directing other comprehensive measures to assure long
team environmental compliance with environmental laws and regulations; the manager can ensure that
the necessary systems are established or actions taken to gather complete and accurate information for
permit application requirements; and where authority to sign documents has been assigned or delegated
to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively, or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or
tanking elected official [40 CFR 122.22).
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
1. The authorization is made in writing by a person described above;
2. The authorization specified either an individual or a position having responsibility for the overall
operation of the regulated facility or activity, such as the position of plant manager, operator of a well or
well field, superintendent, a position of equivalent responsibility, or an individual or position having
overall responsibility for environmental matters for the company. (A duly authorized representative may
thus be either a named individual or any individual occupying a named position.); and
3. The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate
because a different individual or position has responsibility for the overall operation of the facility, a new
authorization satisfying the requirements of paragraph (b) of this section must be submitted to the Director
prior to or together with any reports, information, or applications to be signed by an authorized
representative [40 CFR 122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the
following certification [40 CFR 122.221:
'I 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. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.'
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition [40 CFR 122.41 (0].
13. Permit Modification. Revocation and Reissuance or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the
permit, revoking and reissuing the petmit, or terminating the permit as allowed by the laws, rules, and regulations
contained m Title 40, Code of Federal Regulations, Pars 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et_ a1
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 21-1.0105 (b) (2)
may cause this Division to initiate action to revoke the permit
Section C. Operation and Maintenance of Pollution Controls
Certified Operator
Upon classification of the permitted facility by the Certification Commission, the Permittee shall employ a
certified water pollution control treatment system operator in responsible charge (ORC) of the watts pollution
control treatment system. Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the water pollution control treatment system by the Certification Commission. The
Permittee must also employ one or more certified Back-up ORCs who possess a currently valid certificate of the
type of the system. Back-up ORCs must possess a grade equal to (or no more than one grade less than) the grade
of the system [15A NCAC 8G.0201].
The ORC of each Class I facility must
➢ Visit the facility at least weekly
➢ Comply with all other conditions of 15A NCAC 8G.0204.
The ORC of each Class II, III and IV facility must:
➢ Visit the facility at least five days per week, excluding holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 8G.0204.
Once the facility is classified, the Permittee shall submit a letter to the Certification Commission designating the
operator in responsible charge:
a. Within 60 calendar days prior to wastewater being introduced into a new system
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b. Within 120 calendar days of
➢ Receiving notification of a change in the classification of the system requiring the designation of a
new ORC and back-up ORC
➢ A vacancy in the position of ORC or back-up ORC.
2. Proper Operation and Maintenance
The Permittee shall at all times provide the operation and maintenance resources necessary to operate the existing
facilities at optimum efficiency. The Permittee shall at all times properly operate and maintain all facilities and
systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the Permittee to install
and operate backup or auxiliary facilities only when necessary to achieve compliance with the conditions of the
permit [40 CFR 122.41 (e)].
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41
(c)]-
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41 (m) (2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice (40 CFR 122.41 (m) (3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior
notice, if possible at least ten days before the date of the bypass; including an evaluation of the
anticipated quality and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II. E. 6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(I) of this section.
5. D se
a. Effect of an upset [40 CFR 122 41 (n) (2)]: An upset constitutes an affirmative defense to an action
brought for noncompliance with such technology based permit effluent limitations if the requirements of
paragraph b. of this condition are met No determination made during administrative review of claims that
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noncompliance was caused by upset, and before an action for noncompliance, is final administrative action
subject to judicial review.
b. Conditions necessary for a demonstration of upset A Permittee who wishes to establish the
affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or
other relevant evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II. E. 6. (b) of this permit.
(4) The Pemnittee complied with any remedial measures required under Part II. B. 2. of this permit
c. Burden of proof [40 CFR 122.41 (n) (4)]: The Permittee seeking to establish the occurrence of an
upset has the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States. The Permittee
shall comply with all existing Federal regulations governing the disposal of sewage sludge. Upon promulgation of
40 CFR Part 503, any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR 503. The
Pennittee shall comply with applicable 40 CFR 503 Standards for the Use and Disposal of Sewage Sludge (when
promulgated) within the time provided in the regulation, even if the permit is not modified to incorporate the
requirement The Pemtittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by L5A NCAC 21-1.0124 —
Reliability) to prevent the discharge of untreated or inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period the sample represents. All samples shall be taken at the
monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted
by any other wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority [40 CFR 122.41 G)].
2. Rektorting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR I, 1.1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period
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. Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the following address:
NC DENR / Division of Water Quality / Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per ,year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation -
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Pan I
of this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to
NCGS 143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to
Section 304(p), 33 USC 1314, of the Federal Water Pollution Control Act (as Amended), and 40 CFR 136; or in
the case of sludge use or disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum
detection and reporting levels that are below the permit discharge requirements and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge requirements,
then the most sensitive (method with the lowest possible detection and reporting level) approved method must
be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by
a fine of not more than $10,000 per violation[, or by imprisonment for not more than two years per violation, or
by both. If a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more
than 4 years, or both [40 CFR 122.411.
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge
use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40
CFR 503), the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122 41).
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record
the following information (40 CFR 122.411:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
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e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Pertnittee shall allow the Director, or an authorized representative (including an authorized contractor acting
as a representative of the Director), upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the Permittee's premises where a regulated facility or activity is located or conducted, or where
records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the Clean Water Act, any substances or parameters at any location [40 CFR 122.41 (i)].
Section E Reporting Requirements
Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit The discharge
of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall
constitute a violation of the permit
2. Planned Changes
The Pemmittee shall give notice to the Director as soon as possible of any planned physical alterations or
additions to the permitted facility [40 CFR 122.410)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the pemtit, nor to
notification requirements under 40 CFR 122.42 (a) (1).
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices,
and such alteration, addition or change may justify the application of permit conditions that are different
from or absent in the existing permit, including notification of additional use or disposal sites not reported
during the permit application process or not reported pursuant to an approved land application plan.
3. Antidpated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.410) (2)].
4. Transfers
This pemtit is not transferable to any person except after notice to the Director. The Director may require
modification or revocation and reissuance of the permit to document the chi of ownership. Any such action
may incorporate other requirements as may be necessary under the Clean Water Act [40 CFR 122.41 (1) (3)].
S. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41 (1) (4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II. D. 2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR
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6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written
submission shall contain a description of the noncompliance, and its cause; the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance [40 CFR 122.41 (1) (6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II. E. 5 and 6. of this permit at
the time monitoring reports are submitted. The reports shall contain the information listed in Part II. E. 6. of
this permit [40 CFR 122.41 (1) (7)].
B. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit
such facts or information [40 CFR 122.410) (8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following.
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester, the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to receiving
waters without treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division. As required by the Act, effluent data shall not be considered confidential Knowingly making
any false statement on any such report may result in the imposition of criminal penalties as provided for in
NCGS 143-2151(b)(2) or in Section 309 of the Federal Act
11. Penalties for Falsification of Retorts
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit, including
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not more than $25,000 per violation, or by imprisonment for not more than two years per violation, or by both
140 CFR 122.41].
12. Annual Performance Reports
Pernittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.IC).
The report shall summarize the performance of the collection or treatment system, as well as the extent to which
the facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality.
The report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon
which annual period is used for evaluation.
PART III
OTHER REQUIREMENTS
Section A. Construction
The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an
Authorization to Construct (AtC) permit Issuance of an AtC will not occur until Final Plans and Specifications for
the proposed construction have been submitted by the Permittee and approved by the Division.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122A2):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 pg/L) for acrolem and acrylonitrile; five hundred micrograms
per liter (500 µg/L) for 2.4-dinitrophenol and for 2-methyl-4.6-dinitrophenol; and one milligram per liter
(I mg/L) for antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels";
0) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter 0 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
The Permittee shall evaluate all wastewater disposal alternatives and pursue the most environmentally sound
alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with the tetras
and conditions of the NPDFS permit or governing Hiles, regulations or laws, the Permittee shall submit a report in
such form and detail as required by the Division evaluating these alternatives and a plan of action within 60 days of
notification by the Division.
Section E. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system
covered by this permit. The Division may require specific measures during deactivation of the system to prevent
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adverse impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit
continue at the permitted facility.
PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Publicly Owned Treatment Works (POTWs)
All POTWs must provide adequate notice to the Director of the following:
1. Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to
section 301 or 306 of CWA if it were directly discharging those pollutants; and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger
as influent to that POTW at the time of issuance of the permit
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of
effluent introduced into the POTW, and (2) any anticipated impact of the change on the quantity or quality
of effluent to be discharged from the POTW.
Section B. Municipal Control of Pollutants from Industrial Users
1. Effluent limitations are listed in Part I of this permit Other pollutants attributable to inputs from
industries using the municipal system may be present in the Permittee's discharge. At such time as
sufficient information becomes available to establish limitations for such pollutants, this permit may be
revised to specify effluent limitations for any or all of such other pollutants in accordance with best
practicable technology or water quality standards.
2. Under no circumstances shall the Permittee allow introduction of the following wastes in the waste
treatment system:
a. Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a dosed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees
Centigrade using the test methods specified in 40 CFR 261.21;
b. Pollutants which will cause corrosive structural damage to the POTW', but in no case Discharges
with pH lower than 5.0, unless the works is specifically designed to accommodate such Discharges;
C. Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW
resulting in Interference;
d. Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow
rate and/or pollutant concentration which will cause Interference with the POTW;
e. Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in
no case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C
(104°F) unless the Division, upon request of the POTW, approves alternate temperature limits;
£. Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
cause interference or pass through;
g. Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a
quantity that may cause acute worker health and safety problems;
h. Any trucked or hauled pollutants, except at discharge points designated by the POTW.
3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the
Permittee to supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to
ensure compliance by the Permittee with all applicable effluent limitations. Such actions by the Permittee
may be necessary regarding some or all of the industries discharging to the municipal system.
4. The Permitter shall require any industrial discharges sending influent to the permitted system to meet
Federal Pretreatment Standards promulgated in response to Section 307(b) of the Act Prior to accepting
wastewater from any significant industrial user, the Permittee shall either develop and submit to the
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Division a Pretreatment Program for approval per 15A NCAC 2H .0907(a) or modify an existing
Pretreatment Program per 15A NCAC 2H .0907(b).
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved
POTW Pretreatment Program or to include a compliance schedule for the development of a POTW
Pretreatment Program as required under Section 402(b)(8) of the Clean Water Act and implementing
regulations or by the requirements of the approved State pretreatment program, as appropriate.
Section C. Pretreatment Programs
Under authority of sections 307(b) and (c) and 402(b)(8) of the Clean Water Act and implementing regulations 40
CFR Part 403, North Carolina General Statute 143-215.3 (14) and implementing regulations 15A NCAC 2H
.0900, and in accordance with the approved pretreatment program, all provisions and regulations contained and
referenced in the Pretreatment Program Submittal are an enforceable part of this permit.
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the Clean
Water Act, the Federal Pretreatment Regulations 40 CFR Part 403, the State Pretreatment Regulations 15A
NCAC 2H .0900, and the legal authorities, policies, procedures, and financial provisions contained in its
pretreatment program submission and Division approved modifications there of. Such operation shall include
but is not limited to the implementation of the following conditions and requirements:
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program.
2. Industrial Waste Survey (IWS)
The Permittee shall update its Industrial Waste Survey (IWS) to include all users of the sewer collection
system at least once every five years.
3. Monitoring Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific
data to be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of
specific pretreatment local limits. Effluent data from the Plan shall be reported on the DMRs (as required
by Part II, Section D, and Section E.S.).
4. Headworks Analysis A) and Local Limits
The Permittee shall obtain Division approval of a Headworks Analysis (HWA) at least once every five
years, and as required by the Division. Within 180 days of the effective date of this permit (or any
subsequent permit modification) the Permittee shall submit to the Division a written technical evaluation
of the need to revise local limits (ie., an updated HWA or documentation of why one is not needed) 140
CFR 122.44). The Permittee shall develop, in accordance with 40 CFR 403.5(c) and 15A NCAC 2H .0909,
specific Local Limits to implement the prohibitions listed in 40 CFR 403.5(a) and (b) and 15A NCAC 2H
.0909.
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all significant industrial users, permits for
operation of pretreatment equipment and discharge to the Permittee's treatment works. These permits
shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control
technologies to assure that their wastewater discharge will meet all applicable pretreatment standards and
requirements. The Petmittee shall maintain a current Allocation Table (AT) which s+m*r ni es the results
of the Headworks Analysis (HWA) and the limits from all Industrial User Pretreatment Permits (IUP).
Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA.
Version 8/12006

i Permit Standard Conditions
Page 15 of 16
6. Authorization to Construct (A jQ
The Permittee shall ensure that an Authorization to Construct pemhit (AtC) is issued to all applicable
industrial users for the construction or modification of any pretreatment facility. Prior to the issuance of
an AtC, the proposed pretreatment facility and treatment process must be evaluated for its capacity to
comply with all Industrial User Pretreatment Permit (IUP) limitations.
POTW Inspection & Monitoring of their SIUs
The Permitter shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by industrial
users, compliance with applicable pretreatment standards. The Permittee must
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year, and
b. Sample all Significant Industrial Users (SIUs) at least twice per calendar year for all permit -
limited pollutants, once during the period from January 1 through June 30 and once during the
period from July 1 through December 31, except for organic compounds which shall be sampled
once per calendar year,
8. SIU Self Monitoring and RRepporting
The Permittee shall require all industrial users to comply with the applicable monitoring and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit,
or in 15A NCAC 2H .0908.
9. Enforcement Response Plan)
The Pemtittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the Clean Water Act (40 CFR 405 et. seq.), prohibitive
discharge standards as set forth in 40 CFR 403.5 and 1SA NCAC 2H .0909, and specific local limitations.
All enforcement actions shall be consistent with the Enforcement Response Plan (ERP) approved by the
Division.
10. Pretreatment Annual Reports (PART
The Pennittee shall report to the Division in accordance with 15A NCAC 2H .0908. In lieu of submitting
annual reports, Modified Pretreatment Programs developed under 15A NCAC 2H .0904 (b) may be
required to meet with Division personnel periodically to discuss enforcement of pretreatment requirements
and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual
Report (PAR) describing its pretreatment activities over the previous twelve months to the Division at the
following address:
NC DENR / DWQ / Pretreatment Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
These reports shall be submitted according to a schedule established by the Director and shall contain the
following.
aj Narrative
A brief discussion of reasons for, status of, and actions taken for all Significant Industrial
Users (SIUs) in Significant Non -Compliance (SNC);
b.) Pretreatment Program Summary =
A pretreatment program summary (PPS) on specific forms approved by the Division;
c.) SSumWmt Non -Compliance Report ($NCR)
The nature of the violations and the actions taken or proposed to correct the violations on
specific forms approved by the Division;
d) Industrial Data Somma'v Forms ( )SZ
Version 8rI)M

NPDF,S Permit Standard Conditions '
Page 16 of 16 -
Monitoring data from samples collected by both the POTW and the Significant Industrial
User (SIU). These analytical results must be reported on Industrial Data Summary Forms
(IDSF) or other specific format approved by the Division;
e.) Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules,
public notice of SIUs in SNC, and any other information, upon request, which in the
opinion of the Director is needed to determine compliance with the pretreatment
implementation requirements of this pemvt;
11. Public Notice
The Permittee shall publish annually a list of Significant Industrial Users (SIUs) that were in Significant
Non -Compliance (SNC) as defined in the Permittee's Division -approved Sewer Use Ordinance with
applicable pretreatment requirements and standards during the previous twelve month period. This list
shall be published within four months of the applicable twelve-month period.
12. Record Keeoine
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along
with support information including general records, water quality records, and records of industrial impact
on the POTW.
13. Funding and Financial Report
The Permittee shall maintain adequate funding and staffing levels to accomplish the objectives of its
approved pretreatment program.
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits
modifications, POTW monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan
modifications, shall be considered a permit modification and shall be governed by 15 NCAC 2H .0114 and
15A NCAC 2H .0907.

Romanski, Autumn
From: Puryear, Chris[[e-mail]]
Sent: Monday, February 11, 20134:00 PM
To: Romanski, Autumn
Subject: Defoamer name change
Attachments: Defoamer Foamtrol AF3560 (2).pdf; Defoamer Advantage NF417 MSDS (2).pdf
Ms. Romanski,
Attached you will find two MSDS for defoamer. The GE/Betz Foamtrol AF3560 is what we are presently using to
suppress foam in our final effluent discharge. The second MSDS is for Ashland Advantage NF417. According to Ashland
they purchased GE/Betz Chemical and the two defoamers are actually the exact same material produced at the same
location. The only difference is that since it is now a Ashland product it requires a Ashland MSDS. I have informed
Ashland that even though the two materials are the same they have different MSDS's and the change would have to be
approved by our regional office. I am requesting your approval to allow the mill to use the Ashland product. If you have
any questions please feel free to contact me at 252-533-6237 or reply to this email. Thank you.
Chris Puryear.
The information contained in this message and any attached files may be privileged and/or confidential and protected from disclosure. If you are not the intended
recipient, any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is strictly prohibited. If you have
received this transmission in error, please so notify the sender immediately without reading it. Also, please promptly destroy the original transmission and its
attachments. Any views or opinions presented in this message or attachments are those of the author and do not necessarily represent those of KapStone Paper
and Packaging Corporation or its subsidiaries.

0
Material Safety Data Sheet
FOAMTROL AF3560
GE
Water & Process Technologies
1 Identification of Product and Company
Identification of substance or preparation
FOAMTROL AF3560
Product Application Area
Antifoam
Company/Undertaking Identification
GE Betz, Inc.
4636 Somerton Road
Trevose, PA 19053
T 215 355-3300, F 215 953 5524
Emergency Telephone
[phone]
Prepared by Product Stewardship Group: 215 355-3300
2 Composition / Information On Ingredients
Issue Date: 30-MAR-2007
S u percedes: 30-MAR-2007
Information for specific product ingredients as required by the
Q.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to
additional sections of this MSDS for our assessment of the potential
hazards of this formulation.
HAZARDOUS INGREDIENTS:
Cas# Chemical Name Range(W/W
24938-91-8 POLY(OXY-1,2-ETHANEDIYL), 0.5-1.5
ALPHA-TRIDECYL-OMEGA-HYDROXY-
irritant (eyes and skin)
3 Hazards Identification
aaaaaaa xaax xxwwwwxwwwwwwwxwwwawaaaaaa xaaaaaa•awxxwwwww wwwwwwwaxaaaaaaaaxawaxwxwx
EMERGENCY OVERVIEW
CAUTION
May cause slight irritation to the skin. May cause moderate
irritation to the eyes. Vapors, gases, mists or aerosols may cause
irritation to the upper respiratory tract. Prolonged exposure may
cause dizziness and headache.
DOT hazard is not applicable
Odor: Slight; Appearance: White To Off -White, Dispersion
Substance or Preparation: FOAMTROL AF3560 Page 1

Fire fighters should wear positive pressure self-contained breathing
apparatus(full face -piece type). Proper fire -extinguishing media:
dry chemical, carbon dioxide, foam or water
}}f}f 1f 1f}}fllf ii##iiiff}f}f}11RiRRiRiif}f}}ff11f 11fiR}RR#ii#i#i#11ff}f}}111f#1}
POTENTIAL HEALTH EFFECTS
ACUTE SKIN EFFECTS:
Primary route of exposure; May cause slight irritation to the skin.
ACUTE EYE EFFECTS:
May cause moderate irritation to the eyes.
ACUTE RESPIRATORY EFFECTS:
Primary route of exposure;Vapors, gases, mists or aerosols may
cause irritation to the upper respiratory tract. Prolonged exposure
may cause dizziness and headache.
INGESTION EFFECTS:
May cause slight gastrointestinal irritation with possible nausea,
vomiting, abdominal discomfort and diarrhea.
TARGET ORGANS:
No evidence of potential chronic effects.
MEDICAL CONDITIONS AGGRAVATED:
Not known.
SYMPTOMS OF EXPOSURE:
Inhalation may cause irritation of the respiratory tract. Skin
contact may cause itching and/or redness.
4 First Aid Measures
SKIN CONTACT:
Wash thoroughly with soap and water. Remove contaminated clothing.
Get medical attention if irritation develops or persists.
EYE CONTACT:
Remove contact lenses. Hold eyelids apart. Immediately flush eyes
with plenty of low-pressure water for at least 15 minutes. Get
immediate medical attention.
INHALATION:
If nasal, throat or lung irritation develops - remove to fresh air
and get medical attention.
INGESTION:
Do not feed anything by mouth to an unconscious or convulsive
victim. Do not induce vomiting. Immediately contact physician.
Dilute contents of stomach using 3-4 glasses milk or water.
NOTES TO PHYSICIANS:
No special instructions
5 Fire Fighting Measures
Substance or Preparation: FOAMTROL AF3560 Page 2

FIRE FIGHTING INSTRUCTIONS:
Fire fighters should wear positive pressure self-contained breathing
apparatus (full face -piece type).
EXTINGUISHING MEDIA:
dry chemical, carbon dioxide, foam or water
HAZARDOUS DECOMPOSITION PRODUCTS:
oxides of carbon
FLASH POINT:
> 213F > 101C P-M(CC)
6 Accidental Release Measures
PROTECTION AND SPILL CONTAINMENT:
Ventilate area. Use specified protective equipment. Contain and
absorb on absorbent material. Place in waste disposal container.
Flush area with water. Wet area may be slippery. Spread sand/grit.
DISPOSAL INSTRUCTIONS:
Water contaminated with this product may be sent to a sanitary sewer
treatment facility,in accordance with any local agreement,a permitted
waste treatment facility or discharged under a permit. Product
as is - Incinerate or land dispose in an approved landfill.
7 Handling & Storage
HANDLING:
Clean spill immediately. Wash contaminated skin promptly.
STORAGE:
Keep containers closed when not in use. Store in cool ventilated
location. Store away from oxidizers. Shelf life 45 days.
8 Exposure Controls / Personal Protection
EXPOSURE LIMITS
CHEMICAL NAME
POLY(OXY-1,2-ETHANEDIYL), ALPHA-TRIDECYL-OMEGA-HYDROXY-
PEL (OSHA): NOT DETERMINED
TLV (ACGIH): NOT DETERMINED
ENGINEERING CONTROLS:
adequate ventilation
PERSONAL PROTECTIVE EQUIPMENT:
Use protective equipment in accordance with 29CFR 1910 Subpart I
RESPIRATORY PROTECTION:
A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR
1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER
WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.
USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED
WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR -RESPIRATORS.
If air -purifying respirator use is appropriate, use a
respirator with dust/mist filters.
SKIN PROTECTION:
neoprene gloves-- Wash off after each use. Replace as
necessary.
EYE PROTECTION:
splash proof chemical goggles
9 Physical & Chemical Properties
Substance or Preparation: FOAMTROL AF3560 Page 3

Specific Gray.(70F,21C) 0.991
Freeze Point (F) 35
Freeze Point (C) 2
Viscosity(cps 70F,21C) 915
Vapor Pressure (mmHG) - 18.0
Vapor Density (air=1) < 1.00
t Solubility (water) < 1.0
Odor Slight
Appearance White To Off -White
Physical State Dispersion
Flash Point P-M(CC) > 213F > 100C
pH As Is (approx.) 7.8
Evaporation Rate (Ether=l) < 1.00
Percent VOC: 0.0
NA = not applicable ND = not determined
10 Stability & Reactivity
STABILITY:
Stable under normal storage conditions.
HAZARDOUS POLYMERIZATION:
Will not occur.
INCOMPATIBILITIES:
May react with strong oxidizers.
DECOMPOSITION PRODUCTS:
oxides of carbon
INTERNAL PUNPOUT/CLEANOUT CATEGORIES:
"B"
11 Toxicological Information
No Data Available.
12 Ecological Information
AQUATIC TOXICOLOGY
Fathead Minnow 96 Hour Static Acute Bioassay
LC50= 3490; No Effect Level= 2500 mg/L
BIODEGRADATION
No Data Available.
13 Disposal Considerations
If this undiluted product is discarded as a waste, the US RCRA
hazardous waste identification number is
Not applicable.
Please be advised; however, that state and local requirements for
waste disposal may be more restrictive or otherwise different from
federal regulations. Consult state and local regulations regarding
the proper disposal of this material.
14 Transport Information
Substance or Preparation: FOAMTROL AF3560 Page 4

DOT HAZARD: Not Applicable
PROPER SHIPPING NAME:
DOT EMERGENCY RESPONSE GUIDE #: Not applicable
Note: Some containers may be DOT exempt, please check SOL for
exact container classification
15 Regulatory Information
TSCA:
All components of this product are listed in the TSCA inventory.
CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ):
No regulated constituent present at OSHA thresholds
FOOD AND DRUG ADNINISTRATION:
21 CFR 176.210 (defoaming agents used in the manufacture of
paper and paperboard)
When used in this specified application, all ingredients
comprising this product are authorized by FDA for the
manufacture of paper and paperboard that may contact aqueous
and fatty foods as per 21 CFR 176.170(a)(4).
SARA SECTION 312 HAZARD CLASS:
Immediate(acute)
SARA SECTION 302 CHEMICALS:
No regulated constituent present at OSHA thresholds
SARA SECTION 313 CHEMICALS:
No regulated constituent present at OSHA thresholds
CALIFORNIA REGULATORY INFORMATION
CALIFORNIA SAFE DRINKING WATER AND TOXIC
ENFORCEMENT ACT (PROPOSITION 65):
No regulated constituents present
MICHIGAN REGULATORY INFORMATION
No regulated constituent present at OSHA thresholds
16 Other Information
NFPA/HMIS
Health 1
Fire 0
Reactivity 0
Special NONE
(1) Protective Equipment B
CODE TRANSLATION
Slight Hazard
Minimal Hazard
Minimal Hazard
No special Hazard
Goggles,Gloves
(1) refer to section 8 of MSDS for additional protective equipment
recommendations.
CHANGE LOG
EFFECTIVE
DATE
MSDS status: 29-AUG-2003
09-OCT-2003
07-JUN-2006
30-MAR-2007
REVISIONS TO SECTION:
12
16
5,7,10
Substance or Preparation: FOAMTROL AF3560
SUPERCEDES
** NEW ••
29-AUG-2003
09-OCT-2003
07-JUN-2006
Page 5

SAFETY DATA SHEET
AdvantageTm NF417 Defoaming Agent
TM Trademark, Ashland or its subsidiaries,
registered in various countries427882
1. IDENTIFICATION OF THE SUBSTANCE/MIXTURE AND OF THE
COMPANY/UNDERTAKING
Page: 1
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
Ashland
Regulatory Information Number 1-800-325-3751
P.O. Box 2219
Telephone [phone]
Columbus, OH 43216
Emergency telephone number 1-800-ASHLAND (1-800-274-
5263)
Product name
AdvantageTm NF417 Defoaming Agent
Tm Trademark, Ashland or its subsidiaries, registered in various
countries
Product code
427882
2. HAZARDS IDENTIFICATION
Emergency Overview
Appearance: liquid, opaque
NOTICE: WHILE THIS MATERIAL HAS A LOW LEVEL OF TOXICITY, GOOD
INDUSTRIAL HYGIENE PRACTICES ARE ENCOURAGED TO MINIMIZE EXPOSURE.
Potential Health Effects
Exposure routes
Inhalation, Skin absorption, Skin contact, Eye Contact, Ingestion
Eye contact
May cause mild eye irritation. Symptoms include stinging, tearing, and redness.
Skin contact
May cause slight skin irritation.
Ingestion
Swallowing small amounts of this material during normal handling is not likely to cause harmful
effects. Swallowing large amounts may be harmful.
Page 1 / 10

ASHLAN13s
SAFETY DATA SHEET
AdvantageTm NF417 Defoaming Agent
Tm Trademark, Ashland or its subsidiaries,
registered in various countries427882
Page: 2
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
Inhalation
It is possible to breathe this material under certain conditions of handling and use (for example,
during heating, spraying, or stirring). Breathing small amounts of this material during normal handling is
not likely to cause harmful effects. Breathing large amounts may be harmful. Symptoms are not
expected at air concentrations below the recommended exposure limits, if applicable (see Section 8.).
Aggravated Medical Condition
No data
Symptoms
No data
Target Organs
No data
Carcinogenicity
This material is not listed as a carcinogen by the International Agency for Research on Cancer
(IARC), the National Toxicology Program (NTP), or the Occupational Safety and Health Administration
(OSHA).
Reproductive hazard
Based on the available information, risk to the fetus from maternal exposure to this material
cannot be assessed.
3. COMPOSTTION/INFORMATION ON INGREDIENTS
This material is not hazardous under the criteria of the Federal OSHA Hazard Communication
Standard 29CFR 1910.1200.
4. FIRST AID MEASURES
Eyes
If symptoms develop, move individual away from exposure and into fresh air. Flush eyes gently
with water while holding eyelids apart. If symptoms persist or there is any visual difficulty, seek
medical attention.
Page 2 / 10

ASHLAN")
SAFETY DATA SHEET
AdvantageTm NF417 Defoaming Agent
Tm Trademark, Ashland or its subsidiaries,
registered in various countries427882
Page: 3
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
Skin
Remove contaminated clothing. Wash exposed area with soap and water. If symptoms persist,
seek medical attention. Launder clothing before reuse.
Ingestion
Seek medical attention. If individual is drowsy or unconscious, do not give anything by mouth;
place individual on the left side with the head down. Contact a physician, medical facility, or poison
control center for advice about whether to induce vomiting. If possible, do not leave individual
unattended.
Inhalation
If symptoms develop, move individual away from exposure and into fresh air. If symptoms
persist, seek medical attention. If breathing is difficult, administer oxygen. Keep person warm and
quiet; seek immediate medical attention.
Notes to physician
Hazards: No information available.
Treatment: No information available.
5. FIREFIGHTING MEASURES
Suitable extinguishing media
Dry chemical, Carbon dioxide (CO2), Water spray
Hazardous combustion products
carbon dioxide and carbon monoxide, undefined organics
Precautions for fire -fighting
Wear full firefighting turn -out gear (full Bunker gear), and respiratory protection (SCBA). Use
water spray to cool fire exposed containers and structures until fire is out if it can be done with minimal
risk. Avoid spreading burning material with water used for cooling purposes.
NFPA Flammable and Combustible Liquids Classification
Combustible Liquid Class IIIB
6. ACCIDENTAL RELEASE MEASURES
Page 3 / 10

L`
ASHLANU®
SAFETY DATA SHEET
AdvantageTm NF417 Defoaming Agent
TM Trademark, Ashland or its subsidiaries,
registered in various countries427882
Page: 4
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
Personal precautions
For personal protection see section 8. Persons not wearing protective equipment should be
excluded from area of spill until clean-up has been completed.
Environmental precautions
Prevent spreading over a wide area (e.g. by containment or oil barriers). Do not let product enter
drains. Do not flush into surface water or sanitary sewer system. See Section 13 of this MSDS for
information on disposal of diluted product.
Methods for cleaning up
Keep in suitable, closed containers for disposal. Soak up with inert absorbent material (e.g. sand,
silica gel, acid binder, universal binder, sawdust).
Other information
Comply with all applicable federal, state, and local regulations.
7. HANDLING AND STORAGE
Handling
Containers of this material may be hazardous when emptied. Since emptied containers retain
product residues (vapor, liquid, and/or solid), all hazard precautions given in the data sheet must be
observed.
Storage
Store in a cool, dry, ventilated area. Keep from freezing.
8. EXPOSURE CONTROLS/PERSONAL PROTECTION
Exposure Guidelines
Contains no substances with occupational exposure limit values.
General advice
These recommendations provide general guidance for handling this product. Personal protective
equipment should be selected for individual applications and should consider factors which affect
exposure potential, such as handling practices, chemical concentrations and ventilation. It is ultimately
the responsibility of the employer to follow regulatory guidelines established by local authorities.
Page 4 / 10

ASHLAN 13o
SAFETY DATA SHEET
AdvantageTm NF417 Defoaming Agent
TM Trademark, Ashland or its subsidiaries,
registered in various countries427882
Page: 5
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
Exposure controls
Provide sufficient mechanical (general and/or local exhaust) ventilation to maintain exposure
below exposure guidelines (if applicable) or below levels that cause known, suspected or apparent
adverse effects.
Eye protection
Not required under normal conditions of use. Wear splash -proof safety goggles if material could
be misted or splashed into eyes.
Skin and body protection
Wear normal work clothing including long pants, long-sleeved shirts and foot covering to
prevent direct contact of the product with the skin. Launder clothing before reuse. If skin irritation
develops, contact your facility health and safety professional or your local safety equipment supplier to
determine the proper personal protective equipment for your use.
Wear resistant gloves (consult your safety equipment supplier).
Respiratory protection
A NIOSH-approved air -purifying respirator with an appropriate cartridge and/or filter may be
permissible under certain circumstances where airborne concentrations are expected to exceed exposure
limits (if applicable) or if overexposure has otherwise been determined. Protection provided by air -
purifying respirators is limited. Use a positive pressure, air -supplied respirator if there is any potential
for uncontrolled release, exposure levels are not known or any other circumstances where an air -
purifying respirator may not provide adequate protection.
9. PHYSICAL AND CHEMICAL PROPERTIES
Physical state
liquid
Colour
opaque, off-white
Odour
fatty odour
Boiling oint/boilin range
> 212 OF /> 100 °C
Melting point/range
32 OF / 0 °C
H
7- 9 5% as an emulsion
Flash point
> 200.I °F / > 93.4 °C Pens Martens closed cu
Vapour pressure
< 1.330 hPa @ 68 OF / 20 °C
Relative vapor density
> 1 AIR=1
Density
0.989 g1cm3
Page 5 / 10

ASH«NI3m
SAFETY DATA SHEET
AdvantageTM NF417 Defoaming Agent
TM Trademark, Ashland or its subsidiaries,
registered in various countries427882
Water
Page: 6
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
I Viscositv. dvnamic 1 250 - 1.200 mPa.s Cad 27 °C I
10. STABILITY AND REACTIVITY
Stability
Stable.
Conditions to avoid
excessive heat
Incompatible products
halogens, strong mineral acids, Strong oxidizing agents
Hazardous decomposition products
carbon dioxide and carbon monoxide, undefined organics
Hazardous reactions
Product will not undergo hazardous polymerization.
11. TOXICOLOGICAL INFORMATION
Acute oral toxicity
Acute oral toxicity - no data available
Product
Acute inhalation toxicity
Acute inhalation toxicity - no data available
Product
Acute dermal toxicity
Acute dermal toxicity - no data available
Product
Page 6 / 10

ASHLLNN U®
SAFETY DATA SHEET
AdvantageTm NF417 Defoaming Agent
TM Trademark, Ashland or its subsidiaries,
registered in various countries427882
Acute toxicity (other routes of administration)
Acute toxicity (other no data available
routes of administration)
12. ECOLOGICAL INFORMATION
- Product : no data
Bioaccumulation
Bioaccumulation -Product : no data available
Ecotoxicity effects
to IISa
to fish -
Page: 7
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
Exposure time: 96 It
Species: Pimephales promelas (fathead minnow)
Method: OECD Test Guideline 203
Test Type: static test
Toxicity to daphnia and other aquatic
invertebrates_
Toxicity to daphnia and
EC 50: 5,619 mg/1
other aquatic invertebrates
Exposure time: 48 It
- Product
Species: Daphnia magna (Water flea)
Method: OECD Test Guideline 202
Test Type: static test
Toxicity to algae
Toxicity to algae - no data available
Product
Toxicity to bacteria
Toxicity to bacteria - no data available
Page 7 / 10

ASHLANU®
SAFETY DATA SHEET
AdvantageTm NF417 Defoaming Agent
Tm Trademark, Ashland or its subsidiaries,
registered in various countries427882
Product
13. DISPOSAL CONSIDERATIONS
Page: 8
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
Waste disposal methods
Dispose of in accordance with all applicable local, state and federal regulations. Water
contaminated with, or water dilutions of, this product may be disposed of or discharged to a sanitary
sewer treatment facility or a permitted waste treatment facility in accordance with a local permit or any
local agreement.
14. TRANSPORT INFORMATION
REGULATION
ID
PROPER SHIPPING NAME
*HAZARD
SUBSIDIARY
I PACKING
I MARINE
NUMBER
CLASS
HAZARDS
GROUP
POLLUTANT
/ LTD. TY.
U.S. DOT - ROAD
Not dangerous goods
U.S. DOT - INLAND WATERWAYS
Not dangerous goods
TRANSPORT CANADA - RAIL
Not dangerous goods
Page 8 / 10

• 4 .
ASHLAIV X
SAFETY DATA SHEET
AdvantageTm NF417 Defoaming Agent
Tm Trademark, Ashland or its subsidiaries,
registered in various countries427882
INTERNATIONAL AIR TRANSPORT ASSOCIATION - CARGO
Not dangerous goods
INTERNATIONAL
Page: 9
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
MEXICAN REGULATION FOR THE LAND TRANSPORT OF HAZARDOUS MATERIALS AND
WASTES
*ORM = ORM-D, CBL =
Dangerous goods descriptions (if indicated above) may not reflect quantity, end -use or region -specific
exceptions that can be applied. Consult shipping documents for descriptions that are specific to the
shipment.
15. REGULATORY INFORMATION
California Prop. 65
Proposition 65 warnings are not required for this product based
on the results of a risk assessment.
SARA Hazard Classification
SARA 311/312 Classification
No SARA Hazards
SARA 313 Component(s)
SARA 313: This material does not contain any chemical components with known CAS numbers that
exceed the threshold (De Minimis) reporting levels established by SARA Title III, Section 313.
Notification status
Page 9 / 10

ASHLAN13®
SAFETY DATA SHEET
AdvantageTM NF417 Defoaming Agent
Tm Trademark, Ashland or its subsidiaries,
registered in various countries427882
Page: 10
Revision Date: 12/21/2012
Print Date: 1/3/2013
MSDS Number: R0702076
Version: 1.7
US. Toxic Substances Control Act(positive
listing)
Canada. Canadian Environmental Protection Act (CEPA).
Domestic Substances List DSL . Can. Gaz. Part II, Vol. 133
y (positive listing)
Australia. Industrial Chemical (Notification and Assessment)
Act
n (Negative listing)
New Zealand. Inventory of Chemicals (NZIoC), as published
by ERMA New Zealand
n (Negative listing)
Japan. Kashin-Hou Law List
n (Negative listing)
Korea. Toxic Chemical Control Law TCCL) List
n (Negative listing)
Philippines. The Toxic Substances and Hazardous and Nuclear
Waste Control Act
n (Negative listing)
China. Inventory of Existing Chemical Substances
n (Negative listing)
HMIS
NFPA
Health
1
1
Flammability
1
1
Physical hazards
0
Instability
0
Specific Hazard
--
--
16.OTHER INFORMATION
The information accumulated herein is believed to be accurate but is not warranted to be whether
originating with the company or not. Recipients are advised to confirm in advance of need that the
information is current, applicable, and suitable to their circumstances. This MSDS has been prepared by
Ashland's Environmental Health and Safety Department (1 -800-325-375 1).
Page 10 / 10

TRIDECYL ALCOHOT FTHOXYLATE (POLYOXYETHYL- TRIDECYL ETHER) Page 1 of 3
1
Search
Iwww.chemicalland2l.com
DECYL ALCOHOL ETHOXYLATES
DUCT IDENTIFICATION
NO. 24938-91-8
CS NO.
MULA C13Hz)(OCHZCHz),OH
. WT. xo
CODE
(CITY Oral rat LD50: 2850 mg/kg
DNYMS olpha thciecyl-omega-hydroxy-poly(oxy-1,2-ethanediyl);
oxyethylene Tridecyl alcohol: Polyoxyethylene hidecyl alcohol: POE Tridecyl alcohol;
oxyethylene Tridecyl Ether,
F MATERIALS
:ATION
SURFACTANT
L AND CHEMICAL PROPERTIES (10 mot)
L STATE
clear liquid or white semi -sold
POINT
POINT
GRAVITY
Y IN WATER
Soluble
)SITY (CPA)
IR DENSITY
sCTIVE INDEX
RATINGS Health:0 Flammability: I Reactivity: 0
POINT
Stable under ordinary conditions
y alcohol ethoxylates, clear to yellowish liquid to waxy solids depending on alkyl chain length
the number of ethoxy groups, are non ionic surfactants which contain both hydrophobic tail
ion (fatty alcohol part) and hydrophilic polar head groups (ethoxy chain pad), and are thus
i to dissolve in both aqueous and oil phase and to reduce the surface tension of liquids.
lene oxide (also tolled epoxyethane and oxirone) is the simplest cyclic ether or epoxide, with
formula CZH,O: reactive material which is added to the base of alcohols (or amines) to form
)xylated surfactants. The Hydrophilic-Upophilic Balance (HLB) of EO surfactant is related to the
rophilic portion of the molecule. More hydrophilic groups enable more solubility in water as
e hydrogen bondings exist. They are non-ionic in solution which has no electrical charge,
:h means well -work in hard water at low temperatures as well as stability in acid and alkali
tion and compatibility with other surfactants. Generally, surfactant's name are formed by
Ing the mole number of ethylene oxide. There is a wide HUB range depend their motor ratios
Neen fatty alcohol and EO. The very low (2, 2.5 or 3) mole ratio products are used to prepare
(sodium louryl ether sulfate) which is used as a foaming and cleansing agent for shampoos
cleansers, suited for high viscosity products and low pH products. Slightly higher mole ratio
iucts are used as wetting agent. The E.0 surfoctants of 7-12 moles ratio with alcohol are
)ble for detergent application. Higher moles ratio products are emulsifiers. Their 3
esentative functions are as wetting agent, detergency and emulsifier.
applications include:
s and Industnol Cleaners. Dispersants, Stabilaers, Sonit¢ers, Defoaming Agents.
iical Emulsifiers. Metal Working, Textile Processing, Paper Dunking, Drilling Products
)te Anionic Surfactants Synthesis, Dust Control, Adhesive, Plastic Industry. Lube Oil,
and Pharmaceuticals.
Fatly alcohol ethoxylates
Products Carbon length CAS 9
Alkyl Alcohol ethoxyaaee
Alkyl Alcohol (C6-C121 ethoxylates
Alkyl Alcohol (CS-C22) ethoxylates
Alkyl Alcohol (C8-C10)ethoxylates
Alkyl Alcohol (C8CI8) ethoxylates
Alkyl Alcohol (C8-CI6) ethoxylates
Coco alcohol ethoxylates
Alkyl Alcohol (C9-CI I) ethoxylotes
Branched Alkyl Alcohols (C9-Cl1) ethoxylates
Alkyl Alcohol (C9-C 16) ethoxylates
Alkyl Alcohol (CIO-CI4) ethoxylates
Alkyl Alcohol (C 10-C 16)ethoxylates
lsodecyl ethoxylates
Decyl alcohol ethoxylates
Alkyl Alcohol (C I aC 12) ethoxylates
74432-13-6
6 - 12
68439-45-2
8 - 22
69013-19-0
8-10
71060-57-6
8 - 18
157707-43-2
8-16
71243-46-4
8-18
61791-13-7
9 - 11
68439-46-3
9-11
78330-20-8
9 - 16
97043-91-9
10-14
66455-15-0
10 -16
68002-97-1
10
61827-42-7
10
26183-52-8
10-12
67254-71-1
http://chemicalland2l.com/specialtychem/perchem[MDECYL%20ALCOHOLa/*20ETH... 2/12/2013

TRIDECYL ALCOHOL BTHOXYLATE (POLYOXYETHYL
i TRIDECYL ETHER) Page 2 of 3
Branched Alkyl Alcohol (CI1-C 13) ethoxylates
11 -13
68439-54-3
Branched Alkyl Alcohol (Cl 1-CI4) ethoxylates
11 - 14
78330-21-9
Undecyl alcohol ethoxylotes
11
127036-24-2
Linear Undecyl alcohol ethoxylates
I
3439MI-I
Secondary Alcohol (CI1-C 15) ethoxylotes
11 - 15
68131-40.8
Alkyl Alcohol(C12C13) ethoxylates
12-13
66455-149
Alkyl Alcohol (C12-C20) ethoxylotes
12-20
68526-94-3
Secondary Alcohol (C I2-C 14) ethoxylates
12- 14
84133�50-6
Alkyl Alcohol jC12-C14) ethoxylates
12- 14
68439-50-9
Alkyl Alcohol IC12CI81 ethoxylotes
12- 18
68213-23-0
Alkyl Alcohol (CI 2C16) ethoxylotes
12-16
6MI-12-2
Dodecyl alcohol ethoxylotes
12
9002-92-0
Linear Alkyl Alcohol(C12-C15) ethoxylates
12-15
68131-39-5
Alkyl Alcohol (C 12-C I51 ethoxylotes
12- 15
106232 33-1
Tndecyl alcohol ethoxylates
13
24938-91-8
Alkyl Alcohol (C 13-C 15) ethoxylotes
13-15
64425-86-1
Isotndecanol ethoxylates
13
69011-36-5
lsotridecyl alcohol ethoxylotes
13
9043-30-5
Alkyl Alcohol (C I4C 15) ethoxylates
14. 15
127944-68-5
Tetrodecyl ethoxylotes
14
27306-79-2
Alkyl Alcohol (C 16-C22) ethoxylotes
16-22
69227-20-9
Alkyl Alcohol (C 16-C18) ethoxylates
16- 18
68439-49-6
Unsaturated Alkyl Alcohol (CT 6-C 18) ethoxylates
16-18
68920-66-1
Tallow alcohol ethoxylotes
16- I8
61791-2B-4
Hexodecyl alcohol ethoxylotes
16
9004-95-9
unsaturated alkyl Alcohol (C16-C 18) ethoxylotes
16- 18
68155-01-1
Stearyl alcohol ethoxylates
18
9005-00-9
Oleyl alcohol ethoxylotes
18
9004-98-2
ES SPECIFICATION
5 MOL
i MOL WT. 420
EARANCE Clear liquid
LOR,APHA 10 Max
CIFIC GRAVITY 0.955 i0.005
3 HYDROXYL VALUE 135 (mg KOH/g)
6 - 7 (3%)
E PEG 0.5%mac
TER 0.1%max
RX HLB 10.5
7 MOL
3 MOL WT. 508
EARANCE Clear liquid
LOR,APHA 10max
CIFIC GRAVITY 0.985t 0.005
a HYDROXYL VALUE 110 (mg KOH/g)
6 - 7 (3%)
E PEG 1.0%rrwx
TER 0.1%max
'RX HLB 12.0
10 MOL
:a MOL WT. 640
EARANCE white Paste
LOR,APHA IOmox
HYDROXYL VALUE 85 (mg KOH/g)
6 - 7 (3%)
)UD POINT 70 C
TER 0.1%max
E PEG I.0%max
'RX HLB 13.5
14 MOL
3 MOL WT. 815
'EARANCE white paste
LOR,APHA 10max
HYDROXYL VALUE 69 (mg KOH/g)
6-7(3%)
=PEG 1.0%mox
TER 0.1%max
'RX HLB 15.0
KING 200liter drum
CARD CUSS Not regulated
NO.
http://chemicalland2l .com/specialtychem/perchem/TRIDECYL%20ALCOHOL%20ETH... 2/12/2013

TRIDECYL ALCOHO" STHOXYLATE (POLYOXYETHYL— TRIDECYL ETHER) Page 3 of 3
http://chemicalland2I .com/specialtychem/percherirMDECYL%20ALCOHOL%20ETH... 2/12/2013

North Carolina
Beverly Eaves Perdue
Governor
Q��
NCDENR
Department of Environment and
Division of Water Quality
Charles Wakild, P.E.
Director
December 19, 2012
Ms. Mary Lee Ransmeier
Environmental Programs Manager
Kapstone — Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Natural Resources
Subject: Compliance Evaluation Inspection
Kapstone - Kraft Paper Corporation - Roanoke Rapids Paper Mill
Permit No. NC0000752 and NCS00106
Halifax County
Dear Ms. Ransmeier:
Dee Freeman
Secretary
On December 3, 2012, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
compliance evaluation inspection of the subject facility. The assistance provided by Mr. Chris
Puryear, the operator in responsible charge (ORC) of the facility, and Mr. Neil Davis, the backup
ORC, was appreciated as it facilitated the inspection process. The inspection report is attached.
The following observations were made:
Kapstone — 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, aeration basin, and three stabilization ponds. The plant discharges
to Roanoke River, a Class C water in the Roanoke River basin.
1. All three influent pumps were in operation. The primary clarifier was in good condition.
2. Sludge from the primary clarifier was dewatered at the sludge handling facility, Belt
presses, screw presses, and chemical feed system were in operational condition.
Dewatered sludge was disposed at the onsite land file.
3. Effluent from the clarifier was further treated at the aeration basin. 26 of 31 aerators were
in use at the time of inspection (all aerators were operable).
4. Effluent from the aeration basin was further treated in the three stabilization ponds before
being discharged to the river.
5. The ORC maintains a daily logbook. Lab results, chain -of -custody forms, and DMRs
were complete and current, kept in good order and ready for review. July 2012 DMR data
were compared to lab bench sheets; no data transcription errors were noted during the
inspection.
North Carolina Division of Water Quality 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone] Customer Service
Internet: w vncwatetquality.org Location. 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer- 50% Rxycle&l0%Post Consumer Paper

Capstone - Kraft Paper Corporation - R,_ __ __:e Rapids Paper Mill
Permit No. NCO000752 and NCS000106
Compliance Evaluation Inspection
6. The right of way to the outfa11001 was well maintained. The effluent was observed to be
clear and free of solids. No visible impacts were noted immediately downstream the
effluent pipe.
7. Field lab parameter (Certificate No. 183) calibration and analysis records were reviewed
during the inspection.
8. A compliance evaluation inspection for the NPDES stormwater permit (No. NCS000106)
was also conducted. The facility has developed and implemented a Stormwater Pollution
Prevention Plan (SPPP), which includes all required components. All stormwater
discharge outfalls were observed; these outfalls and the right-of-way were well
maintained. Please be reminded to review and update the SPPP before the end of
2012.
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: chena.zhang_Camcdenngov).
Sincerely,
Cheng Zhang
Environmental Specialist
Attachments
Compliance Inspection Reports
Cc: Central Files w/attachment
Raleigh Regional Office w/attachment
Chris Puryear— ORC w/attachment
Kapstone — Kraft Paper Corporation

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460 OMB No. 2040-0057
Water Compliance In-qpectinn Rppnrt 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 I u I 2 1 5 I 3I NC0000752 111 12I 12/12/03 117 181 C I 191 e I 20I I
LJ U U U J
Remarks
21IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII11111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 CIA --Reserved-
67I 169 70I I 71 I tyI 72' N I 731LI 174 75L I I I I I I 180
u t� 1J
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)
Roanoke Rapids Mill
10:00 AM 12/12/03
12/06/01
Exit Time/Date
Permit Expiration Date
100 Gaston Rd
Roanoke Rapids NC 27870
01:00 PM 12/12/03
17/03/31
Name(s) of Onsite Repmsentafive(s)rTitles(syPhone and Fax Number(s)
Other Facility Data
///
Thomas C Puryear/ORC/252-533-6237/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Mary Lee Ransmeier,100 Gaston Rd Roanoke Rapid NC 27870//252-533-6398/2525336451
No
Section C: Areas Evaluated During Inspection Check only those areas evaluated
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory Storm Water
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
Chang Zhang RRO WO//919-791-4200/
�^
d�
nat re of Manag ant O A er Agency/Office/Phone and Fax Numbers Date
l Gf 1 �12.:2 20
q v
EPA Form W-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

Permit: NC0000752
Inspection Date: 12103/2012
Owner - Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ ❑
Judge, and other that are applicable?
Comment: The facility analyzes MLSS, pH, DO, and TOC for process control
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
❑
■
❑
Is the facility as described in the permit?
■
❑
❑
❑
# Are there any special conditions for the permit?
■
❑
❑
❑
Is access to the plant site restricted to the general public?
■
❑
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
Comment: The facility is required to check pH of river intake water.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
■
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
■
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
■
❑
Comment:
Flow Measurement - Influent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
❑
❑
rl
Is the flow meter operational?
■
Cl
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
■
❑
❑
Cl
Comment:
Flow Measurement - Effluent
Yes No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
❑
❑
❑
Is the flow meter operational?
■
Cl
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
■
❑
❑
❑
Comment:
Solids Handling Equipment
Yes No NA
NE
Is the equipment operational?
■
❑
❑
❑
Page # 3

Parini NC0000752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 12J0312012 Inspection Type: Compliance Evaluation
Solids Handling Equipment
Yes
No
NA
NE
Is the chemical feed equipment operational?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Is the site free of high level of solids in filtrate from filler presses or vacuum filters?
■
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
■
❑
❑
❑
The facility has an approved sludge management plan?
■
❑
❑
❑
Comment: Sludge dewatering units and chemical feed system were in good condition.
Dewatered sludge goes to the onsite land fill.
Chemical Feed
Yes
No
NA
NE
Is containment adequate?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Are backup pumps available?
■
❑
❑
❑
Is the site free of excessive leaking?
■
❑
❑
❑
s t�7711-1 ii
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
❑
❑
❑
Is the wet well free of excessive grease?
■
❑
❑
❑
Are all pumps present?
■
❑
❑
❑
Are all pumps operable?
■
❑
❑
❑
Are float controls operable?
❑
❑
■
❑
Is SCADA telemetry available and operational?
❑
❑
■
❑
Is audible and visual alarm available and operational?
❑
❑
■
❑
Comment: All three pumps were in operation.
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?
■
❑
❑
❑
Is disposal of screening in compliance?
■
❑
❑
❑
Page # 4

Permit: NC0000752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 12/03/2012 Inspection Type: Compliance Evaluation
Bar Screens Yes No NA NE
Is the unit in good condition?
■
❑
❑
❑
Comment:
Primary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier.
■
❑
❑
❑
Are weirs level?
■
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
Cl
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
■
❑
❑
❑
Is the site free of excessive Floating sludge?
■
❑
❑
❑
Is the drive unit operational?
■
❑
❑
❑
Is the sludge blanket level acceptable?
■
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately''% of the sidewall depth)
■
❑
❑
❑
Comment: Sludge blanket was about 3 feet.
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?
❑
❑
■
❑
Is lagoon free of excessive Floating materials?
■
❑
❑
❑
# Are baffles between ponds or effluent baffles adjustable?
■
❑
❑
❑
Are dike slopes clear of woody vegetation?
■
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
■
❑
❑
❑
Are dikes free of seepage?
■
❑
❑
❑
Are dikes free of erosion?
■
❑
❑
❑
Are dikes free of burrowing animals?
■
❑
❑
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
■
❑
❑
❑
# If excessive algae is present, has barley straw been used to help control the growth?
■
❑
❑
❑
Is the lagoon surface free of weeds?
■
❑
❑
❑
Page # 5

Permit: NC0000752
Inspection Date: 12ION2012
Owner -Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
Lagoons
Yes
No
NA
NE
Is the lagoon free of short circuiting?
■
❑
❑
❑
Comment:
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
❑
❑
❑
Are all other paremeters(excluding field parameters) performed by a certified lab?
■
❑
❑
❑
# Is the facility using a contract lab?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/_ 0.2 degrees?
■
❑
❑
❑
Incubator (BOO) set to 20.0 degrees Celsius +/_ 1.0 degrees?
■
❑
❑
❑
Comment: Field lab parameters calibration and analysis were reviewed.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected above side streams?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Is sampling performed according to the permit?
■
❑
❑
❑
Comment:
Effluent Sampling
Yes No
NA
NE
Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
❑
❑
❑
Comment:
Aeration Basins
Yes No NA
NE
Mode of operation
Type of aeration system
Surface
Is the basin free of dead spots?
■
❑
❑
❑
Page # 6

Permit: NC0000752
Inspection Date: 1210312012
Aeration Basins
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?
Owner - Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/I)
Comment: All 31 aerators were in operable condition, while 26 units were used and
DO was 1.36 mg/L at the time of inspection.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWO?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment:
Yes No NA NE
■ ❑ ❑ ❑
0 0 ■ 0
■ 0 0 0
■❑❑0
■ 0 0 0
Yes No NA NE
■
IN
■ 0 0 0
n❑■0
0 0 ■ 0
■ 0 0 0
■nn0
■ 0 0 0
■ 0 0 0
nn■❑
Page r 7

Re ial Inspectors' Checklist fc field Parameters
Facili Name: oa.n ckQ- AeLp*?dr rctrer�M-q
egional Plant Inspector: --
NPDES #: C O00O7-!­ �-
Regional Inspector Contact #: ?t F— 7 4I — 4LxJ-
Field Lab Certification M 3
Region: R D
Lab Contact:
Date: (-2i.) /-L0 i-,?--
I . Check the parameter(s) performed at this site for reporting purposes.
❑ Total Residual Chlorine (TRC) Temperature (TEMP) ® Specific Conductivity (SC)
[X pH ® Dissolved Oxygen (DO) ❑ Settleable Residue (SETT)
General Laboratory (note anv exceptions in section XI)
Are instruments, meters, probes, photometric cells, etc. maintained in good condition?
Yes ❑ No
Are standards, reagents and consumables used within manufacturer expiration dates?
RC gel standard is exempt.]
® Yes ❑ No
Are the following items documented where applicable):
Item
TRC
pH
TEMP
DO
SC
SETT
Date of sample collection*
V
✓
V
✓
Time of sample collection*
V
Sample collector's initials or signature
V
V
V
Date of sample analysis*
V
Time of sample analysis*
V
✓
V
r/
Analyst initials or signature
V
V
V
r/
Sample location
✓1
1 V
✓
`Date and time of sample collection and analysis may be the same for in situ 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: ❑ pg/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: A x ff P 71
Is the pH meter calibrated with at least 2 buffers per mfg's instructions each day of use?
Note buffers used:
Yes
❑ No
Is the pH meter calibration checked with an additional buffer each day of use? Note check
buffer used:
01 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 analyzed within 15 minutes of collection?
® Yes
❑ No
Are sample results reported to 0.1 pH units?
Yes
0 No

V. Temperature
What instrument(s) is usea 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?
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]
Yes
❑ No
Are sample results reported in degrees C?
Z Yes
❑ No
VI. Dissolved Oxygen
DO meter make and model: Y I 1 PO A
Is the air calibration of the DO meter performed each day of use?
0 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: Orlon ? S'fa y-
Is the meter calibrated daily according to the manufacturer's instructions? Note standard
used this is generally a one -point calibration):
Yes
❑ No
Is a daily check standard analyzed? Note value:
m Yes
❑ No
Are the following items documented:
Meter calibration?
Yes
❑ No
Are samples analyzed within 28 days of collection?
® 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:
❑ Yes
❑ No
X. Is follow-up by the Laboratory Certification program recommended?
❑ Yes
❑ No
XI. Additional comments:
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 linda.chavis(cDncdenr.aov.
Revision 04/20/2012

Romanski, Autumn
From:
Romanski, Autumn
Sent:
Friday, October 26, 2012 1:15 PM
To:
Moore, Tom
Cc:
Manuel, Vanessa; Scott, Michele
Subject:
Bims uploads to the Echo Data Base
Attachments:
Autumn Romanski.vcf, image001.jpg; KapstonepaperAmmendedDMRDecllJanMarl2.PDF
Kapstone Paper called about EPA Echo data- Two NOD's were issued by the RRO in April
2012.
NOD-2012-MV-0001 and NOD-2012-MV-0002, the facility says they sent an amended DMR to
RRO and CO, but I can see in Bims that nothing was amended, so I am guessing CO did not
get the amended copy? I have attached the letter dated May 9, 2012 that Mack Wiggins
received and filed at RRO, so that the amendment can be made.
*The permittee says this ended up on the EPA Echo Database? I thought NOD's were not
uploaded.
Can you let me know if NOD's are uploaded? p6mia- IVA coesS
Thank you for your time and assistance. P alCrGXA
Autumn lot" l Z
Autumn RomansM
NC DENR Division of Water Quality
Environmental Program Consultant
Raleigh Regional Office
[phone]
[e-mail]
3800 Barrett Drive
Raleigh, NC 27609
Email correspondence to and from this address is
subject to the North Carolina Public Records Law
and may be disclosed to third parties unless the
content is exempt by statute or other regulation.
1

252S336465 03:31:00 p.m. 10-25-2012 1 111
KapStone Kraft Paper
Corporation
ROANOKE RAPIDS MILL
FAX
TO:qu7VM.,V
Phone
Roe rs 6
Fax Phone 717 %&9— A %/
CC:
Date
I Number of pages to follow cc10
lover sheet
C%4.3 1Ux�PfMC—
I FROM: EOHS Department
Phone
Fax Phone
KapStone Kraft Paper
Corporation
100 Gaston Road
Roanoke Rapids, NC
27870
REMARKS: ❑ Urgent 2� For your review ❑ Reply ASAP ❑ Please Comment
�n d� XV0X'r0;d �,� �,2_ s ° - our,
znr
ZSZ- .533-GZ 37 �i�-�
0 /", L a P1,
Note: The material contained in this communication is intended only for the use of the
addressee. It may contain information that is confidential, proprietary, attorney privileged, and
exempt from disclosure under applicable law. If the reader of this communication is not the
intended recipient, you are hereby notified that any dissemination, distribution or duplication of
this communication is prohibited. If you have received this communication in error, please
notify us immediately by telephone and return, by mail, the original message to us. Thank you.

03:31: 10 p.m. 10-25-2012 2/11
KAPMNE
May 9, 2012
Mr. Mack Wiggins
Surface Water Protection Section
NCDENR
1628 Mail Service Center
Raleigh, N.C. 27699-1628
Dear Mr. Wiggins:
KA►/TON[
KRAFT PAPER CORPORATION
A OMaion of KAPS70NE PAPER AND PACKAGING CORPORATION
100 Gaelm ROW Po ke RaPKK NC 27870
kaPSIa*paper.=
This letter is in response to Notice of Deficiency letters that we received from Mr. Danny Smith
concerning a frequency violation while measuring our effluent temperature. We were told by Mr.
Smith to contact you if we had any questions about the notices.
We generate our MR-1's using several different Excel spreadsheets to input the accumulated monthly
data which is then sent to the state. In November of 2011 we switched from Microsoft Office 2003
to Office 2007 and also began using Windows 7. We tried to make sure that all data, macros and
spreadsheets involved in the preparation of the MR-1's transferred correctly. With the receipt of
your letter we found out that we did have an issue. It appears that MR-1 date line No.5 on the
effluent (001) sheet did not copy the macro to automatically input the effluent temperature for that
day from the spreadsheet. We have corrected the software issue and everything appears to be
working as it should.
The letters we received from Mr. Smith stated that data was missing on 03/10/12 and 12/10/11. Both
of these dates are Saturdays and therefore do not require data The actual missing data was for
03/05/12 and 12/05/11. We discovered that temperature data was also missing from 01/05/12. The
reason the other months did not show missing data was because the 5a' day of these months fell on a
weekend. I have included revised Effluent MR-I's for the aforementioned months that includes the
missing data. I have also included copies of the raw temperature data from our daily (hand written)
workbook for those missing days.
I am aware that the Notices of Deficiency do not require a formal response but compliance is very
important to this facility and to our Corporation so I felt that it was prudent to provide you with an
explanation. Since the effluent temperature data for those dates did exist, Kapstone requests that the
Notice's of Deficiency be removed from our records. If you have any questions please don't hesitate
to contact me at 252-533-6237 or [e-mail]
Sincerely,
:?,. (
AniI J. Co`line
Mill Manager
xc: Paul Kinnin Mike Knudson
Neal Davis Ben k'hite
Chris Puryear

2525336465 03.31:26 p.m. 10-25-2012 3111
Effluent 001
rpm
Facility Name: Ka stone Paper IClass. IV Coun :Halifax
Operator in Responsible Charge (ORC): Thomas C. Puryear Grade: IV Phone [phone]
Certified Laboratories: 1) International Paper Laboratory, Certificate k 181. 2) Oxford Laboratories EPA 37221
Check Box it ORC Has Changed
Mail ORIG'L - 1 COPY to.
Ann: Central Files
Div. of water Quality
1617 Mail Service Center
Raleigh, NC 27699.1617
0.
(Signature or Operator in Responsitid Charge) Date
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
TO THE BEST OF MY KNOWLEDGE.
50050
00010
00400
00310
005M
00530
00300
00600
00665
00610
00095
y
O
h
q
66E
`o
Pi
c
o
y
E
`0
n
rn
o
0
O
d
m
¢
T'
4
P
min
iT
o.
U
c
m
o
F
a
y
g
S
m
m
0
v
a
b
c
d
a
Z
6
h
o
n
8
a
H
m
w
=
c
5
m
o
HRS
YIN
MGD
°C
Sid Units
Ib./da
m L
I Ib./da
m /L
m L
I m L
I <
I m L
moh/cm
10700
24
Y
16.8
10.31
7.51
1892
3082
2.5
1
1-
1424
2
0700
24
Y
17.4
10.4
7.7
2119
3483
3.8
1
1402
3.0700
24
N
18,
.
4
0700
24
N
17.7
5
0700
24
Y
17.4
11.2
TO
1698
2322
6.1
i
1490
6
0700
24
Y
14.1
12.6
7.5
1458
1882
2.3
4.07
0.401
1.20
1482
70700
24
Y
18.3
14,6
7.4
2747
3968
1.2
1416
8
0700
24
Y
18.6
12.9
7.8
2358
3723
3.6
1430
9
07
24
Y
66.5
' 11.6
7.8
1871
3715
27
1449
10
0700
24
N
15.3
11
0700
24
N
117
12
07DOI
24
Y
9.9
7.5
7.5
1139
1404
3.5
1513
13
07001
24
Y
15..6
7.5
7.3
1939
2472
2.2
1518
14
07001
24
Y
18.0
- -8.1
7.4
2447
3153
2.7
1427
1507001
24
Y
18.0
9.3
7.6
2537
3753
2.4
145H
16
0700
24
Y
17.4
10.6
7.4
3280
5369
1.1
1525
17
0700
24
N
17.4
18
0700
24
N
17.7
19
0700
24
B
16.8
' 7.5
- 23
3531
6936
12
1451
20
0700
24
B 1
14.4
8.3
7.51
2126
6485
2.7
1614
21
0700
24
B
15.0
9.5
7,61
3378
<
5567
1.7
1514
22
0700
24
B
20.4
11.5
7.5
5240
9187
1.2
1521
23
0700
24
HOL
20 a
24
0700
24
N
20.1
25
0700
24
N
18.6
26
0700
24
HOL
17.1
770700
24
Y
16.3
5.3
7.2
4364
6321
1.6
1560
28
0700
24
Y
17.1
5.1
7.5
4835
7273
1.7
1532
29
0700
24
Y
17.7
8,1
7.3
4960
6936
2.9
1 564
30
0700
24
Y
18.6
7.8
7.3
4995
7136
1.9
1589
31
0700
24
N
18.6
Aver a
17.0
9.5
2946
4708
2.5
4,07
0.401
120
1494
Maximum
20.4
14.6
7.8
5240
9187
6.1
4.07
0.401
1,20T
1614
Minimum
9.9
5.1
7.2
1139
1404
1.1
4.07
0401
1,20
1402
Comp (CYGrab (G)
G
G
C
C IC
G
C
C
C
G
LM22Lhly Limit
28
6-9
6852
16800

25M336465
03. 31:54 p.m. 10-25-2012 4/11
Effluent 001
NPDES No.: NC 0000752
IDischarge No.: 001
jMonjK Jan iYear 2012
Facility Name Ka stone Pa er
JOBS& IV
ICounty Halifax
Operator in Responsible Charge (ORC): Thomas C. Puryear
Grade: IV Phone [phone]
Certified Laooratones: 1 Ka ne Pa r Laboratory, Certificate # 183: 2 Meritech Laboratory Certificate # 165
Check Box 4 ORC Has Changed Persons Collecting Samples: Paul Kinnin
Mail ORIG'L + 1 COPY W
Central Files Div. e, &St'
Div. of Water Qualityx (ire/
1617 Mall Service Center (Signature of Operator in Respc6dible Charge) Date
Raleigh, NC 27699-1617 BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
TO THE BEST OF MY KNOWLEDGE,
50050
00010
00400
00310
00500
00530
00300
00600
00665
00610
00095
H
3F
'm
c
w
rn
O
2
Q
C
E
=
0
ry
0
2
N
m
N
g
C
rn
rn
°
N
?
x
`0
m
=N
N
a
R
c
o
HRS
YIN
MGD
°C
Std Units
lb./day
m L
I Ib./da
m /L
/L
<
mglL
moh/cm
1
0700
' 24
NL
18.3
2
0700
24
HOL
13.8
3
07DO
24-
Y
13,2
71
- 7.3
3721
$284:
2:8
1650
4
0700
24
B
12.6
1.8
7.1
3583
7461
5.4
1685
5:0700.24
B
12.9
5,1
7,7
3324
5594
39
1609
65700
24
B
12.9
5.6
7.6
3486
5057
3.1
1674
7
0700
24
N
12:9
8
0700
24
N
12.9
9
0700
_ 24
Y
12.9
8.7
7.3
3228
5487
1.2
1704
10
0700
24
1 Y
1 12.6
8.01
7.31
2995
4939
0.8
7.60
0.5441
1.70
1693
11
0700:
> 24
Y
12.0
<' 9.3
7.3
3720
6725
> 1:0
1678
12
0700
24
Y
12.6
9.5
7.5
3457
5780
2.0
1688
13
07DO
24 '
Y
;':12;8
' 9:7
7.2
3352
6885
_1.1
1687
14
0700
24
N
12.6
215
0700
. 24 ,
- N
22.0
-
16
0700
24
Y
11.7
6.1
7.5
2752
5660
1.6
1678
17
0700
' 24
Y
12:0
6.9
7.5
2722
5404
' 1.3
1708
18
0700
24
Y
12.0
9.1
7.5
2442
5404
1.9
1664
190700
24 1
Y 1
11.4
7,01
7.51
211:1
4849
2.3
1691
20
0700
24
Y
12.3
7.6
7.4
2708
5745
1.1
1676
21
0700
, 24
IN
> >12.9
22
0700
24
N
11.7
23
0700
24:
Y
10.a
6A
7.5
1738
3783
2.2
1676
24
0700
24
B
13.8
7.5
7.4
2256
5524
0.7
1664
25
0700
24
Y
14.4
8,6
7.3
3219
5885
0.9
1595
26
0700
24
B
14.4
8.8
7.4
3110
55241
1,1
1654
27
0700
24
Y
18.0
11.5
7.4
4579
7656
0:8
<
1645
28
0700
24
N
15.6
29
0700
: 24
N
L 15,0
30
0700
24
Y
15.3
9.8
7.3
3547
6125
1.1
1651
310700
24
Y
15.3
_9.4
7.3
3624
7273
1.0
1647
Avera a
13.4
7.8
3130
5764
1.8
760
0.544
1
1.70
1667
Maximum
18.3
11.5
7.7
4579
7656
54
. 760
0.544
1.70'
1706
Minimum
10.8
1.8
71
1738
3783
0.7
7.60
0.544
1.70
1595
Comp (C)/Grab(G)
G
G.
C
C'
C
G.MonthlyLimit
28
6-9
6852
16800

2525336465
03:32. 21 p.m. 10-25-2012 5/11
Effluent 001
NPDES No NC 0000752
Discharge No.: 001
Month: Mar Year: 2012
FacilityName: Ka stone Paper
Class: IV
lCounty Halifax
Operator in Responsible Charge (ORC): Thomas C. Puryear
Grade: IV Phone [phone]
Certified Laboratories. i Ka stone Paper Laboratory, Certificate # 183; 2 Meritech Laboratory Certificate # 165
Check Box f ORC Has Changed Persons Collectin Samples: Paul Kinnin
Mail ORIG'L . 1 COPY to:
Attn: Central Files
Div. of Water Quality
1617 Mail Service Center (Signature of Operator in Responsible rge) Date
Raleigh. NC 27699-1617 BY THIS SIGNATURE. I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
TO THE BEST OF MY KNOWLEDGE.
50050
00010
D0400
00310
00500
00530
00300
00600
00665
00610
00095
o
q
5
6
m
O
O
°
s
E
i
h
tY
R
i
8
O
m
0
m
2
t
g'
:a
r°-
S
M
z
5
z
p
o
HRS
Y/N
MGD
°C
Std Units
lb./day
m L
I lb./day
I m /L
m /L
I m L
I <
L
pmoh/cm
1
0700
24
Y
16.8
12.9
7.31
3587
7566
. 1.0
1740
2
0700
24
Y
17.4
13.7
7.41
3613
8272
1.2
1731
3
0700
24
N
17.4
4
0700
24
N
17.7
55700
24
Y
17.4
11.9
7 3
. 3773
7981
1.2
-
1731
6
0700
24
Y
12.3
9.0
7.4
2934
6258
2.7
7.74
0.470
1.60
1764
7
0700
'24
Y
15.9
9.8
7.1
3461
7161
121
1667
8
0700
24
Y
16.5
12.2
7.1
3564
7018
0.8
1742
9
0700
24
1 Y
1 16.5
14A
7.2
3674
1 70181
1.0
1743
10
0700
24
1 N
1 16.2
11
0700
24
1 N
1 1&
12
0700
24
1 Y
15.0
13.6
7.21
3315
6755
0.9
1
1739
130700
24
Y
15.0
14.5
7.2
3265
6630
0,8
1730
14
0700
24
Y
14.7
172
7.1
3371
7724
0.6
1696
15
07DO
24
Y
19.2
17.3
7.2
4500
8006
' 0.13
1713
16
0700
24
Y
20.7
19.1
7.3
4903
8977
0.5
1731
170700
24
N
20.4
18
0700
24
N
20.4
19
0700
24
Y
-20.4
19.9
7.4
4509
8167
0:6
1733
20
0700
24
Y 1
20.4
21.2
7.4
4407
1
83371
0.9
1730
210700
24
Y
20.1
22.6
7.2
4342
88IR51
0.71
1713
22
0700
24
8
20.1
21.51
7,21
4593
8214
0.3
1729
23
07DO
24
Y
20.1
2211
7.3f
4459
8046
0.4
1718
24
0700
24
N
204
25
0700
24-
N
20.7.
26
0700
24
Y
21.0
2001.731
4343
8232
0.5
1
17DO
27
0700
24
Y
20.4
17.61
731
4468
8337
1.1
1704
28
0700
24
Y
20.1
16.5
7.3
4342
7376
0.6
1689
29
0700
24
Y
21,0
18.9
7.3
5132
9282
1.3
-
1693
30
07001
24 1
3
21.3
19.4
7.4
4690
1
71061
1.8
1695
31
700
24
N
20.4
Average
18.4
16,6
4056
7788
0.9
7.74
0,470
1.60
1720
Maximum
21.3
22.6
7.4
5132
9262
27
7.74
0.470
1,60
17"
Minimum
12.3
9.0
7.1
2934
6258
0.3
7.74
0.470
160
1667
Comp C)/Grab (G)
G
G
C
C
C
G
C
C
C
G
Monthl Lima
28
6-9
6852
16800

2525336465 03:32:49 p.m. 10-25-2012 6111

03:33:04 p.m. 10-25-2012
2525336465
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`2525336465 03:33:41 p.m. 10-25-2012 10/11
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of Days

KAPSTONB
KRAFT PAPER CORPORATION
A DIvisIon of KAPSTONE PAPER AND PACKAGING CORPORATION
100 Gaston Road Roanoke Rapids, NC 27870
kapstonepapeccom
May 9, 2012
Mr. Mack Wiggins
Surface Water Protection Section
NCDENR
1628 Mail Service Center
Raleigh, N.C. 27699-1628
Dear Mr. Wiggins:
1 1 2012
This letter is in response to Notice of Deficiency letters that we received from Mr. Danny Smith
concerning a frequency violation while measuring our effluent temperature. We were told by Mr.
Smith to contact you if we had any questions about the notices.
We generate our MR-l's using several different Excel spreadsheets to input the accumulated monthly
data which is then sent to the state. In November of 2011 we switched from Microsoft Office 2003
to Office 2007 and also began using Windows 7. We tried to make sure that all data, macros and
spreadsheets involved in the preparation of the MR-1's transferred correctly. With the receipt of
your letter we found out that we did have an issue. It appears that MR-1 date line No.5 on the
effluent (001) sheet did not copy the macro to automatically input the effluent temperature for that
day from the spreadsheet. We have corrected the software issue and everything appears to be
working as it should.
The letters we received from Mr. Smith stated that data was missing on 03/10/12 and 12/10/11. Both
of these dates are Saturdays and therefore do not require data. The actual missing data was for
03/05/12 and 12/05/11. We discovered that temperature data was also missing from 01/05/12. The
reason the other months did not show missing data was because the 5d' day of these months fell on a
weekend. I have included revised Effluent MR-1's for the aforementioned months that includes the
missing data. I have also included copies of the raw temperature data from our daily (hand written)
workbook for those missing days.
I am aware that the Notices of Deficiency do not require a formal response but compliance is very
important to this facility and to our Corporation so I felt that it was prudent to provide you with an
explanation. Since the effluent temperature data for those dates did exist, Kapstone requests that the
Notice's of Deficiency be removed from our records. If you have any questions please don't hesitate
to contact me at 252-533-6237 or [e-mail]
Sincerely,
t
Antra 1.Co lins
Mill Manager
xc: Paul Kinnin Mike Knudson
Neal Davis Ben White
Chris Puryear

Effluent 001
NPDES No.: NC 0000752
Discharge No.: 001
JIVIonth: Dec IYear 2011
Facility Name: Kapstone Pape
I
lClass, IV
County: Halifax
Operator in Responsible Charge (ORC): Thomas C. Puryear
Grade: IV Phone [phone]
Certified Laboratories: 1 International Paper Laboratory, Certificate # 183; 2 Oxford Laboratories EPA 37221
Check Box if ORC Has Changed U JlPerson(s) Collecting Samples: Paul Kinnin
Mail ORIG'L + 1 COPY to: n
Attn: Central Files
Div. of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
0
(Signature of Operator in Responsibfd Charge) Date
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
TO THE BEST OF MY KNOWLEDGE.
50050
00010
00400
00310
00500
00530
00300
00600
00665
00610
00095
0
0
E
E
F-
>
c
Q
O
2
O
m
in
c
O
Ta
Q
O
U
O
d
O
3
LL
a
E
n
N
m
N
m
r
N
-6
o
r/J
O
j
rp
S
m
x
C
N
o
Z
m
ro-
2
L
m
N
z
N
Z
o
E
_
0
V
HRS
Y/N
MGD
°C
Std Units
lb./day
mg/L
lb./day
mg/L
mg/L
mg/L
<
mg/L
pmoh/cm
1
0700
24
'Y
16.8
10.3
7.5
'1892
3082
':2.5
1424
2
0700
24
Y
17.4
10.4
7.7
2119
3483
3.8
1402
30700
24
N
18.0
4
0700
24
N
17.7
50700
24
Y
17.4:
112
7.6
:1698
2322
` 6.1
1490
6
0700
24
Y
14.1
12.6
7.5
1458
1882
2.3
4.07
0.401
1.20
1482
7107001
24
1 Y
18,31
14.6
7.4
2747
3968
''1.2
1
1416
8
0700
24
Y
18.6
12.9
7.8
2358
3723
3.6
1430
9
0700
24
Y
165
11,6
7.8
1871
3715
2.7
1449
10
0700
24
N
15.3
110700
24
N
117
12
0700
24
Y
9.9
7.5
7.5
1139
1404
3.5
1
1513
13
0700
24
Y
15,6
7.5
7.3
1939
2472
;; 2.2
1516
14
0700
24
Y
18.0
8.11
7.41
2447
1
3153
2.7
1
1
1427
151070011
24
1 Y
18.0
9.3
7.6
2537
3753
< 2.4
1458
16
0700
24
Y
17.4
10.6
7.4
3280
5369
1.1
1525
170700
24
N
17.4
18
0700
24
N
17.7
190700
24
B
16.8
7.5
7.3
3531
6936
'<:1 2
1451
20
0700
24
B
14.4
> 8.3
7.5
2126
6485
2.7
1614
21
0700
24
B
15.0
9.5
> 7.6
3378
5567
< 17
1514
22
0700
24
B
20.4
11.5
7.51
5240
1 9187
1.2
1521
2310700
24
HOL
20.4
2410700
24
N
20.1
25
0700
24
; `N
18.6
26
0700
24
1 HOL
1 17.1
27
0700
24
1 Y
16.31
5.3
7.2
4364
6321
1.6
1560
28
0700
24
1 Y
17.1
5 1
7.5
4835
7273
1.7
1532
29
0700
24
Y
17.7
8,1:;
7.3
4960
-
6938
f<2 9
1564
30
0700
24
Y
18.6
7.8
7.3
4995
7136
1.9
1589
31
0700
24
N
18.6
Average
17.0
9.5
2946
4708
2.5
4.07
0.401
1.20
1494
Maximum
20.4
14.6:
7.8
:524Q
9187
& 1
4.07
0.401
1.20
1614
Minimum
Comp (C)/Grab (G)
9.9
5.1
G '
7.2
'. G
1139
C
I C'I
1404
C
1.11
%.G
4071
-C
04011
I C
1.20
1402
Monthly Limit
28
6-9
6852
16800
I'd 1 I N12

Effluent 001
NPDES No.: NC 0000752
Discharge No.: 001
Month: Jan Year: 2012
Facility Name: Kapstone Paper
Class: IV
JiCounty7 Halifax
Operator in Responsible Charge (ORC): Thomas C. Puryear
Grade: IV Phone [phone]
Certified Laboratories: 1)Ka stone Pa er Laboratory, Certificate # 183; 2 Meritech Laboratory Certificate # 165
Check Box if ORC Has Changed Person(s) Collecting Samples: Paul Kinnin
Mail ORIG'L + 1 COPY to: . 11 /l
Aftn: Central Files
Div. of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
C,
(Signature of Operator in Respc /dible Charge) Date
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
TO THE BEST OF MY KNOWLEDGE.
50050
00010
00400
00310
00500
1 00530
00300
00600
00665
00610
00095
o
E
E
H
E
Q
0
O
«
n
c
o
Em
F
0
O
=
C
2
O
m
>,
N
3
O
a
12
Sy'
E
n
U
c
N
m
o
O
m
F
N
-6
m
m
°
6
tq
c
a
N
c
w
N
c
w
c
z
m
�-
0
c
n
0
o
Q.
m
F-
m
y
=
z
c
0
o
o
E
j
C
HRS
Y/N
MGD
°C
Std Units
lb./day
mg/L
lb./day
mg/L
mg/L
mg/L
<
mg/L
Nmoh/cm
10700
24
N
18.3
2
0700
24
HOL
13.8
30700
24
;;Y
1$.2
7.1
7.3
3721
5284
2.8
1650
4
0700
24
B
12.6
1.8
7.1
3583
7461
5.4
1685
50700
24
B
12.9
5.1
7 7
3324
5594
3.9
1609
6
0700
24
B
12.9
5.6
7.6
3486
5057
3.1
1674
7107001
24 1
N
12:9
8
0700
24
N
12.9
90700
24
Y
12.9
8.7
7.3
; 3228
5487
'; 1.2
1
1704
10
0700
24
Y
12.6
8.0
7.3
2995
4939
0.8
T601
0.544
1.70
1693
110700
24
Y
12.6
9.3
7.3
3720
6725
10
1
1678
12
0700
24
Y
12.6
9.5
7.5
3457
5780
2.0
1688
130700
24
Y
12,6
9.7
7.2
;3352
$885
1 1
1687
140700
24
N
12.6
1510700
24
1 N
1 12.0
16
0700
24
1 Y
11.71
6.1
7.5
2752
5660
1.6
1678
170700
24_
Y
12.0
6.9
7.5
2722
5404
1.3
1706
18
0700
24
Y
12.0
9.1
7.5
2442
5404
1.9
1664
190700
24
Y
11.4
7.0
7.5
2111
4849
? 2.3
1
1691
20
0700
24
Y
12.3
7.6
7.4
2708
5745
1.1
1
1676
210700
24
N
12.9
22
0700
24
N
11.7
23
0700
24
Y
10.8
6.4
7.5
1738
1 37831
2.2
1676
24
07001
24
1 B
13.8
7.5
7.4
2256
1 5524
0.7
1664
25
0700
24
` Y
14.41
8.6
'' 7.3
3279
1 5885
O,9
>
1595
26
0700
24
B
14.41
8.8
7.4
3110
1 5524
1.1
1654
27
0700
=24
Y
18.01
11.5
7.4
4579
1 7656
0.8
1645
28
0700
24
N
15.6
29
0700
24
N
15.0
30
0700
24
Y
15.3
9.81
7.3
3547
6125
1.1
1651
3110700
24
Y
1523
9.4
7.31
3624
7273
% 1.5
1647
Avera a
13.4
7.8
5764
1.8
7.60
0.544
1.70
1667
Maximum
18.3
11.5
7656
< &4
7.60
0.544
1.70
1706Minimum
101
1.8
G..G
t74579
3783
0.7
7.60
0.544
1.70
1595Comp(C)/Grab(G)
GMonthl
Limit
28
6-
16800

Effluent 001
NPDES No.: NC 0000752
IDischarge No.: 001
IMonth7 Mar Year: 2012
Facility Name: Kapstone Paper
I
jClass7 IV
County: Halifax
Operator in Responsible Charge (ORC): Thomas C. Puryear
Grade: IV Phone [phone]
Certified Laboratories: 1)Kastone Paper Laboratory, Certificate # 183, 2)Meritech Laboratory Certificate # 165
Check Box if ORC Has Changed
Mail ORIG'L+ i COPY to:
Attn: Central Files
Div. of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Paul Kinnin
(Signature of Operator in Responsible C66rge) Date
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
TO THE BEST OF MY KNOWLEDGE.
50050
00010
00400
00310
00500
00530
00300
00600
00665
00610
00095
E
E
f
i
N
n
C
v
H
O
C
OU
¢ O
N
3
o
LL
m
10
E
U
N
Yl
N
O
o
v
0
c
O
N"
a
2
y
o
?
0
O
L
o
E
Nm
Z
c
m
2
Z
E o
E
Z.
u5
Uc
HRS
Y/N
MGD
°C
Std Units
lb./day
mg/L
lb./day
mg/L
mg/L
m /L
<
mg/L
pmoh/cm
1
0700
24
Y
16.8
12.9
7.3
3587
7566
: 1.0
1740
2
0700
24
Y
17.4
13.7
7.4
3613
8272
1.2
1731
3
0700
24
N
174
4
0700
24
N
17.7
50700
24 '
Y
17.4
11.9
' 7.3
3773
7981
1.2
1731
6
0700
24
Y
12.3
9.0
7.4
2934
6258
2.7
7.74
0.470
1.60
1764
7
0700
24
Y
15.91
9.8
' 7.1
3451
>
7161
1.1
1667
8
07001
24
Y
16.5
12.2
7.1
3564
7018
0.8
1742
9
0700
24
Y
165
14.4
7.2
3674
7018
;' 1.0
1743
10
0700
24
N
16.2
11
0700:
24
N
15,0
12
0700
24
Y
15.0
13.6
7.2
3315
6755
0.9
1739
13
0700
24
Y
15,0
14.5
72
3265
6630
0.8
1730
14
0700
24
Y
14.7
17.2
7.11
3371
7724
0.6
1
1696
1510700
24
Y
19.21
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakhild, P. E. Dee Freeman
Governor Director Secretary
April 25, 2012
Mr. Neal Davis
Kapstone Kraft Paper Corporation
1100 Gaston Road
Roanoke Rapids, North Carolina 27870
Subject: Compliance Inspection
Kapstone Kraft Paper Corporation
Permit No. WQ0000436, WQ0013516
& WQ0021577
Halifax County
Dear Mr. Davis:
The Aquifer Protection Section of the Division of Water Quality inspected the Kapstone facility landfill,
land application and distribution operations as referenced above by Permit on April 17, 2012. Thank you
for your time and consideration during the inspection.
As discussed at time of inspection, land application is not occurring. Instead residuals are being land
filled. Fly ash is being distributed as a potting soil amendment as discussed at time of inspection. The
treatment system components were found to be operational and well maintained.
The land fill condition was found to be favorable with no signs of any stability issues. Phase one has a
healthy vegetative stand and is being maintained. Phase two also was found to be well maintained.
The Division is reviewing the ground water monitoring data and will respond to Kapstone with the
findings of the review. Mr. Eric Rice is the person to contact for any additional questions you may have
pertinent to the review status.
If I can be of assistance or you have questions about this letter, please contact me by phone (919) 791-
4240 or via email.
Sincerely,
cc: APS/RRO
Halifax County Health Department
1617 Mail Service Center. Raleigh. Nonh Carolina 27699.1617
Location: 512 N. Salisbury St. Raleigh. North Carolina 27604
Phone. [phone] � FAX [phone]
Internet'. www.ncwaleraualty ura
An Equal Opportunity \ Anirnnative Action Errployer
Z�
Steve Kaltenbach
Environmental Specialist
stephen.kaltenbachna ncdenr.eov
PgagVED
APR 2 6 1UV
EO14S
Nose Carolina
Naturally

NCDENR
North Carolina Department of Environment and
Beverly Eaves Perdue
Governor
Division of Water Quality
Charles Wakild, P.E.
Director
April 30, 2012
CERTIFIED MAIL 7011 1570 0000 6988 7518
RETURN RECEIPT REQUESTED
Anita J. Collins
Kapstone Kraft Corporation.
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: NOTICE OF DEFICIENCY
NOD-2012-MV-0001
Kapstone Kraft Corporation
Permit No.NC0000752
Halifax County
Dear Ms. Collins:
Natural Resources
Dee Freeman
Secretary
A review of the March, 2012 Discharge Monitoring Report (DMR) revealed a violation of
the following parameter(s) at Outfall 001:
Parameter
Date
IMeasuring Frequenc—y7
Violation
emperature, Water
Peg. Centigrade
3/10/12
X week
requency Violation
Thank you for your attention to this matter. Remedial actions should be taken to correct the
cause(s) of this violation. Unresolved violations may lead to the issuance of a Notice of
Violation and/or assessments of civil penalties.
If you have any questions or require any additional information, please contact Mack Wiggins at
[phone] or at E-Mail Mack. [e-mail].
N. C. Division of Water Quality
Raleigh Regional office
1628 Mail service Center. Raleigh. NC 27699-1628
Phone: [phone] FAX: [phone]
Customer Servioe: 1-877-623-6748
Internet: www,ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
None
i Carolina
NIZA14u!!y

Page 2 of 2
Kapstone Kraft Corporation
Halifax County
incer y,
Danny Smi
Regional upervisor
Surface Water Protection Section
cc: RRO File Copy
DWQ Central Files

LV 3-
RIAMED
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor Director Secretary
April 30, 2012
CERTIFIED MAIL 7011 1570 0000 6988 7549
RETURN RECEIPT REQUESTED
Anita J. Collins
Kapstone Kraft Corporation.
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: NOTICE OF DEFICIENCY
NOD-2012-MV-0002
Kapstone Kraft Corporation
Permit No.NC0000752
Halifax County
Dear Ms. Collins:
A review of the December, 2011 Discharge Monitoring Report (DMR) revealed a violation of
the following parameter(s) at Outfal1001:
Parameter
I Date
Measuring Frequcncy
I Violation
emperature, Water
Peg. Centi rade
12/10/11
X week
requency Violation
Thank you for your attention to this matter. Remedial actions should be taken to correct the
cause(s) of this violation. Unresolved violations may lead to the issuance of a Notice of
Violation and/or assessments of civil penalties.
If you have any questions or require any additional information, please contact Mack Wiggins at
(919) 7914200 or at E-Mail Mack. [e-mail].
N. C. Division of Water Quality
Raleigh Regional Office
1628 Mail Service Center, Relegh, NC 276W1628
Phone: 919-791 A2001 FAX: [phone]
Customer Service: 1-877-623-6748
Internet: wwwmcwaterquality.org
An Equal Opportunity \ Affirmative Action Employer
Nae hCarolina
oNaturally

Page 2 of 2
Kapstone Kraft Corporation
Halifax County .
L�9�'n �y�r
Danny Sm'
Regional upervisor
Surface Water Protection Section
cc: RRO File Copy
DWQ Central Files

Hall, Mandy
From: Donald Crowder [[e-mail]]
Sent: Thursday, April 26, 2012 11:15 AM
To: Hall, Mandy
Cc: [e-mail]; [e-mail],
[e-mail]
Subject: High Flows at Wastewater Treatment Plant
Categories: Red Category
Mandy,
Below is a summary of the message I left you today.
Thank you for all you help.
Donald Crowder
April 26, 2012
Between 3AM and SAM we had 1.25" of rain. Upon arrival at the WWTP, Bobby Lyons found high flows
entering the plant. Sludge depth in #2 clarifier was 11 ft. Bobby slowed the speed of the influent pumps down
and called me (7:40AM) to advise of situation at WWTP. Bobby advised that no sludge was carrying over the
clarifier weirs; however some floc was carrying over. Advised Bobby to shut down oxidation ditch drives down
and to monitor sludge level in #2 clarifier and that I would be at the WWTP shortly. Upon arriving at the water
treatment plant advised Bill Hux that we need to start filling the #1 clarifier to prevent sludge washout. Prior
to pull splitter gate to fill #1 clarifier, effluent flow was 2.0 mgd, after pulling splitter gate effluent flow
dropped back to >.8 mgd and dropping. Had floc carryover passing through the chlorine basin for roughly 2.5
hours. When I left the WWTP at 10:OOAM to go to the water treatment plant to call and email you the effluent
flow had dropped back to .6 mgd.
1

WD NR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Ms. Mary Lee Ransmeier
Environmental Programs Manager
Kapstone — Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Division of Water Quality
Coleen H. Sullins Dee Freeman
Director Secretary
November 3, 2011
Subject: Compliance Evaluation Inspections
Kapstone Wastewater Treatment Plant
NPDES Wastewater Permit NC0000752 and
NPDES Stormwater Permit NCS000106
Halifax County
Dear Ms. Ransmeier:
I, Dave Parnell of the Raleigh Regional Office of the Division of Water Quality (DWQ), conducted two
Compliance Evaluation Inspections (CEI) on October 31, 2011, consisting of the NPDES Wastewater
and Stormwater inspections. The assistance of Mr. Chris Puryear, Operator in Responsible Charge
(ORC), Mr. Neal Davis, Backup Operator in Responsible Charge (BORC) and Mr. Paul Kinnin,
Laboratory Manager, was appreciated. Please review the attached Basinwide Information Management
System (BIMS) inspection checklists summarizing the inspections.
Below is a list of findings and recommendations developed from the inspections:
I. NPDES Wastewater Permit Inspection:
1. The current permit was reissued May 9, 2007 and expires March 31, 2012, The application
process was discussed with Mr. Puryear and an application has been submitted to DWQ.
2. The 28.0 MGD wastewater treatment plant consists of the following units: mechanical bar
screen, primary clarifier, emergency holding pond, sludge lagoon, aeration basin and three
stabilization ponds. Discharges from the plant are into the Roanoke River, which is Class C
waters in the Roanoke River Basin. The facility is classified as a W W-4, and both Mr.
Puryear and Mr. Davis are W-W 4 certified.
3. The inspection began in the plant office and proceeded to the laboratory. All paperwork was
well organized and easily accessible. Discharge Monitoring Reports were reviewed for
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone]
Intemet www.ncwaterquality org 1628 Mail Service Center Raleigh. NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/1 o % Post Consumer Paper
One
N,,p,�rtthhCarolina
r/Vlltl=11,0
Customer Service
877-623-6748

Kapstone NPDE 3stewater and Stormwater Permit Complianc 3luation Inspections
compliance with permit limits and monitoring requirements. Chain -of -custody records were
available and found to be in order. A contract lab is used by this facility (Meritech). Sample
storage in Laboratory was kept at a temperature of 1.0 degrees Celsius. The effluent
composite sampling is flow proportional and the refrigerator temperature was not within
required limits. Mr. Puryear will replace the thermometer that appeared to be
malfunctioning. The effluent flow meter was last calibrated on July 21, 2011 and the flow
meter on the main ditch to the clarifier was calibrated on July 21, 2011.
4. The overall condition of the facility was found to be good, which is indicative of good
housekeeping practices. The mechanical bar screen was in acceptable condition. Debris is
removed to the on -site landfill as needed.
5. The Primary Clarifier was inspected and found to be in good condition and functioning
properly. There was no sign of weir blockage, short circuiting or evidence of floating sludge.
6. The flow from the Primary Clarifier is gravity fed to the aeration pond. Nutrients are added
to effluent at this point before entering the ponds. There appears to be ample aeration. (One
aerator is offline for maintenance but this is an acceptable practice). There were no dead
spots or excessive foaming on the surface of the ponds.
7. From the aeration pond the effluent flows to a series of lagoons. The surface of the ponds
was free of vegetation as was the shoreline.
8. The final stabilization pond discharge has a bar screen and a composite sampler and from
there the flow is discharged to the river. The effluent pipe observed and appeared to be in
good condition. There was a trace of foam on the surface of the river at the discharge point,
but was in the acceptable range.
II. NPDES Stormwater Permit Inspection:
1. The permit was available for review during the CEI.
2. Secondary containment is required at this facility and was inspected during the site visit and
found to be in compliance.
3. The Stormwater Pollution Prevention Plan (SP3) was reviewed by during the inspection. As
we discussed, the following deficiencies were discovered:
• Include a Stormwater facility Inspection Program.
Please be specific and. follow the requirements set forth in your permit when revising your plan. All
requirements of the permit must be components contained in the plan. The relocated Representative
Outfall Status (ROS) was discussed and pointed out to me during the inspection. Newly installed
BMPs were observed during the inspection and will help with the quality of the Stormwater

NPDES yrlmolday Inspection Type
11 12
0000752 1 11/10/3, I17 18I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

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- Permit: NC0000752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 10/312011 Inspection Type: Compliance Evaluation
Laboratory
Yes No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■ ❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
■ n
n
❑
# Is the facility using a contract lab?
■ fl
Cl
0
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
n
n
■
n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
n
■
Q
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
■
❑
❑
❑
Comment: 19.8C
Operations & Maintenance Yes No
NA
NE
Is the plant generally clean with acceptable housekeeping?
■
❑
❑
❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge
■
Cl
❑
❑
Judge, and other that are applicable?
Comment:
a c
—'
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?
■
n
n
❑
Is disposal of screening in compliance?
■
n
11
❑
Is the unit in good condition?
■
❑
❑
O
Comment:
Flow Measurement - Influent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
fl
Is flow meter calibrated annually?
■
Q
fl
fl
Is the flow meter operational?
■
n
n
n
(If units are separated) Does the chart recorder match the flow meter?
rl
❑
■
❑
Comment: Calibrated 7/21/11
Flow Measurement - Effluent
Yes No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
❑
❑
❑
Page # 4

Permit: NC0000752 Owner - Facility:
Inspection Date: 10/31/2011 Inspection Type:
Roanoke Rapids Mill
Compliance Evaluation
'
Flow Measurement - Effluent
Yes
No
NA
NE
Is the flow meter operational?
0110
❑
(If units are separated) Does the chart recorder match the flow meter?
000
❑
Comment:
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
❑
❑
❑
Is the wet well free of excessive grease?
■
n
❑
❑
Are all pumps present?
■
❑
n
n
Are all pumps operable?
■
n
n
n
Are float controls operable?
n
n
n
■
Is SCADA telemetry available and operational?
n
n
n
■
Is audible and visual alarm available and operational?
n
n
❑
■
Comment:
Primary Clarifier
Yes No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
n
n
n
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
n
n
n
Are weirs level?
■
n
n
❑
Is the site free of weir blockage?
■
n
n
n
Is the site free of evidence of short-circuiting?
■
n
n
n
Is scum removal adequate?
■
n
n
n
Is the site free of excessive floating sludge?
■
n
n
n
Is the drive unit operational?
■
n
n
❑
Is the sludge blanket level acceptable?
n
F1
F1
■
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
n
n
n
■
Comment:
Aeration Basins
Yes No
NA
NE
Mode of operation
Ext.
Air
Type of aeration system Surface
Is the basin free of dead spots? ■ n n n
Are surface aerators and mixers operational? ■ n n ❑
Are the diffusers operational? n O ■ n
Page # 5

Permit: NC0000752
Inspection Date: 10/31/2011
Owner - Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
Aeration Basins
Yes
No
NA
NE
Is the foam the proper color for the treatment process?
■
n
n
n
Does the foam cover less than 25% of the basin's surface?
■
n
0
n
Is the DO level acceptable?
■
n
n
Cl
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
n
n
n
Comment: 30 of 31 aerators functioning this date.
Lagoons
Yes
No
NA
NE
Type of lagoons?
Facultative
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Serves
# Is a re -circulation line present?
■ n
n
n
Is lagoon free of excessive floating materials?
■ n
❑
n
# Are baffles between ponds or effluent baffles adjustable?
■ n
❑
❑
Are dike slopes clear of woody vegetation?
■ n
n
n
Are weeds controlled around the edge of the lagoon?
■ n
n
n
Are dikes free of seepage?
■ n
n
n
Are dikes free of erosion?
■ n
0
n
Are dikes free of burrowing animals?
■ n
0
n
# Has the sludge blanket in the lagoon (a) been measured periodically in multiple locations?
❑ 0
n
■
# If excessive algae is present, has barley straw been used to help control the growth?
■ n
n
n
Is the lagoon surface free of weeds?
■ n
n
El
Is the lagoon free of short circuiting?
■ n
n
n
Comment: Periodically the lagoons are drained down and dredged.
Pump Station - Effluent
Yes No NA
NE
Is the pump wet well free of bypass lines or structures?
■ Cl
n
p
Are all pumps present?
■ ❑
n
n
Are all pumps operable?
■ n
n
n
Are float controls operable?
n n
n
■
Is SCADA telemetry available and operational?
n n
n
■
Is audible and visual alarm available and operational?
n n n ■
Page # 6

Permit: NC0000752
Inspection Date: 10/3112011
Pump Station - Effluent
Comment:
Effluent Sampling
Is Composite sampling Flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
Owner -Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: Sampled on a time basis.
Effluent Pipe
Is right of way to the ouffall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Comment:
Yes No NA NE
Yes No NA NE
o■nn
■ n n n
■nnn
■nnn
■nnn
■ n n ❑
Yes No NA NE
■nnn
■nnn
nn■n
Yes No NA NE
■ ❑ ❑ ❑
nnn■
nnn■
n n n ■
nnn■
nnn■
nnn■
Page u 7

Regional Field Inspectors Check List for Field Parameters
Name of site to be Inspected: �(', ,s/o.�
oa C
Date: /D
Field certification # (if applicable):/
Inspector:
NPDES #: A7L000v7sL Region:=`
I. Circle the parameter or parameters performed at this site.
esidual Chlorin ettleable Solid(WQ onductivit�eemperature
II. Instrumentation:
A. Does the facility have the equipment necessary to analyze
field parameters as circled above?
1 A pH meter
Ysls�
No
2 A Residual Chlorine meter
Yes
No
3. DO meter
Yee
4. A Cone for settleable solids
Yees/
No
5. A thermometer or meter that measures temperature.
No
6 Conductivity meter
Yegl�
No
III. Calibration/Analysis:
1. Is the pH meter calibrated with 2 buffers and
checked with a third buffer each day of use?
Yes�
No
2. For Total Residual Chlorine, is a check standard
analyzed each day of use?
Yes
New
3. Is the air calibration of the DO meter performed
each day of use?
Yexr-�
No
4. For Settleable Solids, is 1 liter of sample
settled for 1 hour?
Yes
No IA/A
5. Is the temperature measuring device calibrated
annually against a certified thermometer?
Y
No
6. For Conductivity, is a calibration standard
analyzed each day of use?
Y
No

Permit: NCS000106
SOC:
County: Halifax
Region: Raleigh
Compliance Inspection Report
Effective: 08/01/09 Expiration: 07/31/14 Owner: Kapstone Kraft Paper Corporation
Effective: Expiration: Facility: Roanoke Rapids Mill
100 Gaston Rd
Contact Person: Mary lee Ransmeier
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title:
Inspection Date: 10/31/2011 EntryTime: 10:00 AM
Primary Inspector: David R Parnell
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Roanoke Rapids NC 27870
Phone: [phone]
Certification:
Exit Time: 01:00 PM
Phone:
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000J 06 Owner - Facility: Kapstone Kraft Paper Corporation
Inspection Date: 10/31/2011 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
Page:2

Permit: NCS000106 Owner - Facility: Kapstone Kraft Paper Corporation
Inspection Date: 10/31/2011 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■ D
# Does the Plan include a General Location (LISGS) map?
■ D D p
# Does the Plan include a "Narrative Description of Practices'?
■ D D n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■ ❑ D
# Does the Plan include a list of significant spills occurring during the past 3 years?
■ n D n
# Has the facility evaluated feasible alternatives to current practices?
■ rl
# Does the facility provide all necessary secondary containment?
■ n n n
# Does the Plan include a BMP summary?
■ fl D D
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■ D D D
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■ D D f1
# Does the facility provide and document Employee Training?
■ D D D
# Does the Plan include a list of Responsible Party(s)?
■ n n D
# Is the Plan reviewed and updated annually?
■ 0 D Cl
# Does the Plan include a Stormwater Facility Inspection Program?
D ■ D D
Has the Stormwater Pollution Prevention Plan been implemented?
■ D D D
Comment: Update SPPP to include a specific Stormwater Facility Inspection Program.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ O O
Comment:
Analytical Monitoring
Yes No NA NE
Has the facility conducted its Analytical monitoring?
■ o
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■ O O
Comment:
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■ D 0 D
# Were all outfalls observed during the inspection?
■ D n n
# If the facility has representative outfall status, is it properly documented by the Division?
■ D D D
# Has the facility evaluated all illicit (non stormwater) discharges?
■ D D D
Comment: Observed BMPs on site to improve quality of Stormwater
Page3

United States Environmental Protection Agency
EPA Washington, D.C. 20460 Form Approved.
OMB No. 2040_0057
ntpr Cmm�II^nCp InSnpf th i Rannh APProval expires 8-37-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I N l 2 1 51 31 NC0000752 111 12I 11/10/31 117 18I r� l 191 c 1 20 U
,. IJ U l Remarks IJ lJ
Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 QA-----------Reserved----_
671 1
-J `.J 69 701 I 71 I ty I 72 (N I 731L1J 11 74 75I I I I I I I 18C
Section B: FacilityData u
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)
Roanoke Rapids Mill 10:00 AM 11/10/31 07/08/01
100 Gaston Rd Exit Time/Date Permit Expiration Date
Roanoke Rapids NC 27870 01:00 PM 11/10/31 12/03/31
Name(s) of Onsite Representative(s)Mtles(syPhone and Fax Number(s) I Other Facility Data
Thomas C Puryear/ORC/252-533-6237/
i
me, Address of Responsible OfficiaVTitie/Phone and Fax Number
ry Lee Ransmeier, 100 Gaston Rd Roanoke Rapid NC 27870//252-533-6398/252533 51nNo t�
Section C: Areas Evaluated DuringInspection (Check onlythose areas evaluated)
Permit 0 Flow Measurement E Operations & Maintenance Records/Reports
Self -Monitoring Program ■ Sludge Handling Disposal E Facility Site Review Effluent/Receiving Waters
Laboratory ■Storm Water
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
]David RRiPamell W ;� �t ® RRO WO//919-791-4260/
Date
10-3 )-1I
S re of Manage O A.Rey6weAgency/Office/Phone and Fax Numbers Date
a��i✓ ten. Al
'/.1.7)%�
EPA Form ^0-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

Kapstone NPDES :tewater and Stormwater Permit Compliance cation Inspections
The Kapstone wastewater treatment plant is considered to be in compliance with the NPDES wastewater
and stormwater permits at the time of these inspections. Please continue to be diligent in adhering to the
requirements of the permits. If you have any questions concerning this report, please do not hesitate to
contact me at 919-791-4200.
Sincerely,
� A-tq
Dave Parnell
Environmental Specialist
Raleigh Regional Office
Attachment: CEI Inspection Reports
cc: Central Files
SWP/RRO Files

AG�MAIL
KNEW
D
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Ms. Mary Ransmeier
100 Gaston Rd.
Roanoke Rapids, NC 27870
Coleen H. Sullins
Director
April 27, 2010
Subject: Whole effluent toxicity test results
Roanoke Rapids Mill (Kapstone) WWTP
NPDES Permit # NC0000752/001
Halifax County
Dear Ms. Ransmeier,
Dee Freeman
Secretary
The aquatic toxicity test using 24-hr composite samples of effluent discharged from Roanoke Rapids Mill
WWTP has been completed. Roanoke Rapids Mill (Kapstone) WWTP has an effluent discharge permitted
that is 28.0 million gallons per day (MGD) entering the Roanoke River (7Q10 of 1120 CFS). Whole
effluent samples were collected on April 6 and April 9 by Vicki Webb for use in a chronic C'eriodaphnia
duhia pass -fail toxicity test. The test using these samples resulted in a pass. l'oxicity test infomlation
follows.
Test 7"ype 3-13rood Ceriexlaphnia dabia chronic pass fail
Test Concentrations 3.7%
Test Result
Control Survival
Control Mean Reproduction
Test Treatment Survival
Treatment Mean Reproduction
First Sample pH
First Sample Conductivity
First Sample Total Residual Chlorine
Second Sample pH
Second Sample Conductivity
Second Sample Total Residual Chlorine
Pass
100%
29.3
92%
30.5
7.52 SU
1327 micromhos/cm
<0.1 mg/L
7.65
1342 micromhos/cm
<0.1 mg/L
If you have any questions concerning the toxicity sampling or results, please contact me either by phone
at [phone] or email at vicki.webb(a)nedenr.gov.
Sincerely,
Vicki Webb
Environmental Specialist
Nye Carolina
cc: RRO files tltCalr/
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: viw.v.ncwaterqualBy.org 1628 Mail Service Center Raleigh. NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Acton Employer— 50% Recycleo/10% Post Consumer Paper

Aam
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
September 28, 2011
ANITRA J COLLINS
MILL MANAGER
KAPSTONE KRAFT PAPER CORPORATION
100 GASTON ROAD
ROANOKE RAPIDS NC 27870
Dear Ms. Collins:
SEP29201;
Rain
Dee Freeman
Secretary
Subject: Receipt of permit renewal application
NPDES Permit NC0000752
Roanoke Rapids Mill
Halifax County
The NPDES Unit received your permit renewal application on September 27, 2011. A member of the
NPDES Unit will review your application. They will contact you if additional information is required to complete
your permit renewal. You should expect to receive a draft permit approximately 30-45 days before your existing
permit expires.
If you have any additional questions concerning renewal of the subject permit, please contact Sergei
Chemikov at [phone].
Sincerely,
Dina Sprinkle
Point Source Branch
cc: CENTRAL. FILES
Raleigh Regional Office/Surface Water Protection
NPDES Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: 91 M07-63001 FAX: [phone] Customer Service: "77-623-6748 NorthCarolina
Internet: www.ncwaterquality.org An Equal Opportunity 1 Affinnafive Action Employer Qt✓/1
ural y

14
,IS
KAPSTONE
September 8, 2011
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:
KAPSTONS
KRAFT PAPER CORPORATION
A Divisbn of KAPSTONE PAPER AND PACKAGING CORPORATION
100 Gaston Roatl Roanoke Rapids, NC 27870
kapstonepaw com
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, 2012). The Purpose of this correspondence is to request renewal of
NPDES Permit No. 0000752 for the Kapstone Kraft Paper mill located in Roanoke Rapids, North
rurnt;nn Fnelnsed 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
III Application Form 2C — Wastewater Discharge Information
• Mill Water Balance Diagram
• Wastewater Treatment System Diagram
• Wastewater Treatment System Narrative Description
Qc���d�
SE
P 2 7 2011
DENR-WATER QUALITY
POINT SOURCE BRANCH
• Sludge Management Plan Narrative Description
• Results of Priority Pollutant Analysis
• Results of Analysis Required under Part V-B and V-C of Form 2C
Since the last renewal of NPDES permit NC0000752, the only major change to the wastewater
treatment system has been the elimination of discharge No. 003. This discharge consisted of
non -contact cooling water associated with the production of turpentine. The formally directly
discharged non -contact cooling water is presently used in various areas of the mill as a source of
hot water. The re -use of this hot water has reduced the total amount of water withdrawn from
the Roanoke River used in our paper making process.
During the chemical analysis of discharge 002 (non -contact evaporator cooling water), the
presence of Bis(2-ethylhexyl)phthalate (DEHP)was detected at the microgram per liter level.
We have investigated where this material could have entered the waste stream from our process
and cannot find a source. The only explanation for a source of the DEHP was the equipment

used to collect the analytical sample. The temperature of the sample, when collected, was
approximately 120 degrees F. A Nalgene carboy was used to collect the composite sample and
Nalgene tubing was used to connect the sample pump and sample stream to the carboy. A
sample of distilled water was collected using the same sample train and when analyzed the
presence of DEHP was detected. It is possible that the DEHP leached from the carboy and/or
the sample tubing. We collected a grab sample of the cooling water using a stainless steel
container and immediately transferred it to glass bottles. The analysis of the grab sample
showed that the DEHP was not present in the cooling water.
In the same non -contact cooling water sample, from discharge No. 002, the presence of
chloroform was also detected in the microgram per liter level. An investigation of where the
chloroform could have entered the sample was conducted. It was determined that the material
used to clean the sample container prior to collecting the sample could have caused the
chloroform to be present. The discharge was re -sampled using a new sample container and the
results of the analysis showed that no chloroform was detected.
It should be noted that this facility does not manage storm water under our NPDES discharge
permit. The mill has an individual Storm Water permit (NCS000106) that was renewed in 2009
and has an expiration date of July 31, 2014.
If you have any questions regarding the permit renewal application please don't hesitate to call
Mike Knudson at 252-533-6280 or Chris Puryear at 252-533-6237.
Sincerely,
A �0��r
Anitra J. Collins
Mill Manager
xc: Neal Davis
Mike Knudson
Chris Puryear
Paul Kinnin (w/o attachments)

International Paper, Roanoke Rapids Mill
NPDES Permit N00000752 Renewal Application
Table of Contents
EPA Form 3510- l (General Information Form)
Topographic Map of Mill Site and Discharge Points - Appendix A
Application Form 2C — Wastewater Discharge Information - Appendix B
General Facility/Outfall Information
Outfall 001
Outfall 002
Mill Water Balance Diagram - Appendix C
Wastewater Treatment System Diagram -
Wastewater Treatment System Narrative Description - Appendix D
Sludge Management Plan Narrative Description —
Results of Priority Pollutant Analysis - Appendix E
Results of Analysis Required under Part V-B and V-C of Form 2C —
Additional Chloroform and DEHP analysis for Outfall 002 -

Please print or type in the unshaded areas only Fnr Anoroved. OMB No. 2040-0086. Approval expires 5-31-92
fill-in areas are s
aced for eure type i.e., iz cna
U.B. ENVIRONMENTAL PROTECT ON AGENCY
I. EPA I.D. NUMBER
FORM
n
GENERAL INFORMATION
a
""
NCD044737807
n
D
1
\-EPA
Consolidated Permits Program
F
x ,3 ,4
is
GENERAL
Read
the "General Instructions" before startin .
iel
LABEL ITEMS
GENERAL
has been provided,
a preprinted label hire heart provided,
I. EPA I.D. NUMBER
affix rt in the de reT111 ed "Parr Review the
a
inforaticn carehro arty it is
n
incorrect cross through and enter the
III. FACILITY NAME
p
bbeelow. Also d anyeof �hpe p apt infield dames
absent the area ,fo the I9 of the lab p�
�sp that should
PLEASE
space information
age
PLACE LABEL IN THIS SPACE appear) please provide It In the proper fill.
V. FACILITY
It the label iss cam lets
in arceaatta) belowct
lust
MAILING LIST
you. corn
w�hStar
II, V and -w-pt notneed
m be
completed re�gafill .Complete all items
the
inswctl�orreh fa dettalPedovitt descriptions
VI. FACILITY
LOCATION
and for the lectaI authorization under which
Ihls data Is'oll'lected.
II. POLLUTANT CHARACTERISTICS
p ate rou o elermine a er you needto submit any permit application ors tote you answer yes an
Mark *X* in the box in the third column
questions, you must submit this form and the supplemental from listed in the parenthesis following the question.
"no' to each you need not submit any of these fors. You may anawer'no* If your activity Is
the supplemental form Is attached. 11 you answer question,
it r uirementis see Section C of the instructions. See also Section D of the Instructions for definitions of bold-feced
IFIC QUESTIONS
excHresults
ARK•X'
MARK'X' SPECIFIC QUESTIONS FORN
FORM YES NO
YES NO "4 H
ATTACHED
Bepu ow tree meM •
n a discharge to waten of tics
❑
X ❑
s or t ac ry air exa try a
proposed) Include a concentrated an and
or aqua" animal
❑
X)
feWing oppe�ration
f•elllty which results In a dischargeie
production
to waters of the U.S.? (FORM2BIx1
1T is
C. c cumen reau n
to watxa of iM U.S. other then
)(
)(
s propose ao IY ant sedescribedX
M A a B above) which witl result In a dbcltar9e
za
x7
ell charges
those described In A or B above? FORM 2C
ls wabn of IM U.S.? FORM 2D
or will you nett at info acI i in us1 a or
22
a or t n act 1y Vest store, a apnea
hazardous wastes? (FORM 3)
❑
X ❑
you
munKlpN effluent below the lowermost stratum
containing, within one Quarter mile of tfta wall
❑
X
❑
bon underground aoumes d tldnking wateR
31
3s
FOAM 4
b
m
Cuyor YW inl t • ac enY
produced water other fluids which are brought to
❑
X ❑
you ar yW n e t a ec iry u a
special proceDaes luth ire mining of su8er by the
seen process, solution mining of minerals, In
❑
X
❑
the surface In connection will conventional oil or
natural gas production, infect fluids used for
situ combustion of food fuel, w recovery of
energy? (FORM dy
enhanced Brigat dl or natural gas, or hied
geolMmul
fluids for storage of liquid hydrocarbons?
38
3•
❑
30
X ❑
FORM 4
• ac a pro 8 ovary source
which ls one of the 28 Industrial categories listed
t ec a p • on•ry source
Industrial p tegodu
which n at orls of th• and
listed In lM Instructions end which will potentially
❑
X
❑
In the Instructions and which will potentially emk
100 tons per year of any irk pollutonl regulated
emir 260 tons ppeer year of any all pollutant
regulated under the Clean Air Ad and may adect
under the Clean AIr Act and me agent or be
located In ant am? FORM 5
or be [mated In an attainment am? FORM 5
43
a
da
40
dt 41
lit. NAME OF FACILITY
o SKIP Kapstone Kraft Paper Corporation, Roanoke Rapids Mill
I
1
as
IV. FACILITY CONTACT
A. NAME A TITLE le
trier a title B. PHONE are. code A no.
o Puryear, Chris, Environmental Engineer 111 252 533 6237
2
as a 51 5x 53
V. FACILITY MAILING ADDRESS
A. STREET OR P.O. BOX
9 100 Gaston Road
a Df I —A
S. CITY OR TOWN
C. STATE D. ZIP CODE
Roanoke Rapids
NC 27870 FSEP 2 7 2011
4
t e
n 42 , at
VI. FACILITY LOCATION ATER QunuTY
A. STREET ROUTE NO. OR OTHER SPECIFIC IDENTIFIER T SOURCE BRANCH
100 Gaston Road
_
s
a
a
B. COUNTY NAME
Halifax
40
C. CITY OR TOWN
g
D. STATE E. ZIP CODE F. COUNTY CODE
Roanoke Raplda
NC
27870
52 54
e
at 11
47 sl
to
,e
a0
r (INTINI furl (IN RE' VEKSE

CONTINUED FROM THE FRONT -
VII. SIC CODES 4-di it, in order o1 priority)B.
SECOND
A. FIRST
16 (specify) '
2611 (specify)
Pulp mill
7 Paper and Allled Products s
° e
1 1 17
C. THIRD
D. FOURTH
2621 (specify) ' 2631 (specify)
Paperboard mill
175Paper mill 1e 6 e
17
16 1
VI --.OPERATOR INFORMATION B. Is the name listed in Kom
A. NAME VIII-A also the owne>rr
pstone Kraft Paper Corporation X YES ❑ NO
. PHONE area code 8 no.PERATOR Enter the to letter Into the answer
533 6237
M = PUBLIC (abler then federal w Slate) p (specify52
O=OTHER(speoly) a 1e 2i21
NKapslone
E STREET OR PO BOXston
MCODEIX,.IINDIAN
RoadF.
CITY OR TOWN24 G. STATEAN LANnoke
Rapids NC l ty boateES X NO
°0 °2 +
X. EXISTING ENVIRONMENTAL PERMITS
A. NPOES (DIschargm to Surface Water D. PSD Air Emissions from Prigoosed Saecee
NC000075? 9 P
9 N
is 1 17 is /5 1s 17 is
B. uic undo an;f2t�W of Fluids E.OTHER s(Specify)
°Air Ouallty (01649T48) Storm Water
9 U 9 (NCS000106)
,s 17 is 30 15 is 17 isC. RCRA HazaWastes E. OTHER s eci (Specify)
I ° Landfill (W00000436) Land
OP3516tion
T
9 9 ( )
to n ie 16 1 17 i w
XI. MAP
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map mu
intake and discharge structures, each of itst
a
show the outline of the facility, the location of each of its existing and proposed
hazardous waste treatment, storage, or disposal facilities, and each well where N injects fluids underground. Include all springs,
rivers and other surface water bodies In the map area. See instructions for precise reauirements.
XII. NATURE OF BUSINESS(provide a brief description)
Rapids high quality unbleached Kraft paper and
The Kapstone Paper Corporation, Roanoke mill produces
The mill Is Integrated Including power generation, chemical recovery, pulp production and final
paperboard.
paper and paperboard manufacture.
XIII. CERTIFICATION see instructions
familiar with the information submitted in this application and
1 certify under penalty o/ law that I have personally examined and am
that, based on my inquiry of those persons immediately responsible for obtaining the information contained in
all attachments and
the application, I believe that the information is true, accurate and complete. I am aware that there are significant penalties for
submitting/alas In/ormat Includl the sslbi1 of line and Imprison C DATE SIGNED
A. NAME 8 OFFICIAL TITLE (type or pnnf) B IGNA URE ^
9 0Q, If
Anitra J. Collins, Mill Mana er
COMMENTS FOR OFFICIAL USE ONLY
c
C Se
e 1 If

Appendix A

Dt LORML
IR
17/4 w

Appendix B

Appendix E

'Ily
Vter
r.26 MGD
-low
=rom
Liver
17.9 MGD
Paper Mill Influent
Water in
Paper Mill
W -.1 Cold Water Tank
r
Evapotaum to Almosphoc
33 GPM
Water is Paper
5.8 MGD
a.7 GPM
Paper Mill Etta,,, 5.8 MGD
Wood Pulpmill
263 GPM 0.36 MGD
F Out
Secondary Blow Heat
Primary Turp Condenser 0.22 MGD
Pulp Mill Secondary Reflux Condenser 0.30 MGD PWp Wll Pttlumt 2.32 MGD
Influent Turp Condenser Cooling Water 1.44 MGD
oat
i
IN Condensate Collection Cnodeaaa¢ Collectwn En wttl 050 MGD
r---
Hard-pipe Feed Tank 0.50 MGD
Utility
oat
Utility IN B Evaporators Surface Condenser 0.92 MGD utvur W1 u<d
Influent r -' - - - - C Evaporators Surface Condenser 1.51 MGD
Boiler Water Makeup 0.50 MGD
Slaker Stacks 0.07 MGD
Ash Pond 0.14 MGD
Non -Contact i IN
3.15 MGD
Influent Non -Contact Water Nwloouct wamr m Rrver SPA MGD
Surface Condenser Overflow 5.8 MGD
Rynwater 0.07 MGD
Waste
water
Treatment
Flow to River
107 MGD
Recycle ---------------
Recycle - - - - - -'- -
Roanoke Rapids Mill Water Balance Revised August,2011

Roanoke Rapkk
Wastewater Treatment Plant
\ 4 - 30 hp kIrU2 ueru/ors
J _ ]A hp All f32 uerulors
.. _ 74 ho hlah •peed nv rface ucrslors
Swfmwuu D'nch
Site plan - Roanoke Rapids

Appendix D

Kapstone
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 be 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 0.8 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.) We also have the capability of adding defoamer to the aeration pond
influent flow to prevent excessive foam. 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 Bimey 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 (W00000436) onsite landfill.
July, 2011

Kapstone
Roanoke Rapids Mill
NPDES Permit Renewal
During the treatment process solids accumulate in the first stabilization pond. This pond
is periodically dredged to remove those solids to assure optimum treatment efficiency.
Dredging from the Stabilization ponds are pumped to the old sludge pond where it is
allowed to decant. Leachate from the old sludge pond, and the onsite landfill, flow by
gravity into the aeration pond and treated along with the other wastewater.
July,2011

September 13, 2011
Kapstone Kraft Paper Corporation
Roanoke Rapids Mill
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 is about 40% solids, is then taken to the mill's
onsite landfill (Permit Number W00000436). Periodically the sludge from the sludge
presses are applied to permitted lands under Land Application Permit No. W00013516.
All filtrate from the sludge press is returned to the head of the wastewater plant for
treatment.
Whenever 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.

From
EzzrooU
SUMMIT
ENVIRONMENTAL TECHNOLOGIES, INC.
Ana/yflcal Laboratorlea
ErrwtmT
C.li�t Me 1A Mo Collected Aaehis
071492 1114727-01 13-JJ-11 Bmmlda
C1im1Me lah.JON Calimed Aael#a
071492 1114727.01 13-JJ-11 Gro= Mphm
08/0812011 10:24 1504 P.008/008
August05,2011
Client: Meritech Environmental laboratories
Address: 642 Tarow Rd.
Rai&Ael NC 27320
Received: 7/20/201 l
Project N: NIA
Reesi uain March Mghod DE LQQ an Anted
NO ___ MW L 300.0 1 OS 01-Aup-11 ND
&mi
u +/- 2.77
[faits MO& Malhcd QE
Pcl/I L EPA 1
900.0
LQG Rn Aash s
3 31-Akil MD
C11.1
lah fw
Cdllocud AnsMs
RUDA
U911
Ma9ss Mdhd
DE
LQG
Rn Awym
071492
1114727-01
13-1ui-11 Grow Bets
20.43 +/- 2.19
Pc10
L
EPA
1
4
31-1J-11 MO
Psstleldes 404
CHmt IN
I [Do
Callrswd Auallle
Rah
LIALM
Match
AnalYd
071492
1114727-01
13-JW-11 Delp - BHC
NO
pg/L
L
608
1
0.2
22JUI-11 KMG
071492
1114727-01
13Jul-11 4,4' - DOE
NO
pg/L
L
608
1
0.2
22-JJ-11 KMG
071492
1114727-01
13-JJ-11 4,4' - DDT
NO
P9/L
L
608
1
0.2
22dW-I1 KMG
071492
1114727-01
13-JJ-ll Aldrar
NO
pg/L
L
606
1
0.4
22-1J-1 l KMG
071492
1114727-01
13-1J-11 Alpha - BHC
NO
I.WL
L
606
1
0.2
22-Jul-11 KMG
071492
1114727-01
13-IJ-11 Alpha-Endosulfan (1)
NO
pg/L
L
608
1
0.2
22-M-11 KMG
071492
1114727.01
13-1u1-11 Bets - BHC
NO
Pg/L
L
608
1
1
22-Jul-11 04G
071492
1114727-01
13.1J-11 4,4' - DDO
NO
WA
L
608
1
10
22-1J-11 KMG
071492
1114727-01
13-M-11 Chlordane
NO
P9/1-
L
608
1
0.2
22-JJ-11 KMG
071492
1114727-01
13-JW-11 Toxaphene
NO
pg/L
L
608
1
0.2
22-1u111 KMG
071492
1114727-01
13-JW-11 Dlddrin
NO
pg/L
L
608
1
0.2
22-Jul-11 KMG
071492
1114727-01
13-JW-11 EndasWfsn SW/ate
NO
Pg/L
L
600
1
0.2
22-Ad-11 KMG
071492
1114727-01
13-1J-11 Endrin
NO
pWL
L
608
1
02
22-Jul-11 KMG
071492
1114727-01
13-AA-11 Endrin Aldehyde
NO
pg/L
L
608
1
0.2
22-Jup11 1040
071492
1114727-01
13-J&11 Gans - BHC
NO
pg/L
L
608
1
0.2
22-/J-11 KMG
071492
1114727-01
13-JJ-11 HeptaWor
NO
pWL
L
608
1
0.4
22-1u1-11 KMG
071492
1114727-01
13-JJ-I1 Hephtldor Epoxide
NO
Pg/L
L
608
1
0.2
22-Jul-11 KMG
071492
1114727-01
13NA-11 Seta-EndoeJhn (tr)
NO
pg(L
L
600
1
0.2
22JJ-ll 104G
071492
1114727.01
13-Jul-11 Er&M Ketcne
NO
pg/L
L
608
1
02
22-AA-11 KMG
071492
1114727-01
13JJ-11 MettwyclJor _
NO
pWL
L
608
1
0.2
22-Jul-11 V4G
Client MO
I-b-1D8
Collmod Anahls
Read
Untie
bl"
Mdhd
OP
LOG
R® Asehral
071492
1114727-01
13-Jul-112,3,7,8=TCDD_--,_NO
pg/I
L
16139
2
1
28-JU-11 CM
01m, mm Uk" Cmllmt A Asalyte Rweh ldolu Mttk Mdhd ul LQG Roes An,
071494 _ 1114727-02 13Jul-11 Bromlds _ _ NO mg/I L 300,0 1 04 OS-Aug-11 MO
Pages 4
"Ana/ytical Inteyrlty" • EPA Certified - NELAP Certified
33tO Win Street - Cuyahoga Fells, Ohio 44223 • Phone: [phone] • Fax: [phone]
Web Site wwwsettak.com

Meritech, Inc.
Environmental Laboratory
f Laboratory Certification No.165
Neal Davis
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870
Report Date:
Date Sample Rcvd:
8/8/11
7/14/11
Meritech Work Order#
07141192 Sample: Sample#1 Effluent Comp
Limit
7/13-14/11
Method
Parameters
COD
$ggyj
127 mg/L
Analysis Date
7/15/11
Reporting
15 mg/L
EPA410.4
Chloride
29.7 mg/L
7/18/11
0.10 mg/L
SM 4500 Cl C
Fluoride
0.2 mg/L
7/15/11
0.1 mg/L
SM 4500FC
Color, Adjusted
245 C.U.
7/16/11
SM 2120E
MBAS
0.46 mg/L
7/15/11
0.10 mg/L
SM 5540C
Ammonia, Nitrogen
0.7 mg/L
7/25/11
0.1 mg/L
EPA 350.1
TKN
3.72 mg/L
7/22/11
0.20 mg/L
EPA 351.1
Nitrate/Nitrite Nitrogen
0.37 mg/L
7/20/11
0.10 mg/L
EPA 353.2
Nitrogen, total
4.09 mg/L
7/25/11
0.20 mg/L
EPA 353.2
Sulfate
785 mg/L
7/18/11
5 mg/L
SM 426C
Sulfite
<2.5 mg/L
7/15/11
2.5 mg/L
SM 4500S03B
Aluminum, total
0.310 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Antimony, total
0.053 mg/L
7/22/11
0.025 mg/L
EPA 200.7
Arsenic, total
< 0.010 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Barium, total
0.078 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Beryllium, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Boron, total
0.200 mg/L
7/25/11
0.050 mg/L
EPA 200.7
Cadmium, total
0.014 mg/L
7/22/11
0,002 mg/L
EPA 200.7
Chromium, total
0.015 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Cobalt, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Copper, total
0.011 mg/L
7/22/11
0.002 mg/L
EPA 200.7
Iron, total
0.126 mg/L
7/22/11
0.025 mg/L
EPA 200.7
Lead, total
< 0.010 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Magnesium, total
7.73 mg/L
7/26/11
0.100 mg/L
EPA 200.7
Manganese, total
0.387 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Mercury, total
< 0.0002 mg/L
7/20/11
0.0002 mg/L
EPA 245.1
Molybdenum, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Nickel, total
< 0.010 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Phosphorous, total
2.38 mg/L
7/22/11
0.020 mg/L
EPA 200.7
Selenium, total
0.025 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Silver, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Thallium, total
< 0.020 mg/L
7/22/11
0.020 mg/L
EPA 200.7
Tin, total
< 0.025 mg/L
7/22/11
0.025 mg/L
EPA 200.7
Titanium, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Zinc, total
< 0.010 mg/L
7/22/11
0.010 mg/L
EPA 200.7
TOC
14.7 mg/L
7/21/11
2 mg/L
SM 5310C
Sulfide
< 0.1 mg/L
7/19/11
0.1 mg/L
SM 4500 SD

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
WCon'[�ct: Neal Davis
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870
Report Date:
Date Sample Rcvd:
8/8/11
7/14/11
Meritech Work Order #
07141192A Sample:
Sample #1 Effluent
Comp
7/13-14/11
Parameters
Result
Analysis Date
Reporting Limit
Method
EPA 608
Attached
7/22/11
EPA 624
Attached
7/20/11
Trip Blank
Attached
7/20/11
EPA 625 BNA
Attached
7/26/11
Meritech Work Order #
07141193 Sample:
Sample #1 Effluent Grab
7/14/ 11
Parameters
Result
Analysis Date
Reporting •Limit
Method
Cyanide, total
< 0.005 m L
g/
7 11
27 / /
0.005 mg/L
1 col / 100 ml
EPA 335.4
SM 9222D
Fecal Coliform
13 col/100 mL
< 5 mg/L
7/14/11
7/18/11
5 mg/L
EPA 1664A
Oil & Grease (HEM)
Phenols, total
< 0.010 mg/L
7/19/11
0.010 mg/L
EPA 420.1
g6gaVED
AUG 15 2011
EOS
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320

MERI TECH,
INC.
ENVIRONMENTAL LABORATORIES
A Division of water Technology and
Controls, Inc.
Client: Kapstone Paper
Meritech ID: 07141192
Project: 608
Extraction: 7/20/11
Client Sample ID: #1 Eff Comp
Analysis: 7/22/11
Sample Collection: 7/13-14/11
Analyst: Summit
EPA 608 - Orp-anochlorine Pesticides
Parameter Result
Aldrin
< 0.4 mg/L
a-BHC
< 0.2 mg/L
b-BHC
< 1 mg/L
< 0.2 m L
g-BHC
< 0.2 mg/L
4,4'-DDD
< 10 mg/L
4,4'-DDE
<0.2 mg/L
4,4'-DDT
< 0.2 mg/L
Dieldrin
< 0.2 mg/L
Endosulfan 1
< 0.2 mg/L
Endosulfan 11
< 0.2 mg/L
Endosulfan sulfate
< 0.2 mg/L
Endrin
< 0.2 mg/L
Endrin aldehyde
< 0.2 mg/L
Heptachlor
< 0.4 mg/L
Heptachlor epoxide
< 0.2 mg/L
Toxaphene
< 0.2 mg/L
Aroclor - 1016
< 0.0002 mg/L
Aroclor - 1221
< 0.0002 mg/L
Aroclor - 1232
< 0.0002 mg/L
Aroclor- 1242
<0.0002 mg/L
Aroclor - 1248
< 0.0002 mg/L
Aroclor - 1254
< 0.0002 mg/L
Aroclor- 1260
<0.0002 mg/L
Chlordane
< 0.2 mg/L
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320

Client:
Project:
Client Sample ID:
Sample Collection:
Parameter
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Benzyl butyl phthalate
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
2-Chloronaphthalene
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anlhracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,31-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
1,2-Diphenylhydrazine
MERI TECH, INC,
Environmental Laboratories
A Division of Water Technology and Controls, Inc.
Kapstone Paper
Meritech ID#:
07141192
625
Analysis:
07/26/11
Sarri I Effluent
Extraction:
07/18/11
07/14/11
Analyst:
MC
Dilution Factor:
1
EPA 625 SEMIVOLATILE ORGANICS
RM11 Parameter
<10 ug/L
Fluoranthene
<10 ug/L
Fluorene
<10 ug/L
Hexachlorobenzene
<50 ug/L
Hexachlorobutadiene
<10 ug/L
Hexachlorocyclopentadiene
<10 ug/L
Hexachloroethane
<10 ug/L
Indeno(1,2,3-cd)pyrene
<10 ug/L
Isophorone
<10 ug(L
2-Methylnaphthalene
<10 ug/L
Naphthalene
<10 ug/L
Nitrobenzene
<10 ug/L
N-Nitrosodimethylamine
<10 ug/L,
N-Nitrosodi-n-propylamine
< 10 ug/L
N-Nitrosodiphenylamine
<10 ug/L
Phenanthrene
<10 ug(L
Pyrene
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug(L
_- _
<10 ug(L
�4-Chloro-3-methyiphenol
<10 ug/L
Chlorophenol
<10 ug/L
2,4-Dichlorophenol
<10 ug(L
2,4-Dimethylphenol
<50 ug/L
2,4-Dinitrophenol
<10 ug/L
4,6-Dinitro-2-methylphenol
<IO ug/L
enol
�N�itrophenol
<10 ug/L
4-Nitrophenol
<10 ug/L
Pentachlorophenol
<10 ug/L
Phenol
<10 ug(L
2,4,6-Trichlorophenol
<10 ug(L
I hereby certify that I have reviewed and approve these data.
<10 ug/L
<10 ug/L
<10 ug(L
<10 ug/L
<50 ug/L
<10 ug(L
<10 ug(L
<10 ug(L
<10 ug/L
<10 ug/L
<10 ug(L
<10 ug(L
<10 ug/L
<10 ug(L
<10 ug/L
<10 ug(L.
<10 ug/L
<10 ug(L
<10 ug(L
<10 ug(L
<10 ug(L
<50 ug/L
<50 ug/L
<10 ug/L
<50 ug(L
<50 ug(L
<10 ug/L
<10 ug/L
t p��
Laboratory Representative
'q
642 Tamco Road' Reidsville, NC 27320
,nnn, 1An A9A4 Or, * r11R1 IA7-1522 Fax

MERI TECH, INC.
Environmental Laboratories
A Division of Water Technology and Controls, Inc.
Chris P ear Meritech ID#: 07141192
Client: Analysis: 07/20/11
Project: Sample# 1 Effluent VWV
Client Sample ID: Sample # I Effluent Analyst: Dilution Factor: 1
Sample Collection: 07/14/11
EPA 624 VOLATILE ORGANICS
Parameter
Result
< 1.00 ug/L
Benzene
Dichlorobromomethane
< 1.00 ug/L
Dichlorodifluoromethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L"
Methyl Bromide
< 5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chloroethane
< 5.00 ug/L
2-Chloroethyl vinyl ether
< 5.00 ug/L
Chloroform
< 1.00 ug(L
Methyl Chloride
< 5.00 ug/L
Chlorodibromomethane
< 1.00 ug(L
1,2-Dibromoethane
< 1.00 ug/L
1, 1 -Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug(L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
1,1-Dichloroethylene
< 1.00 ug/L
trans-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
cis-1,3-Dichloropropylene
< 1.00 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
< 1.00 ug/L
Tetrachloroethylene
< 1.00 ug(L
Toluene
< 1.00 ug/L
1,1,1-Trichloroethane
< 1.00 ug/L
1,1,2-Trichloroethane
< 1.00 ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoromethane
< 5.00 u<
Vinyl chloride
5.00 ug/L
Additional COmMOan s
<50.0 ug/L
Acrolein
Acrylonitrile
<10.0 ug/L
Bis(chloromethyl)ether"
<10.0 ugIL
I hereby certify that 1 have reviewed and approve these data.
• Based on library search.
�! • Tt C�
Laboratory Representative

Client:
Project:
Client Sample ID:
Sample Collection:
MERI TECH, INC.
Environmental Laboratories
A Division of Water Technology and Controls, Inc.
Chris Puryear
Sample # l Effluent
Trip Blank
07/ 14/ 11
Meritech ID#:
Analysis:
Analyst:
Dilution Factor:
EPA 624 VOLATILE ORGANICS
parameter
< 1.00 up/L.
Benzene
Dichlorobromomethane
< 1.00 ug/L
< 1.00 ug/L
Dichlorodifluoromethane
< 1.00 ug/L
Bromoform
< 5.00 ug/L
Methyl Bromide
< 1.00 ug/L
Carbon Tetrachloride
< 1.00 up/L.
Chlorobenzene
< 5.00 ug/L
Chloroethane
2-Chlor0ethy1 vinyl ether
< 5.00 ug/L
< 1.00 ug/L
Chloroform
< 5.00 ug/L
Methyl Chloride
< 1.00 ug/L
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
1,1-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< I.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L.
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1,00 ug/L
l,l-Dichloroethylene
< 1.00 ugfL
trans-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
cis-1,3-DichloropropYlene
trans-1,3-Dichloropropylene
< 1.00 ug/L
< 1.00 ug/L
Ethyl benzene
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
< 1.00 ug/L
< 1.00 ug/L
Tetrachloroethylene
< i.00 ug/L.
Toluene
1,1,1-Trichloroethane
< 1 00 up/L.
< 1.00 ug/L
1,1,2-Trichloroethane
< 1.00 ug/L
TrichloroethYlene
<5.00 ug/L
Trichlorofluoromethane
< 5,00 ug/L
Vinyl chloride
Additional Compounds
<50.0 ug/L
Acrolein
<I0.0 ug/L
Acrylonitrile
Bis(chloromethyl)ether
<10.0 ug/L
07141192tb
07/20/11
VWV
I hereby certify that I have reviewed and approve these data.
• Based on library search.
LaboratoryRepresentative
Reidsville, NC 27320

From: 0810812011 M 24 #504 P.007/008
SUMMIT
ENVIRONMENTAL TECHNOLOGIES, INC.
Analyt/cel Laboratories August 05, 2011
Client Meritech Env(rownenul Labmtoria
1 1z CC)
b (6j 1 „T,—n Address: Rai Tama xa
v w ('{- I tJC, Raidm70. NC 21720
V15(2hG OD Z Pwaived: 7/20/201I
Project N: N/A
S.X=LM9
071494
—__�--.----
CJlaut�t
071494
1,1, rDlr
I114727-02
laa.II71
1114727-02
CollwIM Anlaa
13-Jul-11 Gmn AIpM
._
Clllltsld Aoalrie
13-)u1-11 Gran Beta
flgaY
U +1- 2.5
Bg11Y
U +/- 1.72
Lhhl
PWI
LhiM
PWl
Mach MaEad
L EPA
800.0__
Muds mat hud
L EPA
900.0
12e
1
OE
I
LQQ
3
LQQ
4
Bn Alulna
31-)ul-11 t40
an Aaahal
31-h1-11 MO
Peadleldae 006
_-----
---
cli—tWe
071494
Let-!>J17
1114727-02
Cglia1W An -Me
13-1u1-11 Delta - Bl1C
BraWt
NO
UMM
YALU
Maha9
QF
LQQ
8n AOahmt
071494
1114727-02
13Jul-I14,4' - DOE
NO
pg/L
L
608
1
0.2
22-h1-11 KMG
071494
1114727-02
13-3PI.11 4,4' - DDT
NO
Pg/L
L
608
1
0.2
2214-11 KMG
071494
1114727-02
13-3u1.11 Aldnn
NO
PWL
L
608
1
0.2
22Jul-11 KMG
071494
1L14727-02
13-luFlI Alpha - BHC
NO
pg/L
L
608
1
0.4
22-Jul-11 KMG
071494
1114727-02
13-Jul-I1 Alpha-Endosuyan (1)
NO
pg/L
L
608
1
0.2
22-Its-11 KMG
071494
1114727-02
13-)Lt-I1 Beta - BHC
ND
PWL
L
608
1
0.2
22-1W-11 KMG
071494
1114727.02
13-JUF114,4--DOD
NO
P9/L
L
L
606
1
1
22-Akil KMG
071494
1114727-02
13-Jul-11 Chlordane
NO
09/1.
608
1
10
22Jul-11 KMG
071494
1114727-02
13Jul-11 Toxaptw,
NO
Pq/L
L
608
1
0.2
22-luF11 KMG
071494
1114727-02
13-3a-11 DMldrin
ND
pg/L
L
600
1
0.2
22-Jul-11 KMG
071494
1114727-02
13-Jul-II EndaWran Su f to
NO
Pg/L
L
L
608
1
0.2
22-)LA-11 KMG
071494
1114727-02
13Juh11 Endtln
NO
19I1
608
1
0.2
22-Jul-11 KMG
071494
1114727-02
13-3ul-11 Enddn Aldehyde
NO
pg/L
L
608
1
0.2
22Jul- I KMG
071491
1114727-02
13-AA-II Gamma - allC
ND
pg/L
L
L
60e
1
0,2
22-Jul-11 KMG
071494
1114727-02
13-Jul-I1 Heptachlor
NO
P9/1.
608
1
0.2
22-J4-11 KMG
071494
1114727-02
13-Jul-I1 Hepmddor Epwdde
ND
Pg(L
L
L
608
1
OA
22-Jul-11 KMG
071494
1114727-02
13-)ui-11 Bet"ridonee, (11)
NO
PWL
L
606
1
0.2
22-1u1-21 KMG
071494
1114727.02
13-Ju1-11 EndM Ketone
ND
pg/L
608
1
0.2
22-1u1.11 0%
071491
1114727-02
13-hd-1l MetlnxydJor
NO
IW/L
L
608
1
0,2
22-)ul-II KMG
_
--
PWL
L
600
1
0.2
22_]W-II KMG
Clla tMe
071494
LAh M
1114727-02
CgilmW Amlyia
13-Jul-II 2,3,7,8.7CD0
9m11
NO
1111b1 Maids RC;hW
RP
LQfl
Bum Aaahal
P911
L
16139
2
1
28-JuFlI CM
Page a
"Analytical Integrity" • EPA Certified - NELAP Certified
3310 Win Street . Cuyahoga Falls, Ohio 44223 • Phone: [phone] Fax: [phone]
Web Slle: www.setrek.com

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Neal Davis
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870
Report Date:
Date Sample Rcvd:
8/8/11
7/14/11
Meritech Work Order #
07141194 Sample:
Sample #2 Cooling Water
Limit
7/13-14/11
Parameters
COD
Result
< 15 mg/L
Analysis Date
7/15/11
Reporting
15 mg/L
Method
EPA 410.4
Chloride
13.2 mg/L.
7/18/11
0.10 mg/L
SM 4500 Cl C
Fluoride
0.2 mg/L
7/15/11
0.1 mg/L
SM 4500FC
Color, Adjusted
< 25 C.U.
7/16/11
SM 2120E
MBAS
0.16 mg/L
7/15/11
0.10 mg/L
SM SS40C
Ammonia, Nitrogen
< 0.1 mg/L
7/25/11
0.1 mg/L
EPA 350.1
TKN
0.35 mg/L
7/22/11
0.20 mg/L
EPA 351.1
Nitrate/Nitrite Nitrogen
< 0.10 mg/L
7/20/11
0.10 mg/L
EPA 353.2
Nitrogen, total
0.35 mg/L
7/25/11
0.20 mg/L
EPA 353.2
Sulfate
13 mg/L
7/18/11
5 mg/L
SM 426C
Sulfite
< 2.5 mg/L
7/15/11
2.5 mg/L
SM 4500S03B
Aluminum, total
0.077 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Antimony, total
0.040 mg/L
7/22/11
0.025 mg/L
EPA 200.7
Arsenic, total
< 0.010 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Barium, total
0.057 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Beryllium, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Boron, total
1.57 mg/L
7/25/11
0.050 mg/L
EPA 200.7
Cadmium, total
0.015 mg/L
7/22/11
0.002 mg/L
EPA 200.7
Chromium, total
0.017 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Cobalt, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Copper, total
0.002 mg/L
7/22/11
0.002 mg/L
EPA 200.7
Iron, total
0.242 mg/L
7/22/11
0.025 mg/L
EPA 200.7
Lead, total
< 0.010 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Magnesium, total
3.80 mg/L
7/26/11
0.100 mg/L
EPA 200.7
Manganese, total
0.186 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Mercury, total
< 0.0002 mg/L
7/20/11
0.0002 mg/L
EPA 245.1
Molybdenum, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Nickel, total
< 0.010 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Phosphorous, total
2.07 mg/L
7/22/11
0.020 mg/L
EPA 200.7
Selenium, total
0.031 mg/L
7/22/11
0.010 mg/L
EPA 200.7
Silver, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Thallium, total
< 0.020 mg/L
7/22/11
0.020 mg/L
EPA 200.7
Tin, total
< 0.025 mg/L
7/22/11
0.025 mg/L
EPA 200.7
Titanium, total
< 0.005 mg/L
7/22/11
0.005 mg/L
EPA 200.7
Zinc, total
< 0.010 mg/L
7/22/11
0.010 mg/L
EPA 200.7
TOC
3.92 mg/L
7/21/11
2 mg/L
SM 5310C
Sulfide
< 0.1 mg/L
7/19/11
0.1 mg/L
SM 4500 SD

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Report Date: 8/8/ 11
Co act: Neal Davis
Client: Kapstone Paper & Packaging
100 Gaston Rd. Date Sample Rcvd: 7/14/11
ennnnke Raoids. NC 27870
Meritech Work Order # 07141194A Sample: Sample #2 Cooling Water
7/13-14/11
All V� geporttine Llm►t Method
Parameters
Result
EPA 608
Attached
7/22/11
EPA 624
Attached
7/20/11
Trip Blank
Attached
7/20/11
EPA 625 BNA
Attached
7/26/11
Meritech Work Order # 0714119S Sample: Sample #2 Cooling Water
7/14/11
Parameters
Cyanide, total
Result
< 0,005 mg/L
Analysis gate
7/27/ 11
Reportina Limit
0.005 mg/L
1 col/100 ml
Method
EPA 335.4
SM 9222D
Fecal Coliform
5 col/mL
7/18/11/11
7/1
5 mg/L
EPA1664A
Oil & Grease (HEM)
< 5 mg/L
<0.010 mg/L
7/19/11
0.010 mg/L
EPA 420.1
Phenols, total
I hereby certify that I have reviewed and approve these data.
wlj�2
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320

MERI TECH, INC.
ENVIRONMENTAL LABORATORIES
A Division of Water Technology and Controls, Inc.
Client: Kapstone Paper
Project: 608
Client Sample ID: #2 Cooling
Water
Sample Collection: 7/13-14/11
Meritech ID: 07141194
Extraction: 7/20/11
Analysis: 7/22/11
Analyst: Summit
EPA 608 - Orzanochlorine Pesticides
Parameter Result
Aldrin
< 0.4 mg/L
a-BHC
< 0.2 mg/L
b-BHC
< 1 mg/L
d-BHC
< 0.2 mg/L
g-BHC
< 0.2 mg/L
4,4'-DDD
< 10 mg/L
4,4'-DDE
< 0.2 mg/L
4,4'-DDT
< 0.2 mg/L
Dieldrin
< 0.2 mg/L
Endosulfan I
< 0.2 mg/L
Endosulfan II
< 0.2 mg/L
Endosulfan sulfate
< 0.2 mg/L
Endrin
< 0.2 mg/L
Endrin aldehyde
< 0.2 mg/L
Heptachlor
< 0.4 mg/L
Heptachlor epoxide
< 0.2 mg/L
Toxaphene
< 0.2 mg/L
Aroclor - 1016
< 0.0002 mg/L
Aroclor - 1221
< 0.0002 mg/L
Aroclor - 1232
< 0.0002 mg/L
Aroclor - 1242
< 0.0002 mg/L
Aroclor - 1248
< 0.0002 mg/L
Aroclor - 1254
< 0.0002 mg/L
Aroclor - 1260
< 0.0002 mg/L
Chlordane
< 0.2 mg/L
I hereby certify that I have reviewed and approve these data.
U. lvjec
Laboratory Representative
. Reidsville, NC 27320

Client:
Project:
Client Sample ID:
Sample Collection:
Parameter
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)0uoranthene
Benzo(k)nuoranthene
Benzo(g,h,i)perylene
Benzyl butyl phthalate
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
2-Chloronaphthalene
4-Chlorophenylphenyl ether
Chrysene
Dibenzo(a,h)anthracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthaiate
Di-n-butyl phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
1,2-Diphenylhydmzine
MERITECH, INC.
Environmental Laboratories
A Division of Water Technology and controls, Inc.
Kapstone Paper
625
Sample k2 Cooling Water
07/14/11
Meritech ID#: 07141194
Analysis: 07/26/11
Extraction: 07/18/11
Analyst: MC
Dilution Factor: 1
EPA 625 SEMIVOLATILE ORGANICS
Result Parameter
<10 ug/L
Fluoranthene
<10 ug/L
Fluorene
<10 ug/L
Hexachlorobenzene
<50 ug/L
Hexachlorobutadiene
<10 ug(L
Hexachlorocyclopentadiene
<10 ug(L
Hexachloroethane
<10 ug(L
Indeno(1,2,3-cd)pyrene
<10 ug(L
Isophorone
<10 ug/L
2-Methylnaphthalene
<10 ug(L
Naphthalene
<10 ug/L
Nitrobenzene
<10 ug/L
N-Nitrosodimethylamine
<10 ug/L
N-Nitrosodi-n-propylamine
13.5 ug(L
N-Nitrosodiphenylamine
<10 ug/L
Phenanthrene
<10 ug/L
Pyrene
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug(L
<10 ug(L
4-Chioro-3-methylphenol
<10 ug(L
2-Chlorophenol
<10 ug/L
2,4-Dichlorophenol
<10 ug/L
2,4-Dimethylphenol
<50 ug/L
2.4-Dinitrophenol
<10 ug/L
4,6-Dinitro-2-methylphenol
<10 ug/L
2-Nitrophenol
<10 ug(L
4-Nitrophenol
<10 ug/L
Pentachlorophenol
<10 ug/L
Phenol
<10 ug/L
2,4,6-Trichlorophenol
<10 ug/L
1 hereby certify that I have reviewed and approve these data.
<10 ug(L
<IO ug(L
<10 ug(L
<10 ug(L
<50 ug(L
<10 ug(L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug(L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug(L
<10 ug/L
<10 ug/L
<10 ug(L
<50 ug/L
<50 ug(L
<10 ug(L.
<50 ug(L
<50 ug(L
<10 ug/L
<10 ug(L
Laboratory Representative
642 Tamco Road' Reidsville, NC 27320
M361 342-4748 Ph " [phone] Fax

MERITECH, INC.
' Environmental Laboratories
A Division of Water Technology and controls, Inc.
Chris Puryear Meritech ID#: 07141194
Client: Analysis: 07/25/1 1
Project: Sample # 2 Cooling Water V W V
Analyst:
Client Sample ID: Sample # 2 Cooling Water Dilution Factor: 1
Sample Collection: 07/14/11
EPA 624 VOLATILE ORGANICS
Parameter
Result
< 1.00 ug/L
Benzene
Dichlorobromomethane
< 1.00 ug/L
Dichlurodifluoromethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L
< 5.00 ug/L
Methyl Bromide
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chloroethane
< 5.00 ug/L
2-Chloroethyl vinyl ether
< 5.00 ug/L
Chloroform
2.39 ug/L
Methyl Chloride
< 5.00 ug/L
Chlorodibromomethane
< L00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
I,1-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1,00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
I,1-Dichloroethylene
< 1.00 ug/L
trans-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
< 1.00 ug/L
cis-1,3-Dichloropropylene
< 1.00 ug/L
trans-1,3-Dichloropropylene
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetmchloroethane
< 1.00 ug/L
Tetrachloroethylene
< 1,00 ug/L
Toluene
< 1.00 ug/L
1,1,1-Trichloroethane
< 1.00 ug/L
1,1,2-Trichloroethane
< 1.00 ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoromethane
< 5.00 ug/L
Vinyl chloride
< 5.00 ug/L
Additional ComMOUnds
<ug/L
Acrolein
<10.0 0.0 ug/L
Acrylonitrile
Bis(chloromethyl)ether •
<I0.0 ug/L
l hereby certify that I have reviewed and approve these data.
• Based on library search.
U
Laboratory Representative
adl Tamco Road' Reidsville, NC 27320

Client:
Project:
MERITECH, INC.
Environmental Laboratories
A Division of Water Technology and Controls, Inc.
Chris Puryear
Sample # 2 Cooling Water
Client Sample ID: Trip Blank
Sample Collection: 07/14/11
Meritech ID#: 07141194tb
Analysis: 07/201I 1
Analyst: VWV
Dilution Factor: I
EPA 624 VOLATILE ORGANRICS
Parameter
< 1.00 ug/L
Benzene
Dichlorobromomethane
< 1.00 ug/L
Dichlorodifluoromethane
< 1 ug/L
Bromoforrn
< < 11.00 ug/L
ug/L
Methyl Bromide
Carbon Tetrachloride
.00
< 1.00 ug/L
Chlorobenzene
.00 ug/L
< < 11.00 ug/L
Chloroethane
2-Chloroethyl vinyl ether
< 5 .00 ug/L
Chloroform
< .00 ug/L
< 1.00 ug/L
Methyl Chloride
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
1,1-Dichloroethane
< 1.00 ug/L
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1 00 ug/L
1,3-Dichlorobenzene
1,1-Dichloroethylene
< 1.00 ug/L
trans-1,2-Dichloroethylene
< 1.00 u
1,2-Dichloropropane
< 1.00 ug/L
< 1.00 ug/L
cis-1,3-Dichloropropylene
< 1.00 u
trans-1,3-Dichloropropylene
Ethyl benzene
< 1.00 ug/L
�
< 1.00 ug/L
Methylene chloride
1,1,2,2-Tetrachloroethane
< 1.00 u L
Tetrachloroethylene
< 1 00 u
< 1.00 ug/LToluene < 1.00 ug/L
I,1,1-Trichloroethane
< 1.00 ug/L
1,1,2-Trichloroethane
100 ug/L
< 1ethylene
Trichloro
Trichlorofluoromethane
< ug/L
.00 u
Vinyl chloride
< 500 ug/L
gfL
Additional Compounds
<50.0 ug/L
Acrolein
Acrylonitrile
<10.0 ug/L
Bis(chloromethyl)ether •
<10.0 ug/L
I hereby certify that I have reviewed and approve these data.
• Based on library search.
Laboratory Representative
642 Tamco Road " Reidsville, NC 27320
_. - - .-... -, . ,e,&%'*A')-I M FaY

MERITECH, INC.
Environmental Laboratories
A Division of Water Technology and Controls, Inc.
Client: p p
Ka Stone Paper Meritech ID#: 08241192 Project: 624 Analysis: 08/26/11
Client Sample ID: Cooling Water 002 Analyst: V WV
Sample Collection: 08/23/11 Dilution Factor: I
EPA 624 VOLATILE ORGANICS
Parameter Result
Chluroform
hereby certify that I have reviewed and approve these data.
< 1.00 ug/L
p ;z.
SEP 12 2011
EONS
Laboratory Representative
642 Tannco Road' Reidsville, NC 27320
111at zd9.d7dFt Ph' 13361 342-1522 Fax

MERI TECH, INC.
Environmental Laboratories
A Division of Water Technology and Controls, Inc.
Client: KapStone Paper
Project: 624
Client Sample ID: Trip Blank
Sample Collection: 08/23/11
Meritech ID#: 08241192tb
Analysis: 08126/11
Analyst: VWV
Dilution Factor: I
EPA 624 VOLATILE ORGANICS
Result
Paraeter
m
Chloroform
< 1.00 v191.
I hereby certify that I have reviewed and approve these data.
�, (GSWVJ
SE?
2 NAA
Laboratory Representative
642 Tamco Road' Reidsville, NC 27320
(3361 342-4748 Ph' [phone] Fax

MERITECH, INC.
Environmental Laboratories
A Dlvislcn of Water Technology and Controls, Inc.
Meritech ID11:
09071190
Client:
Keystone Paper
Analysis:
09/ 15/ 11
Project:
625
Extraction:
09/12/11
Client Sample lD:
Sampler
P
Analyst:
MC
Sample Collection:
09/06/11
Dilation Factor:
I
Bls(2-ethylhexyl)phtha la tt
I hereby certify that I have reviewed and approve these data.
19.2 ug/L
oratory epresentative
642 Tamco Road' Reidsville, NC 27320
ieoa% ')A')-A7dR Ph* 13361 342-1522 Fax

MERITECH, INC.
Environmental Laboratories
A Division of Water Technology and Controls, Inc.
Client:
Kapstone Paper
Meritech IDO:
09071 191
Project:
625
Analysis:
09/15/11
Client Sample ID:
Non -Contact 1P15,eh ta.7. 00 L
Extraction:
09/12/11
Sample Collection:
09/06/11
Analyst:
MC
Dilution Factor:
I
EPA 625 SEMIVOLATILE ORGANICS -Phthalate Only
B is(2-ethythexy I)phthelate
I hereby certify that I have reviewed and approve these data.
<10 ug/L
,�-Zc
—Laboratory RepresentativT
642 Tamco Road' Reidsville, NC 27320
ron�9Aft A9AO ML s ieee\ 9AH 4l97 Caw

NCDEE R
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
December 31, 2009
Ms. Mary Lee Ransmeier
Environmental Programs Manager
Kapstone — Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: Compliance Evaluation Inspections
Kapstone Wastewater Treatment Plant
NPDES Wastewater Permit NC0000752 and
NPDES Stormwater Permit NCS000106
Halifax County
Dear Ms. Ransmeier:
F.in
Natural Resources
Dee Freeman
Secretary
I, Dave Parnell of the Raleigh Regional Office of the Division of Water Quality, conducted two
Compliance Evaluation Inspections (CEI) on December 28, 2009, consisting of the NPDES Wastewater
and Stormwater inspections. Your assistance, and the assistance of Mr. Chris Puryear, Operator in
Responsible Charge (ORC), Mr. Neal Davis, Backup Operator in Responsible Charge (BORC) and Mr.
Paul Kinnin, Laboratory Manager, was appreciated. Please review the attached Basinwide Information
Management System (BIMS) inspection checklists summarizing the inspections.
Below is a list of findings and recommendations developed from the inspections:
I. NPDES Wastewater Permit Inspection:
1. The current permit was reissued May 9, 2007 and expires March 31, 2012,
2. The 28.0 MGD wastewater treatment plant consists of the following units: mechanical bar
screen, primary clarifier, emergency holding pond, sludge lagoon, aeration basin and three
stabilization ponds. Discharges from the plant are into the Roanoke River, which is Class C
waters in the Roanoke River Basin. The facility is classified as a WW-4, and both Mr.
Puryear and Mr. Davis are W-W 4 certified.
3. The inspection began in the plant office and proceeded to the laboratory. All paperwork was
well organized and easily accessible. Discharge Monitoring Reports were reviewed for
Pmo Carolina
XV1=!!y
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: w .ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affinna8ve Action Employer — 50 % Recyclee/70 % Post Consumer Paper

Kapstone NPDES Wa! iter and Stormwater Permit Compliance Eval i Inspections
compliance with permit limits and monitoring requirements. Chain of custody records were
available and found to be in order. The facility also uses a contract laboratory. Sample
storage in Laboratory was kept at a temperature of 1.0 degrees Celsius. The effluent
composite sampling is flow proportional and the refrigerator temperature was kept at 1.5
degrees Celsius. The effluent flow meter was last calibrated on April 24, 2009 and the flow
meter on the main ditch to the clarifier was calibrated on March 20, 2009.
4. The overall condition of the facility was found to be good, which is indicative of good
housekeeping practices. The mechanical bar screen was in acceptable condition. Debris is
removed to the on -site landfill as needed.
5. The Primary Clarifier was inspected and found to be in good condition and functioning
properly. There was no sign of weir blockage, short circuiting or evidence of floating sludge.
6. The solids handling equipment included a sludge press for removing water and concentrating
solids prior to transporting the dewatered sludge to the landfill. Sulfuric acid is added for pH
control and polymer is added to thicken the material. This process functioned well on the
date of this inspection
7. The flow from the Primary Clarifier is gravity fed to the aeration pond. Nutrients are added
to effluent at this point before entering the ponds. There appears to be ample aeration.
(Some aerators are offline for maintenance but this is an acceptable practice). There were no
dead spots or excessive foaming on the surface of the ponds. Maintenance crews were
removing vegetation from the shoreline at the time of the inspection.
8. From the aeration pond the effluent flows to a series of lagoons. The surface of the ponds
was free of vegetation as was the shoreline.
9. The final stabilization pond discharge has a bar screen and a composite sampler and from
there the flow is discharged to the river. The effluent pipe was submerged due to high water
levels in the river. There was a trace of foam on the surface of the river at the discharge
point, but was in the acceptable range.
II. NPDES Stormwater Permit Inspection:
1. The permit was available for review during the CEI.
2. Secondary containment is required at this facility and was inspected during the site visit and
found to be in compliance.
3. The Stormwater Pollution Prevention Plan (SP3) was reviewed by during the inspection. As
we discussed, there are a couple of deficiencies in the plan that need addressing by your
engineer when your plan is updated in February 2010:
• Include a "Narrative Description of Practices" in the revised plan.
• Include a Preventative Maintenance and Good Housekeeping Plan within the SP3.

Kapstone I :S Wastewater and Stormwater Permit Comr a Evaluation Inspections
• Include a Stormwater facility Inspection Program.
Please be specific and follow the requirements set forth in your permit when revising your
plan. All requirements of the permit must be components contained in the plan.
4. The relocated Representative Outfall Status (ROS) was discussed and pointed out to me during
the inspection. This location was reported to have produced much better sample results according
to Mr. Davis.
The Kapstone wastewater treatment plant is considered to be in compliance with the NPDES wastewater
and stormwater permits at the time of these inspections. Please continue to be diligent in adhering to the
requirements of the permits. If you have any questions concerning this report, please do not hesitate to
contact me at 919-791-4200.
Sincerely,
� M--e- �a'rt ztz#
Dave Parnell
Environmental Specialist
Raleigh Regional Office
Attachment: CEI Inspection Reports
cc: Central Files
SWP/RRO files

United States Environmental Protection Agency
Forth Approved.
Washington, D.C. 20460
EPA
OMB No. 2040-0057
Water Compliance inspection Re ort
Approval expires 8-31-98
Sedicn A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
1 I kl 2 I sl 31 NC0000752 111 12I 09/12/28 117 18I CI 191 cl 201 I
LJ L.J 4J IJ
Remarks
211 11 I l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l 11111 is
Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 CA -------------------Reserved-----
72u 7374 75I I I I 80
67I 169 70J 71 ty
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Dale
POTW name and NPDES permit Number)
Roanoke Rapids Mill
10:30 AM 09/12/28
07/08/01
Exit Time/Date
Permit Expiration Date
100 Gaston Rd
Roanoke Rapids NC 27870
02:45 PM 09/12/28
12/03/31
Name(s) of Onsite Representative(s)fritles(s)/Phone and Fax Number(s)
Other Facility Data
Thomas C Puryear/ORC/252-533-6237/
Name, Address of Responsible Official/Title/Phone and Fax Number
James R Jackson, //252-533-6000/2525336465 Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit ■ Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Pretreatment
Effluent/Receiving Waters Laboratory Storm Water
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
David R Parnell RRO WQ//919-791-4260/
�I�/
Si re of Manag ant Q A viewer AW celphone and Fax Numbers Date
EPA Form 60-3 (Rev 9-94) Previous editions are obsolete.
Page * 1

NPDES yr/mo/day Inspection Type
3I NC0000752 I11 12I 09/12/28 I17 18UC
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

Permit: NC0000752 Owner- Facility: Roanoke Rapids Mill
Inspection Date: 12/2812009 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 application?
❑
❑
■
❑
Is the facility as described in the permit?
0
Cl
❑
❑
# Are there any special conditions for the permit?
■
❑
❑
❑
Is access to the plant site restricted to the general public?
■
❑
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
❑
❑
❑
Is all required information readily available, complete and current?
■
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
■
❑
❑
❑
Is the chain -of -custody complete?
■
❑
❑
❑
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
N
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
0
Are DMRs complete: do they include all permit parameters?
■
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWO?
❑
❑
■
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
■
Cl
❑
❑
Is the ORC visitation log available and current?
■
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
■
❑
Facility has copy of previous year's Annual Report on file for review?
■
❑
❑
❑
Comment:
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
■
❑
❑
❑
Page # 3

Permit: NC0000752 Owner- Facility: Roanoke Rapids Mill
Inspection Date: 12/28/2009 Inspection Type: Compliance Evaluation
Operations & Maintenance
Yes
No
NA
NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑
❑
❑
■
Judge, and other that are applicable?
Comment:
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
■
❑
❑
❑
# Is the facility using a contract lab?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Incubator (Fecal Colifonm) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
■
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
■
❑
Comment: Contract Lab is Meritech.
Flow Measurement - Influent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
❑
❑
❑
Is the flow meter operational? ■ ❑ ❑ ❑
(if units are separated) Does the chart recorder match the flow meter? ■ ❑ ❑ ❑
Comment: Last calibration = 4.24.09
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?
■
❑
❑
❑
Is disposal of screening in compliance?
■
❑
❑
❑
Is the unit in good condition?
■
❑
❑
❑
Comment: Debris to on -site landfill
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
■
❑
❑
❑
Is the chemical feed equipment operational?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Page # 4

Permit: NC0000752
Inspection Date: 12/2&2009
Owner • Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
Solids Handling Equipment
Yes
No
NA NE
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
■
❑
❑
❑
The facility has an approved sludge management plan?
❑
❑
❑
■
Comment: Well run operation.
Primary Clarifier
Yes
No
NA NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifies?
■
❑
❑
❑
Are weirs level?
■
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
■
❑
❑
❑
Is the site free of excessive floating sludge?
■
❑
❑
❑
Is the drive unit operational?
■
❑
❑
❑
Is the sludge blanket level acceptable?
❑
❑
■
❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
❑
❑
■
❑
Comment: Sludge blanket is not an issue at this type of WWTP
Chemical Feed
Yes
No
NA
NE
Is containment adequate?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Are backup pumps available?
❑
❑
❑
■
Is the site free of excessive leaking?
■
❑
❑
❑
Comment:
Aeration Basins
Yes
No
NA
NE
Mode of operation
Type of aeration system
Surface
Is the basin free of dead spots?
■
❑
❑
❑
Are surface aerators and mixers operational?
MOOD
Are the diffusers operational?
❑
❑
■
❑
Is the foam the proper color for the treatment process?
■
❑
❑
❑
Page # 5

9 # abed
❑
❑
❑
■
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❑
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❑
❑
❑
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❑
❑
❑
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❑
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❑
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❑
❑
❑
■
Zs!ew!ue 6wmownq;o aay say p aiy
❑
❑
❑
■
Zuolsoia;o gay sa�lp aiy
Cl
❑
❑
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496edeas;o gay saH!p ajV
❑
❑
❑
■
6uoo6el aql;o a6pa ayl punae palloyuoo spasm eiV
❑
❑
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Permit: NC0000752
Inspection Date: 12/28/2009
Effluent Sampling
Is proper volume collected?
Is the tubing clean?
Owner • Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: Storage Temp = 1.5C
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment: Trace amounts of foam is present on surface of river
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ■ ❑
Page # 7

11
Ak;
KAPSTONE
May 19, 2009
Ms. Autumn Hoban
Surface Water Protection Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, N.C. 27609
Dear Ms. Hoban,
KAPSTONE
KRAFT PAPER CORPORATION
A Division of KAPSTONE PAPER AND PACKAGING CORPORATION
100 Gaston Road Roanoke Rapids, NO 27870
252,533,6000 fax:[phone] KAPSTONEPAPER.com
MAY 2 0 2009
This letter is in response to your NPDES compliance inspection report that we received
on May 1, 2009. We are very pleased with the results of your inspection and will
continue to maintain a compliant facility
In Section D, Page 2 of your report, you have requested additional information
associated with the results of water quality analysis of samples collected during your
visit. Your request includes:
Please submit the sample results taken by Kapstone the day of the inspection
Please submit findinjzs and response document with regards to the sample results
Attached you will find a copy of the analysis of the samples you split with us during
your visit. When comparing the results from the state lab to the results we obtained
from Meritech it appears that the parameters of concern noted in your inspection report
vary greatly (except for sulfate). Due to the large differences between the results we
went to our files and looked at the results of the analysis performed during the last
NPDES permit application (2006). Below is a table showing the results of analysis from
the State lab, Meritech and Oxford labs 2006.
Results
Parameter
State Lab 12/08
Meritech 12/08 Oxford Labs 6/06
Fluoride
8.0 mg/l
0.4 mg/l 0.37 mg/1
Copper
4.4 ug/l
<0.2 ug/l 0.7 ug/1
TDS
946 mg/l
798 mg/l----------
Sulfate
460 mg/l
303 mg/1 488 mg/l
Phenols
31 mg/l
0.037 mg/1 0.006 mg/1
As you can see there appears to be a significant difference between the results you
obtained from the State lab and the last two sets of analysis we conducted.

As far as effluent sulfate concentration is concerned, we use sodium sulfate in our
manufacturing process and we monitor losses of that material on a daily basis. We are
continually looking for methods to reduce the amount of sodium sulfate losses and it
appears that between 2006 and 2008 losses have decreased.
With regard to the Total Dissolved Solids (TDS) value we have never been required to
perform a TDS analysis on our effluent. We could not find a reference to TDS under
Class C waters (designation for Roanoke River), but it does appear under Standards for
Class WS-I waters.
In reference to your comment about a break in the Outfall 003 non -contact cooling water
line, we no longer discharge from that point source. From in-house studies a beneficial
reuse was found for this warm water and this discharge point has subsequently
abandoned. In the future we will report "no flow" for Outfall 003 and remove it from
the NPDES permit during the next renewal process.
I hope we have answered your concerns. If you have additional questions or if we can
be of further assistance please don't hesitate to contact me at 252-533-6255 or Chris
Puryear at 252-533-6237.
Sincerely,
M Lee R smeier
Envirdimitntal Programs Manager
Attachments: Meritech Inc. Environmental Laboratory Results-3 pages
xc: Antra Collins, VP Operations Manager, KapStone Paper
Chris Puryear, Environmental Engineer, ORC
Neal Davis, Environmental Engineer

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
i
Neal Davis Report Date:
tG Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870 Date Sample Rcvd:
/21134/tF
12/26/08
12/12/08
Meritech Work Order #
12120829 Sample:
Flow To River 01 Grab
12/10/08
Parameters
Result
Analysis Date
Reporting Limit
Method
BOD, 5 day
13.5 mg/L
12/12/08
2.0 mg/L
SM 5210B
Total Dissolved Solids
798 mg/L
12/12/08
10 mg/L
SM 2540C
Total Suspended Solids
3mg/L
12/12/08
1mg/L
SM2540D
Chloride
18.2 mg/L
12/22/08
0.10 mg/L
SM4500C1C
Fluoride
0.4 mg/L
12/12/08
0.1 mg/L
SM 4500FC
TKN
4.97 mg/L
12/19/08
0.20 mg/L
EPA 351.1
Nitrate/Nitrite Nitrogen
< 0.10 mg/L
12/12/08
0.10 mg/L
EPA 353.2
Nitrogen, Total
4.97 mg/L
12/23/08
0.20 mg/L
EPA 353.2
Sulfate
303 mg/L
12/17/08
5 mg/L
SM426C
Aluminum, total
0.752 mg/L
12/18/08
0.050 mg/L
EPA 200.7
Antimony, total
<0.025 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Arsenic, total
0.023 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Barium, total
0.111 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Beryllium, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Cadmium, total
<0.002 mg/L
12/18/08
0.002 mg/L
EPA 200.7
Calcium, total
35.9 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Chromium, total
< 0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Cobalt, total
< 0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Copper, total
<0.002 mg/L
12/18/08
0.002 mg/L
EPA 200.7
Iron, total
0.230 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Lead, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Lithium, total
< 0.100 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Magnesium, total
7.17 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Manganese, total
0.626 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Mercury, total
<0.0002 mg/L
12/16/08
0.0002 mg/L
EPA 245.1
Molybdenum, total
< 0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Nickel, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Phosphorus, total
0.441 mg/L
12/18/08
0.020 mg/L
EPA 200.7
Potassium, total
25.7 mg/L
12/23/08
0.200 mg/L
EPA 200.7
Selenium, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Silver, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Sodium, total
204 mg/L
12/23/08
0.200 mg/L
EPA 200.7
Thallium, total
< 0.020 mg/L
12/18/08
0.020 mg/L
EPA 200.7
Tin, total
< 0.025 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Titanium, total
0.006 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Vanadium, total
<0.040 mg/L
12/18/08
0.040 mg/L
EPA 200.7
Zinc, total
0.020 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Phenols, total
0.037 mg/L
12/16/08
0.010 mg/L
EPA 420.1
I hereby certify that I have reviezved and approve these data.
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina
27320
tel.[phone]
fax.[phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
.f
•
Neal Davis Report Date:
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870 Date Sample Rcvd:
12/26/08
12/12/08
Meritech Work Order #
12120831 Sample:
Turp Cooling 03 Grab
12/10/08
Parameters
Result
Analysis Date
Reporting Limit
Method
BOD, 5 day
< 2.0 mg/L
12/12/08
2.0 mg/L
SM 5210B
Total Dissolved Solids
66 mg/L
12/12/08
10 mg/L
SM 2540C
Total Suspended Solids
8 mg/L
12/12/08
1 mg/L
SM 2540D
Chloride
9.21 mg/L
12/22/08
0.10 mg/L
SM 4500 Cl C
Fluoride
<0.1 mg/L
12/12/08
0.1 mg/L
SM4500FC
TKN
0.33 mg/L
12/19/08
0.20 mg/L
EPA 351.1
Nitrate/Nitrite Nitrogen
<0.10 mg/L
12/12/08
0.10 mg/L
EPA 353.2
Nitrogen, Total
0.33 mg/L
12/23/08
0.20 mg/L
EPA 353.2
Sulfate
11 mg/L
12/17/08
5 mg/L
SM426C
Aluminum, total
0.109 mg/L
12/18/08
0.050 mg/L
EPA 200.7
Antimony, total
<0.025 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Arsenic, total
< 0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Barium, total
0.025 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Beryllium, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Cadmium, total
<0.002 mg/L
12/18/08
0.002 mg/L
EPA 200.7
Calcium, total
7.31 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Chromium, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Cobalt, total
< 0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Copper, total
<0.002 mg/L
12/18/08
0.002 mg/L
EPA 200.7
Iron, total
0.198 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Lead, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Lithium, total
< 0.100 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Magnesium, total
3.42 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Manganese, total
0.09 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Mercury, total
<0.0002mg/ L
12/16/08
0.0002mg/L
EPA245.1
Molybdenum, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Nickel, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Phosphorus, total
0.089 mg/L
12/18/08
0.020 mg/L
EPA 200.7
Potassium, total
2.64 mg/L
12/23/08
0.200 mg/L
EPA 200.7
Selenium, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Silver, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Sodium, total
7.61 mg/L
12/23/08
0.200 mg/L
EPA 200.7
Thallium, total
< 0.020 mg/L
12/18/08
0.020 mg/L
EPA 200.7
Tin, total
<0.025 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Titanium, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Vanadium, total
< 0.040 mg/L
12/18/08
0.040 mg/L
EPA 200.7
Zinc, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
I hereby certify that I have reviewed and approve these data.
Q&' "/9-
Labbratory epresentative
642 Tamco Road, Reidsville,
North Carolina 27320
tel.[phone]
fax.[phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Neal Davis Report Date:
Client: Kapstone Paper & Packaging
100 Gaston Rd.
Roanoke Rapids, NC 27870 Date Sample Rcvd:
12/26/08
12/12/08
Meritech Work Order #
12120830 Sample:
B & C Cooling 02 Grab
12/10/08
Parameters
Result
Analysis Date
Reporting Limit
Method
BOD, 5 day
<2.0 mg/L
12/12/08
2.0 mg/L
SM 5210B
Total Dissolved Solids
97 mg/L
12/12/08
10 mg/L
SM 2540C
Total Suspended Solids
< 1 mg/L
12/12/08
1 mg/L
SM 2540D
Chloride
12.8 mg/L
12/12/08
0.10 mg/L
SM 4500 CI C
Fluoride
0.3 mg/L
12/12/08
0.1 mg/L
SM 4500FC
TKN
0.44 mg/L
12/19/08
0.20 mg/L
EPA 351.1
Nitrate/Nitrite Nitrogen
<0.10 mg/L
12/12/08
0.10 mg/L
EPA353.2
Nitrogen, Total
0.44 mg/L
12/23/08
0.20 mg/L
EPA 353.2
Sulfate
11 mg/L
12/17/08
5 mg/L
SM426C
Aluminum, total
0.081 mg/L
12/18/08
0.050 mg/L
EPA 200.7
Antimony, total
<0.025 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Arsenic, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Barium, total
0.028 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Beryllium, total
< 0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Cadmium, total
< 0.002 mg/L
12/18/08
0.002 mg/L
EPA 200.7
Calcium, total
8.56 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Chromium, total
0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Cobalt, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Copper, total
< 0.002 mg/L
12/18/08
0.002 mg/L
EPA 200.7
Iron, total
0.331 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Lead, total
<0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Lithium, total
<0.100 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Magnesium, total
3.76 mg/L
12/23/08
0.100 mg/L
EPA 200.7
Manganese, total
0.086 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Mercury, total
<0.0002 mg/L
12/16/08
0.0002 mg/L
EPA 245.1
Molybdenum, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Nickel, total
< 0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Phosphorus, total
0.114 mg/L
12/18/08
0.020 mg/L
EPA 200.7
Potassium, total
3.02 mg/L
12/23/08
0.200 mg/L
EPA 200.7
Selenium, total
< 0.010 mg/L
12/18/08
0.010 mg/L
EPA 200.7
Silver, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Sodium, total
11.2 mg/L
12/22/08
0.200 mg/L
EPA 200.7
Thallium, total
<0.020 mg/L
12/18/08
0.020 mg/L
EPA 200.7
Tin, total
<0.025 mg/L
12/18/08
0.025 mg/L
EPA 200.7
Titanium, total
<0.005 mg/L
12/18/08
0.005 mg/L
EPA 200.7
Vanadium, total
< 0.040 mg/L
12/18/08
0.040 mg/L
EPA 200.7
Zinc, total
0.016 mg/L
12/18/08
0.010 mg/L
EPA 200.7
I hereby certify that I have reviewed and approve these data.
0,�'4 /&-
'Caboratory Representative
642 Tamco Road, Reidsville,
North Carolina 27320
tel.[phone]
fax.[phone]

Beverly Eaves Perdue
Governor
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
April 22, 2009
APR 2 7 2009
183
Mr. Paul Kinnin
Kapstone Kraft Paper Corporation, Roanoke Rapids Mill
100 Gaston Road
Roanoke Rapids, NC 27870-1900
Dee Freeman
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Kinnin :
Enclosed is a report for the inspection performed on February 26, 2009 by Mr. Todd Crawford. Where
finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply this
office with a written item for item description of how these finding(s) were corrected. If the finding(s)
cited in the enclosed report are not corrected, enforcement actions may be recommended. For
certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A
NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from this office. Thank you
for your cooperation during the inspection. If you wish to obtain an electronic copy of this report by
email or if you have questions or need additional information, please contact us at 919-733-3908.
Sincerely, l ,
Dana Zatterwhite
Certification Unit Supervisor
Laboratory Section
Enclosure
cc: Todd Crawf rd
Wa i on Regional Office
iPd/e;9h
DENR DWD Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail service Center, Raleigh, North Carolina 27699-1623 One
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 NorthCarolina
Phone: [phone] FAX: [phone]
Internet www.dwgiab.org Naturally
An Equal Opportunity l Artirmative Action Employer Customer service: 1-877-623-6748 www.ncwaterquality.org

On -Site Inspection Report
LABORATORY NAME: Kapstone Kraft Paper Corporation, Roanoke Rapids
ADDRESS: 100 Gaston Rd
Roanoke Rapids, NC 27870-1900
CERTIFICATE #: 183
DATE OF INSPECTION: February 26, 2009
TYPE OF INSPECTION: Industrial Maintenance
AUDITOR(S): Todd Crawford
LOCAL PERSON(S) CONTACTED: Neal Davis, Paul Kinnin
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
II. GENERAL COMMENTS:
The lab was generally neat and well organized. All equipment appeared well maintained.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
BOD - Standard Methods, 19'" Edition, 5210 B
A. Finding: Extra nutrients are not being added for dilutions with >67% sample (>201 mL).
Requirement: BOD bottles containing more that 201 mL of sample should have extra nutrients
added to them. Ref: North Carolina Wastewater/Groundwater Laboratory Certification (NC
WW/GW LC) policy based upon SM 20t" 5210 B. (4) (f). and SM 21s' 5210 B. (5) (c) (2).
Comment: The best way to do this is to use pillows made for 300 mL bottle size. Add 1 pillow
to each bottle containing more than 201 mL sample.
Documentation
B. Finding: Calibration times for pH and Dissolved Oxygen (D. O.) meters are not being
documented. This is considered pertinent information.
Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly
manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a)
(7) (A)

IV
Page 2
#183 Kapstone Kraft Paper Corp., Roanoke Rapids
C. Finding: The laboratory needs to increase the documentation of materials and reagents used
or made in the laboratory as well as procedures for standard and reagent preparation.
Requirement: All chemicals, reagents, standards and consumables used by the laboratory
must have the following information documented: Date received, Date Opened (in use), Vendor,
Lot Number, and Expiration Date (where specified). A system (e.g., traceable identifiers) must
be in place that links standard/reagent preparation information to analytical batches in which the
solutions are used. Documentation of solution preparation must include the analyst's initials,
date of preparation, the volume or weight of standard(s) used, the solvent and final volume of
the solution. This information as well as the vendor, manufacturer, lot number, and expiration
date must be retained for primary standards, chemicals, reagents, and materials used for a
period of five years. Consumable materials such as pH buffers, lots of pre -made standards
and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: North
Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Policy,
01/07/2009.
PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for October, November and December, 2008. The following error was noted:
Date
Parameter
Location
Value on
Benchsheet
Value on DMR
10/17/08
Temperature
I Effluent
23.4°C
23.7°C
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office
for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this
report will be forwarded to the Regional Office.
V. CONCLUSIONS:
Correcting the above -cited findings will help this lab to produce quality data and meet certification
requirements. The inspector would like to thank the staff for its assistance during the inspection and
data review process. Please respond to all findings.
Report prepared by: Todd Crawford
Report reviewed by: Chet Whiting
Date: February 27, 2009
Date: April 20, 2009

■ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery Is desired.
■ Print your name and address on the reverse
so that we can return the card to You.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
MS. MARY LEE RANSMEIER
ENVIRONMENTAL PROGRAMS MANAGER
KAPSTONE-ROANOKE RAPIDS MILL
100 GASTON RD
ROANOKE RAPIDS NC 27370
20APRIL2009 SURFACE HOBAN HALIFAX CO.
NC0000752 Kapstone-Roanoke Rapids Mailed 4/30/09
A. Signature C3RB�
X ❑ Addres
B. Received b7 (Pd d Name) C. Date of D AC
C 1
D. Is deliveryaddress difrerera tram Kem 17 No
If YES, enter delivery address below:
3. Service Type
0 Cer[Kied Mall ❑ Express Mall
❑ Registered ❑ Return Receipt for Merchandise
❑ Insured Mall ❑ C.O.D.
4. Rastrlcted Delivery? (ems Fee) ❑ Yes
z. 7pp6 0860 0002 6049 6669
- Domestic Return Receipt
PS Form 3811, February 2004
Sao

r ( �
Michael F. Easley, Governor
W, illiamlG.J2oss Jr., Secretary
North Carolina Department of Environment and Natural Resources
Colson H. Sullins, Director
Division of Water Quality
April 20,2009
Ms. Mary Lee Ransmeier
Environmental Programs Manager
Kapstone — Roanoke Rapids Mill
100 Gaston Rd
Roanoke Rapids, NC 27870
Subject: NPDES Compliance Inspection Report
Kapstone — Roanoke Rapids Mill
NPDES Permit No. NC0000752 A
Stormwater Permit No. NCS000106
Halifax County
Dear Ms. Ransmeier:
The North Carolina Division of Water Quality conducted an inspection of the Kapstone Facility on
December 10, 2008. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES Permit No. NC0000752 and
NCS000106.
A summary of the findings and comments noted during this inspection is provided in Section D on
Page 2 of the attached copy of the complete inspection report entitled "Water Compliance Inspection
Report". There were no significant issues or findings noted during this inspection, however we do
request a response to the items listed under Section D of this report within 30 days of receipt of this
inspection.
If you have any questions concerning this report, please contact me at 919-791-4247 in the Raleigh
Regional Office.
Sincerely,
R.±R�cI.711/
Autumn Hoban
Environmental Senior Specialist
Attachments
Raleigh Regional Office — File
DWQ/Raleigh — Central Files
DWQ/Raleigh — Stormwater Unit
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C3 Certified Fee
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C3 ReturnReceipt Fee Postmark
C3 (Endorsement Required) Here
IM Rroted Delivery Fee
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MS. MARY LEE RANSMEIER
-0 ENVIRONMENTAL PROGRAMS MANAGER
C3 KAPSTONE-ROANOKE RAPIDS MILL
C3
M1 100 GASTON RD --- ----------------
ROANOKE RAPIDS NC 27870
20APRIL2009 SURFACE HOBAN HALIFAX CO.
NCOODD752 Kapstone-Roanoke Rapids Mailed 4/301
I.�"HthCaro jna
Q !ry
North Caroline Division of Water Quality
Internet: W Ww.ncwateroual Iv
1817 Mail Service Center
Raleigh. NC 27699-1617
Phone [phone]
Customer Service
Ora
Location: 512 N. Salisbury St.
Raleigh, NC 27604
Fax [phone]
1-877-623-6748
An Equal Opportunity/Affirmative Action Employer -50% Recyoledn 0% Post Consumer Paper

Section D: Summary of Findings/Comments
(Attach additional sheets of narrative and checklists as necessary)
Permit:
Your NPDES Wastewater permit became effective May 9, 2007 and will not expire until March
31, 2012. The facility is not currently under a Special Order by Consent.
The permittee is reminded to read, understand and comply with all of the terms and conditions
contained in the permit. If you have questions concerning your responsibilities, call the Raleigh
Regional Office to speak to a Division of Water Quality Surface Water staff member.
2. Comuliance Schedules:
The permit does not have any outstanding compliance schedules for this facility.
3. Facility Site Review:
The overall condition of the plant site was satisfactory. The appearance of the facility was in
good condition indicating that the current housekeeping practices are very good.
4. Self-Monitorine Program:
You are reminded that your monitoring samples must be collected, preserved, and analyzed by
appropriate procedures and methods. You should maintain records of the sampler temperature,
and a certified laboratory must calibrate the sample thermometers annually.
Your operator is reminded that he/she must keep a logbook of all operation/maintenance
activities undertaken at the facility. The logbook should include all daily process control
activities including any field measurements conducted for process control. A visitation log for
the facility must also be maintained.
The facility is currently in compliance with these requirements.
5. Records/Reports:
a) A review of the daily monitoring data submitted during the previous 12-month period
indicates the facility was in compliance with the permit requirements and/or limitations.
The facility was issued no Penalty Assessment(s) and no Notice(s)of Violation for the period
from December 2007 to October 2008.
The permittee currently does not have any unpaid penalties. The permittee is reminded of
his obligation to pay any penalties levied by the State of North Carolina for non-compliance
with your NPDESpermtt.
b) The facility must designate a certified Operator -in -Responsible -Charge (ORC) having a
certification level equal to or greater than the facility classification. A Back-up ORC must
also be designated with a minimum certification level at least one level less than the facility
classification.
The facility is currently in compliance with these requirements. The facility is classified as a
WW-4 the Operator in Responsible Charge is Chris Puryear, WW-4 Cert. No. 8275
and the Back Up Operator is Neal Davis WW-4 Cert. No. 6740. The operators have done
an excellent iob operating the plant The ORC is conscientious of process control
parameters that facilitate a :cient plant operations and maintenance.
Page 2-1

4
6. Laboratorv:
For all analytical data submitted for compliance monitoring purposes, a certified laboratory
must be utilized for all laboratory analysis. Additionally, if field parameter testing is conducted,
an operator certified to perform the specified field parameter analysis is also required. The
operator needs to be sure to calibrate all meters/instrurnentation before each use and retain all
calibration records.
The acili is currently in compliance with these re uirements and utilizes commercial
laboratory, Meritech Inc Cert. No 165
7. Flow Measurement:
If the permit requires a flow measurement device for determining the effluent flow, the flow
measurement device must be calibrated annually.
significantly lower than the permitted flow of 28 MGD
8. Effluent/Receiving Waters:
The effluent discharge should be clear with a continuous flow with no visible changes to the
receiving waters.
The effluent discharge was clear and flow was continuous The receiving waters looked clear
with no visible changes from the effluent discharge
9. Pretreatment:
This facility influent stream consists of domestic and process wastewater and currently does not
require pre-treatment.
10. Solids Handlin isposal•
The facility must dispose of solids by an acceptable method such as a landfill or utilize the
services of an approved solids hauling and disposal contractor, which requires the facility to be
included under the contractor's non -discharge permit (i.e. land application). The facility is
reminded to maintain adequate records (i.e. shipment dates, quantities, etc.) of any solids
hauling and/or disposal activities.
11. Compliance Sampling:
Compliance sampling was conducted during the inspection. The results are attached.
Page 2-2

12. Operations & Maintenance:
The following items were noted during the inspection:
A) NPDES Outfal1001 (process water and stormwater) was sampled during the inspection and
t0ollowing are "possible" water quality Parameters of concern to the Roanoke River (Class
C waters:
Reference
Fluoride = 8 mp/L Water Quality Std (Class C) Freshwater Aquatic = 1.8 mg/L
Copper = 4.4 up —IL Water Quality Action Level (Class C)= 7ug/L
TDS = 946 mg/L Water Quality Standard (Water Supply)= 500 mg/L
Sulfates = 460 in" Water Quality Standard (C1assC)= 250 mg/L
Phenolics = 31 mg& Not to result in fish -flesh tainting or impairment of best usage
Please review Section D: Summary of Findings and Comments page2 of the EPA Water
Compliance Inspection for more details.
Please submit the sample results taken by Kapstone the day of the inspection.
Please submit a %indings and response document with regards to the sample results.
13. Compliance Status:
® Compliant
Name and Signature of Inspector:
AutuYn Hoban
Surface Water Protection Section
Raleigh Regional Office
❑ Non -compliant ❑ Neither
� 0 ,-w �
Date
Page 2-3

A
EPA
_....--,,._,�� �,,.,�������cnoo rrorecuon Agency
WashingNn, D C. 20460
Form Approved.
OMB No. 2040-0057
Water COm Iiance Ins ectiou Re
Ort
APProval expires B-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code
1
NPDES yr/mo/day
Inspection Type
Inspector Fac Type
UN2 Us3I
NC0000752 I11 12I 08/12/10 117
18
u
,9u 20u
1J
z,1111111111111111111111111111IIIIII111111II11116
Remarks
1
Inspection Work Days
Facility Self -Monitoring Evaluation Rating Bi CIA
------Reserved-------
67I 159
70J 71 72J
731 J 74 75I I 180
Section B: FacilityData
- - — -----••-•• -• • --•^o •'!Q_�«� tFUI it luusulai users mscnarging to ::#
/Date Permit Effective Date
POTW name and NPDES permit umber)
Roanoke Rapids Mill 08/12/10 07/08/01
100 Gaston Rd Date Permit Expiration Date
Roanoke Rapids NC 27870
OB/12/10 12/03 /31
Name(s) of Onsite Representative(s)!1'itles(s)/Phone and Fax Number(s) lity Data
Thomas C Puryear/ORC/252-533-6237/
i
me,Address of Responsible Official/Title/Phone and Fax Number
mea R Jackson, //252-533-6000/2525336465 Contacted
NOSection C: Areas Evaluated Durin Inspection (Check only those areas evaluated)
Permit ■ Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program ■ Sludge Handling Disposal . Facility Site Review ■ Compliance Schedules
Pretreatment ■ Effluent/Receiving Waters . Laboratory Storm Water
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)
Autumn Hoban I
i
Signature of Management O A Reviewer
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Agency/Office/Phone and Fax Numbers
RRO WO///
Agency/Office(Phone and Fax Numbers
Date
y/'7�o'I
Date
Page # 1

w
NPDES yr/mo/day Inspection Type (cont .) I
3I NC0000752 I11 12I 08/12/10 I17 18'_,
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The facility was in compliance with the permit requirements. The plant personnel were very knowledgeable
and cooperative. Observations at the plant indicate that the permittee takes environmental responsiblities
serious and proactively works to prevent water quality issues.
The results of the sampling and a map of outfall locations are attached to the inspection.
NPDES Outfall 003-non-contact cooling water discharge- No sample results were of concern with regards to
water quality. *The facility reported a break in the cooling water process line in February 2009, that resulted
in no water quality issues.
NPDES Outfall 002-non-contact cooling water discharge- No sample results were of concern with regards to
water cl uality.
NPDES Outfall 001-process and stormwater discharge- Sample results to note:
*Fluoride = 8 mg/L Water Quality Standard (Class C) Freshwater Aquatic Life = 1.8 mg/L
Copper = 4.4 ug/L
*TDS = 946 mg/L Water Quality Standard (Water Supply)= 500 mg/L
*Sulfates = 460 mg/L Water Quality Standard (Class C) = 250mg/L
*Phenolics = 31 mg/L Not to result in fish -flesh tainting or impairment of best usage
*denotes "possible" water quality parameters of concern.
The Fluoride "may be city water that was discharged to outfall 001 the day of the inspection". This should
be determined and eliminated as possible.
DWQ requests that Kapstone forward sample results obtained at the same outfalls during this inspection for
our records.
Page # 2

Vr
Permit: NC0000752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 12110/2008 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the pennittee submitted a new application?
❑ ❑ N ❑
Is the facility as described in the permit?
■ ❑ O ❑
# Are there any special conditions for the permit?
0 ❑ O ❑
Is access to the plant site restricted to the general public?
❑ 0 ❑
Is the inspector granted access to all areas for inspection?
❑ ❑
Comment:
Compliance Schedules
Yea No NA WE
Is there a compliance schedule for this facility?
❑ ❑ M ❑
Is the facility compliant with the permit and conditions for the review period?
❑ ❑ N ❑
Comment:
Pump Station - Influent
Yes No NA NE
Is the pump wet well free of bypass lines or structures?
❑
❑ ❑
Is the wet well free of excessive grease?
❑ ❑ ❑
Are all pumps present?
❑ ❑ ■ ❑
Are all pumps operable?
❑ ❑ ■ ❑
Are float controls operable?
❑ ❑ ■ ❑
Is SCADA telemetry available and operational?
❑ ❑ 0 ❑
Is audible and visual alarm available and operational?
❑ ❑
N ❑
Comment: Wastewater enters the Wastewater treatment system by gravity flow
through a concrete lined open channel.
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
0 ❑ ❑ ❑
Is flow meter calibrated annually?
. ❑ ❑ ❑
Is the flow meter operational?
. ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter?
0 ❑ ❑ ❑
Comment: The flow meter is calibrated monthly.
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
. ❑ ❑ ❑
Is flow meter calibrated annually?
■ ❑ ❑ ❑
Is the flow meter operational?
■ ❑ ❑ ❑
Page # 3

Permit: NC0000752 Owner- Facility: Roanoke Rapids Mill
Inspection Date: 12110/2008 Inspection Type: Compliance Evaluation
Flow Measurement - Effluent Yes No NA NE
(If units are separated) Does the chart recorder match the flow meter? ■ ❑ ❑ ❑
Comment: Wastewater effluent flows by gravity to a series of 3 stabilization basins
with a retention time of 30-35 days.
The flow is controlled by an electrically operated butterfly valve at the discharge to the
river.
A Marsh McBirney multi -probe velocity flow meter is installed and is calibrated monthly.
Discharge flow is currently averaging 17 MGD, significantly below the permitted
discharge of 28 MGD.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
❑
❑
❑
Comment: Sampling is performed as required by the permit.
Samples were collected by DWQ at outfall 001, 002, and 003 as part of this inspection.
Kapstone also collected samples at the same time the day of the inspection.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MISS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ ❑
Judge, and other that are applicable?
Comment:
Aeration Basins Yes No NA NE
Mode of operation
Type of aeration system
Surface
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? ■ ❑ ❑ ❑
Page # 4

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IV
11
Permit: NC0000752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 12/10/2008 Inspection Type: Compliance Evaluation
Lagoons
Yes No NA NE
# If excessive algae is present, has barley straw been used to help control the growth?
❑ ❑ ■ ❑
Is the lagoon surface free of weeds?
■ ❑ ❑ ❑
Is the lagoon free of short circuiting?
■ Cl ❑ ❑
Comment: The facility has 3 stablization basins (lagoons) and 1 sludge lagoon. Total
treatment area of 370 acres.
The lagoons are well maintained with more than adequate capacity for the waste flow.
Dredging is conducted as frequently as need at stabilization basin #1, and dredging 1/3
of each lagoon per year is routine.
No algae was observed.
Solids Handling Equipment
Yes
No
NA NE
Is the equipment operational?
■
❑
❑
❑
Is the chemical feed equipment operational?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
■
❑
❑
❑
The facility has an approved sludge management plan?
❑
❑
❑
■
Comment:
Chemical Feed
Yes
No
NA
NE
Is containment adequate?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Are backup pumps available?
■
❑
❑
❑
Is the site free of excessive leaking?
■
❑
❑
❑
Comment:
Nutrient Removal
Yes
No
NA
NE
# Is total nitrogen removal required?
■
❑
❑
❑
# Is total phosphorous removal required?
■
❑
❑
❑
Type
Chemical
# Is chemical feed required to sustain process?
■
❑
❑
❑
Is nutrient removal process operating property?
■
❑
❑
❑
Page # 6

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Permit: NC0000752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 12/10/2008 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DM Rs complete: do they include all permit parameters?
■
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
❑
■
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
■
❑
❑
❑
Is the ORC visitation log available and current?
■
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
❑
❑
❑
Is a copy of the current NPDES permit available on site?
■
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
■
Comment: Chris Puryear is the ORC, Certificate #8275 and Neal Davis is the back-up
ORC, Certificate #6740.
Both operators are very knowledgeable and their assistance during the inspection was
greatly appreciated.
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
❑
❑
❑
■
Is the generator tested by interrupting primary power source?
❑
❑
❑
■
Is the generator tested under load?
❑
❑
❑
■
Was generator tested 8 operational during the inspection?
❑
❑
❑
■
Do the generator(s) have adequate capacity to operate the entire wastewater site?
❑
❑
❑
■
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
❑
❑
❑
■
Is the generator fuel level monitored?
❑
❑
❑
■
Comment: The facility makes its own power as well as having some power supply
from local power company.
Page # 8

Permit: NCS000106
SOC:
County: Halifax
Region: Raleigh
Compliance Inspection Report
Effective: 03/07/03 Expiration: 03/31/08 Owner: Kapstone Kraft Paper Corporation
Effective: Expiration: Facility: Roanoke Rapids Mill
100 Gaston Rd
Contact Person: Mary Lee Ransmeier
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Roanoke Rapids NC 27870
Title: Phone: [phone]
Certification: Phone:
Inspection Data: 12/10/2008 Entry Time: 01:00 PM Exit Time: 04.00 PM
Primary Inspector: Autumn Hoban I{ Phone:
Secondary Inapector(e): i
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Inspection Type: Compliance Evaluation
Page:1

Permit: NCS000106 Owner -Facility: Kapstone Kraft Paper Corporation
Inspection Date: 12'10.%2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page:2

Permit: NCS000106 Owner - Facility: Kapstone Kraft Paper Corporation
Inspection Date: 12/10/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ❑ ❑
At Does the Plan include a "Narrative Description of Practices'?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■ ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ❑ ❑
Al Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
Comment:
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its qualitative Monitoring semi-annually?
a ❑ 110
Comment:
Analytical Monitoring
Yes No NA NE
Has the facility conducted its Analytical monitoring?
❑ ❑ m ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑ ❑ 0 ❑
Comment: No on -site vehicle maintenance.
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
0 ❑ ❑ ❑
# Were all outfalis observed during the inspection?
0 ❑ ❑ ❑
At If the facility has representative outfall status, is it properly documented by the Division?
❑ ❑ N ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
0 ❑ ❑ ❑
Page: 3

Permit: NCS000106 Owner - Facility: Kapstone Kraft Paper Corporation
Inspection Date: 12/10/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: One of the three stormwater outfalls should be removed from the permit.
The stormwater runoff at this location comes from the closed and capped ash landfill
area owned by International Paper and is not part of Kapstone Paper.
Page: 4

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4 - So hp AirO2 ncruturs _
3 - 75 hp AIrU2 wr.t.rs
1 I - 75 hp high ap..d surr.ce aerator
13 - 60 hp high ap..d surf".. ^ryju s
Total — 2030 hp
L,LIP ✓4
ndfill G�r✓�
Roanoke Rlver_��
Siormwou Ditch
vt
Site Plan - Roanoke Rapids

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County: Halifax
River Basin ROA
Report To RROSP
Collector.
A HOBAN
Region:
RRO
Sample Matrix:
Surfacewater
Loc. Type:
Effluent
Emergency Yes/No
CDC Yes/NO
Location ID: RROSPNLC
VisittO
Loc. Deem: KAPSTONE PAPER
Collect Date: 12110/2008 Collect Time:: 01:50
Sample Qualifiers and Comments
Sample ID:
AB38767
PC Number#
BW935
Date Received:
12/11/2008
Time Received:
09:00
Labworks LoginlD
DSAUNDERS
Date Reported:
1/12/09
Report Generated: 01/12/2009
Sample Depth
Routine Qualifiers
For a more detailed description of these qualifier codes refer to www.dwqlab.org under Staff Access
A -Value reported is the average of two or more determinations
B1-Countable membranes with <20 colonies; Estimated
B2- Counts from all filters were zero.
83- Countable membranes with more than 60 or 80 colonies; Estimated
B4-Filters have counts of both >60 or 80 and < 20; Estimated
BS-Too many colonies were present; too numerous to count (TNTC)
J2- Reported value failed to meet OC criteria for either precision or accuracy; Estimated
J3-The sample matrix interfered with the ability to make any accurate determination; Estimated
J6-The lab analysis was from an unpreserved or improperly chemically preserved sample; Estimated
NI -The component has been tentatively identified based on mass spectral library search and has an estimated value
LAB
N3-Estimated concentration is < POL and >MDL
NE -No established PQL
P-Elevated PQL due to matrix interference and/or sample dilution
01-Holding time exceeded prior to receipt at lab.
Q2- Holding time exceeded following receipt by lab
PQL- Practical Quantitation Limit -subject to change due to instrument sensi0vdy
U- Samples analyzed for this compound but not detected
X1- Sample not analyzed for this compound
Laboratory Section>> 1623 Mail Service Center, Raleigh, INC 27699-1623 [phone]
Page 1 of 4

NC DWQ Laboratory Section Results
Location ID'. RROSPNLC
Loc. Descr.: KAPSTONE PAPER
Visit ID
Sample ID
At53452tf
Collect Date:
12/1012008
Collect Time::
01:50
Analyte Name POL Result Qualifier Units Analyst/Date Approved
Via tOfnPenstura at receipt by tab 1.6 T DSAUNDERS HPARK
Method Reference 12I11/08 12111/OB
By
SOD, 5-Day In liquid 2.0 16 mg/L BSWANSON CGREEN
Method Reference APHA5210B 12/12/08 12/22/08
Resldue_Susperded In liquid 5.2 10 M91L LBUCK ESTAFFORD
Method Reference APHA2540b20d1 12/12/08 1/5109
Ian Chromatography
TITLE—
mg/L
AWILLIAMS
CGREEN
Method Reference EPA300.0
1/6f09
1/12/09
Phenolics Total In llgtdd
10
31
ugfL
MIBRAHIMI
CGREEN
Method Reference LAC10-210-00-1-A
12/19/08
1/8/09
Total DIBeaNed Solids In liquid
12
946
1119I1-
AWILLIAMS
CGREEN
Method Reference APHA2540C-18TH
12116/08
lzr2ma
Chloride
1.0
20 U,P
mgfI-
AWILLIAMS
CGREEN
Method Reference EPA 300.0
1/6I09
VIVD9
Fluoride
0.4
8.0 U,P
M91L
AWILLIAMS
CGREEN
Method Reference EPA 300.0
1/6/09
1/12109
Sulfate
20
460
M91L
AWILLIAMS
CGREEN
Mehod Reference EPA 3000
M*9
1/12109
NUT
NF13 as N In BgNd
0.02
1.5
mgfL as N
MAJAYI
CGREEN
Method Reference Lact D-107-06-14
12/12108
122208
Total I~ N as N In liquid
0.2
4.0
mg/L as IN
MOVERMAN
CGREEN
Method Reference Ladu110746-2-H
12/18/09
12122=
NO21NO3 as N In 11"
0.02
0.02
myL as N
MAJAYI
CGREEN
Method Reference Lac10.107-041<
12JI2108
12=08
Phosphonts total as P In IkW
0.02
0.44
mg/L as P
GBELK
CGREEN
Method ReMnce Lac10-115-M-1EF
12119MB
12/23I08
7440-224
Ag by ICPMS
5.0
5.0 U
ugr-
PGAUTHIER
ESTAFFORD
Method Reference EPA 200,8
1229N8
1!//09
7429-905
Al by ICP
50
610
ug(L
DSTANLEY
ESTAFFORD
Method Reference EPA 200.7
1218108
1//109
7440-38-2
As by ICPMS
2.0
33
U9IL
PGAUTHIER
ESTAFFORD
Method Reference EPA 200.8
1229/08
12109
Laboratory Section>> 1623 Mail Service Center, Raleigh, NC 27699.1623 (919) 73"908 Page 2 of 4

NC �D4WQ La6oratory Sample ID AB38767
Location ID: RROSPNLC Section eSUCtS
Loc. Descc:, KAPSTONE PAPER Collect Date: 12/10/2008
Visit ID
Collect Time 01:50
Name POL Result Qualifier Units AnalysVDete q pprovad By /Date
Method Ralerance
EPA 200.7
--
w�
UI IANLLT
ESTAFFORD
7440-41-7
Be by ICP
12/2Z08
12/09
Method Reference
EPA 200.7
5.0
6.0
U
uglL
DSTANLEY
ESTAFFORD
7440 -70-2
Ca by ICP
12/18I08
12A9
Method Reference
EPA200.7
0.10
37
M91L
DSTANLEY
ESTAFFORD
744043-9
Co by ICPMS
1222108
U109
Method Reference
EPA 200.8
1.0
1.0
U
uglL
PGAUTHIER
ESTAFFORD
7440<8-4
Cobalt by ICP
1229MB
12/09
Melhotl ReMence
EPA 200.7
50
50
U
LIWL
DSTANLEY
ESTAFFORD
7440d7-3
Qby ICPMS
12/18I08
12/09
Method Reference
EPA 200.8
10
10
U
W/L
PGAUTHIER
ESTAFFORD
7440-50A
nr fv Irouc
1229/08
1/ m
Method Reference EPA 200.8
w� -UAUI HIEH ESTAFFORD
7440 12/29108 12/09
-48-0 Fe by ICP � 240
Method Reference EPA 200.7 1/9fL DSTANLEY ESTAFFORD
7439 1211=8 12/O9
Method Reference
EPA 245.1
-- -
-
w�
oJnirvINLK
ESTF
0, ICP
12rJN08
1/7/09
Method Reference
EPA 200.7
O.iO
17
MOIL
DSTANLEY
ESTF
12QMB
ICP
117M
Method Reference
EPA 200.7
25
25
U
ug1L
DSTANLEY
ESTA
1211MB
bylCP
ln/09
Method Reference
EPA 200.7
0.10
7.3
M91L
DSTANLEY
ESTA
12=8
by ICP
1/7/09
MethoO Reference
EPA 200.7
10
600
ug1L
DSTANLEY
ESTA
by ICPMS
1211 W8
ln/09
Method Reference
EPA 200.8
10
10
U
WfL
PGAUTHIER
ESTA
by ICP
1229/08
12/09
Me0 Reference
EPA 200.7
0.10
300
fllgll.
DSTANLEY
ESTA
y ICPMS
12122108
117/09
Metho4 Reference
EPA 200.8
10
10
U
ILIA
PGAUTHIER
ESTA
OyICPMS
12129MS
177/09
Method Reference
EPA 200.8
10
10
U
ug1L
PGAUTHIER
-ESTA
ry ICPMS
1229108
117/09
Method Reference
EPA 200.8
10
10
U
119fL
PGAUTHIER
ESTAI
1229/08
12/09
Laboratory Section 1623 Mall ServlCa Canter, Raleigh, NC 27699-1623 (919) 733.39N Page 3 of 4

NC q)WQ Laboratory Section ResultsSampleID Mete/ 0/Collect Dale: 12/1012008
Location ID: RROSPNLC
Loa Deecc:-
KAPSTONE PAPER Collet Time:: Ot:50
Mart 10
CAR x Analvte Name PQL Result Qualifier Units Analyst/Date Approved 6y 0
1. -_-
- -- 1229108 1O109
Method Reference EPA 2001
7440-31.5 So by ICPMS 10 10 U Ug1L PGAUTHIER ESTAFFORD
a9
Ref EPA 2008
12/29108 1n
7440-2"
7440-32-6
Method erence
Thal0lan (TI) ICPMS
Method Rebrence EPA200.8
TI (fthIU n) by ICP
10
10
10
10
U
U
UQfL
UG(L
PGAUTHIER
12/29/08
DSTANLEY
10108
ESTAFFORD
1///09
ESTAFFORD
1//109
7440-62-2
Method Reference EPA 200.7
V by ICP
25
25
U
UgIL
DSTANLEY
12/18108
ESTAFFORD
117109
7440-66-6
Method Reference EPA200.7
Zn by ICPMS
10
10
U
UWL
PGAUTHIER
ESTAFFORD
1/7109
I,-- n o.m.— EPA 200.8
12/29/08
Laboratory Section» 1623 Mall Service Center, Raleigh, NC 27699.1623 [phone]

aft
D"ION OF WATER QUALITY
Ckmh" llb—Wy III"" I W.W Q..INy
MORI Y ❑ cA
❑ AMBIENT ❑ QA ❑ STREAM YY EFFLUENT
COMPLIANCE CHAINOF CUSTODY /—"
❑ LAKE ❑ INFLUENT
❑ EMERGENCY VISIT ID ESTUARY ❑
s1.tlw L.ut1..: ,
R...b:��Fa11C90I %Lem k�le°aI
T]Re Fad I D.W - DM, DR, DRM
V.1.. TTp- A, T4 L
qit) g35y
uo lYlp D,
D.�djll-DS
T. Re.rvd (�
R..,ry d By Ub
Du. R k d
Dw. Reported
C—iwT, S, R
COUNTY,
''r
AVER BASIN:
�/ni
REPORTTO
Re(P..tl Once
OIYae
COLLECTOR(S)
E-dm d ROD R..W
S.d:
.�
CM.rWtd:
S.?
COMMENTS:

v
Sample ID:
AB38768
county Halifax
'.
warFH
PO Number#
8W9355
River Basin RDA
QF
QG
Date Received '.
12]1112008
RROP
Report To -�_
O�
Tin r
Time Received'.
09:00
Collector. A HOBAN
> y
G
Labworks Loginl0
DSAUNDERS
Region RRO
Dale Reported:
1/12/09
Sample Matrix-. Surfacewater
Report Generated:
01/12/2009
Loc. TypeEffluent
Emergency Yes/No
VisitlD
CDC Yes/No
1 I �Ot
Loc. Descr.: KApSTONE PAPER
I
Locaton ID RROSPNLC
Collect Date 12/1012008
Collect Time:: 02:20
Sample Depth
Sample Qualifiers and Comments
Routine Qualifiers
For a more detailed description of these qualifier codes refer to www.dwqlab.org under Staff Access
A -Value reported is the average of two or more deter tinations
BI-Countable membranes win QO colonies Estimated
82- Counts from all filters were zero.
B3- Countable membranes with more than 60 or 80 colonies, Estimated
84-Filters have counts of both >60 or 80 and < 20. Estimated
B5-Too many colonies were present; too numerous to count (TNTC)
J2- Reported value failed to meal QC criteria for either precision or accuracy; Estimated
J3-The sample matrix interfered with the ability to make any accurate determination; Estimated
J6-The lab analysis was from an unpreserved or improperly chemically preserved sample; Estimated
N1-The component has been tentatively identified based on mass spectral library search and has an estimated value
LAB
N}Estimated concentration is < PQL and >MDL
NE -No established PQL
P-Elevated PQL due to matrix interference and/or sample dilution
Qt-Holding time exceeded prior to receipt at lab.
Q2- Holding time exceeded following receipt by lab
POL- Practical Quantilation Limit -subject to change due to instrument sensitivity
U- Samples analyzed for this compound but not detected
X1- Sample not analyzed for this compound
Laboratory Section» 1623 Mail Service Center, Raleigh, NC 27699-1623 [phone] Page 1 or 4

Location ID: RROSPNLC NC DWQLa6oratorySCCtl07�CSlCtS
Lm Dever.: KAPSTONE PAPER
Visit ID
Sample ID
Collect Date:
CollectTime::
AB38768
1211012008
02:20
CAS # Analyte Name
PQL
Result Qualifier
Units
Analyst/Date
�� 1ermPeratlee
A PProved By /Data
Method Reference
1.6
C
DSAUNDERS
HPARKER
WARO
12/11/08
12/11K)a
Resldue_Suspended In liquid
Method Rafinence APHA25400.20N
6.2
62 U
mg1L
LBUCK
ESTAFFORD
WET
12/12/08
1/5/09
Ion Chromatography
Method Reference EPA 300A
_nTLE_
M91L
AWILLIAMS
CGREEN
Total Dlaedve0 We inliquid
1/6/09
Mice
Method Reference APHA254OC-18TH
12
81
n�L
AWILUAMS
CGREEN
Chlallde
12/16/O8
1222108
Method Reference EPA 300.0
1.0
12
m91L
AWILLIAMS
CGREEN
FLIOfWB
1/6/09
1/9/09
Method Reference EPA 300.0
0.4
0.4 U
m91L
AWILLIAMS
CGREEN
Sulfate
1/ri/09
1AIM9
Method Reference EPA 300.0
2.0
7.8
M91L
AWILUAMS
CGREEN
NUT
1/6109
1/9/00
NH3 as N In liquid
Method Re/erence Lac10-107-O6.1J
0.02
0.07
rtglL as
MAJAYI
CGREEN
TOW I981dahl N as N W 14W
12/12/08
12/22/08
Method Reference Lacha1107-0S2-H
0.2
OA1
mg(L asN
MOVERMAN
CGREEN
NO2+NO3 as N In IIquW
12/1&08
12/22/08
Method Reference Lac10-107-04-1c
0.02
0.04
mg/Lw N
MAJAYI
CGREEN
phoopllolUe_tdal 88 P In Iiqutld
12/12/08
1222/08
McNotl Reference Lac10.115-01-1 EF
0.02
0.06
mglL le P
GBELK
CGREEN
MET
12/18/08
1223108
7440-224
AG by ICPMS
Method Reference EPA 200.8
5.0
5.0 U
LIg1L
PGAUTHIER
ESTAFFORD
7429-90-5
AI by (CP
1229108
1/7/Og
Method Reference EPA 200.7
50
95
ug1L
DSTANLEY
ESTAFFORD
7440-38-2
Av by ICPMS
12/IM9
In/o9
Method Reference EPA 200.8
2.0
20 U
Ilg/L
PGAUTHIER
ES
TAFFORD
7440-38-3
Be by ICP
1229M
1n/o9
Method Reference EPA 200.7
10
31
Ilg/L
DSTANLEY
ESTAFFORD
744041-7
Be by ICP
122=8
1n109
Method Reference EPA 200.7
5.0
5.0 U
Ilg/L
DSTANLEY
ESTAFFORD
7440-70-2
cabylcP
12/18/08
1O/0)
Method Reference EPA 200.7
0.10
9.3
n1gIL
DSTANLEY
ESTAFFORD
1222/08
1/7/D9
Laboratory Section» 1623 Mall SOMICO Center, Raleigh, NC 27699.1623 [phone]
Page 2 014

Location ID: RROSPNLC
Loc. Descr.: KAPSTONE PAPER
Visit ID
Analyte
NC (DWQ Laboratory Section Results
aampWe iu ...,-........
Collect Date: 12/1012008
Collect Time:: 02:20
, —• •-•—
Method Reference
EPA 200.8
122Wo8
lam
7440484
744047-3
Cobalt by ICP
Method Reference
Cr by ICPMS
EPA 200.7
50
10
50
10
U
U
Ug(L
Ug1L
DSTANLEY
12/18108
PGAUTHIER
1229108
ESTAFFORD
lf7t09
ESTAFFORD
12/09
Method Reference
EPA200.8
7440-50-8
011 by ICPMS
Method Reference
EPA200.8
2.0
2.7
Ugfl-
PGAUTHIER
1229/08
ESTAFFORD
117109
7440484
Fe by ICP
Method Reference
EPA200.7
50
390
uglL
DSTANLEY
12/18108
ESTAFFORD
12/09
7439-97-6
Fig 245.1
Method Reference
EPA245.1
0.2
020
U
UgtL
BSKINNER
1250/08
ESTAFFORD
lam
7440-09-7
Kby ICP
Method Reference
EPA 2003
0.10
3.0
fnQIL
DSTANLEY
1222708
ESTAFFORD
177/09
7439-93-2
U ICP
Method Refermce
EPA 200.7
25
25
U
Ug1L
DSTANLEY
1211 WO8
ESTAFFORD
1f7/09
7439-954
Mg by ICP
Method Reference
EPA 200.7
0.10
4.1
ni
DSTANLEY
12/22/08
ESTAFFORD
12/09
7439-96-5
Mn by ICP
Method Reference
EPA 200.7
10
90
UgfL
DSTANLEY
12118I08
ESTAFFORD
1RM
7439-98-7
MO by ICPMS
10
10
U
U9fL
PGAUTHIER
ESTAFFORD
Method Reference
EPA 200.8
1229/08
1/7/O9
7440-234
Na by ICP
0.10
13
mgtL
DSTANLEY
ESTAFFORD
Method Refermce
EPA200.7
1222V8
117109
7440-02-0
A by ICPMS
10
10
U
UWL
PGAUTHIER
ESTAFFORD
Method Reference
EPA 200.8
1229N8
12t09
7439-92-1
Pb by ICPMS
10
10
U
U911.
PGAUTHIER
ESTAFFORD
Method Reference
EPA2008
1229108
1/7,09
7440-36-0
Sb by ICPMS
10
10
U
t1g1L
PGAUTHIER
ESTAFFORD
Method Reference
EPA200.8
1229N8
1/7/09
778249-2
Se by ICPMS
5.0
5.0
U
tglL
PGAUTHIER
ESTAFFORD
Method Reference
EPA 200.8
1229/O8
lf7109
7440-31-5
Sn by ICPMS
10
10
U
ugIL
PGAUTHIER
ESTAFFORD
Method Reference
EPA200.8
1229108
1R/09
7440-28-0
ThvJk n(T1)ICPMS
10
10
U
U91L
PGAUTHIER
ESTAFFORD
Method Reference
EPA 2008
1229I08
lam
Laboratory Section 1623 Mall Service Center, Raleigh, NC 27699-1623 [phone] rage o oT 4

Location ID: RROSPNLC
Loc. Descr.: KAPSTONE PAPER
Vsh ID
jyl- Lvyy Laboratory SectionWgsurts
Units
Method Reference EPA 200.7
Method Rvn,,a EPA 200.7
Method Referenee EPA 200,8
Collect Date:
Collect Time:
12/19/08
12/18/08
1212WO8
12/10/2008
02:20
tPPov
EST- �
1/7/O9
CSTAFFORO
la/ug
ESTAFFORD
lnng
Laboratory SecLon>> 1620 Mail Service Center, Raleigh, NC 27699.1623 19191733.3908
Page 4 of 4

DIVISION OF WATER QUALITY
p n
Cb..d y laboratory Report/Wafer Qutlfy
SAMPLETYPE
COUNTY ItoQX
Den Received
RIVER BASIN:
AMBIENP NT QA
STREAM
EFFLUENT
TRRece MBy
REPORT TO a Rc®mW off.
COMPLIANCE CHAIN OF CUSTODY
❑LAKE
INFLUENT
COLT :
El EMERGENCY
VISIT ID ES ARY ❑
K n`�/Val• �I �
r/
Dm Released
D.n Reported
Ofi�afed ROD Ilage:
.SuDY lnuffoa:
Seed: CYbriuW:-
Re4rW:
� �8
71-e.C� 00 q �Oel'['tn
)
7l q CCC4:,,3
Sfatba d/I.asadaa Cade
v000-7saooa
Dan �-
°an`'" ~W )O
71�e
O
DW-DM, DB DBM
ep
K gsType -A,B L
COBpounT,S BIVC-
peType
D
'
0 310 ws
COD H.Rh 340 m
Chlonda W
NH3 u N 610 mgfL
Lt-LWuuin 1132 u
Tr m N 625
M - mum 92]
COD Law 735
R • EPA 443.0 vmdified ion
NO2 lus NO3 as N 630 mAfL
m
M.-M.1055
Cahf. MF Fece131616 /100m1
P: as P 665
Ns Sodium 929
Colifum- MF ToW 31500 /IOgW
Color: T.80 c.u.
4 a
POd P )OSO)
m
Anemc ToW 1002
COhf. wl a Feco131615 /I W W
Colm: H 83 H- c.u.
P- Di..N d n P 666 m
Se- S.I. 1147
Coliform: Fecal Sa 31673 /1001w
Color pH ] 6 82 c.0
K-Pa . .&fL
u gfL
H - Mmmy 71900
Rmiduc Told 500
C de 720 WL
Cd-Cadmmin 1027 URIL
J3.Barium
Volmik SOS
Fluande 951
C,-Ch ml. TOW 1034
q ochlonne Penindcs
Fixed 510
Formuldetrydc)1880 MWL
Cu-C 10/2
hone Pesnada
Ra d. Suspended 530 m
G1. vW qIs 556
Ni-Nicbe11067 WL
O�..Pcsomdes
Volmle 535
Hardneu ToW 900 MKII,
Pb- Lead 1051
.
AcW HerbmWes
Fiord 540
S C.M 95 mihoslm-
Z.- Z. I092
pH 403 mJn
MBAS 382W
V-Vmadnm
BasdNemald:AcW Fxnacfeble Org,,cs
MWtW to vii45 416
Phenols 32]30
-SJvm IOTI UIVLTPH
Di el RV
Al to H435
Sulf945
9
AI-Alummmt 1105 URIL-
ABalmi H b 8.3 415
SWfid. da )45
Bs Ilium 1012
ursa
Pble Ovcs VOA bonk 'd
Allulm� b N d 5 qU
Ca- Calcium 916
TPH Guoluv
TOb. 680 MIA
T.&U
Co- COW1103)
TPH/BTEX Gasoline
Tmbidi )6 NTU
Hexavalmt Chromium a
Fe. hen 1065 WL
e
PhywpW&=
Colifarm ToW Tuhe lim,w
Bicasbmum
Mo-mo
Cmba .11L
Sb-Mtmou
Told Divolved SolWs
Se -Tin
TI-TheRium UiVL
Ti-TiWtum u
T eon ertivd C
H -1631 n
COMMENTS:

uounty: HALIFAX
River Basin RDA
Report To RROSP
Collector
A H BAN
Region:
RRRO
Sample Matnx:
Surfacewater
Loc, Type:
Etn en
Emergency Yes/No
COC Yes/No
Location lD-. NC0000752003
VisitlD
Loc. Deacr.: KAPSTONE PAPER
Collect Date: 12/10f2008 Collect Time 03:05
Sample Qualifiers and Comments
Routine Qualifiers
Sample ID:
PO Number #
Date Received
Time Received:
Labworks LogmI0
Date Reported:
Report Generated.
Sample Depth
For a more detailed description of these qualifier codes refer to www.dwglab.org under Staff Access
A -Value reported is the average of Nro or more determinations -
Bl-Countable membranes with <20 colonies; Estimated
82- Counts from all filters were zero.
83- Countable membranes with more than 60 or 80 colonies, Estimated
B4-Filters have counts of both >60 or 80 and 120, Estimated
B5-Too many colonies were present; too numerous to count (TNTC)
J2- Reported value failed to meet QC criteria for either precision or accuracy; Estimated
J3-The sample matrix interfered with the ability to make any accurate determination; Estimated
J&The lab analysis was from an unpreserved or improperly chemically preserved sample; Estimated
N1-The component has been tentatively identified based on mass spectral library search and has an estimated value
LAB
N3-Estimated concentration is < PQL and >MDL
NE -No established PQL
P-Elevated PQL due to matrix interference andfor sample dilution
Qt-Holding time exceeded prior to receipt at lab.
Q2- Holding time exceeded following receipt by lab
PQL- Practical Quantitation Limit -subject to change due to instrument sensitivity
U- Samples analyzed for this compound but not detected
X1- Sample not analyzed for this compound
AB38769
8W9356
12/11/2008
09:00
DSAUNDERS
1/16/09
01 /22/2009
2 3 _�"J
Laboratory Section>> 1623 Mail Service Center, Raleigh, NC 27699-1623 [phone]
Page 1 of 4

NC D WQ Laboratory Section W§sults Sample ID 9
AA ,B38768769
Location ID: NC0000752003 Collect Date:
Loc. Descr.: KAPSTONE PAPER Collect Time:: 03:05
Visit ID
CAS # Analyte Name PQL Raeult Qualifier Units Analysl/Date Approvea by fvew
1Me wrpwakn atreceipt bl,lab 1.6 •C VjAUNUtKb nrnnn
12/11m8 12/11/08
Method Reference _
Realdtte_SusiWided In liquid 6.2 62 U M91L LBUCK ESTAFFORD
Method Ref.APHA254D0.201h 12/12/08 1/5/09
lon ChromatoGraPhN
TITLE-
mWL
AWILLIAMS
CGREEN
Method Referenm EPA 300-0
1/6m9
15/09
Taal Dissolved Solids In liquid
12
72
mwL
AWILLIAMS
CGREEN
Method Reference APHA2540C-18TH
12/16m8
1222=
Chloride
10
12
m91L
AWILLIAMS
CGREEN
Method Referenm EPA 300.0
116j99
19/09
Fluodda
0.4
0.4 .0
M91L
AWILLIAMS
CGREEN
Method Reference EPA 300o
1/5m9
19m9
Sulfate
2.0
6.5
Prot
AWILLIAMS
CGREEN
Method Reference EPA 300.0
116m9
19109
NUT
NH3 as N In liquid
0.02
0.02 U
m91L ds N
MAJAYI
CGREEN
Method Reference Lec10.107-06-1-J
12/12108
1222m8
Total lQMde" N as N In Bgtld
0.2
028
mgfi-asN
MOVERMAN
CGREEN
Method Reference Lacha1107-062-1-1
12/108
12r22108
NO2*NO3 as N In"
0.02
0.06
mp1L as N
MAJAYI
CGREEN
Method Reference Lwl()407-04.1�
12/12m8
1222108
Phosphorus_btal as P In Bald
0.02
0.02
m91L as P
GBELK
CGREEN
Method Reference LacIO-115.01-1EF
12/18/08
12/23108
7440-22.4
A9 by ICPMS
5.0
5.0
U
ugn-
PGAUTHIER
ESTAFFORD
Method Reference
EPA 2001
1229108
117m8
7429-90-5
At by ICP
50
150
U91L
DSTANLEY
ESTAFFORD
Method Reference
EPA200.7
12/19m8
117m9
7440-38-2
As by ICPMS
2.0
2.0
U
U91L
PGAUTHIER
ESTAFFORD
Method Reference
EPA 200.8
1229MB
1f7/09
7440-38-3
Ba by ICP
10
26
Lori-
DSTANLEY
ESTAFFORD
Method Reference
EPA 2003
1222m8
1/7m9
744041-7
Be by ICP
5.0
5.0
U
Vt.
DSTANLEY
ESTAFFORD
Method Reference
EPA 200.7
12/19108
V7109
7440-70-2
Ce by ICP
0.10
9.0
m91L
DSTANLEY
ESTAFFORD
Method Reference
EPA 200.7
1222108
1//I09
Laboratory Seetlon» 1623 Mall Service Center, Raleigh, NC 27699-1623 [phone] Page 2 of 4

Location ID: NC0000762003
Loc. Descr.: KAPSTONE PAPER
Visit ID
NC 1D WQQ Laboratory Section J;�fsults
Collect Date:
Collect Time::
12/10/2008
03:05
Analyte Name POL Result Quailfler Unite AnalysUDate q
pproved By /Data
Method Retmence
EPA 200.8
-
a,r,rrvnU
7440d8i
Cohan by ICP
1229/08
1 nm9
Method Reference
EPA 200.7
�
�
U
uWL
DSTANLEY
ESTAFFORD
7440-47-3
Cr by ICPMS
12118108
1nm9
Method Reference
EPA 200.8
10
10
U
U91L
PGAUTHIER
ESTAFFORD
744a50a
a gr lcPMs
1229/08
1nm9
Method Reference
EPA 200.8
2.0
2.0
u
IgIL
PGAUTHIER
ESTAFFORD
7440<8�
Fe by ICP
1212MB
tn/09
Method Reference
EPA 200J
50
210
uglL
DSTANLEY
ESTAFFORD
7439-97b
H9 243.1
12/18m8
inm9
Method Ralerenca
EPA 246.1
0.2
020
U
WIL
BSKINNER
ESTAFFORD
7440-09-7
K by ICP
12rwm
1nm9
Method Reference
EPA 200.7
0.1041
m91L
DSTANLEY
ESTAFFORD
7439-93-2
UICP
1222m8
in/09
Method Reference
EPA 200.7
25
25
U
u0L
DSTANLEY
ESTAFFORD
7439-95-0
Mg by ICP
12/lame
In=
Method Reference
EPA 2003
0.10
3.8
Illp/L
DSTANLEY
ESTAFFORD
7439-96-5
Mn b/ICP
12/22/08
1nm910
Method Reference
EPA 2fp.]
93
uWL
DSTANLEY
ESTAFFORD
7439-98-7
Motby ICPMS
12118m8
tnm9
Method Reference
EPq 200.8
10
10
U
WfL
PGAUTHIER
ESTAFFORD
7440-231
Na by ICP
1229/08
117m9
Method Ralerer,ce
EPA 200.7
0.10
8.6
mWL
DSTANLEY
ESTAFFORD
7440-02-0
NI by ICPMS
1222108
lam
Method Reference
EPA 200.8
10
10
U
IWL
PGAUTHIER
ESTAFFORD
7439-92-1
Pb by ICPMS
1229109
1nm9
Method Reference
EPA 200.8
10
10
U
uWL
PGAUI HIER
ESTAFFORD
7440-36-0
Sid by
by ICPMS
1n/09
Method Raferar¢e
EPA 200.8
10
10
U
u91L
PGAU7HIER
ESTAFFORD
-
7782-49-2
Se by ICPMS
1229108
inme5.0
Method Reference
EPA 200.8
5.0
U
WfL
PGAUTHIER
ESTAFFORD
7440-315
Sn by ICPMS
1229m8
1nm9
Method Relerervw
EPA 200.8
10
10
U
upft-
PGAUTHIER
ESTAFFORD
7440-26-0
Thelllum (TI) ICPMS
1229m8
lnm9
Method Reference
EPA200.8
10
10
U
ILIA
PGAUTHIER
ESTAFFORD
1229108 1 nm9
Laboratory Section» 1623 Mall Service Center, Raleigh, NC 27699-1623 )919) 733-3908
Page 3 of 4

NC (D WQ Laboratory Section Wgsults Sample ID AB38769
Location ID'. NC0000752003 Collect Date: 12/1012008
Loc. Descr.: KAPSTONE PAPER Collect Time.: 03:05
vsit ID
CAS # Analyte Name PQL Result Qualifier Units Analysvuate Approved 9y luate
laelhOe Reference
EPA 200.7
12118/08
117109
7440.62-2 V by ICP
25 25 U ugfL DSTANLEY
ESTAFFORD
MethM Reference
EPA200.7
1208I08
117M
7440-66-6 Zn by ICPMS
10 10 U ug1L PGAUTHIER
ESTAFFORD
MaMW Reference
EPA 200.8
12r2ws
Witte
Laboratory Section» 1623 Mall Service Center, Raleigh, INC 27699-1623 (919( 733-3908 Page 4 014

COUNTY :
K
RIVER BASIN:
REPORTTO I,et
RcSiu:� ORa:e
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Ms. Autumn Hoban
NCDENR
Division of Water Quality
3800 Barrett Drive
Raleigh, NC 27609
February 12, 2009
Subject: Permit No 7521,ic dO607 �
KapStone Kra t Paper Corporation
Non -Contact Cooling Water Discharge
Dear Ms. Hoban,
0
KAPETONE
KRAFT PAPER CORPORATION
A Division of KAPSTONE PAPER AND PACKAGING CORPORATION
100 Castor, Road Roanoke Rapids. NC 27870
kapstonepaper corn
1 �
. I FEB 1 8 70f1q
�DENR RkiEIGH RE;; r -IrF
Confirming our phone conversation of February 10, 2009, I contacted the DWQ office
the afternoon of February 9, 2009 to report an unknown process discharge from our non -
contact cooling water outfall 003. At approximately 1:00 PM the pulp mill operator
acknowledged a spike in effluent conductivity and notified operations and environmental
personnel. A slightly foamy plume was discharging to the river. We began to shutdown
processes to determine where process material could be entering the non -contact sewer.
Your office was first notified at 2:45 PM. Flow of the discharge was less than 15 gpm
during the one hour event and there was no harm to the environment as a result. At your
suggestion, we sampled the discharge and upstream -downstream locations and found no
water quality issues. Subsequently, no other unauthorized discharges have occurred.
Our investigation has determined that following the severe freeze in late January, a leak
developed in a process sewer that contaminated the non -contact cooling water
intermittently during shutdown or start-up of the process. The incidents were so
infrequent and brief that we could not determine the source and concluded that we needed
to replace the conductivity probe. The probe was replaced the morning of February 9 and
we had a conductivity spike that afternoon and were able to isolate the problem. We
have made modifications to isolate and repair all impacted sewer areas.
If you have any questions or concerns, please contact me at 252-533-6255.
Sincerely,
�A-✓tcz�u�v�
MaO
Lee ansmeier
Environmental Programs Manager

C7A
Copy:
Myrl Nisely, DWQ
Barry Herzberg, DWQ
Anitra Collins, KapStone
Chris Puryear, KapStone

Re: Kapstone Paper- Question on pher-"-3 total/standards
Subject: Re: Kapstone Paper- Question on phenolics total/standards
From: Connie Brower <[e-mail]>
Date: Wed, 21 Jan 2009 12:28:43 -0500 /V
To: Autumn Hoban <[e-mail]>, sergei chernikov (�
<sergei.cherni kov@ncmail. net>
a00u
Autumn -
300 ug/L is the comparable "narrative" baseline for total phenolics in a Class C stream-- as I
noted in my voice mail to you -- if you are receiving complaints of "taste and odor" issues with
fish - then the standard has been exceeded, irrespective of the baseline of 300 ug/L.
hope this helps - call if you need additional information
Connie
Autumn Hoban wrote:
Connie,
yS
I recently sampled at Kapstone Paper and found phenolic total of 31 ug/L t outfall
G'
001-Class C, Roanoke River.
The guidance document has a note about a calculation is needed with regards to the
standards on this.
Can you give me some general guidance on what a result of 31 ug/L means?
The permit requires phenols to be sampled, if biocides are added. It appears they have
phenols present, but are not currently sampling. I am pretty sure they are adding
biocides. Just want to decide if I need to address this as part of the inspection write up
and if we should request that phenol sampling be done per the permit based on these
sampling results????
Thanks for any guidance and assistance you can provide.
Sincerely,
Autumn
Autumn Hoban
Environmental Specialist
NCDENR- Raleigh Regional
Surface water Protection
3800 Barrett Drive
Raleigh, NC 27609
1 of 2 3/17/2009 9:28 AM