NC0000752_Draft Permit (Major Modification)_20240402

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ROY COOPER f
Governor ''
ELIZABETH S.BISER a.
Secretary eft 0twero®
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
April 2, 2024
Mr. Benjamin P. White, General Manager
WestRock Kraft Paper, LLC
100 Gaston Rd.
Roanoke Rapids,North Carolina 27870
Subject: Draft NPDES Major
Modification
Permit NC0000752
Roanoke Rapids Mill WWTP
Halifax County
Facility Class IV
Dear Mr. White:
Enclosed with this letter is a copy of the Draft Major Modification for your facility. Please review
the draft very carefully to ensure thorough understanding of the conditions and requirements it
contains.
The Draft Major Modification contains the following significant changes from your current
permit:
• The Temperature Mixing Zone (700 ft. by 200 ft.) has been added to the permit.
Please provide any comments you have regarding the draft major modification to this office
by May 6,2024. At this time, the Division is also publishing a notice in the newspapers of general
circulation in Halifax County,inviting public comment on the draft major modification. Following
the 30-day comment period,we will review all pertinent comments received and take appropriate
action on the permit modification.
The NPDES Standard Conditions (Parts II, III, and IV) are not included with this draft. They can
be found at the following link if you would like to review them in conjunction with this draft permit.
https://bit.ly/2BZ4xxx
North Carolina Department of Environmental Quality I Division of Water Resources
D E Q�� 512 North Salisbury Street 11611 Mail Service Center I Raleigh,North Carolina 27699-1611
6.1MW�_o.wr\ r 919.707.9000

If you have any questions about the NPDES permit process,please contact me at the following e-
mail address: sergei.chernikovQdeq.nc.gov, or telephone number: 919-707-3606.
Sincerely,
Sergei Chernikov,Ph.D.
Environmental Engineer III
Industrial NPDES Permitting Unit
cc: NPDES Files
EPA Region IV(e-copy)
Raleigh Regional Office/ Surface Water Protection(e-copy)
Aquatic Toxicology Unit(e-copy)
TACU (e-copy)
N512 Northorth CarolinaSalisbury Street
Department of Environmental Quality Division of Water Resources
1611 Mail Service Center Raleigh,North Carolina 27699-1611
y�r,�, �� 919.707.9000

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
Draft 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,
WestRock Kraft Paper, LLC
is hereby authorized to discharge wastewater from a facility located at the
Roanoke Rapids Mill WWTP
100 Gaston Road
Roanoke Rapids
Halifax County
to receiving waters designated as the Roanoke River in the Roanoke River Basin
in accordance with effluent limitations, monitoring requirements, and other applicable
conditions set forth in Parts I, II, III and IV hereof.
This permit modification shall become effective
This permit and authorization to discharge shall expire at midnight on February 28, 2028.
Signed this day
Douglas Dowden
Environmental Program Supervisor II
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 8

Permit NC0000752
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility,whether for operation or discharge are hereby revoked.
As of this permit issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions included herein.
WestRock Kraft Paper, LLC 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 8s C evaporator (outfall 002),
and
3. Discharge from said treatment works, located at the Roanoke Rapids Mill Wastewater
Treatment Plant, North Roanoke Avenue, Roanoke Rapids, Halifax County, at the
locations specified on the attached map into the Roanoke River which is classified C
waters in the Roanoke River Basin.
Page 2 of 8

Permit NC0000752
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall serial number 001 - process water and
stormwater. Such discharges shall be limited and monitored6 by the Permittee as specified below:
EFFLUENT LIMITS MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly Daily Measurement Sample Sample
Average Maximum Frequency Type Locations
Flow 28.0 MGD Continuous Recorder I or E
BOD, 5-day, 20°C 9,145.0 18,289.0 Daily5 Composite E
lbs/day lbs/day
Total Suspended Solids 19,596.0 39,191.0 Daily5 Composite E
lbs/day lbs/day
Dissolved Oxygen, mg/L Weekly Grab E, U, D
Temperature, °C See A. Weekly Grab E, U, D
(8.)
Conductivity, µmho/cm Weekly Grab E, U, D
NH3 as N, mg/L Monthly Composite E
Total Nitrogen Monthly Composite E
(NO2+NO3+TKN), mg/L
Total Phosphorus, mg/L Monthly Composite E
Chronic Toxicity2'3 Quarterly Composite E
Total Copper3, µg/L Quarterly Composite E
pH 6.0-9.0 standard units Daily5 Grab E
Pentachlorophenol4 1.89 lbs/day Weekly Grab E
Trichlorophenol4 1.73 lbs/day Weekly Grab E
Total Hardness, mg/L Monthly Composite E, U
PFAS7 Annually Grab Effluent
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.
2. Chronic Toxicity (Ceriodaphnia) P/F at 3.7%; March, June, September, and December; see A.
(3.), Chronic Toxicity Pass/Fail Permit Limit.
3. Monitoring for metals and the whole effluent toxicity test shall be conducted at the same time.
4. Monitoring for pentachlorophenol and trichlorophenol is not required unless chlorophenolic
containing biocides are used at the facility. If chlorophenolic-containing biocides are used at
the facility, monitoring for pentachlorophenol and trichlorophenol shall commence immediately
for the duration of the use of the biocides and for a period of not less than two months after
discontinuing use of the biocides.
5. Daily shall mean every day except Saturdays, Sundays, and legal holidays.
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (6.).
7. Please see special condition A. (7).
8. Please note that Part A. (8.) applies to whether the increased temperature at the mixing zone
boundary results from either outfall 001 or outfall 002. The thermal mixing zone boundary
temperature condition in outfall 002 still shall be met.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The facility shall use method 1631E for Mercury analysis.
Page 3 of 8

Permit NC0000752
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall(s) serial number 002 - non-contact cooling
water. Such discharges shall be limited and monitored4 by the Permittee as specified below:
EFFLUENT LIMITS MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly Daily Measurement Sample Sample
Average Maximum Frequency Type Locations
« Semi-
FloEstimate Effluent
annually
Temperature °C See note 1 See note 1 Monthly Grab Effluent,
Point A, Point B
Temperature °C See not 1 See2not 1 Monthly Calculated Point A, Point B
Semi- Effluent,
pH 6.0 - 9.0 standard units2 Grab Upstream,
annually Downstream3
Footnotes:
1. The temperature of the effluent will be regulated so that the temperature of the receiving
stream does not increase more than 2.8°C (5.05°F) above the natural water temperature
and does not exceed a maximum of 32°C (89.6°F). For the monthly average, report the
largest difference of the temperature between the upstream sampling point (natural
background condition) and Point A or Point B. For the daily maximum, report the highest
temperature at Point A or Point B. See A. (8.).
2. The pH shall not be less than 6.0 standard units nor more than 9.0 standard units. In the
event that effluent pH shall be recorded outside this range, any value that falls within the
range of pH measured at the upstream and downstream points shall be considered
compliant. Effluent pH shall be sampled on the same days that stream samples for pH are
taken. See Condition A. (5.), pH Re-opener.
3. Upstream at NC Highway 48 Bridge, Downstream at NC Highway 158.
4. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (6.).
5. Point A and Point B are identified on the Attachment 1 and represent the lower boundary of
the temperature mixing zone.
There shall be no chromium, zinc or copper added to the treatment system except as pre-
approved additives to biocidal compounds. The permittee shall obtain authorization from
the Division prior to any use of biocide in the cooling water (See A. (4), Biocide Condition).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 8

Permit NC0000752
A. (3.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 3.7%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
February 1998, or subsequent versions or"North Carolina Phase II Chronic Whole Effluent Toxicity
Test Procedure" (Revised-February 1998) or subsequent versions. The tests will be performed
during the months of March, June, September, and December. Effluent sampling for this testing
shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the quarterly test procedure results in a failure or ChV below the permit limit, then
multiple-concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity
Test Procedure" (Revised-December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWR Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Or,results can be sent to the email,[e-mail].
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and
all concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring
is required, the permittee will complete the information located at the top of the aquatic toxicity
(AT) test form indicating the facility name, permit number, pipe number, county, and the
month/year of the report with the notation of"No Flow" in the comment area of the form. The
report shall be submitted to the Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Assessment of toxicity compliance is based
on the toxicity testing month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Resources indicate potential impacts to the receiving stream, this permit may be
re-opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate
environmental controls, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day of the month following the month of the initial
monitoring.
Page 5 of 8

Permit NC0000752
A. (4.) BIOCIDE CONDITION
[G.S. 143-215.1(b)]
The permitted shall not use any biocides except those approved in conjunction with the permit
application. The permitted shall notify the Director in writing at least ninety (90) days prior to
instituting use of any additional biocide in the treatment system, which may be toxic to aquatic life
(other than biocides previously reported to the Division). Such notification shall include completion
of Biocide Worksheet Form 101 and a map indicating the discharge point and receiving stream.
A.(5.) pH REOPENER
[G.S. 143-215.1(b)]
The Division may re-open this permit to remove pH limitation footnotes at Outfall 002, should new
information indicate water quality problems due to declining pH in this portion of the river.
A. (6.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of
this permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (all
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month
and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the
state's eDMR application is compliant with EPA's Cross-Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,
1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be
submitted to the mailing address above. See "How to Request a Waiver from Electronic
Reporting" section below.
Page 6 of 8

Permit NC0000752
Regardless of the submission method, the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility, on the last day of the month
following the commencement of discharge.
Starting on December 21, 2025, the permittee must electronically report the following
compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the
designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool
for each type of electronic submission and for each state. Instructions on how to access and
use the appropriate electronic reporting tool will be available as well. Information on EPA's
NPDES Electronic Reporting Rule is found at:
https://www.federalregister.gov/documents/2015/10/22/2015-24954/national-pollutant-
d ischarge-elimination-sy stem-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain
an electronic reporting waiver, a permittee must first submit an electronic reporting waiver
request to the Division. Requests for temporary electronic reporting waivers must be submitted
in writing to the Division for written approval at least sixty (60) days prior to the date the
facility would be required under this permit to begin submitting monitoring data and reports.
The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At
such time, monitoring data and reports shall be submitted electronically to the Division unless
the permittee re-applies for and is granted a new temporary electronic reporting waiver by the
Division. Approved electronic reporting waivers are not transferrable. Only permittees with an
approved reporting waiver request may submit monitoring data and reports on paper to the
Division for the period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found
on the following web page:
http://deg.nc.gov/about/divisions/water-resources/edmr
Page 7 of 8

Permit NC0000752
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.)
(d))
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority
for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR
user account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please
visit the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
"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. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
5. Records Retention [Supplements Section D. (6.11
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from
the date of the report. This period may be extended by request of the Director at any time [40
CFR 122.41].
A. (7.) PFAS MONITORING IN THE EFFLUENT
[G.S. 143-215.1(b)]
Upon EPA approval of method 1633 the facility shall employ this analysis for PFAS compounds
covered under this method. The analysis shall be conducted annually. If method 1633 is not
approved the facility shall employ EPA 537 Modified method for PFAS analysis.
Results of the PFAS analysis shall be submitted to the DEQ on the DMR, including electronic
reporting.
A. (8.) THERMAL MIXING ZONE
[G.S. 143-215.1(b)]
This permit incorporates a thermal mixing zone and establishes the size of the mixing zone based on
the critical month of the year (September). The established mixing zone is 700 ft. long and 200 ft.
wide. This mixing zone implements monthly temperature sampling at the following locations to
assure compliance with the specific state temperature standard:
1) Point A - middle of the lower boundary of the mixing zone.
2) Point B-the edge of the lower boundary of the mixing zone closer to the middle of the stream.
3) The "natural water temperature" noted on A.(2.) Footnote #1, will be based on the Upstream
sampling point listed in the permit.
Both sampling points A 86 B are identified on Attachment 1.
Page 8 of 8

Attachment 1
} :
Legend
Thermal Mixing Zone Boundary 3
Outfall 002
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Point B
Point A
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