WQ0021577_Final Permit_20150522

Pat McCrory
Governor
NCDENR
North Carolina Department of Environment and Natural Resources
May 22, 2015
Wilbur G. Kessinger, Jr., Vice -President of Mill Operations
Kapstone Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, North Carolina 27870
Dear Mr. Kessinger:
Donald van der Vaart
Subject: Permit No. WQ0021577
Kapstone Kraft Paper &
Packaging Corporation
Distribution of Class A
Residuals
Halifax County
Secretary
In accordance with your permit renewal and major modification request received July 17, 2014,
we are forwarding herewith Permit No. WQ0021577 dated May 22, 2015, to Kapstone Kraft Paper
Corporation for the continued operation of the subject residuals management program.
Modifications to the subject permit are as follows:
:o The maximum dry tons per year of Flyash from the Roanoke Rapids Facility has been
reduced from 15,000 to 1,649.
➢ The maximurn dry tons per year from the Roanoke Rapids Facility Primary Clarifier has
been reduced from 15,000 to 1,649.
Conditions have been added to the permit related to the direct land application
of residuals.
➢ Uses for the residuals as outlined in the Management Plan have been updated.
This permit shall be effective from the date of issuance until November 30, 2019, and shall void
Permit No. WQ0021577 issued February 20, 2009 and shall be subject to the conditions and Iimitations as
specified therein. Please pay particular attention to the monitoring requirements listed in Attachment A
for they may differ from the previous permit issuance. Failure to establish an adequate system for
Collecting and maintaining the required operational information shall result in future compliance
problems.
Please note the following permit conditions are new since the last permit issuance:
Condition I1.4. — directs Permittee to the approved sites for residual land application.
:,, Condition 11.5. —lists the ceiling concentration requirements for land application sites.
v Condition 1I. 9 — lists the setbacks for Class B land application sites.
Non -Discharge Permitting unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] ! Internet: hft:/IporWl.ncdenr.ofqfwebANQ
An Equal Opportunity! Affirmative Action Employer— Made in part with recycled paper

Mr. Kessinger
May 22, 2015
Page 2 of 4
➢ Condition 11.11 — requires the land application area to be clearly marked.
Condition 11. 12 — requires bulk residuals not to be applied in exceedence of agronomic
rates as well as specific language pertaining to the Kapstone residuals.
;> Condition 1I. 14 — requires remediation action if the groundwater standards are not met at
the compliance boundary.
➢ Condition II. 15 -- requires action if the groundwater standards are not met at the review
boundary.
i� Condition 111.2 — requires the Raleigh Regional Office and the appropriate IocaI
government official to be notified at least 48 hours prior to the initial residuals land
application to any new land application site.
Condition 111.3 — requires the Raleigh Regional Office shall be notified via email or
telephone at least 24 hours prior to conducting any land application activity.
➢ Condition 111.8 — does not allow residuals to be stored at any land application site, unless
written approval has been requested and received from the Division.
➢ Condition 111. 12 — outlines public access restrictions that apply to residual land
application sites
i� Condition III. 13 — outlines the public access controls for the land application sites.
iv Condition III. 14 — outlines the harvesting and grazing restrictions that apply to residual
land application sites after each land application event.
➢ Condition III. 15 -- requires the Permittee to acquire from each landowner or
lessee/operator a statement detailing the volume of other nutrient sources that have been
applied to the site, and a copy of the most recent Nutrient Management Plan (NMP) for
those operations where a NMP is required by the US Department of Agriculture
National Resources Conservation Service (NRCS) or other State Agencies.
i> Condition 111. 16 — requires that no residuals shall be land applied unless the submitted
Land Owner Agreement Attachment (LOAA) between the Permittee and landowners or
lessees/operators of the land application site is in full force and effect.
➢ Condition IV. 5 — requires an annual representative soils analysis (i.e., Standard Soil
Fertility Analysis) shall be conducted on each land application site
Condition IV. 7 — requires the Permittee to maintain records tracking all residual land
application events.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall 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 at 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and
binding.

Mr. Kessinger
May 22, 2015
Page 3 of
If you need additional information concerning this matter, please contact Alice M. Wessner at
[phone] or [e-mail].
Sincerely,
b
,(w- S. Jay Zimmerman, Director
Division of Water Resources
cc: Halifax County Health Department (Electronic Copy) Dr. Cardra E. Burns, MPA, DBA, CLC
E-Mail: [e-mail]
Raleigh Regional Office, '[Water Quality Regional Operations Section (Electronic Copy)
Branch Residuals & Soils, LLC., 8646 West Market Street, Suite 111, Greensboro, NC 27409
(Electronic Copy) [e-mail]
Beth Buffington — Protection and Enforcement Branch (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

Mr. Kessinger
May 22, 2015
Page 4 of 4

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF CLASS A RESIDUALS PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Kapstone Kraft Paper Corporation
Northampton County
FOR THE
continued operation of a residuals management program for Kapstone Kraft Paper Corporation for the
distribution of Class A fly ash residuals from the wastewater residuals ash pond and the surface disposal
unit approved under Permit Number WQ0000436, and primary clarifier solids residuals as a bi-product of
paper production with a very small amount of domestic wastewater contribution, all produced at the
Roanoke Rapids, NC Mill located at North Roanoke Avenue (i.e., at an approximate latitude of 36°28' 19"
and longitude of 77°38' 14") in Roanoke Rapids, North Carolina. The very small quantity of domestic
waste that is a component part of the subject waste stream is accommodated by the treatment process to
achieve a Class A equivalent quality and does not change the classification of the end product. The
program shall result in the distribution of up to 15,000 dry tons per year of fly ash residuals and 15,000
dry tons per year of industrial primary clarifier residuals from the sources listed in the most recently -
certified Attachment A. Direct land application of the residuals will be performed under the Permittee's
Land Application of Residual Solids (503 Exempt) permit (Permit 9WQ0013516) and is not included as
an allowable use in this permit. All residuals under this permit will be distributed to second parties for
the approved uses as listed:
(1) Admixture for composts, soil amendments, and potting soils, and
(2) As a replacement for sawdust in the manufacture of bricks Use as a sorptive media for
hazardous waste;
(3) 5orptive media or land fill daily cover, or other beneficial uses where ash is disposed of at a
permitted facility;
With no discharge of wastes to surface waters, pursuant to the permit application package received on
July 17, 2014, and in conformity with the project plan, specifications, and other supporting data
subsequently filed and approved by the Department of Enviromnent and Natural Resources and
considered a part of this permit.
This permit shall be effective froze the elate of issuance until November 30, 2019, shall void Permit No.
WQ0021577 issued February 20, 2009 and shall be subject to the following specified conditions and
limitations:
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L SCHEDULES
No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
2. The permittee shall be in full compliance with the regional office notification requirements
established in Condition II1.3. by April 1, 2015.
3. The permittee shall be in full compliance with the signage requirements established in Condition III.
13 by July 1, 2015.
H. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all times
so there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance
conditions due to improper operation and maintenance, the Pcrmittee shall immediately cease land
applying residuals to the site or distribution of residuals whichever residuals are affected., contact the
Raleigh regional office supervisor, and take any immediate corrective actions.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this residuals management program.
3. Only residuals generated by the facilities listed in Attachment A are approved for land application or
distribution in accordance with this permit.
4. Only the sites listed in Attachment B are approved for residuals Iand application.
5. Pollutant concentrations in residuals applied to land application sites listed in Attachment B shall not
exceed the following Ceiling Concentrations (i.e., dry weight basis) or Cumulative Pollutant
Loading Rates (CPLRs):
Parameter
Ceiling Concentration
(milligrams per kilogram)
CPLR
(pounds per acre)
Arsenic
75
36
Cadmium
85
34
Copper
4,300
1,338
Lead
840
267
Mercury
57
15
Molybdenum.
75
nla
Nickel
420
374
Selenium.
100
89
Zinc
7,500
2,498
The Permittee shall determine compliance with the CPLRs using one of the following methods:
a. By calculating the existing cumulative level of pollutants using actual analytical data from all
historical land application events of residuals, or
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b. For land where residuals application have not occurred or for which the required data is
incomplete, by determining background concentrations through representative soil sampling.
6. Residuals that are distributed or land applied shall meet Class A and B pathogen reduction
requirements in 15A NCAC 02T .1106 (a) and (b) and (b)(2). Exceptions to this requirement shall be
specified in Attachment A.
7. Biological residuals (i.e. residuals generated during the treatment of domestic or animal processing
wastewater, or the biological treatment of industrial wastewater, and as identified in Attachment A)
that are distributed or land applied shall meet one of the vector attraction reduction alternatives in
15A NCAC 02T .1107(a). Exceptions to this requirement shall be specified in Attachment A.
&. Setbacks for treatment and storage facilities shall be as follows:
Setback Description
Setback
(feet)
Habitable residence or place of public assembly under separate ownership or not
100
to be maintained as part of the project site
Property lines
50
Private or public water supply
100
Surface waters (streams — intermittent and perennial, perennial waterbodies, and
50
wetlands)
Wells with exception to monitoring wells
100
All treatment and storage facilities were originally permitted prior to September 1, 2006
9. Setbacks for Class A land applied bulk residuals shall be as follows:
Setback by residual type
Setback Description
(feet)
Liquid
Cake*
Private or public water supply
100
100
Surface waters (streams — intermittent and
100
25
perennial, perennial waterbodies, and wetlands
Surface water diversions (ephemeral streams,
25
0
waterways, ditches)
Groundwater lowering ditches (where the bottom
25
0
of the ditch intersects the SHWT
Wells with exception to monitoring wells
100
100
Bedrock outcrops
25
0
* Unless otherwise noted in Attachment A, "cake" residuals are those that have greater than 15%
solids by weight and can be stacked without flowing, as well as can be handled, transported and
spread as a solid (e.g., using a backhoe, front end loader, stinger spreader, broadcast spreader or
other equipment designed for handling solid materials) without leaving any significant liquid
fraction behind.
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11. Land application areas shall be clearly marked on each site prior to and during any residuals
application event.
a. Bulk residuals and other sources of Plant Available Nitrogen (PAN) shall not be applied in
exceedance of the most limiting factor of these three criteria: allowable application thickness,
lime requirements of the soil, and the nitrogen needs of the crop (agronomic rates). Appropriate
agronomic rates shall be calculated using expected nitrogen requirements based on the
determined Realistic Yield Expectations (RYE) using any of the following methods:
b. Division's pre -approved site specific historical data for specific crop or soil types by calculating
the mean of the best three yields of the last five consecutive crop harvests for each field.
c. North Carolina Historical Data for specific crop and soil types as provided by North Carolina
State University Department of Soil Science (http://nutrients.soil.nesu.edu/yields/zndex.php}.
A copy shall be kept on file and reprinted every five years in accordance with Condition 1V.7.
d. If the RYE cannot be determined using methods (a) or (b) above, the Permittee may use the RYE
and appropriate nutrient application rates reported in any of the following documents:
i. Crop management plan as outlined by the local Cooperative Extension Office, the North
Carolina Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, or other agronomist.
ii. Waste Utilization Plan as outlined by the Senate Bill 1217 Interagency Group - Guidance
Document: Chapter 1
(http://www.ncag_r.pov/SWC/tech/documents/9th Guidance Doc _100109 pdf).
iii. Certified Nutrient Management Plan as outlined by the Natural Resources Conservations
Services (NRCS). These plans must meet the USDA-NRCS 590 Nutrient Management
Standards(flp://ftp-fe.se.egov.usda.gov/NHQpractice-standards/standards/590p dfl
e. If the RYE and appropriate nutrient application rates cannot be determined, the Permittee shall
contact the Division to determine necessary action.
12. When residuals are land applied to grazed pasture, hay crop realistic nitrogen rate shall be reduced by
25% in accordance with the USDA-NRCS 590 Nutrient Management Standards.
13. If land application sites are to be over -seeded or double -cropped (e.g., bermuda grass in the summer
and rye grass in the winter with both crops to receive residuals), then the second crop can receive an
application of PAN at a rate not to exceed 50 pounds per acre per year (lbs/aclyr). This practice may
be allowed as long as the second crop is to be harvested or grazed. If the second crop is to be planted
for erosion control only and is to be tilled into the soil, then no additional PAN shall be applied.
14. The Permittee shall not distribute Class A residuals that have a sodium adsorption ratio (SAR) of 10
or higher without prior written Division approval. The Pennittee may seek approval by
demonstrating that the entity accepting the residuals is: aware of the effects of a high SAR content;
has agreed on proper residual application rates; and has agreed to operational considerations to ensure
that the high SAR content will not adversely impact the receiving sites. Recommendations regarding
sodium application rate, soil amendments (e.g., gypsum, etc.) or a mechanism for maintaining site
integrity and conditions conducive to crop growth, can be obtained from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, a North Carolina Licensed Soil Scientist, or an agronomist.
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15. These residuals land application sites were individually permitted on or after December 30, 1983;
therefore, the compliance boundary is established at either 250 feet from the residual land application
area, or 50 feet within the property boundary, whichever is closest to the residual land application
area. An exceedance of groundwater standards at or beyond the compliance boundary is subject to
remediation action according to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in
accordance with North Carolina General Statute 143-215.6A through 143-215.6C. Any approved
relocation of the COMPLIANCE BOUNDARY will be noted in Attachment B.
16. The review boundary shall be established midway between the compliance boundary and the residual
land application area. Any exceedance of groundwater standards at the review boundary shall require
action in accordance with 15A NCAC 02L .0106.
17. No wells, other than Division approved monitoring wells, shall be constructed within the compliance
boundary, except as provided by 15A NCAC 02L .0107(g).
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards.
2. The Raleigh Regional Office, telephone number [phone], and the appropriate local
government official (i.e., county manager, city manager, or health director) shall be notified at least
48 hours prior to the initial residuals land application to any new land application site. Notification to
the regional supervisor shall be made from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
3. The Raleigh Regional Office shall be notified via email or telephone, [phone], at least 24
hours prior to conducting any land application activity. Such notification shall indicate, at a
minimum, the anticipated application times, field IDs, and location of land application activities. if it
becomes necessary to apply to additional fields due to unforeseen events, the Regional Office shall be
notified prior to commencing the application to those fields.
4. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan)
Modifications to the O&M Plan shall be approved by the Division prior to utilization of the new plan.
The O&M Plan, at the minimum, shall include:
a) Operational functions;
b) Maintenance schedules;
e) Safety measures;
d) Spill response plan;
e) Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including record keeping and actions to be
taken by the inspector in the event that noncompliance is observed pursuant to the
noncompliance notification requirements under the monitoring and reporting section of the
permit;
f) Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring;
ii. Detailed description of monitoring procedures including parameters to be monitored;
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iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for
any foreseen fluctuations in residuals quality and indicate the most limiting times for
residuals to meet pathogen and vector attraction reduction requirements (e.g, facilities that
land apply multiple times per year but have an annual sampling frequency, may need to
sample during winter months when pathogen reduction is most Iikely to be negatively
affected by cold temperatures).
Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in
responsible charge (ORC) and one or more certified operators as back-up ORCs in accordance with
15A NCAC 08G .0201. The ORC or their back-up shall visit the facilities in accordance with 15A
NCAC 08G. 0204, or as specified in the most recently approved O&M plan (i.e., see Condition III.
4.), and shall comply with all other conditions of 15A NCAC 08G. 0204. For more information
regarding classification and designation requirements, please contact the Division of Water
Resources' Technical Assistance & Certification Unit at [phone].
6. When the Permittee land applies bulk residuals, a copy of this permit and a copy of O&M Plan shall
be maintained at the land application sites during land application activities.
7. When the Permittee transports or land applies bulk residuals, the spill control provisions shall be
maintained in all residuals transport and application vehicles.
8. Residuals shall not be stored at any land application site, unless written approval has been requested
and received from the Division.
9. When the Permittee land applies bulk residuals, adequate measures shall be taken to prevent wind
erosion and surface runoff from conveying residuals from the land application sites onto adjacent
properties or into surface waters.
10. When the Permittee land applies bulk residuals, a suitable vegetative cover shall be maintained on
land application sites onto which residuals are applied, or application shall be in accordance with the
crop management plan outlined by the local Cooperative Extension Office, the Department of
Agriculture and Consumer Services, the Natural Resource Conservation Service, or an agronomist
and as approved by the Division.
11. Bulk residuals shall not be land applied under the following conditions:
a. If the residuals are likely to adversely affect a threatened or endangered species listed under
section 4 of the Endangered Species Act or its designated critical habitat;
b. If the application causes prolonged nuisance conditions;
c. If the land fails to assimilate the bulk residuals or the application causes the contravention of
surface water or groundwater standards;
d. If the land is flooded, frozen or snow-covered, or is otherwise in a condition such that runoff of
the residuals would occur;
e. Within the 100-year flood elevation, unless the bulk residuals are injected or incorporated within
a 24-hour period following a residuals land application event;
f. During a measurable precipitation event (i.c., greater than 0.01 inch per hour), or within 24 hours
following a rainfall event of 0.5 inches or greater in a 24-hour period;
g. If the slope is greater than 10% for surface applied liquid residuals, or if the slope is greater than
18% for injected or incorporated bulk liquid residuals;
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h. If the soil pH is not maintained at 6.0 or greater, unless sufficient amounts of lime are applied to
achieve a final soil pH of at least 6.0, or if an agronomist provides information indicating that the
pH of the soil, residuals and lime mixture is suitable for the specified crop. Any approved
variations to the acceptable soil pH (6.0) will be noted in this permit;
i. If the land does not have an established vegetative cover unless the residuals are incorporated or
injected within a 24-hour period following a residuals land application event. Any field that is in
a USDA no -till program shall be exempted from meeting this vegetative cover requirement;
j. If the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
k. if the vertical separation of bedrock and the depth of residuals application is less than one foot;
12. The following public access restrictions apply to residual land application sites:
a. Public access to public contact sites (e.g., golf courses, parks, ball fields, etc.) shall be restricted
for 365 days after a residuals land application event;
b. Public access to non-public contact sites shall be restricted for 30 days after a residuals Iand
application event.
13. Public access controls shall include the posting of signs with a minimum area of 3 square feet (e.g.,
1.5' x 2'). Each sign shall indicate the activities conducted at each site, permit number, and name and
contact information, including the Permittee or applicator's telephone number. Signs shall be posted
in a clearly visible and conspicuous manner at the entrance to each land application site during a land
application event, and for as long as the public access restrictions required under 111.12 apply.
14. The following harvesting and grazing restrictions apply to residual land application sites after each
land application event:
Harvesting and Grazing Description
Restricted
Duration
Animals shall not be allowed to graze during land application activities and
restricted period. Sites that are to be used for grazing shall have fencing to
30 days
prevent access after each land application event.
Food crops, feed crops and fiber crops shall not be harvested for:
30 days
Turf grown on land where residuals have been applied shall not be harvested for:
12 months
Food crops with harvested parts that touch the residual/soil mixture and are
totally above the land surface (e.g., tobacco, melons, cucumbers, squash, etc.)
14 months
shall not be harvested for:
When the residuals remain on the land surface for four months or longer prior to
incorporation into the soil, food crops with harvested parts below the land
20 months
surface (e.g., root crops such as potatoes, carrots, radishes, etc.) shall not be
harvested for:
When the residuals remain on the land surface for less than four months prior to
incorporation into the soil, food crops with harvested parts below the land
38 months
surface shall not be harvested for:
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15. The Permittee shall acquire from each landowner or lessee/operator a statement detailing the volume
of other nutrient sources (i.e., manufactured fertilizers, manures, or other animal waste products) that
have been applied to the site, and a copy of the most recent Nutrient Management Plan (NMP) for
those operations where a NMP is required by the US Department of Agriculture — National Resources
Conservation Service (NRCS) or other State Agencies. The Permittee shall calculate allowable
nutrient loading rates based on the provided information and use appropriate reductions.
For the purpose of this permit condition, a Crop Management Plan. (CMP), Waste Utilization Plan
(WUP) or Certified Nutrient Management Plan (CNMP) shall also be considered a Nutrient
Management Plan.
16. No residuals shall be land applied unless the submitted Land Owner Agreement Attachment (LOAA)
between the Permittee and landowners or lessees/operators of the land application site is in full force
and effect. These agreements shall be considered expired concurrent with the permit expiration date,
and shall be renewed during the permit renewal process.
17. A Utilization Agreement between the Permittee and the entity agreeing to accept and distribute Class
A bulk residuals shall be in place prior to distribution of the bulk residuals. The agreement shall
specify the agreeing entity's responsibilities. The Permittee or his designee and the person
responsible for application of the residuals shall sign the Utilization Agreement, which shall be
considered expired concurrent with the permit expiration date, and shall be renewed during the permit
renewal process.
a. At a minimum, the Utilization Agreement shall stipulate the following:
b. By agreeing to accept the bulk Class A residuals, it is recognized that the application of these
residuals is allowed under the conditions of this agreement. Land application of Class A residuals
is considered the beneficial reuse of a waste under I5A NCAC 02T .l 100, and has been deemed
permitted under I5A NCAC 02T .1103(4) provided the conditions of this agreement are met. Any
action resulting in damages to surface water or groundwater, caused by failure to follow the
conditions of this agreement, is subject to Division enforcement action;
c. The person or entity accepting the bulk Class A residuals shall to the best of their knowledge
meet the following application requirements.
i. List all prohibitions under Condition 111.18 with a statement that bulk residuals shall not be
land applied under these conditions.
ii. Kapstone PCS and Flyash Residuals shall not be stockpiled for more than 60 days prior to
land application;
iii. Application of bulk residuals shall not occur within 100 feet of a public or private water
supply source;
iv. Application of bulk residuals shall not occur within 100 feet of any well, with the exception
of Division approved monitoring wells;
v. Application of bulk residuals shall not occur within 25 feet of surface waters.
d. The generator of the Class A bulk residuals shall provide information on the proper use of the
residuals, including information on the nutrient quantities within the residuals and recommended
application rates. A copy of the label or information sheet attached to bags or other containers, as
specified in the labeling requirements under Condition III.12, is sufficient;
e. The applicator or party accepting bulk residuals from the Permittee shall supply all third parties
receiving bulls residuals with documentation specifying that application shall occur consistent
with the utilization agreement;
f. Instructions, including contact information for key personnel, shall be provided to the applicator
or party receiving bulk residuals in the event that any requirements specified in the utilization
agreement are not met.
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g. A copy of the Utilization Agreement shall be maintained at the land application sites when bulk
residuals are being applied.
18. All residuals shall be adequately stored to prevent untreated leachate runoff. The finished product
may be placed on a concrete pad, placed under shelter or physically covered until it is distributed to
the buyer. If an alternate storage site is used, approval must be obtained from the Division.
14. A label shall be affixed to the bag or other container in which residuals are sold or given away for
land application, or an information sheet shall be provided to the person who receives Class A
residuals. At a minimum, the label or information sheet shall contain the following.
a. The name and address of the person who prepared the residuals;
b. A statement that residual land application is prohibited except in accordance with the instructions
on the label or information sheet;
c. A statement identifying that this material shall be prevented from entering any public or private
water supply source (including wells) and any surface water (e.g., stream, lake, river, wetland,
etc.);
d. A statement that the residuals shall be applied at agronomic rates and recommended rates for its
intended use.
20. The Permittee shall not distribute bulk residuals to any person or entity known to be applying
residuals contrary to the condition of the signed Utilization Agreement.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed.
2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). The analyses [corrosivity, ignitability, reactivity, and toxicity
characteristic leaching procedure (TCLP)j shall be performed at the frequency specified in
Attachment A, and the Permittee shall maintain these results for a minimum of five years. Any
exceptions from the requirements in this condition shall be specified in Attachment A.
The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
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Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0.008)
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400,0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
VinyI chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A,
the Permittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
3. An analysis shall be conducted on residuals from each source generating facility at the frequency
specified in Attachment A, and the Permittee shall maintain the results for a minimum of five years.
The analysis shall include the following parameters:
Aluminum
Mercury
Potassium
Ammonia -Nitrogen
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite Nitrogen
Sodium Adsorption Ratio
(SAR)
Calcium
Percent Total Solids
TKN
Copper
pH
Zinc
Lead
Phosphorus
Magnesium
Plant Available Nitrogen
(by calculation)
4. Residuals shall be monitored for compliance with pathogen and vector attraction reduction
requirements at the frequency specified in Attachment A, and at the time indicated in the sampling
and monitoring sections of the approved O&M plan. The required data shall be specific to the
stabilization process utilized, and sufficient to demonstrate compliance with the Class A pathogen
reduction requirements in 15A NCAC 02T .1106 (a) and (b)(2), and one vector attraction reduction
requirement in 15A NCAC 02T .1107 (a) shall be met. Any exceptions from the requirements in this
condition shall be specified in Attachment A.
WQ0021577 Version 2.0 Shell Version 150101 Page 10 of 14

5. An annual representative soils analysis (i.e., Standard. Soil Fertility Analysis) shall be conducted on
each land application site on which a residuals land application event will occur in the respective
calendar year. This analysis shall be in accordance with the "Guidance on Soil Sampling" located in
the Sampling Instructions section of the NC Department of Agriculture & Consumer Services'
website(http://www.neagr.gov/agronomi/pubs.htm). The Permittee shall maintain these results and a
description of the sampling methodologies used to determine soil fertility for a period of no less than
five years, and shall be made available to the Division upon request. At a minimum, the Standard
Soil Fertility Analysis shall include the following parameters:
Acidity
Exchangeable Sodium Percentage
Phosphorus
Base Saturation (by calculation)
Magnesium
Potassium
Calcium
Manganese
Sodium
Cation Exchange Capacity
Percent Humic Matter
Zinc
Copper
pH
$. Laboratory parameter analyses shall be performed on the residuals as they are land applied or
distributed, and shall be in accordance with the monitoring requirements in 15A NCAC 02B .0505.
7. The Permittee shall maintain records tracking all residual land application events. At a minimum,
these records shall include the following:
a. Source of residuals;
b. Date of land application;
c. Location of land application (i.e., site, field, or zone number as listed in Attachment B);
d. Approximate areas applied to (acres);
e. Method of land application;
f. Weather conditions (e.g., sunny, cloudy, raining, etc.);
g. Predominant Soil Mapping Unit (e.g., CbB2);
h. Soil conditions (e.g., dry, wet, frozen, etc.);
i. Type of crop or crops to be grown on field;
j. Nitrogen Application Rate based on RYES (if using data obtained from the North Carolina State
University Department of Soil Science Website, the printout page shall be kept on file and
reprinted every five years);
k. Volume of residuals land applied in gallons per acre, cubic yard per acre, dry tons per acre, or wet
ton per acre;
Volume of animal waste or other nutrient source applied in gallons per acre, dry ton per acre, or
wet tons per acre;
m. Volume of soil amendments (e.g., lime, gypsum, etc.) applied in gallons per acre, dry ton per
acre, or wet tons per acre; and
n. Annual and cumulative totals in dry tons per acre of residuals as well as animal waste and other
sources of nutrients (e.g., if applicable), annual and cumulative pounds per acre of each heavy
metal (e.g., shall include, but shall not be limited to, arsenic, cadmium, copper, lead, mercury,
molybdenum, nickel, selenium, and zinc), annual pounds per acre of PAN, and annual pounds per
acre of phosphorus applied to each field.
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8. The Permittee shall maintain records tracking all bulk residual distribution or land application events
performed by the Permittee. At a minimum, these records shall include the following:
a. Source of residuals;
b. Date of distribution/land application;
c. Name and address of recipient of residuals;
d. Volume of residuals distributed to each recipient;
e. Intended use of residuals;
f. If land application events performed by the Permittee - Nitrogen Application Rate based on
RYEs (if using data obtained from. the North Carolina State University Department of Soil
Science Website, the printout page shall be kept on file and reprinted every five years).
9. Three copies of an annual report shall be submitted on or before March It. The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Reporting
Forms. Instructions for reporting and annual report forms are available at
htip:Hportal.nedenr.org/web/wglaps/lau/reporting, or can be obtained by contacting the Land
Application Unit directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
10. Noncompliance Notification
The Permittee shall report by telephone to the Raleigh Regional Office, telephone number (919) 791-
4200, 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 with the land application or distribution program resulting in the land application
of significant amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the land application or distribution program resulting in a release of material to
surface waters.
c. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
e. Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
be taken to ensure that the problem does not recur.
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M flan.
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2. Prior to each bulk residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport and application facilities to prevent malfunctions, facility deterioration
and operator errors resulting in discharges, which may cause the release of wastes to the
environment, a threat to human health or a public nuisance. The Permittee shall maintain an
inspection log that includes, at a minimum, the date and time of inspection, observations made, and
any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this inspection log
for a period of five years from the date of inspection, and this log shall be made available to the
Division upon request.
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the land application sites or facilities permitted herein
at any reasonable time for the purpose of determining compliance with this permit; may inspect or
copy any records required to be maintained under the terms and conditions of this permit; and may
collect groundwater, surface water or leachate samples.
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Pennittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
2. This permit shall become voidable if the residuals land application events are not carried out in
accordance with the conditions of this permit.
3. This permit is effective only with respect to the nature and volume of residuals described in the
permit application and other supporting documentation.
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules
in I SA NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4
and under the Division's General Permit NCG010000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
In the event the residuals program changes ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner.
6. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110.
Unless the Division Director grants a variance, expansion of the permitted residuals program
contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC
02T .0120(b).
8. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit.
WQ0021577 Version 2.0 Shell Version 150101 Page 13 of 14

Permit issued this the 22d day of May 2015
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
�gJay Zi erman, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0021577
WQ0021577 Version 2.0 Shell Version 150101 Page 14 of 14

ATTACHMENT A - Approved Residual Sources
Kapstone Kraft Paper Corporation
Certification Date: May 22, 2015
Permit Number: WQ0021577 Version: 2.0
Maximum
Monitoring
Monitoring
Monitoring
Frequency for
Approved
Owner
Facility Name
County
Permit
Biological
Dry Tons
Frequency for
Frequency for
Pathogen &
Mineralization
Number
Residuals
Per Year;
Nan -hazardous
Metals and
Vector Attraction
Rate
Characteristics z
Nutrients 3,11
Reductions a' s, 6
Kapstone Kraft Paper
Kapstone Kraft Paper
Corporation
Corporation — Roanoke
Halifax
NCO000752
No
1,649
Annually
See Table Below
See Table Below
None
Rapids Facility Fl ash'
Kapstone Kraft Paper
Kapstone Kraft Paper
Corporation —Roanoke
Halifax
NCO000752
No
1,649
Annually
See Table Below
See Table Below
0.40
Corporation
Rapids Primary Clarifier
Solid?
Total
3,29$
1. Maximum Dry Tons per Year is the amount of residuals approved for land application and distribution from each permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition IV.2.
3. Testing of metals and nutrients as stipulated under permit Condition IV.3.
4. Analyses of pathogen and vector attraction reductions as stipulated under permit Condition IV A.
5. Monitoring frequencies are based on the actual dry tons applied per year using the table below, unless specified above.
Dry Tons Generated
short tons per ear
Monitoring Frequency
Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
1/Year
=>319 - .=1,650
l/ Quarter (4 times per ear)
=>1,650 - <16,500
I/60 Days (6 times per ear
=-16,500
1/month 12 times per ear}
6. Class A residuals are exempt from meeting the vector attraction reduction requirements in Condition IV.4, provided they are not mixed with residuals that have been generated during the
treatment of domestic wastewater, the treatment of animal processing wastewater, or the biological treatment of industrial wastewater. The Class A residuals must be treated and processed in a
manner as to not meet the definition of `Biological Residuals" as defined in 15A NCAC 02T .1102(6).
7. Only fly ash from a surface disposal unit (monofill) and ash pond. The storage units for this facility are the ash pond and the monofiIl. These residuals are also permitted for disposal in the
Permittee's surface disposal unit under Permitt WQ0000436.
8. Only residuals from the primary clarifier unit and a small domestic wastewater contribution are permitted. These residuals are also permitted for disposal in the Permittee's surface disposal unit
under Permit WQ0000436.
If no land application events occur during a required sampling period (e.g. no land application occur during an entire year when annual monitoring is required), then no
sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data. Those required to submit the annual
report to EPA may be required to mare up the missed sampling, contact the EPA for additional information and clarification.
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