HomeMy WebLinkAboutWQ0021577_Inspection Letter_20240920Docusign Envelope ID: E7A3CADO-8CD1-4OB3-AOD7-33B574FA2E5C
ROY COOPER
Governor
MARY PENNY KELLEY
Secretary
RICHARD E. ROGERS, JR.
Director
Benjamin White
General Manager
WestRock Kraft Paper
PO Box 458
Roanoke Rapids, NC 27870
NORTH CAROLINA
Environmental Quallty
September 20, 2024
SUBJECT: Compliance Inspection Report
WestRock Kraft Paper DCAR
Non -discharge Permit No. WQ0021577
Halifax County
Dear Permittee:
The North Carolina Division of Water Resources (DWR) conducted an inspection of the distribution of class A
residuals (DCAR) program at the above address on August 12, 2024. This inspection was conducted to
verify that the facility is operating in compliance with the conditions and limitations specified in non -
discharge permit no. WQ0021577. DWR representatives, Dorothy Robson and Myles Parker and WestRock
Kraft Paper facility representatives, Michael Knudson and Tyler Hale were present for the inspection. The
findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled "Compliance Inspection Report".
Division records indicate a treatment system consisting of the continued operation of a residuals
management program consisting of the distribution of class A residuals generated by WestRock Kraft Paper
Company and residuals may be distributed to second parties for approved uses.
DWR conducted a review of records and inspected the following areas of the facility: pH adjustment blend
tank, two rotary screen thickeners, two dewatering screw presses with a conveyor belt to load in trucks,
loading dock and drains, and class A residual storage area. The facility operates as Smurfit WestRock and
no enforcements or complaints have been reported in the past five years. Currently, there is no class A
product produced. The review reflected compliance with the subject permit.
Please refer to the attached "Compliance Inspection Report" for additional comments and observations. This
letter is a notification of the results of the compliance inspection. The facility was operating in compliance
with the permit.
North Carolina Department of Environmental Quality I Division of Water Resources
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D E Q�;�� Regional Office I 3800 BarrettDrive I Raleigh North Carolina 27609
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NORTH CA WNA ..
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Docusign Envelope ID: E7A3CADO-8CD1-4OB3-AOD7-33B574FA2E5C
If you have questions or comments about this inspection, then please contact me or Dorothy Robson via
email at dorothy.robson@deq.nc.gov or 919-791-4200.
Sincerely,
Doc/Iu,Siwgnel'd by:
372DCBCB61EE4A8...
Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Compliance Inspection Report
Ec: NON -DISCHARGE Laserfiche
North Carolina Department of Environmental Quality I Division of Water Resources
DE Q Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
NORTH CAROLINA 919.791.4200
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Docusign Envelope ID: E7A3CADO-8CD1-40B3-AOD7-33B574FA2E5C
Compliance Inspection Report
Permit: WQ0021577 Effective: 04/29/20 Expiration: 09/30/26 Owner : Westrock Kraft Paper LLC
SOC: Effective: Expiration: Facility: WestRock Kraft Paper DCAR
County: Halifax 100 Gaston Rd
Region: Raleigh
Roanoke Rapids NC 27870
Contact Person: Mary Lee Ransmeier Title: Phone: 252-533-6255
Directions to Facility:
100 Gasaton Rd. - From Raleigh, take 1-64 east to 1-95 north. Take exit 176 (Route 46) west to Route 48 south. Follow Route 48 a
short distance to the mill, which is on the right.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0000752 Westrock Kraft Paper LLC - Roanoke Rapids MITI WWTP
WQ0000436 Westrock Kraft Paper LLC - WestRock Kraft Paper SDU
Inspection Date: 08/12/2024 Entry Time 10:OOAM Exit Time: 12:OOPM
Primary Inspector: Dorothy M Robson Phone: 919-791-4241
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction Storage
(See attachment summary)
Page 1 of 4
Docusign Envelope ID: E7A3CADO-8CD1-40B3-AOD7-33B574FA2E5C
Permit: WQ0021577 Owner - Facility: Westrock Kraft Paper LLC
Inspection Date: 08/12/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The North Carolina Division of Water Resources (DWR) conducted an inspection of the distribution of class A residuals
(DCAR) program at the above address on August 12, 2024. This inspection was conducted to verify that the facility is
operating in compliance with the conditions and limitations specified in non discharge permit no. WQ0021577. DWR
representatives, Dorothy Robson and Myles Parker and WestRock Kraft Paper facility representatives, Michael Knudson
and Tyler Hale were present for the inspection. The findings and comments noted during this inspection are provided in the
enclosed copy of the inspection report entitled "Compliance Inspection Report".
Division records indicate a treatment system consisting of the continued operation of a residuals management program
consisting of the distribution of class A residuals generated by WestRock Kraft Paper Company and residuals may be
distributed to second parties for approved uses.
DWR conducted a review of records and inspected the following areas of the facility: pH adjustment blend tank, two rotary
screen thickeners, two dewatering screw presses with a conveyor belt to load in trucks, loading dock and drains, and class
A residual storage area. The facility operates as Smurfit WestRock and no enforcements or complaints have been reported
in the past five years. Currently, there is no class A product produced. The review reflected compliance with the subject
permit.
Please refer to the attached "Compliance Inspection Report' for additional comments and observations. This letter is a
notification of the results of the compliance inspection. The facility was operating in compliance with the permit.
Page 2 of 4
Docusign Envelope ID: E7A3CADO-8CD1-40B3-AOD7-33B574FA2E5C
Permit: WQ0021577 Owner - Facility: Westrock Kraft Paper LLC
Inspection Date: 08/12/2024 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Land Application
❑
Distribution and Marketing
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑
❑ 0 ❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑ 0 ❑
Are there any GW quality violations?
❑
❑ 0 ❑
Is GW-59A certification form completed for facility?
❑
❑ 0 ❑
Is a copy of current permit on -site?
0
❑ ❑ ❑
Are current metals and nutrient analysis available?
❑
❑ 0 ❑
Are nutrient and metal loading calculating most limiting parameters?
❑
❑ 0 ❑
a. TCLP analysis?
❑
❑ 0 ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑ 0 ❑
Are PAN balances being maintained?
❑
❑ 0 ❑
Are PAN balances within permit limits?
❑
❑ 0 ❑
Has land application equipment been calibrated?
❑
❑ 0 ❑
Are there pH records for alkaline stabilization?
❑
❑ 0 ❑
Are there pH records for the land application site?
❑
❑ 0 ❑
Are nutrient/crop removal practices in place?
❑
❑ 0 ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑
❑ 0 ❑
Are hauling records available?
❑
❑ 0 ❑
Are hauling records maintained and up-to-date?
0
❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
0
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑
❑ 0 ❑
Comment: No distribution was conducted in 2023.
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
❑
❑ 0 ❑
Class A, all test must be <1000 MPN/dry gram
❑
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
❑
Fecal coliform SM 9222 D (Class B only)
❑
❑ ❑
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
❑
b. pH records for alkaline stabilization (Class A)
❑
❑ ❑
c. pH records for alkaline stabilization (Class B)
❑
❑ ❑
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑
❑ ❑
Page 3 of 4
Docusign Envelope ID: E7A3CADO-8CD1-4OB3-AOD7-33B574FA2E5C
Permit: WQ0021577 Owner - Facility: Westrock Kraft Paper LLC
Inspection Date: 08/12/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment: No distribution of class A product
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Yes No NA NE
Page 4 of 4