Loading...
HomeMy WebLinkAboutNCS000106_APPLICATION_20131218STORMWATER DIVISION CODING SHEET NCS PERMITS PERMIT NO. DOC TYPE ❑ FINAL PERMIT ❑ MONITORING REPORTS VAPPLICATION ❑ COMPLIANCE ❑ OTHER DOC DATE ❑ Zo 13 iz 19 YYYYM M D D Permit Coverage Permit Number Renewal Application Form NCS000106 National Pollutant Discharge Elimination System Stormwater Discharge Permit The following is the information currently in our database for your facility. Please review this information carefully and make all corrections/additions as necessary in the space provided to the right of the current information. Owner Affiliation Information • Reissued Permit will he mailed to the owner address Owner / Organization Name: Owner Contact: Mailing Address: Phone Number: Fax Number: E-mail address: Kapstone Kraft Paper Corporation Anitra Collins 100 Gaston Rd Roanoke Rapid, NC 27870 Facility/Permit Contact Information Facility Name: Roanoke Rapids Mill Facility Physical Address: 100 Gaston Rd Roanoke Rapids, NC 27870 Facility Contact: Mailing Address: Phone Number: Fax Number: E-mail address: 40 Receiving Stream Stream Class: Basin: Sub -Basin: Number of Outfalls: ROANOKE RIVER WS-IV Roanoke River Basin 03-02-08 Wilbur G. Kessinaer, Jr. 252-533-6000 bill.kessinger@kaystonepaper.com Neal R. Davis 100 Gaston Road Roanoke Rapids, NC 27870 252-533-6295 neal.davis®kapstonepaper.com Impaired Waters DL Does this facility discharge to waters listed as impaired or waters with a finalized TM DL? l] Yes ❑ No ® Don't Know ( for information on these waters refer to http://h2o.enr.state.nc.us/su/Impaired Waters TMDL/ ) CERTIFICATION 1 certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete and accurate. Signature /v' r�"'� I / /Date W f �i7u ✓ G, KFS C/y� yr . y/rc �'hcsio�ca�,7�' Q� /✓lI �/ QPc'rc�/�S Print or type name of person signing above Title f 40 Stormwater Permitting Program Please return this completed renewal application form Individual Permit Renewal and other required supplemental information to: 1612 Mail Service Center Raleigh, North Carolina 27699.1612 0 STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT ANDJMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources - Stormwater Permitting Facility Name: Roanoke Rapids Mill Permit Number: NCS000106 Location Address: 100 Gaston Rd Roanoke Rapids, NC 27870 County: Halifax "1 certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information gathered is, to the best of my knowledge and belief, true, accurate and complete." And I certify that the SPPP has been developed, signed and retained at, the named facility location, and the SPPP has been fully implemented at this facility location in accordance with the terms and conditions of the stormwater.discharge permit" ®And "1 am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for knowing violations." Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION. Signature !N Da�te �D 1�"/1S/1•3 �✓i/bur l:ess,rl�ger���. Vlee 71 vs/a<�t>< of /✓%/( C7Fzou 5 Print or type name of person signing above7 Title SPPP Certification 10/13 SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL NPDES STORMWATER PERMIT ®Two copies of each of the following shall accompany this submittal in order for the application to be considered complete: (Do not submit the site Stormwater Pollution Prevention Plan) Initials NRD 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of industrial activities (including storage of materials, disposal areas, process areas and loading and unloading areas), drainage structures, drainage areas for each outfall, building locations and impervious surfaces should be clearly noted. NRD 2. A summary of Analytical Monitoring results during the term of the existing permit (if your permit required analytical sampling). Do not submit individual lab reports. The summary can consist of a table including such items as outfall number, parameters sampled, lab results, date sampled, and storm event data. H NRD 3. A summary of the Visual Monitoring results. Do not submit individual monitoring reports. The summary can consist of a table including such items as outfall number, parameters surveyed, observations, and date monitoring conducted. NRD 4. A summary of the Best Management Practices utilized at the permitted facility. Summary ® should consist of a short narrative description of each BMP's in place at the facility. If the implementation of any BMP's is planned, please include information on these BMP's. NRD 5. A short narrative describing any significant changes in industrial activities at the permitted facility. Significant changes could include the addition or deletion of work processes, changes in material handling practices, changes in material storage practices, and/or changes in the raw materials used by the facility. NRD 6. Certification of the development and implementation of a Stormwater Pollution Prevention Plan for the permitted facility (Sign and return attached form). If the final year analytical monitoring of the existing permit term has not been completed prior to filing the renewal submittal, then the last years monitoring results should be submitted within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal waiting on lab results) E December 12, 2013 Stormwater Permitting Program Individual Permit Renewal 1612 Mail Service Center Raleigh, North Carolina 27699-1612 KAPSTONE KRAFT PAPER CORPORATION A Division of KAPSTONE PAPER AND PACKAGING CORPORATION 100 Gaston Road Roanake Rapids, NC 27870 252.533,6000 fax: 252,533.6401 KAPSTONEPAPER.com 0-40f��1119 ME 0 DEC 1 9 2013 DENR - WATER QUALITY WETLANDS AND STORMINATERBRANCH Re: Stormwater Discharge Permit Renewal, KapStone Kraft Paper Corporation, Roanoke Rapids NC, NCS000106. Mr. Bradley Bennett; Kapstone Kraft Paper Corporation in Roanoke Rapids, NC is requesting renewal of their NPDES stormwater permit NCS 000106. Enclosed you will find three copies of the Renewal Application and the Supplemental Information that was requested for renewal. If there are any questions or concerns. I can be reached by phone at 252-533-6295. Sincerely, mz Neal R. Davis Environmental Engineer KapStone Kraft Paper Corporation Roanoke Rapids, NC Enclosures DEC 1 9 Z013 DENR•WAToRDU�n WEWDSAND STDRMWATER �WCN :OW .KAPSMNE KapStone Kraft Paper Corporation 100 Gaston Road Roanoke Rapids, NC 27870 NPDES Stormwater Permit Coverage Renewal Request Roanoke Rapids Mill Permit Number NCS000106 Halifax County ® 9 @ ' , KAPSTONE KRAFT PAPER 01INeR: RRVIRIONS: ®EcoEngineerin9 c , ROANOKE RAPIDS, NORM GAROLINA KAPSTONE KRAFT PAPER Aa�w�wn.iamzrnenam fir, �. X o gg P 100 GASTON ROAD q 8 ROmon WWI KOMR WOMA .9Y. DRAINAGE AREA EKMfr 0 0 0 0 • KAPSTONE KRAFT PAPER CORP. 100 GASTON ROAD, ROANOKE RAPIDS, NC STORMWATER PERMIT NCS 000106 OUTFALL: TENT EE BENCH MARK DATE COLLECTED TOTAL FLOW MG 120 COD mg/I 100 TSS mg/I 2 TOTAL PHOSPHORUS mg/I 0.03 TOTAL LEAD mg/I 6-9 30 Ph OIL & GREASE Standard mg/I 2009 9/22/2009 0.138 13 31 0.064 < 0.010 6.25 < 5 2010 7/10/2010 0.062 28 23 0.093 < 0.010 7 < 5 10/25/2010 0.173 24 15 0.076 < 0.010 6.9 < 5 2011 5/23/2011 0.086 57 19 0.037 < 0.010 6.9 < 5 9/21/2011 0.0498 < 15 5 0.04 < 0.010 7.3 < 5 2012 5/30/2012 0.909 94 100 0.894 < 0.010 6.5 < 5 11/27/2012 0.104 23 15 0.156 < 0.010 6.7 < 5 2013 6/17/2013 0.0589 30 15 < 0.020 < 0.010 6.9 < 5 11/7/2013 0.665 19 36 0.052 < 0.010 7.4 < 5 KAPSTO RAFT PAPER CORP. 100 GASW ROAD, ROANOKE RAPIDS, NC STORMWATER PERMIT NCS 000106 SUMMARY OF VISUAL OBSERVATIONS DATE COLOR ODOR CLARITY FLOATING SOLIDS SUSPENDED SOLIDS FOAM OIL SHEEN TENT 9/22/2009 LITE TAN NONE TURBID LEAVES CLEAR NONE NONE STOREROOM TAN NONE TURBID LEAVES CLEAR NONE NONE 7/10/2010 TENT LITE TAN NONE VERY GOOD LEAVES NONE NO NO STOREROOM NO NO NO NO NO NO NO 10/25/2010 TENT LITE BROWN NONE GOOD FEW LEAVES FEW BLACK FLECS NO NO STOREROOM LITE GRAY NONE GOOD NONE SLIGHTLYTURBID NO NO EROSION CONTROL DEVICES PUT IN PLACE DECEMBER 2010 5/23/2011 TENT VERY LITE TAN NONE CLEAR FLOWER PETALS SMALL SPECS LEAVES NO NO STOREROOM LITE GRAY NO GOOD FEW TWIGS AN LEAVES FINE DUST NO NO MAY 16 - 19 REPLACED CHECK DAMS AND RAKED OUT 57 STONE 9/21/2011 TENT LITE TAN NONE OPAQUE SPARSE LEAVES PARTICLE SPECS NO NO STOREROOM TAN NONE MUDDY NONE YES SILT NO NO I I April 23 2012 I Performed maintenance on Stormwater BMP Removed 57 stone and replaced around drains and discharge May 14, 2012 Facility Stormwatert Inspection 4/30/2012 TENT LITE TAN NONE OPAQUE PIECES OF LEAVES YES NO NO STOREROOM NONE NONE LITTLE COLOR NONE NONE NO NO AUG. 25, 2012 MILL FLOODED 11.5 INCH RAIN IN ABOUT4.5 HOURS. PHOTOS OCTOBER 1, 2012 REPLACED EROSION CONTROL DEVICES REMOVED FROM FLOOD 11/27/2012 TENT LITE TAN NONE OPAQUE LEAVES SMALL PARTICLES NO NO STOREROOM LITE GRAY NONE OPAQUE LEAVES LIGHT NO NO I March 28,2012 Stormwater Inspection Replaced Rip Rap in Ditches and 57 stone around drains in Trailer Yard, Scale House and Storeroom 6/17/2013 TENT LIGHTTAN NONE OPAQUE NONE VISIBLE SOME NO NO STOREROOM CLEAR NONE LITE SCUM NONE VISIBLE NONE VISIBLE NO NO 7/18/2013IPAINTED AND REPAINTED DRIANSTO STORMWATER BLUE, SUMMER CALL BOARD ® Preventive Maintenance and Good Housekeeping Program The KapStone Kraft Paper Corporation facility (KapStone) is located at 100 Gaston Road, Roanoke Rapids, North Carolina approximately 1 mile west of Interstate 95. Approximate facility coordinates are 36-28-30 N and 77-38-30 W. The site is located directly along the Roanoke River and functions under NPDES Stormwater Permit NCS000106. KapStone produces bulk rolls of unbleached paper from pine round wood and purchased chips. The mill is adjacent to, and generally drains to the Roanoke River through three major sub - basins. The largest sub -basin contains about 155.8 acres, and includes: the pulp mill, paper mill, the wood yard, supporting facilities, and the north portion of a gravel trailer yard. The entire sub -basin drains to the mill's wastewater treatment facility. Petroleum products and chemicals are stored in this area. Petroleum products on site include tall oil, diesel fuel, #6 fuel oil, hydraulic oil, and lubricants. Chemicals include, but are not limited to, sulfuric acid, caustic, defoamers, and sodium hypochlorite. Storage tanks are surrounded by containment. 2. An area of appproximately 0.97 acres known as the "Storeroom" Sub -Basin located north of the storeroom drains directly into the Roanoke River. There are no manufacturing processes in this area. Best Management Practice activities in December 2010, installed block and gravel at this discharge to the river. 3. The third sub -basin drainage area consists of the mill's employee parking, main office, maintenance shop, shipping building, the south gravel trailer yard and truck scales. This area contains about 12.75 acres and drains generally south to a series of stormwater conveyance pipes and ditches and is known as the "Tent" Sub -Basin. Run-off from this system was untreated until December 2010, when the Tent Sub - Basin received additional Best Management Practices. These were submitted and approved by the state and include block and gravel at two inlets, and check dams and silt fences along the open ditches. This discharge area combines with a larger stormwater drainage area of approximately 770 acres from the City of Roanoke Rapids. Based on observations, the areas within the Tent Sub -Basin that would be most likely to contribute to any water quality issues would be the south gravel trailer yard and the roads running through and around the basin. Loading and Unloading Activities Oil and chemicals are located in storage tanks within the mill. A map of their locations is contained within the Stormwater Plan and the Emergency Action Plan. The chemical tanks are filled from rail -cars or tractor -trailers. The unloading points are on concrete pads that ® drain to our process sewer in case of any spills. All chemical tanks are on concrete pads that drain to the process sewer or within concrete containment areas. These containment areas have locked valves that also drain to the process sewer. They are inspected once a week and after a rain event. Records of these inspections are kept in the Containment Log and are part 0 Best Management Plan In July of 2010, a Stormwater Best Management Plan was submitted to the North Carolina Division of Water Quality. The Study was conducted by Eco Engineering a Division of John McAdams Company, Durham, NC. Approval from the NCDENR was received on August 26, 2010. A copy of the manual as submitted is maintained in Neal Davis' EHS Office. Erosion Control devices were installed December of 2010 Stormwater Erosion Control Devices Installed • Check Dams were put in the large ditches surrounding the Scale House. • A 6-inch layer of 57-stone was placed around the parameter of the ditches. The stone is cleaned and/or replaced as needed. • Grass was allowed to grow lining the ditches. • Erosion Control measures were constructed in the Trailer Yard. o The existing drain was raised 16 inches using concrete block. The block was surrounded with 57-stone. The stone is cleaned and/or replaced as needed. o A chain was also installed to keep vehicles out of the area. ® • A check dam of Railroad blast was installed at the Storeroom discharge along with 57- stone for better filtration. The stone is cleaned and/or replaced as needed. Environmental Awareness Training is conducted annually for each employee of KapStone Kraft Paper Corporation, Roanoke Rapids.. A signed copy of the Check for Understanding is kept on file in the EHS trailer. The Environmental training slides are in a tab in the Stormwater Plan. KapStone Roanoke Rapids has a Hazardous Materials Team that receives 32 hours of training annually. Eight hours are Technician Level Training. As part of the mill's Spill Prevention Control and Countermeasure Plan and the Facility Response Plan, two boats are maintained on -site with outboard motors and 1,000 feet of boom. In Case of Spill: Mill Personnel are trained to immediately attempt to stop or control the source of a spill. The mill's Emergency Response Team will take measures to contain and clean up any spilled materials utilizing the adsorbent materials stored in the hazmat truck. Since bulk storage containers are located outside, particular attention is paid to protecting the drainage pathways in the direction of the spill. Use of material to dike, dam or divert the spill may also be used if necessary to prevent the spill from entering the storm drain. Incident and response activities 40 are documented. All but 13.7 acres of the Roanoke Rapids Mill Facility drains to the mill's Wastewater Treatment Plant. The mill has also deployed erosion control devices in the 13.7 acres that could be exposed to stormwater. ® of the Spill Prevention Control and Countermeasure Plan. An electronic copy of the log location: S: drive\Groups\EOHS\EOHS\2013 Containment Log SPCC & Stormwater Tote bins of chemicals are stored at the Paper mill Spra White slab. Empty tote bins are also stored on the cement slab West side of the Paper mill, directly south of the Spra White slab. All of these locations drain to the wastewater treatment plant. Outdoor Process Areas Logs, Bark, Chips, and Sawdust are brought into the mill through the Scale house and stored on the mill site and transported around the mill pneumatically or on conveyor belts. Logs are debarked in the debarking drum and cut into chips. The chips are transported to the Pulp Mill or Chip Storage by conveyor belts to be processed. The sawdust is burned in the boiler. Log and chip holding areas have drains and ditches around them that carry any run-off to the Stormwater Holding Pond, which is then pumped to the emergency pond and later returned to the head of the wastewater plant. Dust Control Process A large portion of the Tent Sub -Basin is gravel and dust is controlled by spraying the roads with river water. The Environmental Programs Department hires a contractor to provide this service. During dry weather, the roads are sprayed three days a week. A Spill Prevention Control and Countermeasure Plan is contained in the Emergency Action ® Plan. It contains procedural and contact information in case of spills and what response is recommended. These can be found in the Emergency Management System on the mills intranet and the EHS trailer. On Site Vehicle Maintenance Monitoring Vehicle maintenance is performed on site in what is known as the Truck shop and the Woodyard Maintenance shop. These areas are enclosed from the weather. Spills are cleaned up with sawdust. Drains in the buildings go to the process sewer. Waste oil is collected in drums that are hauled away by a contractor. General spills from the vehicles and heavy equipment in the mill are cleaned up with sawdust. The sawdust is then burned in the boiler. Waste Disposal Practices The mill has a lined landfill that is permitted for primary clarifier residuals, flyash, and lime mud. This landfill has two of four phases complete with a footprint of 25 acres. The two additional phases will be constructed when the current cells near capacity. Leachate from the landfill is gravity fed to the Aeration Basin of the wastewater treatment facility. All trash is put into dumpsters located throughout the mill and hauled away by a Contractor. a. KAPSTONE KAPSTONE KRAFT PAPER CORPORATION A DiNsion of KAPSTONE PAPER AND PACKAGING CORPORATION 100 Gaston Road Roanoke Rapids. NC 27870 kapstonepapeccom To Whom It May Concern; Kapstone Kraft Paper Corporation has not made any significant changes in the industrial activities at the Roanoke Rapids facility. The only exposure to stormwater runoff is the 12.5 acres listed in the permit. Any other areas of the mill that are exposed to stormwater are piped to our Wastewater Treatment Plant. Permit Number NC0000752. ® Sincerely, Neal 6avis Environmental Engineer Kapstone Kraft Paper Corporation 11 WestRock September 24, 2019 Ms. Lauren Garcia DEMLR Stormwater Division Division of Energy, Mineral and Land Resources 512 North Salisbury St. 1612 Mail Service Center Raleigh, NC 27699-1612 100 Gaston Road Roanoke Rapids, NC 27870 office: 252.533.6295 neal.davis@ westrock.com rr--r FIVED Ov? 27 2019 DENR-LAND QUALITY STORMINATER PERMITTING Subject: KapStone Kraft Paper Corp. / WestRock Kraft Paper LLC Stormwater Permit NCS000106 Dear Ms. Garcia; Please note below, comments from KapStone Kraft Paper Corporation/WestRock Kraft Paper, LLC on the Draft Stormwater Permit dated August 27, 2019, Permit No. NCS000106. i. In November of 2018, WestRock acquired KapStone Kraft Paper Corporation. WestRock is in the process of converting KapStone Kraft Paper Corporation from a corporation to a Limited Liability Company (LLC) and changing the name of the entity to WestRock Kraft Paper, LLC. The electronic form from the edos.deq.nc.gov website will be submitted for the storm water permit ownership change. Please change KapStone Kraft Paper Corporation on the title page of the permit to WestRock Kraft Paper, LLC. Enclosed is a letter from Thomas M. Sigers, Executive Vice President, WestRock, which delegates authority for environmental matters for the Roanoke Rapids mill to Ben White, General Manager (Formerly Mill Manager under KapStone). Page 8 of 29 Footnote 3: We have an email from Ken Pickle dated June 11, 2009, granting ROS status to a stormwater outfall on the site which is behind our storeroom. A copy of the I mail is enclosed with this letter. 3. Page 10 of 29: This is a stipulation about Impaired Waters. In the old permit, page 8 of 11, it is stated that the reason for Roanoke River impaired waters is a mercury Fish Advisory. In the new permit it declares that "This site discharges to impaired waters experiencing problems with turbidity, fluoride, nickel, fecal coliform, arsenic, water temperature, chloride, copper, pH, fish tissue mercury, lead, dissolved oxygen, cadmium, iron and zinc. WestRock takes issue with this. WestRock Michael E. Knudson Environmental Manager 100 Gaston Road direct 252-533 6280 Roanoke Rapids, INC 27870 mobile: 252-326 5288 westrack.com mike. knudson®westrock.com At the ncdenr.maps website that you referenced in your September 20, 2019, email, "Impaired" is not mentioned. The Roanoke River, downstream of the Roanoke River Dam, is classified Gray and states: "There are only data inclusive assessments or at least one pathogen assessment is data inconclusive (except for Mercury in Fish Tissue). The website map shows that the Roanoke River continues Gray all the way to the Albermarie Sound. WestRock objects to labeling the Roanoke River as impaired in the permit for all these parameters when the official NCDENR website does not. Please only note mercury in this stipulation, which is consistent with the old permit as well as State and EPA determinations. If there are any question or concerns please contact Neal Davis at neal.davis(u,westrock.com or 252-533-6295 Sincerely, Benjamin P. White, General Manager WestRock Kraft Paper LLC 100 Gaston Road Roanoke Rapids, NC 27850 Enclosure Copies: Neal Davis Danny Smith (RRO) �OestRock DELEGATION OF AUTHORITY FOR ENVIRONMENTAL MATTERS CONTAINERBOARD MILLS As Executive Vice President of Containerboard Mills, I hereby ratify and confirm the authority of each General Manager (GM) and Designated Representative (DR) listed below to act as the responsible official and/or the duly authorized representative for the purpose of overseeing environmental compliance matters at the facility(ies) he manages (Covered Facilities). This Delegation of Authority includes, without limitation, the authority to execute and submit all environmental applications, certifications and reports required by the Covered Facilities, as well as the authority to act with respect to facilities in the U.S. as the °responsible official" as that term is defined at 40 C.F.R. § 70.2 and corresponding U.S. federal, state and local agency regulations. To the extent allowed by applicable law, the GM or DR may re -delegate this authority, in writing, to any appropriately trained facility manager for the specific purpose of executing any monthly discharge monitoring or similar wastewater report that may be required under a National Pollutant Discharge Elimination System (NPDES) or comparable state or local wastewater discharge permit. This Delegation of Aut y will rem in in effect until revoked or superseded. Thomas M. Stigers Executive Vice Pr ident, Containerboard Mills WestRock Effective Date: September 9, 2019 COVERED FACILITY STATE GENERAL MANAGER COVERED FACILITY STATE GENERAL MANAGER Cowpens SC Steve Leahy North Charleston SC John McCarthy Dublin GA Brian Kinsey Panama City FL Brett Tremblay Fernandina Beach FL Dan Rowland Pointe-aux-Trembles QC Karyne Trudeau Florence SC Devin Nix Roanoke Rapids NC Ben White Hodge LA Eric Taylor Solvay NY Peter Tantalo . opewell VA James Osborne Stevenson AL Darrell Daubert Jacksonville (Seminole) FL Tom Crockett Tacoma WA John Brandt La Tuque QC Pierre Pacarar West Point Mill VA Chris Broome Longview WA Steve Devlin CLOSED MILLS Nina Butler Lynchburg VA Mark Murphy Neal From: Pickle, Ken (ken.pickle®ncdenr.gov] Sent: Thursday, June 11, 2009 4:36 PM To: Ransmeier, MARY Cc: myd.nisely®ncmail.net; Davis, Neal; Bennett, Bradley; Lowther, Brian Subject: RE: KapStone Kraft NCS000106 Dear Ms. Ransmeier, Thanks for being available on such short notice for our unscheduled visit. It really helps the permitters when we can see the site conditions. Based on your note, we are in agreement as to the Storeroom Outfall and as to the sample point for the Tent Outfall. I've re -stated below your points just to confirm our agreement on them; please contact us if I have missed any minor point. I have relayed our conversation and my observations at Kapstone to your permit writer, Brian Lowther, and to our supervisor, Bradley Bennett. Please take this note as written confirmation of certain comments I made while on your site. Specifically, as to your current coverage under the expired individual permit, NCS000106, you are authorized for Representative Outfall Status from this time forward. DWQ will consider the Tent Outfall representative of the stormwater discharges from both the Tent Outfall and the Storeroom Outfall, until and unless significant changes in on - site activities suggest that the Representative Outfall Status is no longer appropriate. Scheduled analytical samples need only be taken for the Tent Outfall. Visual monitoring is to be continued at both outfalls. Further, we are in agreement with the relocation of the sample point for flows from the Tent Outfall to a location further downstream than previously located. As you note and as we discussed, the new location will be close to, but still upstream of the junction with the large flows from off site, i.e. the city stormwater flows. As to provisions in the pending renewed permit, we intend that the Representative Outfall Status will continue for the Tent Outfall, and we will so note in the transmittal letter that will accompany the renewed permit. Administratively it has been our practice to address the granting of Representative Oufall Status by separate letter outside of the permit text, and we propose to continue that practice if you do not object. Similarly, on large and complicated sites we typically do not direct the exact location of stormwater sampling, unless we see a need to. We are in agreement with the current proposed location further downstream, and are agreeable for that location to be continued under the renewed permit. Please contact us for concurrence if you subsequently judge that another location might be more representative of the stormwater flows from your site. Ken Pickle DWQ Stormwater Permitting Unit I* NC Division of Energy, Mineral and Land Resources Review for Permit — NCS000106 Kapstone Kraft Paper Corporation Facility Activities and Processes: • SIC Code 2621— Paper Mills • The facility has a WWTP onsite (NC0000752): limits for BOD, conductivity, copper, DO, flow, TN, ammonia, Ceriodaphnia, pentachlorophenol, pH, TP, TSS, temp, trichlorophenol. • The mill is an integrated pulp and paper mill producing unbleached Kraft paper before packaging. • 2009 Staff Report: The Lowground SW sampling point is currently in permit held by Capstone Paper. In the renewal application they requested removal of the Lowground point because Kapstone no longer is the owner, nut IP is. An email from Myrtl Nisely of the RRO that based on his knowledge of the site and from occasional observations in the last couple years, as well as conversations with the Environmental Staff at the paper mill he recommends that the closed Lowground Landfill not rpq jiy ra a permit. There is no ind st_ riaArr y ry ar rh cation. isolated at "the back 40" of the paper mill property. The site is everywhere heavily vegetated, and the capping materials soak rain so well that there has never been any waterfrom the turtle backed top surface. Any water observed at the toe of the landfill travels through vegetation and is like wise absorbed before it is able to collect at one corner, from which point it would go through a culvert in to a channel to the Roanoke River. Even in heavy rain, there is no flow at the downstream end of the culvert. Therefore, Myrl supports the contention of IP that application for a stormwater permit for the Lowground is unnecessary. • On June 23, 2006 Kapstone Paper, through its wholly -owned subsidiary, Kapstone Kraft Paper Corporation, agreed to purchase the Kraft Papers Business of International Paper Company. The business consists of an unbleached Kraft Paper manufacturing facility in Roanoke Rapids, NC and Ride Rite Converting, an inflatable dunnage bag manufacturer. Kraft Paper produces over 300 unbleached and bleached grade types available that offer best -in -class printability, strength, coatings, and specialized performance characteristics: Multiwall, converting and bag & sack. • Facility produces grocery bags, concrete bags, and lining for boxes. Bring in logs and wood chips. Monitoring Information: • 2009 Staff Report: The visual monitoring shows colors that include brown, tan, gray and orange. The clarity is often opaque or turbid. There are some suspended solids and others signs of pollution at the outfalls. The • lity_hasaa_historyof COD, TSS, Phosphorus, and Lead benchmark exceedances at all out T_ � _ • The mill is adjacent to the Roanoke River and generally drains to the Roanoke River through three major sub_has ns The largest sub -basin which includes the actual paper_m _waod_chip piles and portions of thQ_yard" area drains into the mill's wastewater treatment plant. A small north portion of the mill site drains untreated directly into the Roanoke River. This sub -basin is known as the "Storeroom" sub -basin. The third sub -basin drainage area consist of the mill's employee parking, main office, maintenance shop, shipping building, trailer parking area, and the truck scales. This area drains generally south to a series of stormwater conveyance pipes and ditches and is known as the "Tent" sub -basin. Runoff from this system is untreated and combines with a larger drainage area from the City of Roanoke Rapids before flowing into the Roanoke River. Impairment: • This site discharges to the Roanoke River, an impaired waters experiencing problems with turbidity, fluoride, nickel, fecal coliform, arsenic, water temperature, chloride, copper, pH, fish tissue mercury, lead, dissolved oxygen, cadmium, iron, and zinc.