WQ0021577_Final Permit_20150615

Pat McCrory
Governor
Q; �
NCDENR
North Carolina Department of Environment and Natural Resources
June 15, 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
Secretary
Subject: Permit No. WQ0021577
Kapstone Kraft Paper &
Packaging Corporation
Distribution of Class A
Residuals
Halifax County
In accordance with your permit minor modification request received June 4, 2015 from Bob
Branch of Branch Residuals and Soils, LLC, we are forwarding herewith Permit No. WQ0021577 dated
June 15, 2015, to Kapstone Kraft Paper Corporation for the continued operation of the subject residuals
management program.
Modifications to the subject permit are as follows:
➢ The maximum dry tons per year of Flyash from the Roanoke Rapids Facility has been
reduced from 15,000 to 1,649.
➢ The maximum 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 including individually permitting fields owned by Kapstone Kraft
Paper Corporation.
➢ The Management Plan has been updated outlining the uses for the residuals which
include:
o Sorptive media for hazardous waste,
o Sorptive media for hydrocarbon impacted media,
o Use as a landfill daily cover,
o Admixture for composts, soil amendments, and potting soils and,
o As a replacement for sawdust in the manufacture of bricks
This permit shall be effective from the date of issuance until April 30, 2020, and shall void Permit
No. WQ0021577 issued May 22, 2015 and shall be subject to the conditions and limitations 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.
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: 91M07-64641Internet: http:llportai.ncdenr.00/web/wQ
An Equal Opportunity 1 Affirmative Action Employer — Made in part with recycled paper

Mr. Kessinger
June 15, 2015
Page 2 of 2
Please note the following permit conditions are new since the last permit issuance:
➢ Condition IIA. Lists the pollutant concentrations
➢ Condition III.11. The requirement for the Utilization Agreement
➢ Condition III. 12 Outlines the items that shall be in the Utilization Agreement
I.f 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.
If you need additional information concerning this matter, please contact Alice M. Wessner at
[phone] or [e-mail].
Sincerely,
S. Jay immerman, Director
Division of Water Resources
cc: Halifax County Health Department (Electronic Copy) Dr. Cardra E. Burns, MPA, DBA, CLC
E-Mail: burnse aghalifaxnc.com
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

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 by-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 3 602 8'19"
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 1,649 dry tons per year of fly ash residuals and 1,649 dry
tons per year of industrial primary clarifier residuals from the sources listed in the most recently -certified
Attachment A and to the fields listed in Attachment B. Residuals under this permit may 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) Sorptive media or land fill daily cover, or other beneficial uses where ash is disposed of at a
permitted facility;
(4) As a replacement for sawdust in the manufacture of bricks
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 Environment and Natural Resources and
considered a part of this permit.
This permit shall be effective from the date of issuance until May 31, 2020, shall void Permit No.
WQ0021577 issued May 28, 2015 and shall be subject to the following specified conditions and
limitations:
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I. SCHEDULES
1. 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. [ 15A NCAC 02T .0108(b)(2), 02T .105(d), 02T .0109]
II. 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 Permittee 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. [G.S. 143-215.1 }
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. [15A NCAC 02B
.0200, 02L .0100]
Only residuals generated by the facilities listed in Attachment A are approved for land application or
distribution in accordance with this permit. [G.S. 143-215.1]
4. Pollutant concentrations in residuals distributed or applied to any land application site shall not
exceed the following Ceiling Concentrations or Monthly Average Concentrations (i.e., dry weight
basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
n/a
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
[15A NCAC 02T .11051
5. Residuals that are distributed or land applied shall meet Class A pathogen reduction requirements in
15A NCAC 02T .1106 (a) and (b)(2). Exceptions to this requirement shall be specified in Attachment
A. [ 15A NCAC 02T. 1106]
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6. 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
to be maintained as part of the project site
100
Property lines
50
Private or public water supply
100
Surface waters (streams — intermittent and perennial, perennial waterbodies, and
wetlands)
50
Wells with exception to monitoring wells
100
* All treatment and storage facilities were originally permitted prior to September 1, 2006
[i5A NCAC 02T. 1108]
7. 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
perennial, perennial waterbodies, and wetlands)
100
25
Surface water diversions (ephemeral streams,
waterways, ditches)
25
0
Groundwater lowering ditches (where the bottom
of the ditch intersects the SHWT
25
0
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, slinger spreader, broadcast spreader or
other equipment designed for handling solid materials) without leaving any significant liquid
fraction behind.
[I SA NCAC 02T. 1108]
8. Residuals shall not be applied in exceedance of agronomic rates. Appropriate agronomic rates shall
be calculated based on soil pH, nutrient needs of receiving crop, and ability of soil to incorporate the
residuals. Expected nitrogen requirements shall be based on the determined Realistic Yield
Expectations (RYE) [15A NCAC 02T]
9. Residuals that are distributed shall meet Class A pathogen reduction requirements in 15A NCAC 02T
.1106 (a) and (b)(2). Exceptions to this requirement shall be specified in Attachment A. [15A NCAC
02T .1106]
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10. 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 Permittee 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. [15A NCAC 02T
.0108(b)(1)]
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. [15A NCAC 02T .1110]
2. 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; including details on application and methods to meet Condition II.11.
b) Maintenance schedules;
c) 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 Iocation(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;
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 likely to be negatively
affected by cold temperatures).
[15A NCAC 02T .1100]
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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
I5A 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' Protection and Enforcement Branch [phone]. [15A NCAC 02T .0117]
4. When the Pennittee 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. [15A NCAC 02T
.0108(b)(1)]
When the Permittee transports or land applies bulk residuals, the spill control provisions shall be
maintained in all residuals transport and application vehicles. [15A NCAC 02T .1110]
6. 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. [G.S. 143-215.1]
No fly ash residuals shall be stored at any location other than the surface storage unit adjacent to the
fly ash pond, and other locations approved under Permit Number WQ0000436 at any time, unless
approval has been requested and obtained from the Division.
Residuals shall not be stockpiled for more than 60 days prior to land application [I 5A NCAC 02T
.0108(b)(1)]
9. 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. [15A NCAC 02T .1109(b)(1)]
10. Bulk residuals shall not be Iand 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.e_, 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;
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;
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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.
1. Application exceeds agronomic rates as outlined in Condition 11.8.
[15ANCAC 02T .1109]
11. 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. (I5A NCAC 02T .0108(b)(1), 02T 1104]
12. At a minimum, the Utilization Agreement shall stipulate the following:
a. 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 15A NCAC 02T .1100, and has been deemed
permitted under 15A NCAC 02T . l 103(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;
b. 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 1119 with a statement that bulk residuals shall not be
land applied under these conditions.
ii. Residuals shall not be stockpiled for more than 60 days prior to land application;
iii. Application of bulk residuals shall not occur within 10.0 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.
c. 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 I1I.12, is sufficient;
d. The applicator or party accepting bulk residuals from the Permittee shall supply ail third parties
receiving bulk residuals with documentation specifying that application shall occur consistent
with the utilization agreement;
e. 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.
f. A copy of the Utilization Agreement shall be maintained at the land application sites when bulk
residuals are being applied.
[15A NCAC 02T. 0 1 08(b)(1), 02T 1104]
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13. 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. [15A NCAC 02T .0108(b)(1)]
14. 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. [15A NCAC 02T .1103(a)]
15. 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.
[I 5A NCAC 02T 1109(a)]
16. 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. [15A NCAC 02T .1103(a)]
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. [ 15A NCAC 02T .0108(c)]
2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). Residuals that tests or is classified as a hazardous or toxic waste
under 40 CFR Part 261 shall not be used or disposed under this permit. The analyses
[corrosivity, ignitability, reactivity, and toxicity characteristic leaching procedure (TCLP)l 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)
(0.00s
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)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (I0.0)
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.
[15A NCAC 13A ,0102(b), 02T .1101, 02T .11051
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)
[15A NCAC 02T .1101]
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 I SA NCAC 02T .1107 (a) shall be met. Any exceptions from the requirements in this
condition shall be specified in Attachment A. [15A NCAC 02T .1106, 02T .1107, 02T .I 111(c)]
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An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each land application site listed in Attachment B on which a residuals Iand 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
[ 15A NCAC 02T .1111(d)]
6. 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.
[15A NCAC 02B .0505]
7. The Permittee shall maintain records tracking all residual land application events to fields listed in
Attachment B. 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);
d. Approximate areas applied to (acres);
e. Method of land application;
£ 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;
1. 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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[ 15A NCAC 02T .0I 09(a)]
8. The Permittee shall maintain records tracking all bulk residual distribution or land applied areas not
listed in Attachment B that are 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).
[15A NCAC 02T .0109(a)]
9. Three copies of an annual report shall be submitted on or before March I". The annual report shall
meet the requirements described in the Instructions for Residuals A lication Annual Re ortin
Forms. Instructions for reporting and annual report forms are available at
http://portal.ncdenr.org/web/wq/alas/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
[15A NCAC 02T .111 l(a)]
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. Land application or distribution of residuals 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. [15A NCAC 02T .0105(1), 02T .0108(b)(1)]
WQ0021577 Version 2.1 Shell Version 150101 Page 10 of 12

V.
1. The Pennittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan. [I5A NCAC 02T .0108(b)]
2. Prior to each bulk residuals land application or distribution event, the Permittee or his designee shall
inspect the residuals processing, 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. [ I SA NCAC 02T .0108(b)]
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. [G.S. 143-215.3(a)(2)]
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C. [G.S. 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. [15A NCAC 02T .0110]
This permit is effective only with respect to the nature and volume of residuals described in the
permit application and other supporting documentation. [G.S. 143-215.1]
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 15A 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. [15A NCAC 02T .0105(c)(6)]
5. 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. [I 5A NCAC 02T .0104]
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. [15A NCAC 02T
.0110]
7. UnIess 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). [ 15A NCAC 02T .0120]
WQ0021577 Version 2.1 Shell Version 150101 Page 1 I of 12

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. [ 15A NCAC 02T
.0105(e)(3)]
Permit issued this the 15"' day of JUKE 2015
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
r
S. K Zimmerman, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0021577
WQ0021577 Version 2.1 Shell Version 150101 Page I2 of 12

ATTACHMENT A - Approved Residual Sources
Kapstone Kraft Paper Corporation
Certification Date: June 15, 2015
Permit Number: WQ0021577 Version: 2.1
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
Non -hazardous
Metals and
Vector Attraction
Rate
Characteristics z
Nutrients 3, s
4, s, c
Reductions
Kapstone Kraft Paper
Kapstone Kraft Paper
Not
Corporation
Corporation — Roanoke
Halifax
NC0000752
No
1,649
Annually
See Table Below
See Table Below
Establishcd9
Rapids FacilityFl ash
Kapstone Kraft Paper
Kapstone Kraft Paper
Corporation — Roanoke
Halifax
NC0000752
No
1,649
Annually
See Table Below
See Table Below
0.40
Corporation
Rapids Primary Clarifier
Solids$
Total
3,298
1. Maximum Dry Tons per Year is the amount of residuals approved for land application and distribution from each permitted source. Exceedance of dry tons does not constitute a permit violation
and is only for the determination of the monitoring frequency for Metals, Nutrients, Pathogens and Vector Attrraction Reduction.
2. Analyses to demonstrate that residuals are non -hazardous (Le., TCI P, 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 1VA.
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
I /Year
=>319 - <1,650
1/ Quarter (4 times per ear)
=>1,650 - <16,500
1/60 Days (6 times per ear
=>16,500
1/month (12 times per year)
6. Sources listed in Attachemd A are exempt from meeting the vector attraction reduction requirements in Condition IVA To be applicable for this excemption the 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. These residuals are also permitted for disposal in the Permittee's surface disposal unit under Permitt WQ0000436.
8. The primary clarifier solids include a small domestic wastewater contribution.
9. Mineraliation rate has not been determined. Applicaion rates will be determined in accordance with requirements established in Condition I1.8.
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 make up the missed sampling, contact the EPA for additional information and clarification.
Pagel of 2

ATTACHMENT A - Approved Residual Sources
Kapstone Kraft Paper Corporation
Page 2 of 2
Certification Date: June 15, 2015
Permit Number: WQ0021577 Version: 2.1

j ATTACHMENT B - Approved Land Application Sites
Kapstone Kraft Paper and Packaging Corporation
Certification Date: June XX, 2015
Permit Number: WQ0021577 Version: 2.0
Field
Owner
Lessee
County
Latitude
Longitude
Arc eta
Dominant Soil Series
Field 1A
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.45954
-77.6184
52.40
NoA-Norfolk Sandy Loam 0 - 2 % slopes
Field 1B
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.45782
-77.6217
31.06
NoA-Norfolk Sandy Loam 0 - 2 % slopes
Field I
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.46314
-77.6211
58.54
NoA-Norfolk Sandy Loam 0 - 2 % slopes
Field 1D
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.46111
-77.625
45.72
NoA-Norfolk Sandy Loam 0 - 2 % slopes
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.46714
-77.6229
58.32
TtB2-Turbeville Sandy Clay Loam 2 - 6 %
Field 2
lopes
Field 3
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.47107
-77.6179
47.54
Le- Lenoir Silt Loam 0 - 2 % slopes
Field 4A
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.48131
-77.6222
18.06
TsB-Turbeville Sandy Loam 2 - 6 % slopes
Field 4B
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.48303
-77.6234
12.05
TsB-Turbeville Sandy Loam 2 - 6 % slopes
Field 4C
Kapstone Kraft Paper and Packaging Corporation
Nortbampton
36.47907
-77.6221
6.11
TsB-Turbeville Sandy Loam 2 - 6 % slopes
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.46363
-77.6267
7.26
Tt132-Turbeville Sandy Clay Loam 2 - 6 %
Field 5
slopes
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.45944
-77.627
5.66
TtB2-Turbeville Sandy Clay Loam 2 - 6 %
Field 6
slopes
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.45664
-77.6244
21.69
TsA-Turbeville Sandy Loam 0 - 2 %
Field 7
slopes
Field 8
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.45548
-77,6197
3.20
NoB-Norfolk Sandy Loam 2 — 6% slopes
Field 9
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.4576
-77.6169
18.22
NoB- Norfolk Sandy Loam 2 — 6% slopes
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.47266
-77.6205
8.40
TsA-Turbeville Sandy Loam 0 - 2 %
Field 10
slopes
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.47247
-77.6251
9.19
TtB2-Turbeville Sandy Clay Loam 2 - 6 %
Field 11
slopes
Field 12
Kapstone Kraft Paper and Packaging Corporation
Northampton
36.48917
-77.6417
19.89
Co -Congaree Silt Loam 0 — 4% slopes
Kapstone Kraft Paper and Packaging Corporation
Northampton
36,46795
-77,6264
11.11
TtB2-Turbeville Sandy Clay Loam 2 - 6 %
Test Plots
slopes
Total
434.42
If more land application sites owned by Kapston Kraft Paper Corporation are to be added to the Attachment B, then an application for a permit modification must be submitted to the Division.
Page 2 of 2

ATTACHMENT S - Approved Land Application Sites
Kapstone Kraft Paper and Packaging Corporation
Page 2 of 2
Certification Date: June XX, 2015
Permit Number: WQ0021577 Version: 2.0

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