NC0000752_Compliance Evaluation Inspection_20180411

ROY COOPER
Gover nor
MICHAEL S REGAN
Secretary
WaterResources LINDA CULPEPPER
ENVIRONMENTAL QUALITY Interim Director
April 11, 2018
Mr Benjamin White
Vice President of Mill Operation
Kapstone—Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Subject. Compliance Evaluation Inspection
Kapstone—Kraft Paper Corporation - Roanoke Rapids Paper Mill
Petnnt No. NC0000752
Northampton County
Dear Mr. White.
On November 16, 2016, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a compliance
evaluation inspection of the subject facility. The assistance provided by Mr. Neal Davis, the operator in
responsible charge (ORC), Mr. Chris Williams, the backup ORC, and Mr Paul Kinnin, was appreciated
as it facilitated the inspection process. The inspection report is attached. The following observations
were made
Kapstone—I -aft-Paper Corporation - Roanoke Rapid Paper Mill WWTP is permitted to discharge at
a rate of 28 0 MGD and consist of mechanical bar screen, primary clarifier, emergency holding
pond, sludge lagoon, aeration pond, and three stabilization ponds The plant discharges to Roanoke
River, a Class C water in the Roanoke River basin
1 Current permit expired on March 31, 2017 The facility submitted penult renewal application On
September 23, 2016 A draft pen-nit was sent to the facility for comments
2 All three influent pumps were in operation The primary clarifier was in good condition
3 Sludge from the primary clarifier was dewatered at the sludge handling facility, two trains of belt
presses, screw presses, and chemical feed system were available One train was in use at the time
of inspection, the other was off line for repair and maintenance. Dewatered sludge was disposed
at the onsite land fill. Leachate from the land fill and the old sludge pond flows by gravity into
the aeration pond and is treated along with the effluent from the primary clarifier.
4. Effluent from the clarifier was further treated at the aeration pond All 31 aerators were in
operational condition Numbers of aerators on line was controlled by the DO level in the basin
Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section http/'portal ncdeni org/web/wqlaps
1628 Mail Service Center, Raleigh,NC 27699-1628 Phone [phone]
Location 3800 Barlett Drive,Raleigh,NC 27609 Fax [phone]

Kapstone—Kraft Paper Corpotation-Roanoke Rapids Paper Mill
Permit No NC0000752
5 Effluent from the aeration pond was further treated in the three stabilization ponds before being
discharged to the river.
6. The ORC maintains a daily logbook Lab results, chain-of-custody forms, and Discharge
Monitoring Reports (DMRs) were complete and current, kept in good order and ready for
review. November 2017 DMR data were compared to lab bench sheets; no data transcription
errors were noted during the inspection.
7 The right of way to Outfall 001 was well maintained The effluent was observed to be clear and
free of solids No visible impacts were noted immediately downstream the effluent pipe Outfall
002 was also maintained and accessible.
8. Field lab parameter (Certificate No 183) calibration and analysis records were reviewed during
the inspection
The overall condition of the facility is compliant with Division standards. If you have any questions
regarding the attached reports or any of the findings, please contact Cheng Zhang at [phone] (or
email cheng.zhang@ncdenr gov).
Since ely,
Danny Si ith
Water Quality Regional Supervisor
Raleigh Regional Office
Attachments
Compliance Inspection Report
Cc. Central Files w/attaclunent
Raleigh Regional Office w/attaclunent
Neal Davis— ORC w/attachment

United States Environmental Protection Agency Form Approved
EPA Washington,D C 20460 OMB No 2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A National Data System Coding(i e,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 H 2 [ I 3 I N00000752 111 12 1 18/03/12 117 18 LI, 191 s I 201 I
211 11111111111111 111111111111111111111111111 r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA -------------Reserved —
67 1 1 70 1 1 71 1 I 72 12 1 73 I I 174 751 1 1 1 1 1 1 180
Section B Facility Data L_I
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)
10 00AM 18/03/12 12/06/01
Kapstone Kraft Paper Corporation WWTP
100 Gaston Rd Exit Time/Date Permit Expiration Date
Roanoke Rapid NC 27870 12 30PM 18/03/12 17/03/31
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Neal R Davis/ORC/252-533-6295/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Benjamin P White,PO Box 458 Roanoke Rapids NC
2787004581/252-533-6335/2525336465 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 Bil Facility Site Review lig Effluent/Receiving Waters
® Laboratory
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Cheng Zhang RRO WQ//919-791-4200/ /
C/L--4-110-A-C7 4>----
ignatur of Management A Revie -r Agency/Office/Phone and Fax Numbers Date
atil 6,/ 7./P ,• P1/4g iefi7,,73)71.7 111117 /2
10,21 /57 '
V
EPA Form 60-3(Rev 9-94)Previous editions are obsolete
Page# 1

Permit NC0000752 Owner-Facility Kapstone Kraft Paper Corporation VVWTP
Inspection Date 03/12/2018 Inspection Type Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping'? ® 000
Does the facility analyze process control parameters,for ex MLSS, MCRT, Settleable ® 000
Solids, pH, DO, Sludge Judge, and other that are applicable'?
Comment DO, TSS, pH, and conductitivity
Permit Yes No NA NE
(If the present permit expires in 6 months or less) Has the permittee submitted a new 00110
application?
Is the facility as described in the permit'? U ❑ ❑ ❑
#Are there any special conditions for the permit'? 01=11110
Is access to the plant site restricted to the general public'? ® ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑
Comment Draft permit in review
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? IN 000
Is the chain-of-custody complete'? U ❑ ❑ ❑
Dates,times and location of sampling Ei
Name of individual performing the sampling li
Results of analysis and calibration IM
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete do they include all permit parameters'? !-, ❑ ❑ ❑
Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator 000
on each shift'?
Is the ORC visitation log available and current'? 4 ❑ 1=1111
Is the ORC certified at grade equal to-or higher than the facility classification'? 000
Is the backup operator certified at one grade less or greater than the facility classification? N000
Is a copy of the current NPDES permit available on site'? MI ❑ ❑ ❑
Page# 3

Permit NC0000752 Owner-Facility Kapstone Kraft Paper Corporation WWTP
Inspection Date 03/12/2018 Inspection Type Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ! ❑
Comment
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? U ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? 111000
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ® ❑
Comment Right of way to both Outfall 001 and 002 was maintained properly
Flow Measurement- Influent Yes No NA NE
#Is flow meter used for reporting? 111000
Is flow meter calibrated annually? MOOD
Is the flow meter operational? ® ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? ODIND
Comment Meter was calibrated on August 17, 2017
Solids Handling Equipment Yes No NA NE
Is the equipment operational? MOOD
Is the chemical feed equipment operational? MID00
Is storage adequate? MOOD
Is the site free of high level of solids in filtrate from filter presses or vacuum filters? 10000
Is the site free of sludge buildup on belts and/or rollers of filter press? ® DOD
Is the site free of excessive moisture in belt filter press sludge cake? n ❑ ❑ ❑
The facility has an approved sludge management plan? DOD
Comment Two rotary screen thickeners and two screw presses One of each was off line for
maintenance
Chemical Feed Yes No NA NE
Is containment adequate? MOOD
Is storage adequate? 000
Are backup pumps available? IEI=100
Is the site free of excessive leaking? N1000
Comment Defoamer fed to effluent and aeration basin Surfarlc acid (pH), hydrogen peroxide
(hydrogen sulfide control) and polymer fed to primary clarifier sludge
Page# 4

Permit NC0000752 Owner-Facility Kapstone Kraft Paper Corporation VWVfP
Inspection Date 03/12/2018 Inspection Type Compliance Evaluation
Pump Station -Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? 11000
Is the wet well free of excessive grease? 1111000
Are all pumps present? • 000
Are all pumps operable'? • 000
Are float controls operable'? • 000
Is SCADA telemetry available and operational? ® 000
Is audible and visual alarm available and operational? ® 000
Comment Three pumps controled by SCADA Overflow channel to emergency pond 20 4 acre
emergency pond holds 28 million gallons of waste water under emergency situations, such
as power failure, mechanical problems, or high strength waste
Bar Screens Yes No NA NE
Type of bar screen
a Manual 0
b Mechanical PRI
Are the bars adequately screening debris'? ® ❑ ❑ ❑
Is the screen free of excessive debris'? E1000
Is disposal of screening in compliance? r ❑ ❑ ❑
Is the unit in good condition'? ® ❑ ❑ ❑
Comment Screen runs on timer
Primary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater'? 000
Is the site free of excessive buildup of solids in center well of circular clarifier? - 000
Are weirs level'? 000
Is the site free of weir blockage'? E000
Is the site free of evidence of short-circuiting? E000
Is scum removal adequate? 000
Is the site free of excessive floating sludge? J 000
Is the drive unit operational? ;; 000
Is the sludge blanket level acceptable'? • ) 000
Is the sludge blanket level acceptable'?(Approximately'/of the sidewall depth) 000
Comment
Page# 5

Permit NC0000752 Owner-Facility Kapstone Kraft Paper Corporation VWTP
Inspection Date 03/12/2018 Inspection Type Compliance Evaluation
Aeration Basins Yes No NA NE
Mode of operation Ext Air
Type of aeration system Surface
Is the basin free of dead spots'? • 000
Are surface aerators and mixers operational? , ❑ ❑ ❑
Are the diffusers operational? ® 000
Is the foam the proper color for the treatment process? • 000
Does the foam cover less than 25% of the basin's surface? ® 000
Is the DO level acceptable? ® ❑ ❑ ❑
Is the DO level acceptable?(1 0 to 3 0 mg/I) ® ❑ ❑ ❑
Comment All 31 surface aerators were functional Number of aerators online is controlled by the DO
sensor in the basin DO level at the channel to first stabilization pond ranges from 0 5 to 4
mq/I
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? ® 000
Are all other parameters(excluding field parameters)performed by a certified lab'? 11000
#Is the facility using a contract lab? 111000
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees 11000
Celsius)?
Incubator(Fecal Coliform)set to 44 5 degrees Celsius+/-0 2 degrees? ❑ ❑ ® ❑
Incubator(BOD)set to 20 0 degrees Celsius+/-1 0 degrees? 16100E1
Comment
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ • ❑ ❑
Is sample collected below all treatment units? 11000
Is proper volume collected? • 000
Is the tubing clean? 61000
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees E1000
Celsius)?
Is the facility sampling performed as required by the permit(frequency, sampling type E ❑ ❑ ❑
representative)?
Comment Fixed time fixed volume composite sampling
Influent Sampling Yes No NA NE
Page# 6

Permit NC0000752 Owner-Facility Kapstone Kraft Paper Corporation VVV TP
Inspection Date 03/12/2018 Inspection Type Compliance Evaluation
Influent Sampling Yes No NA NE
#Is composite sampling flow proportional? ❑ NI ❑ ❑
Is sample collected above side streams? • ❑ ❑ 0
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 ® ❑ 0 ❑
Celsius)?
Is sampling performed according to the permit'? ® ❑ ❑ ❑
Comment Fixed time fixed volume composite sampling, no influent flow meter
Lagoons Yes No NA NE
Type of lagoons'? Facultative
#Number of lagoons in operation at time of visit'? 3
Are lagoons operated in'? Series
#Is a re-circulation line present'? ❑ ❑ ® ❑
Is lagoon free of excessive floating materials'? ® 0 ❑ ❑
#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'? IN ❑ ❑ ❑
Are dikes free of erosion'? ® ❑ ❑ ❑
Are dikes free of burrowing animals'? El ❑ 0 0
#Has the sludge blanket in the lagoon(s)been measured periodically in multiple - 3 0 0 0
locations'?
#If excessive algae is present, has barley straw been used to help control the growth'? ❑ ❑ 111 ❑
Is the lagoon surface free of weeds? EI ❑ ❑ ❑
Is the lagoon free of short circuiting'? El ❑ ❑ 0
Comment 1/5 of the first stabilization pond is dredged every year
Page# 7

• Regional Inspectors' Checklist for Field Parameters
Facility Name KGPs e' Pc p r' A ; ii Regional Plant Inspector C k a'r1 c 26 '" -
NPDES # /Vc f)oO073'2 Regional Inspector Contact # S rs'-7 ri - 66-2.-3-5
Field Lab Certification # /83 Region ic-7f = r/,
Lab Contact f k;r, ; - Date 3/ r z/ y0 (X
I. Check the parameter(s) performed at this site for reporting purposes.
❑ Total Residual Chlorine (TRC) n Temperature (TEMP) n Specific Conductivity (SC)
pH ,L Dissolved Oxygen (DO) ❑ Settleable Residue (SETT)
II. General Laboratory (note any exceptions in section XI)
Are instruments, meters, probes, photometric cells, etc maintained in good condition? IX. Yes ❑ No
Are standards, reagents and consumables used within manufacturer expiration dates? 0 Yes ❑ No
[TRC gel standard is exempt I
Are the following items documented ( /where applicable):
Item TRC pH TEMP DO SC SETT
Date of sample collection* X 'x bC )4
Time of sample collection* X 1x X x
Sample collector's initials or signature X .} x
Date of sample analysis* ,' >- /
Time of sample analysis* 76 )1
Analyst initials or signature >C . x s
Sample location X ,}C. X
*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) n Yes I I No
What is the assigned/observed value of the daily check standard?
Is a 5-point calibration verification performed? Note date of last verification ❑ Yes n No
Alternatively, does the lab construct a linear regression, using 5 standards, to calculate ❑ Yes ❑ No
results? Note date of last calibration curve constructed
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 n pg/L n mg/L n Yes No
Are results reported between the facility's permit limit and the compliance limit of 50 pg/L? ❑ Yes n No
If value is less than the low standard, report as "<x", where x=low standard conc
Are samples analyzed within 15 minutes of collection? ❑ Yes No
IV. pH
pH meter make and model O'/oki s— S;Ai( p/-/ ( g 27/ -)
Is the pH meter calibrated with at least 2 buffers per mfg's instructions each day of use? 14 Yes IIINo
Note buffers used 4-, 7 , r O
Is the pH meter calibration checked with an additional buffer each day of use? Note check X Yes ❑ No
buffer used 7
Does the check buffer read within ±0 1 S U of the known value? Ig Yes n No
Are the following items documented
Meter calibration? E Yes ❑ No
Check buffer reading? X Yes No
Are samples analyzed within 15 minutes of collection? X Yes ❑ No
Are sample results reported to 0 1 pH units? y Yes I I No

r
V. Temperature
What instrument(s) is used to measure temperature'? Check all that apply n pH meter
❑ DO meter ❑ Conductivity meter Ill Digital thermometer ❑ Glass thermometer
Is the instrument/thermometer calibration checked at least annually against a NIST LS.Yes ❑ No
traceable or NIST certified thermometer? eui rJ,e_d& rlev✓ /h 2f-o—' cAn 0 ti.0-1l c--/—
Are temperature corrections (even if zero) posted on the instrument/thermometer? I Yes ❑ No
Are samples measured in situ or on-site? [REQUIRED - there is no holding time for IT Yes ❑ No
temperature]
Are sample results reported in degrees C? Iy(I Yes ❑ No
VI. Dissolved Oxygen
DO meter make and model y z - S'',To 4
-----Is-the-air calibration of-the DO meter performed-each day-of use'? - - -n Yes- --n No-- ---
Are the following items documented
Meter calibration'? ® Yes ❑ No
Are samples analyzed within 15 minutes of collection'? Yes ❑ No
Are results reported in mg/L' ❑X Yes ❑ No
VII. Conductivity
Conductivity meter make and model d fk l a N 3 S TA t. E 9 -E/3
Is the meter calibrated daily according to the manufacturer's instructions'? Note standard 74 Yes ❑ No
used (this is generally a one-point calibration) S-0.o Air),9,Z.s.-`c m
Is a daily check standard analyzed'? Note value ‘S--"o 0 ,Lt y".9/-s / c r*-i ® Yes ❑ No
Are the following items documented
Meter calibration? X Yes ❑ No
Are samples analyzed within 28 days of collection'? ® Yes _ No
Are results reported in pmhos/cm (some meters display equivalent pS/cm units)? 7 Yes ❑ No
VIII. 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 agitated after 45 minutes'? I I 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)? n Yes ❑ No
Time of agitation after 45 minutes of settling'? Ii Yes ❑ No
Sample analysis completion (settling end time)? ❑ Yes ❑ No
Are samples analyzed within 48 hours of collection'? ❑ Yes n No
Are results reported in ml/L' f] Yes ❑ No
IX. Was a paper trail (comparing contract lab and on-site data to DMR) [X Yes ❑ No
performed? If so, list months reviewed: tI / 2-v 1 7
X. Is follow-up by the Laboratory Certification program recommended? n Yes 7 No
Xl. Additional comments:
/3, (c,,,Gr - re-cer6i f-,'.e_cP ® r-t �/ 23 i -:—v t r
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@ncdenr qov
Revision 04/20/2012