NCS000106_HISTORICAL FILE_20200924

STORMWATER DIVISION CODING SHEET
NCS PERMITS
PERMIT NO.
N [S DC>DI DC-o
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING REPORTS
❑ APPLICATION
❑ COMPLIANCE
R OTHER Hisroruc�� INFDi�MATl0Y�1
DOC DATE
❑ 2D20®`I2L-
YYYYMMDD

November 30, 2017
Charles Weaver
NC DEQ / DWR / NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Weaver:
KAPSTONE
KRAFT PAPER CORPORATION
A Division of KAPSTONE PAPER AND PACKAGING CORPORATION
100 Gaston Road Roanoke Rapids, NC 27870
kapstonepapercom
RECEIVED
DEC 191017
DENR•LAND QUALITY
STORMWATER PERMITTING
The purpose of this letter is to provide notice of a management change at KapStone Kraft Paper
Corporation in Roanoke Rapids, North Carolina. My name is Benjamin P. White I have assumed
the position of Vice President of Mill Operations, i.e. Corporate Responsible Officer at the
Roanoke Rapids mill effective August 22, 2017. I can be contacted by phone at 252-533-6335 or
by e-mail at Ben. WhitegKapstoneganer.com.
It is my understanding that the Corporate Responsible Officer is authorized to make management
decisions which govern the operation of the regulated facility including having the explicit or
implicit duty of making major capital investment recommendations, and initiating and directing
other comprehensive measures to assure long term environmental compliance with
environmental laws and regulations.
This change of management applies to Wastewater permit NC 0000752, Storm water permit
NCS000106, Distribution of Class a Residuals permit WQ0021577, and Surface Disposal of
Industrial Byproduct Residuals permit WQ 0000436. The Operator in Responsible Charge, Neal
Davis and Back-up Operator in Responsible Charge, Chris Williams will remain the same.
In addition there has been a change of mailing address from:
100 Gaston Road
Roanoke Rapids, NC 27870
To
PO Box 458
Roanoke Rapids, NC 27870
Bethany Georgoulias has entered the changes to the permits in the BIMS system. If there any
questions or additional information is needed please contact Neal Davis at 252-533-6295 or
Mike Knudson at 252-533-6280.
Sincerely,
Benjamin P. White
Vice President of Mill Operations
Copy to EHS Central File

K.
Energy. Mineral A
Land Resources
ENVIRONMENTAL OUPIRV
Division of Energy, Mineral, and Land Resources
Land Quality Section / Stormwater Program
National Pollutant Discharge Elimination System (NPDES)
PERMIT OWNER AFFILIATION DESIGNATION FORM
(Individual Legally Responsible for Permit)
Use this form if there has been:
FOR AGENCY USE ONLY
Date Received
Year
Month
I Day
NO CHANGE in facility ownership or facility name, but the individual
who is legally responsible for the permit has changed.
If the name of the facility has changed, or if the ownership of the facility has changed,
do NOT use this form. Instead, you must rill out a Name -Ownership Change Form
and submit the completed form with all required documentation.
What does "legally responsible individual' mean?
The person is either:
RECEIVED
• the responsible corporate officer (for a corporation); OFr. 19 2017
• the principle executive officer or ranking elected official (for a municipalittyy state, federal or other public
agency); DitNR-LAND QUALITY
• the general partner or proprietor fora partnership or sole ro rietorshiSTORMWATER PERMITTING
g P P P ( P P P P P�
• or, the duly authorized representative of one of the above.
1) Enter the permit number for which this change in Legally Responsible Individual ("Owner Affiliation')
applies:
Individual Permit
N I C I S 10 10 0 1 0 6
2) Facility Information:
Facility name:
Company/Owner Organization:
Facility address:
(or) Certificate of Coverage
N I C I G
KaDStone Kraft Paper Corporation
KapStone Paper and Packaging Corporation
100 Gaston Road
Address
Roanoke Rapids NC 27870
City State Zip
To find the current legally responsible person associated with your permit, go to this website:
htti3://deg.nc. gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-permits/stortnwater-program
and run the Permit Contact Summary Report.
3) OLD OWNER AFFILIATION that should be removed:
Previous legally responsible individual: Wilbur G Kessinger, Jr.
First Ml Last
4) NEW OWNER AFFILIATION (legally responsible for the permit):
Person legally responsible for this permit:
Benjamin P White
First MI Last
S W U-0W NERAFF R123 March2017
Page 1 of 2

NPDES Stormwater Permit OWNER AFFILATION DESIGNATION Form
(if no Facility Name/Ownership Change)
5) Reason for this change:
A result of:
If other please explain:
Vice President Mill Operations
Title
P. O. Box 458
Mailing Address
Roanoke Rapids NC 27870
City State Zip
(5 ) 533-6435 h .n.whit {akaoTtonepaper.com
Telephone - E-mail Address
K.�� M911*11OU
Fax Number
® Employee or management change
❑ Inappropriate or incorrect designation before
❑ Other
The certification below must be completed and signed by the permit holder.
PERMITTEE CERTIFICATION:
I, Benjamin P. White , attest that this application for this change in Owner Affiliation
(person legally responsible for the permit) has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts.of this form are not completed, this change may not be
processed.
Signature
PLEASE SEND THE COMPLETED FORM TO:
Division of Energy, Mineral, and Land Resources
Stormwater Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Date
For more information or staff contacts, please call [phone] or visit the website at:
httu://deq.nc. gov/about/divisions/energy-mineral-land-resources/stormwater
Page 2 of 2
S W U-OW NERAFFIL-23Mar2017

Pickle, Ken
From: Pickle, Ken
Sent: Saturday, April 26, 2014 9:42 AM
To: Bennett, Bradley;'[e-mail]'
Cc: Georgoulias, Bethany
Subject: RE: Kapstone facility in Roanoke Rapids NCS000106
Thanks, Bradley, IT be glad to be Mikes contact from here on, unless you want to continue to respond to him.
Hi Mike, nice to hear from you.
I'll be glad to make the 2009 permit text and other file materials available for copying on your visit up here in the
Archdale Building, 91h floor.
In looking into our stormwater permitting file, here's what I see:
• There is no indication in the file that Kapstone or IP or Champion ever reported that this pond produced a
stormwater discharge.
This large pond was not included as part of the mill's response to our most recent re -issuance of their
stormwater permit, NCS000106, nor in the BMP Management Plan required under that permit. I know that the
pond pre -dated the most recent version of our permit in 2009. My file review back to 1994 does not show any
indication that this is a stormwater pond intended to address the control of pollutants in stormwater discharged
from the facility, although our file is pretty sparse that far back.
Some old drawings in the file indicate that there are numerous contributing pipes into the pond, some of which
might originate in local low points with catch basins draining to the pond. But the scale of the drawings and
lack of legible labeling make this a very tentative assessment. It appears more likely that the pond is intended
to take overflow from two "Mud Ponds' and an "Ash Pond". Further suggesting that no stormwater discharge
from this pond was ever contemplated, or ever took place (i.e., any discharge wouldn't be stormwater, but
wastewater.)
• My summary, based on file contents: The pond is not part of their stormwater control system in the sense of
having a stormwater discharge from it. [I mean: a discharge point from the pond was never reported; a
discharge was never permitted; and it wouldn't be stormwater anyway if drainage from the Mud Ponds or Ash
Ponds are indeed entering the pond.]
Lastly, for your information, this permit expires in July 31,2014, and we are just now turning our attention to our large
backlog this year on individual permits, including this one.
So, to answer your question, depending on the nature of your project, it does not appear that you would be
constrained from modifying the pond itself by the current stormwater permit conditions. However, whether your
project impacts our renewal of the permit later this year could depend on whether or not the project produces new
stormwater-only discharges.
Let me know how I can help further.
Ken
Ken Pickle

Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickleOncdenr.gov
Website: http://i)ortal.ncdenr.org/web/ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Bennett, Bradley
Sent: Friday, April 25, 2014 2:33 PM
To: Pickle, Ken
Subject: FW: Kapstone facility in Roanoke Rapids
Ken,
Do you recall if this was part of Kapstone's BMP plan? I think maybe they had some local flood control requirements
that may have been the reason for the pond?
m
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: bradley.bennettftncdenr.gov
Raleigh, NC 27699-1612 Web: hfo://Dortal.ncdenr.org/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records laws
From: Mike Burden rmaiIto: MBurden(cbmseco.com]
Sent: Friday, April 25, 2014 2:12 PM
To: Bennett, Bradley
Subject: Kapstone facility in Roanoke Rapids
Mr. Bennett,
I was not sure who to contact for this, so please forward to the appropriate staff if required.
Mid -South has been hired by Kapstone for engineering services at their facility in Roanoke Rapids. It was formerly
owned by International Paper. One issue that has come up is the status of the existing basin which I have indicated on
the attached.
Unfortunately we have limited information from Kapstone at this time. They have told us that the basin is an
"emergency" pond but they have asked us to investigate the status of the pond. Specifically, they have asked us to
determine if the pond can be eliminated or reduced in size. At this time we do not know the purpose of the basin so I
am looking for any help you can provide.
From the Stormwater Permitting website, I see that there is an active NPDES Stormwater Permit (NCS000106) for the
facility. Is it possible to email me a copy of the active permit?

Also, does the file for the permit contain any other information, such as reports, calculations, plans, etc that we could
get copies of to help us respond to our client? If so, I would be glad to come in and see if there is anything worth
copying and will pay for the cost of copies.
Thanks in advance for any assistance that you and your staff can provide in helping us respond to our client.
Regards,
Mike
Mike Burden, PE
Senior Civil Engineer
MM
MID -SOUTH ENGINEERING CO
200 Mackenan Drive
Cary NC 27511
Tel: [phone]
Fax: [phone]
Email: mburdenPmseco.com
Billing: P O Box 1399
Hot Springs AR 71902
PH: 501-321-2276
Website: www.mseco.com
MID -SOUTH ENGINEERING CONFIDENTIALITY NOTICE: This e-mail message and any attachments are for the sole use of the intended recipient (s) and may contain proprietary,
confidential, trade secret or privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited and maybe a violation of law. If you are not the
intended recipient or a person responsible for delivering this message to an intended recipient, please contact the sender by reply email and destroy all copies of the original
message immediately

e N
Pickle, Ken
From: Pickle, Ken
Sent: Wednesday, March 19, 2014 9:34 AM
To: 'Karen Callaway'; Bennett, Bradley
Cc: Neal Davis; Parnell, David; Georgoulias, Bethany
Subject: RE: P140011 Kapstone Kraft Paper Corporation - Halifax County
Hi Karen,
• Based on your report of the planned activities, no revision to the permit text is required.
• If Kapstone wants to send us a courtesy copy of the revised site plan, we would file it in the permit file for
Kapstone for any potential future use. But they not required to submit it to us.
• Kapstone is required to update their SPPP to include a site plan that accurately reflects the physical facts of site
configuration. The SPPP does not have to be submitted to us, either. In fact, we prefer that our permittees not
send us the SPPP, since we are constrained by file cabinet space.
• Kapstone should continue to abide by the all the conditions of their permit, including the sampling requirements
and Tier implementation requirements in Part If Section B.
Hi Neal,
Sorry to be late in responding to your voice messages. I've been in and out of the office over the last week, and am just
getting caught up on several messages. If we need to discuss more, please contact me again. I've provided specific
narrow comments (in red) below in Karen's email, just to be sure I've answered your concerns.
Best regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. Dickle(a)ncdenr gov
Website: htto://Dortal.ncdenr.org/web/ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Karen Callaway [mailto:[e-mail]]
Sent: Tuesday, March 18, 2014 6:28 PM
To: Bennett, Bradley; Pickle, Ken
Cc: Neal Davis
Subject: P140011 Kapstone Kraft Paper Corporation - Halifax County
Good Afternoon Bradley and Ken,
Neal Davis with Kapstone Kraft Paper Corporation asked me to contact you re a warehouse addition the plant is
planning. Kapstone plans to add a 28,096 SF warehouse addition to its existing paper mill in Roanoke Rapids.
The total building footprint with two loading docks is 34,653 SF. The project will also include construction of

concrete approach pads for the loading docks. The building site currently is all impervious with a combination
of concrete pads, compacted gravel and asphalt. Therefore, there is no net increase in impervious surface area
for this project. The project plans are currently under review by the City of Roanoke Rapids. No comment; no
permit action required.
The project includes re-routing of existing storm drainage piping that currently is located within the proposed
building pad. The piping is only being re-routed around the proposed building and tied back in to existing
piping. There are no new stormwater outlets from the site as a result of this project. No comment; no permit
action required
Currently there is also a 10" fire suppression water line that runs through the proposed building pad. The plans
call for the line to be relocated around the perimeter of the building and includes relocation of an existing
hydrant and construction of an additional hydrant. All fire suppression water lines are owned and maintained
by Kapstone Kraft Paper Corporation and have backflow prevention assemblies currently in place. No
comment; no permit action required.
The total disturbed area for the project, including an onsite permanent stockpile area, is 4.16 acres. NCDENR
Land Quality issued a Letter of Approval for sedimentation and erosion control on March 13 (HALIFA 2014-
011). No comment; no permit action required.
What additional actions does Kapstone need to take in order for this project to be in compliance with their
individual stormwater permit number NCS000106? Karen and Neal: thanks for this update and for your
inquiry on whether additional actions are required under NCS000106. 1 consider your note as primarily a
courtesy communication and 1 appreciate the courtesy. Note that our permit is a "performance spec" permit -
yyou just have to meet the numbers. We won't tell you what to build to accomplish that. Our permits are
deliberately constructed in this way to acknowledge that site conditions can be widely variable between
different locations. The approach also provides the permittee the maximum freedom in selecting a method to
control stormwater pollution to the numerical levels deemed appropriate based on the best environmental
science available to us.
Thank you so much for your assistance.
Karen G. Callaway, P.E.
Mack Gay Associates, P.A.
1667 Thomas A Betts Pkwy
Rocky Mount, NC 27804
Phone: [phone] Office
252/955-2834 Cell

KAPSTONE
KRAFT PAPER CORPORATION
A Division of KAPSTONE PAPER AND PACKAGING CORPORATION
100 Gaston Road Roanoke Rapids, NC 27870
kapstonepaper.com
January 12, 2011
NCDENR / DWQ / Stormwater Permitting Unit
Attn: Brian C. Lowther
1617 Mail Service Center
512 N. Salisbury St.
Raleigh, North Carolina 27699-1617
Re: Stormwater Best Management Plans, KapStone Kraft Paper Corporation, Roanoke Rapids NC,
NCS000106.
Dear Mr. Lowther;
As you requested. Attached you will find a copy of the Stormwater Best Management Plan prints
for the KapStone Kraft Paper Corporation, Roanoke Rapids, NC, Stormwater Discharge. The
permit number is NCS000106.
Construction of the pollution control devices were completed in December of 2010.
If there are any questions or concerns. I -can be reached by phone at 252-533-6295.
Sincerely,
ZaR. Davis
Environmental Engineer
Enclosures

• 1+`j '
Mr. Brian Lowther
Stormwater Permitting Unit
NCDENR
1617 Mail Service Center
Raleigh, NC 27604
January 5, 2011
Subject: Permit No NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, NC Mill
NPDES Stormwater Permit-BMP
Dear Mr. Lowther,
This letter serves as the final monthly progress report in compliance with NPDES
Stormwater Permit NCS000106 BMP implementation for the time period ending
December 31, 2010. The approved constructed BMPs have been completed. As you
know, we have had good success with meeting the water quality parameters this year
following the relocation of the sample point to a more representative position. Photos of
the completed construction projects are.attached.
If you need any further explanation, please feel free to contact me at 252-533-6255 or at
[e-mail].
Sincerely,
ary ee smeier
Environmental Programs Manager
Copy: Bradley Bennet, DWQ
Anitra J. Collins, V.P. Mill Manager, KapStone
Neal Davis, KapStone
Kevin Yates, EcoEngineering
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road, Roanoke Rapids, NC 27870
JANp62�11

KapStone Kraft Corporation BMP Construction- 01/05/2011
�.
l d'�*+a t�.'uG'4�5..-6`. .y9'�tk!�.. - _ _� � /�a}y„c R -'T• _
;�`Y ! krtl { luiif ..9�T � a.� 1)'^�".-'�+�� t`4 Stk�i'"'` �� #:!i �'•i„r'. `?� Y.t V ' ar ,. � - l:
Picture 1: Block and Gravel Inlet Protection Shipping area
-
Picture 2: Black and Gravel Inlet Protection Closer View
2

KapStone Kraft Corporation BMP Construction - 01/05/2011
Picture 3: Drainage ditch near Scale House
,�x�r, ��t �`.+ �, �} ✓ 1�,ipT a'x'j,j�t^4�y�'�:-1�i y�'Tp a+ j;,Iv;; :1
:`-WA
Picture 4: Drainage ditch along main roadway
3

Apr
KAPSTONE
KAPSTONE
KRAFT PAPER CORPORATION
A Division of KAPSTONE PAPER AND PACKAGING CORPORATION
10o Gaston Road Roanoke Rapids, NC 27870
kapstonepapeccom
November 9, 2010
Mr. Brian Lowther
Stormwater Permitting Unit
NCDENR
1617 Mail Service Center
Raleigh, NC. 27604
Subject: Permit No NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, NC Mill
NPDES Stormwater Permit-BMP
Dear Mr. Lowther,
This letter serves as the required monthly progress report in compliance with NPDES Stormwater
Permit NCS000106 BMP implementation. KapStone has received bids for construction of the
approved Best Management Plans and will begin construction in the month of November.
Please contact me if you need any additional information.
Sincerely,
N al R. Davis
Environmental Engineer
KapStone Kraft Paper Corporation
Enclosures
Copy: Bradley Bennet, DWQ
Mary Lee Ransmeier, Environmental Programs Manager
Anitra Collins, V.P. Mill Manager KapStone
CJ
C
c�
CD
G

E-1
l• ►
Mr. Brian Lowther
Stormwater Permitting Unit
NCDENR
1617 Mail Service Center
Raleigh, NC 27604
September 1, 2010
Subject: Permit No NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, NC Mill
NPDES Stormwater Permit-BMP
Dear Mr. Lowther,
This letter serves as the required monthly progress report in compliance with NPDES
Stormwater Permit NCS000106 BMP implementation for the time period of July 31,
2010 through August 31, 2010.
• Plans for Stormwater Best Management Practices were submitted to
NCDENR on July 30, 2010 and approved on August 23, 2010. Approval
received August 26, 2010.
• Preliminary discussions were held with on -site contractors to advise them that
project construction will be scheduled for October or November 2010.
• We plan to obtain construction bids during September.
Please contact me if you need any additional information.
Sincerely,
Marry Lee nsmeier
Environmental Programs Manager
Copy: Bradley Bennet, DWQ
Anitra J. Collins, V.P. Mill Manager, KapStone
Neal Davis, KapStone
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road, Roanoke Rapids, NC 27870
M1!
SGp032010

WDENR
North Carolina Department
of Environment and Natural Resources
Beverly Eaves Perdue
Division of Water Quality
Coleen H. Sullins Dee Freeman
Governor
Director Secretary
August 23, 2010
Mr. Mary Lee Ransmeier
KapStone Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870.
Subject: Final NPDES Stormwater Permit
Permit NCS000106
KapStone Kraft Paper Corporation
Halifax County
Dear Ms. Ransmeier:
In response to your submitted construction plans for your BMP Management Plan required in your NPDES
stormwater permit NCS000106, the Division of Water Quality (Division) is sending this approval letter- The
construction plans and associated documentation were submitted in a timely fashion and are adequate for
the construction and implementation of your selected BMPs.
Please take notice, the selected BMPs shall be installed, operating, or implemented not later than January 31,
2011. Monthly progress reports shall be submitted to the Division between July 31, 2010 and January 31, 2011, or
until final installation, operation, or implementation of the selected and approved BMPs is achieved.
Please remember the benchmarks will be activated in two years after the permit was issued and the approval
and implementation of the BMP Management Plan does not eliminate the need for the stormwater samples to be
below the benchmarks. If the samples are above the benchmarks then the tier system will come into effect which
could include additional measures to the selected BMPs in the BMP Management Plan.
If you have any questions or comments concerning this permit, contact Brian Lowther at [phone] or
[e-mail].
Sincerely,
Brian C. Lowther
cc: Raleigh Regional Office, Vlater Quality Section
Stormwater Permitting Unit
Central Files
Wetlands and Stormwater Branch
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh'
North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: w .ncwaterquality.otg
An Enual Onmrtnnity 1 Aff,mative Action Emnlover
One
NorthCarolina
JV67irrra!!J

hcoEngineering
A division of The John R. McAdams Company, Inc.
LETTER OF TRANSMITTAL
To: Brian C. Lowther
NCDENR -DWQ
1617 Mail Service Center
Raleiqh, North Carolina 27699-1617
Date: July 30, 2010
** HAND DELIVER **
Re: Kapstone Kraft Paper Job No.. KKP-10000
I am sending you the following item(s):
COPIES
DATE
NO.
DESCRIPTION
1
BMP Stormwater Management Plan set
1
EcoEngineering letter to DWQ
1
BMP Mana ement Plan report notebook
2
Ka stone letter
These are transmitted as checked below:
❑ As requested
® For approval
❑ For review and comment
❑ Foryouruse
Manager
FOR INTERNAL USE ONLY
® Copy Letter of Transmittal Only to File
❑ Copy Entire Document to File
2905 Meridian Parkway, Durham, North Carolina 27713
PO Box 14005, RTP, North Carolina 27709

[JEcoEngineering
A division of The John R. McAdams Company, Inc.
July 30, 2010
Mr. Brian C. Lowther
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Wetlands and Stormwater Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Kapstone Kraft BMP Management Plan
Permit NCS000106
Construction Drawings
KKP-10000
Dear Mr. Lowther:
On behalf of the Kapstone Kraft Paper Corporation and as required in your
March 23, 2010 approval letter of the BMP Management Plan, please find
attached construction drawings for implementation of the selected best
management practices for the project.
The BMP Management Plan dated February 2010 prepared by our office served
as a general .guide to provide stormwater quality measures for the Kapstone
Kraft Paper Mill. This submittal is the construction drawings and details for the
BMP measures selected for implementation at the mill. The attached
construction drawings show the mill layout, location of the selected BMP
measures at the mill, details of each measure, and a general phase approach to
the project. The narrative in the February 2010 BMP Management Plan
(attached for reference) provides a detailed description of each BMP measure
and the proposed goal of reducing stormwater pollutants from entering the
waterways via settling, infiltration, direct removal, or biological and vegetative
uptake.
Please refer to the attached construction drawings and please feel free to contact
me at [phone] should you have any questions or need any further
information. -
Sincerely,
EcoEngineering
A division-o The John R. McAdams Company, Inc.
Research Triangle Park, NC
James'W. Caldwell. PE
Post Office Box 14005
BrojeCt Manager
Research Triangle Park,
-
North Carolina 27709
2905 Meridian Parkway
cc: Mary Lee Ransmeier, Kapstone Kraft Paper Corporation
Durham, Nonh Carolina 27713
800-733-5646
919-287-4262
'
919-361-2269 Fax
www.ecoenor.com I Design Services Focused On Client Success

Research Triangle Park, NC
Post Office Box 14005
Research Triangle Park.
Nonh Carolina 27709
2905 Meridian Parkway
Durham, North Carolina 27713-
800-733-5646
919-287-4262
919-361-2269 Fax
[E—Q]EcoEngineering
A division of The John R. McAdams Company. Inc.
July 30, 2010
Mr. Brian C. Lowther
North Carolina Department of L'nviromnent and Natural Resources
Division of Water Quality, Wetlands and Stormwater Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Kapstone Kraft BMP Management Plan
Permit NCS000106
Construction Drawings
KKP-1 0000
Dear Mr. Lowther:
On behalf of the Kapstone Kraft Paper Corporation and as required in your
March 23, 2010 approval letter of the BMP Management Plan, please find
attached construction drawings for implementation of the selected best
management practices for the project.
The BMP Management Plan dated February 2010 prepared by our office served
as a general guide to provide Stormwater quality measures for the Kapstone
Kraft Paper Mill. This submittal is the construction drawings and details for the
BMP measures selected for implementation at the mill. The attached
construction drawings show the mill layout, location of the selected BMP
measures at the mill, details of each measure, and a general phase, approach to
the project. The narrative in the February 2010 BMP Management Plan
(attached for reference) provides a detailed description of each BMP measure
and the proposed goal of reducing stonnwater pollutants from entering the
waterways via settling, infiltration, direct removal, or biological and vegetative
uptake.
Please refer to the attached construction drawings and please feel.free to contact
Inc at [phone] should you have any questions or need any further
information.
Sincerely,
A division-ofjThe John R. McAdams Company, Inc.
Ja*s:W. Caldwell, PE
1;r6ject Manager
cc: Mary Lee Ransmeier, Kapstone Kraft Paper Corporation
w,•rvi.ecoengr.com Design Services Focused On Client Success

Mr. Brian Lowther
NCDENR
Division of Water Quality, Wetlands and Stormwater Branch
1617 Mail Service Center
Raleigh, NC 27677-1617
(hand -delivered)
July 30, 2010
Subject: Permit No NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, NC Mill
NPDES Stormwater Permit
Dear Mr. Lowther,
The NPDES Stormwater Permit issued to KapStone Kraft Paper Corporation, July
24, 2009, NCS 000106; Section E, requires development and implementation of a BMP
Management Plan to be included in the facilities SPPP. In compliance with that
requirement, KapStone retained EcoEngineering and submitted plans (KKP-10000,
February 2010) on February 25, 2010 which were approved by DWQ on March 23, 2010.
This cover letter accompanies submittal of the proposed construction plans and narrative
description KPP-10000, July 2010. KapStone proposes to have the control measures on
the plans complete and operable by January 31, 2011 as required by the permit pending
timely approval by your office.
We are pleased to report that, after two storm events, there have been no
exceedances of the pending benchmarks since the agreed upon sample location was
moved to a more representative position.
Please contact me if you have any questions at 252-533-6255.
Sincerely,
Ma f L Ransmeier
Environmental Programs Manager
Copy: Ken Pickle, DWQ
Neal Davis, KapStone
Anitra Collins, KapStone
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road. Roanoke Rapids. NC 27870

Enclosures Lowther only: KapStone Kraft Paper, Roanoke Rapids, North Carolina. North
Carolina Division of Water Quality BMP management Plan, KKP-10000, July 2010,
James Caldwell, PE, Project Engineer; D. Amos Clark, PE Division Director
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road, Roanoke Rapids, NC 27870

Mr. Brian Lowther
NCDENR
Division of Water Quality, Wetlands and Stormwater Branch
1617 Mail Service Center
Raleigh, NC 27677-1617
(hand -delivered)
July 30, 2010
Subject: Permit No NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, NC Mill
NPDES Stormwater Permit
Dear Mr. Lowther,
The NPDES Stormwater Pen -nit issued to KapStone Kraft Paper Corporation, July
24, 2009, NCS 000106; Section E, requires development and implementation of a BMP
Management Plan to be included in the facilities SPPP. In compliance with that
requirement, KapStone retained EcoEngineering and submitted plans (KKP-10000,
February 2010) on February 25, 2010 which were approved by DWQ on March 23, 2010.
This cover letter accompanies submittal of the proposed construction plans and narrative
description KPP-10000, July 2010. KapStone proposes to have the control measures on
the plans complete and operable by January 31, 2011 as required by the permit pending
timely approval by your office.
We are pleased to report that, after two storm events, there have been no
exceedances of the pending benchmarks since the agreed upon sample location was
moved to a more representative position.
Please contact me if you have any questions at 252-533-6255.
Sincerely,
��IL
)�L Ransmeier
Environmental Programs Manager
Copy: Ken Pickle, DWQ
Neal Davis, KapStone
Anitra Collins, KapStone
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road, Roanoke Rapids. NC 27870

Enclosures Lowther only: KapStone Kraft Paper, Roanoke Rapids, North Carolina, North
Carolina Division of Water Quality BMP management Plan, KKP-10000, July 2010,
James Caldwell, PE, Project Engineer, D. Amos Clark, PE Division Director
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road, Roanoke Rapids. NC 27870 2

cc:
North Carolina
Beverly Eaves Perdue
Governor
Mr. Mary Lee Ransmeier
KapStone Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Dear Ms. Ransmeier:
FA41es'
PERM
Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
March 23, 2010
Subject: Final NPDES Stormwater Permit
Permit NCS000106
KapStone Kraft Paper Corporation
Halifax County
Dee Freeman
Secretary
In response to your submitted BMP Management Plan required in your NPDES stormwater permit NCS000106,
the Division of Water Quality (Division) is sending this approval letter. The plan required evaluating and
selecting BMP options based on the assessment of the potential for sources to contribute significant quantities of
pollutants to stormwater discharges, and based on data collected through historical monitoring of stormwater
discharges. The submitted plans meet these requirements.
The plan states the goal of the report is to recommend effective measures that will provide a direct benefit to
reducing the pollutants loads in the mill's runoff from the Tent Sub -basin. The selected BMPs should not only be
implemented in the Tent Sub -Basin but all the drainage areas with stormwater outfalls on site. However, the site
can still take their qualitative monitoring samples at the Tent Sub -basin outfall as a representative sample.
Please take notice, upon receipt of this approval you shall develop construction plans for the selected and
approved BMPs. Construction plans, including a narrative description, a construction schedule, and supporting
design calculations, must be submitted for each BMP not later than July 31, 2010.
Please remember the benchmarks will be activated in two years after the permit was issued and the approval
and implementation of the BMP Management Plan does not eliminate the need for the stormwater samples to be
below the benchmarks. If the samples are above the benchmarks then the tier system will come into effect which
could include additional measures to the selected BMPs in the BMP Management Plan.
If you have any questions or comments concerning this permit, contact Brian Lowther at [phone] or
[e-mail].
Raleigh Regional Office, Water Quality Section
Stormwater Permitting Unit
Central Files
Wetlands and Stonnwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St, Raleigh, North Carolina 27604
Phone: 919-80T63001 FAX: [phone] Customer Service: 1-877-623-6748
Internet: www,ncwaterquality.org
An Eaual OoaonuniN \ Allirmalive ACtion Emdover
Sincerely,
Brian C. Lowther
NorthCarolina
Naturally

KAPSTONE
KRAFT PAPER CORPOHAI ION
A Dnis of KAPSTONE PAPER AND PACKAGING CORPORATION
io� Gesun Rcao Pon�o-,�e Rapes. NC ?]b Tu
May 27, 2009
Via FedEx and Electronic Mail
Mr. Brian Lowther
Stormwater Permitting Unit
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27604
Re: Draft NPDES Stormwater Permit, Permit No. NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, Halifax County
Dear Mr. Lowther:
I am writing on behalf of KapStone Kraft Paper Corporation ("KapStone") to provide
comments regarding the above -referenced draft stormwater permit (the "Draft Permit"). t
KapStone's primary objection to the Draft Permit is that it believes that the benchmark numerical
values and tiered best management practice requirements contained in the draft permit are
unreasonable, are arbitrary and capricious, and impose substantial burdens on KapStone without
commensurate, or even discernable, environmental benefit.
The Draft Permit regulates discharges from two stormwater outfalls at the KapStone
Roanoke Rapids facility (the "Facility"). The first of these outfalls (the "Tent SDO") discharges
stormwater from a drainage area of approximately 12.7 acres to a ditch, which in turn discharges to
the Roanoke River. Stormwater from approximately 758 acres within City of Roanoke Rapids (the
"City") outside of the Facility also discharges to the ditch in question. Despite being responsible
for the vast majority of the stormwater discharging to the ditch, the City is not required to
implement any stormwater controls, including monitoring and reporting. Moreover, the volume of
stormwater discharged from the Tent SDO is low in comparison not only to the volume discharged
from the City property, but also to the flow of the Roanoke River, which is a minimum of 1,000
cubic feet per second. Based on the flow of the receiving body of water and the lack of stormwater
controls and monitoring imposed on the vast majority of the drainage area, imposing tiered
response requirements for benchmark exceedances on KapStone will result in little or no
environmental benefit and is arbitrary and capricious. KapStone therefore requests that these
requirements should be deleted from the permit.
I In a letter dated April 28, 2009, the North Carolina Department of Environment and Natural Resources ("DENR"),
Division of Water Quality ("DWQ") extended the comment period until May 27, 2009.

The second regulated outfall (the "Storeroom SDO") discharges stormwater from a drainage
area of approximately 0.97 acres within the Facility directly to the Roanoke River. Discharges
from this outfall during rain events constitute an infinitesimal contribution to flow and pollutant
loading to the Roanoke River. The administrative and financial burdens that the permit would
impose in connection with this outfall are therefore not justified and should be removed.
Alternatively, Kapstone should be allowed to rely on monitoring of the Tent SDO only to
determine the entire Facility's compliance with the benchmark values.
Our understanding is that the benchmark numerical values are not based on water quality
criteria �as is evidenced by the fact that the same values apply regardless of the size of the receiving
stream). The benchmark values, then, are functioning like technology -based effluent limitations in
that, regardless of water quality impacts, pertnittees ultimately may be required to install structural
stormwater controls if they consistently exceed the benchmark values. This leads us to ask
whether and how the Division of Water Quality ("DWQ") has made the policy determination to
impose these requirements across the board on individual stormwater permittees, regardless of
water quality benefits and regardless of the costs imposed on permittees- If DWQ or the
Environmental Management Commission has not engaged in formal rulemaking to adopt this
policy, it seems likely to us that it may be required to do so pursuant to the Administrative
Procedures Act. See N.C.G.S. § 15013-18 et seq.
Enclosed herewith is a copy of the mill site plan, as requested. KapStone looks forward to
working with DWQ to ensure that these comments have been appropriately addressed in the final
stormwater permit. —_
..r/f ten//Fs�•�Jc ftia/ a
�
Sincerely yours � (J 8//u / 16
e
DLeRansmeier 7t 'P^^"
Environmental Programs Manager defer s66-Js ^o
Pro6 /rm� t/hEn wE u-"/!
/�//rPFd 6IP �/ /-P DIPSL'n7d"Fi✓e
Cc: Mr. Bradley Bennet, DWQ oc+%fa// sk14S,
Mr. Steve Levitas, Esq
AnitraJ. Collins, VP Operations Manager /. oK er /e"o, aka// sfa/US a,,17Pn ;n� ; 4
Neal Davis, 2. 0,0 na✓/n9
3, fia 11J Z? 1 u �
• 21y, Sy.?cm�//✓i�9p �fJ {�0 UT/D_d/.//
aY✓ ,� t'o-
gJ�laJd/ a: e✓r.7fPn inBPi^',"_'r��-.rf��z�
2
If that is not the case, it would be difficult to explain applying the same values to receiving water bodies with vastly
different flows. / armrey e �� 70

KAPSTONE
KRAFT PAPER CORPORATION
A Division of KAPSTONE PAPER AND PACKAGING CORPORATION
100 Gaston Road Roanoke Rapids, NC 27870
kapstonepapeccom
May 27, 2009
Via FedEx and Electronic Mail
Mr. Brian Lowther
Stormwater Permitting Unit
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27604
Re: Draft NPDES Stormwater Permit, Permit No. NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, Halifax County
Dear Mr. Lowther:
600z S 9 AVw
I am writing on behalf of KapStone Kraft Paper Corporation ("KapStone") to provide
comments regarding the above -referenced draft stormwater permit (the "Draft Permit").'
KapStone's primary objection to the Draft Permit is that it believes that the benchmark numerical
values and tiered best management practice requirements contained in the draft permit are
unreasonable, are arbitrary and capricious, and impose substantial burdens on KapStone without
commensurate, or even discernable, environmental benefit.
The Draft Permit regulates discharges from two stormwater outfalls at the KapStone
Roanoke Rapids facility (the "Facility"). The first of these outfalls (the "Tent SDO") discharges
stornwater from a drainage area of approximately 12.7 acres to a ditch, which in turn discharges to
the Roanoke River. Stormwater from approximately 758 acres within City of Roanoke Rapids (the
"City") outside of the Facility also discharges to the ditch in question. Despite being responsible
for the vast majority of the stormwater discharging to the ditch, the City is not required to
implement any stormwater controls, including monitoring and reporting. Moreover, the volume of
stormwater discharged from the Tent SDO is low in comparison not only to the volume discharged
from the City property, but also to the flow of the Roanoke River, which is a minimum of 1,000
cubic feet per second. Based on the flow of the receiving body of water and the lack of stormwater
controls and monitoring imposed on the vast majority of the drainage area, imposing tiered
response requirements for benchmark exceedances on KapStone will result in little or no
environmental benefit and is arbitrary and capricious. KapStone therefore requests that these
requirements should be deleted from the permit.
' In a letter dated April 28, 2009, the North Carolina Department of Environment and Natural Resources ("DENR"),
Division of Water Quality ("DWQ") extended the comment period until May 27, 2009.

r_ .. .ri. .�.'� � ,
...
>:
-

The second regulated outfall (the "Storeroom SDO") discharges stormwater from a drainage
area of approximately 0.97 acres within the Facility directly to the Roanoke River. Discharges
from this outfall during rain events constitute an infinitesimal contribution to flow and pollutant
loading to the Roanoke River. The administrative and financial burdens that the permit would
impose in connection with this outfall are therefore not justified and should be removed.
Alternatively, Kapstone should be allowed to rely on monitoring of the Tent SDO only to
determine the entire Facility's compliance with the benchmark values.
Our understanding is that the benchmark numerical values are not based on water quality
criteria �as is evidenced by the fact that the same values apply regardless of the size of the receiving
stream). The benchmark values, then, are functioning hike technology -based effluent limitations in
that, regardless of water quality impacts, permittees ultimately may be required to install structural
stormwater controls if they consistently exceed the benchmark values. This leads us to ask
whether and how the Division of Water Quality ("DWQ") has made the policy detemvnation to
impose these requirements across the board on individual stormwater permittees, regardless of
water quality benefits and regardless of the costs imposed on permittees. If DWQ or the
Environmental Management Commission has not engaged in formal rulemaking to adopt this
policy, it seems likely to us that it may be required to do so pursuant to the Administrative
Procedures Act. See N.C.G.S. § 150B-18 et seq.
Enclosed herewith is a copy of the mill site plan, as requested. KapStone looks forward to
working with DWQ to ensure that these comments have been appropriately addressed in the final
stormwater permit.
Sincerel/Ransmeier
ours
tL
Environmental Programs Manager
Cc: Mr. Bradley Bennet, DWQ
Mr. Steve Levitas, Esq
Anitra J. Collins, VP Operations Manager
Neal Davis, DWQ
Z If that is not the case, it would be difficult to explain applying the same values to receiving water bodies with vastly
different flows.

_ 1
�r
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
cc:
Mary Lee Ransmeier
KapStone Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Dear Ms. Ransmeier:
Division of Water Quality
Coleen H. Sullins
Director
April 29, 2009
Subject: Response to Comments
Permit No. NCS000106
KapStone Kraft Paper Corporation
Halifax County
Dee Freeman
Secretary
I received your comments on the Draft Permit NCS000106 on April 21, 2009. Your comments show concerns
about significant changes in the draft permit. These changes are consistent with general and individual
permit renewals since 2007. All of our permits that include analytical monitoring are moving to at least a
semiannual monitoring schedule and include benchmarks and tiers. We understand that your two
discharges are subject to vehicle traffic and a small flow in comparison to the Roanoke River and city runoff
in the ditch. However, your permit is a federally mandated permit for all stormwater discharges based on
your SIC code.
As far as extending the comment period, we will extend the comment period until May 27, 2009 as talked
about in our phone conversation of Monday, April 27, 2009.
We will review the pictures that were sent to us and we look forward to reviewing the updated site map
that includes drainages areas and/or topography.
If you have any questions or comments concerning this draft permit, contact me at [phone] or
[e-mail]
Raleigh Regional Office
Stormwater Permitting Unit
Wetlands and Stormwater Branch
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet www.nmaterquality.org
An Equal opportunity 1 Affirmative Action Employer
Sincerely,
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
NorthCarolina
Natul'allb,

i; l•
Mr. Brian Lowther
Stormwater Permitting Unit
NCDENR
1617 Mail Service Center
Raleigh, NC 27604
April 21, 2009
Subject: Permit No NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, NC Mill
Draft NPDES Stormwater Permit
Dear Mr. Lowther,
KapStone Kraft Paper is in receipt of a stormwater permit for our location dated March
24, 2009 and received March 25, 2009. There are signifcant changes to the permit from
previous permits which need careful evaluation. Receipt of a permit with so much
additional work (easily double) was much unexpected, and we had not allocated the
manpower or resources for this work. As discussed on the phone, the two discharge
locations on our property are subject only to vehicle traffic and a small flow in
comparison to the Roanoke River and city runoff to the main ditch. KapStone cannot
accept the permit in its current draft which could cause serious hardship to our business
with little or no environmental improvement. We respectfully request an extension of the
review period for an additional 60 days, until June 19, 2009.
After we have developed a more comprehensive list of our concerns, we will contact you
for a possible meeting to discuss this issue.
Please contact me if you need any additional information.
0
Sincerely, a T
1£C '
Mary ee ansmeier� '.
Environmental Programs Manager
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road, Roanoke Rapids, NC 27870

e
Copy: Bradley Bennet, DWQ
Anitra J. Collins, V.P. Mill Manager, KapStone
Neal Davis, KapStone
Tim Davisson, KapStone Legal
KAPSTONE
PAPER AND PACKAGING CORPORATION
100 Gaston Road, Roanoke Rapids, NC 27870
2

NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
DATE: March 25, 2009
TO: Daily Herald
EMAIL: Hera ldclassifiedArrdailyherald.cam
FROM: SARAH YOUNG, DIVISION OF WATER QUALITY
SUBJECT: PUBLIC NOTICE
PAGES: 1
Please publish only the information (Public Notice) below, ONE TIME in the legal section of your paper by
Tuesday, March 31, 2009. Please fax a copy of the proof to me at 919-807-6494 for final approval prior to
publication. Within 10 days after publish date, please send the invoice and two copies of the original affidavit
to:
Sarah Young
NCDENR/DWQ Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699.1617
PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
KapStone Kraft Paper Corporation, 100 Gaston Road, Roanoke Rapids, NC 27870 has applied for an NPDES
Stormwater Permit to discharge stormwater associated with industrial activities at a facility located at KapStone Kraft
Paper Corporation, 100 Gaston Road, Roanoke Rapids, NC, Halifax County. The facility discharges to waters
designated as the Roanoke River, within the Roanoke River Basin.
Copies of the draft permit, No. NCS000106, are available at the following website:
http://h2o.enr.state.nc.us/su/publicnotice.htm
Or by contacting:
Brian Lowther
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Telephone Number: (919)-807-6368
[e-mail]
Persons wishing to comment upon or object to the proposed determination are invited to submit their comments in
writing to the above address no later than April 30, 2009. All comments received prior to that date will be considered
in the final determination regarding permit issuance. All comments and requests should reference draft permit
number NCS000106.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: w .ncwaterquality.org
An Equal opportunity 1 Affirmative Action Employer
NorthiCarolina
Naturally

111-1RIa.rW61_�
STATE OF
NORTH CAROLINA
ENVIRONMENTAL
MANAGEMENT
COMMISSION
1617 MAIL
SERVICE CENTER
RALEIGH,
NORTH CAROLINA
27698.1617
KapStone Kraft Pa-
per Corporation, 100
Gaston Road, Ro-
anOKe Rapids, NC
27870 has applied
for an NPDES
Stormwater Permit
to discharge storm -
water associated
with industrial activi-
des at a fatuity lo-
cated at KapStone
Kraft Paper Corpora-
flon. 100 Gaston
Road. Roanoke
Rapids, NC, Halifax
County. The facility
diachargee to waters
designated as the
Roanoke River,
within the Roanoke
River Basin.
Copies of the draft
Permit, No.
P CS000106, are
available at the fol-
lowing website:
h2o.enr.state.nc.us/s
u/publionotice.htm
Or by contacting:
Brian Lowther
NC Division of water
Quality
1617 Mail Service
Center
Raleigh, NC
2760-1617
Telephone Number;
(919)-807-6368
brian.lowther®home
u.net
Persons wishing to
cnmment upon Of
object to the pro-
posed determination
are invited to submit
their comments In
writing to the above
address no later
than April 3o, 2ooe.
All comments re-
ceived prior to that'
date will be consid-
ered In the final De-
termination regard-
ing permit Issuance.
All ,nmmems and
requests should ref-
erence draft permit
number
NCS000106.
March 31; 2009,
e
Z0/Z0 39Vd G-WN31­1 A_1IVG TTbSLESZSZ bT:TT 600Z/SZ/E0

NCS000106
Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
North Carolina Department of Environment and Natural Resources
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Coleen H. Sullins Director
Division of Water Quality
Facility Name:
Kapstone Kraft Paper Corporation.
NPDES Permit Number:
NCS000106
Facility Location:
100 Gaston Road, Roanoke Rapids, NC (Halifax County)
Type of Activity:
Paper Mill
SIC Code:
2621
Receiving Streams:
See Figure 1
River Basin:
Roanoke River Basin, Sub -basin 03-02-08
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Response Requested by (Date):
03/i t/o9
Central Office Staff Contact:
Return to: Brian Lowther, [phone]
Special Issues:
w Is'suej r
Ratin`;Scat J eas _i 110 hard F
Compliance history
6
Benchmark exceedance
7
Location,(TMDL, T&E
species, etc)
7
Other Challenges:
• Outfall Status of
Lowground
3 .
Difficulty Rating:
23,
Special Issues Explanation:
• One storm water monitoring location at the Low -Ground requires amendment. The Lowgound SW
sampling point is currently in permit held by Kapstone Paper. In the renewal application they requested
removal of the Lowground point because Kapstone no longer is the owner, but IP is. An email from Myrl
Nisely of the RRO that based on his knowledge of the site and from occasional observations in the last
couple of years, as well as conversations with the Environmental Staff at the paper mill he recommends that
the closed Lowground Landfill not require a permit. There is no industrial activity at this location, 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 water from 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 comer, from which point it would go though 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. (See email in
Pagel of 8

NCS000106
file)
Description of Onsite Activities:
• The mill is an integrated pulp and paper mill producing unbleached Kraft paper for packaging.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File
• Central Files
• EPA General Sector -Specific Permit, 2008, Sector B — Paper and Allied Products.
• 2006 303(d) List
• 2006 Roanoke Basinwide Plan
History:
• December 19, 1994: Date permit first issued. Analytical monitoring included TSS, COD, Total
Phosphorous and Total Lead. Sampling was to be done annually.
• June 15, 1999: Reminder Letter to renew permit was sent.
• March 7, 2003: Permit re -issued. Analytical monitoring included COD, TSS, Total Phosphorous and Total
Lead. Sampling was to be done in years 1, 2, 3 and 4. The permittee asked to not do quarterly sampling.
• November 21, 2006: Request for Name Change sent back because they did not include sufficient legal
documents.
• February 23, 2007: Transfer of coverage from International Paper to KapStone Kraft Paper Corporation.
• September 12, 2007: Reminder Letter to renew permit was sent.
• October 15, 2007: Date permittee submitted renewal application.
• September 25,72008: Email correspondence Ken Pickle and Mryl Nisley referring to how to handle a
landfill the International Paper owns that is covered in the expired permit for KapStone.
• December 10, 2008: Compliance Inspection done by Autumn Hoban. The inspection report notes that one
of the three sotrmwater outfalls should be removed from the permit. The stormwater runoff at this location
comes from the closed and capped ash.landfill area owned by International Paper and is not part of Kapstone
Paper. .
Page 2 of 8

NCS000106
NCS000106
Map Scale L24,000
Figure 1: Map of Facility
KapStone Kraft Paper Corporation
Latitude: 360 28' 19" N
Longitude: 770 38' 14" W
County: Halifax
Receving Stream: Roanoke River
Stream Gass: C
Sub -basin: 03-02-08 (Roanoke River Basin)
I
Facility Location
Page 3 of 8

NCS000106
Central Office Review Summary:
Owner's Other Permits:
• NC0000752 — KapStone Kraft Paper Corp. The process waste water outfall has limits for BOD,
Conductivity, Copper, Dissolved Oxygen, Flow, Total Nitrogen, Ammonia, Ceriodaphnia,
Pentachlorophenol, pH, Total Phosphorus, TSS, Temperature, and Trichlorophenol.
• AFS 3708300007 - KapStone Kraft Paper Corporation
2. Gen eralObservations:
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, North Carolina and Ride Rite® Converting,
an inflatable dunnage bag manufacturer located in Fordyce, Arkansas with aggregate 2005 revenues of
approximately $223 million. The transaction was approved by the shareholders of Kapstone Paper on December
29, 2006 and was consummated on January 2, 2007.
Kraft Paper: 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.
3. Impairment: The Roanoke River, 23-(26)a and 23-(26)b, are both on the 303(d) for a Fish Advisory for
Mercury. Basinwide Plan shows that Roanoke River 23-(26)a has TSS and habitat degradation as stressors. The
Basinwide Plan noted that severe bank erosion is occurring on the Roanoke River. River flows are managed for
flood control by the US Army Corp of Engineers and for hydropower generation by private industries. These
managed flows are not similar to natural seasonal flow conditions and subsequently extend the length of time
flooding occurs on the floodplain and in backswamps. In addition, frequent managed high flows at bankfull
heights further accelerate river bank erosion.
4. Threatened and Endangered: There. were no Federally threatened or endangered species within two miles of the
facility based on the Natural Heritage Virtual Workroom. There are some State protected species (see file for
details).
5. Location: Located on the Roanoke River.
6. Industrial Changes Since Previous Permit: In September of 2007 a round wood (log) lay down area was added
north of the Landfill site where runoff drains directly to the treatment plant basin. In 2005 a lay down area for
round wood logs was added on the East side of the mill near the back side of the Emergency pond. All run off
from that area goes into the emergency pond and is pumped to the head of the mill's wastewater plant.
In 2002, a car rinse area was taken out of service and removed from the wastewater permit NC0000752.
7. Aalvtical Monitoring Notes: The analytical monitor was done annually at 3 outfalls. There were exceedances
of the benchmarks for TSS, COD, Phosphorus and Lead. The permittee also included conductivity, pH, and oil
& grease for 3 storm events even though this was no required in their permit.
The EPA General Sector -Specific Permit, 2008, Sector B - Paper and Allied Products does not have any
recommended monitoring for SIC 2621.
8. Qualitative Monitoring Notes: 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 other signs of pollution at the
outfalls.
Page 4 of 8

NCS000106
Table 1: Analytical Monitoring
Required
Sampling
Range
Sample
Date
Total
Flow
(MGD)
Precipitation
(in)
Duration
(hours)
COD
TSS
Phosphorous
Lead
Conductivity
H
I Oil&Grease
Benchmark:
120 mg/L
Benchmark:
100 mg/L
Benchmark:
2 mglL
Benchmark:
.03 mglL
Benchmark:
X mg/L
Benchmark:
6-9 su
Benchmark:
30 mg/L
O utfa 11 1 - Te nt
03/01/03 to
02/29/04
11/19/2003
1.24
1.87
4 2
1.28
40
3t4
0.15
!19'1
03/01/04 to
02/28/05
12/6/2004
0.2
3.55
51
0.006
573
6.48
<5
03/01/05 to
02/28/06
11/21/2005
1.9
13
51
CIL2
0.96
0.026
69
7.75
<5
3/1/2006 to
02/28/07
11/1/2006
0.6
3.48
120'
rs�
0.73
0:035
248
7.05
12
Outfall 2 - N. Storeroom
03/01/03 to
02/2 9/04
11/19/2003
1.24
1.87
57
11 622
0.44
Ox1,13
03/01/04 to
02/28/05
12/6/2004'
_
0.2
3.55
408
40
1.09
01 71
322
6.94
7
03/01/05 to
02/28/06
11/21/2005
1.9
13
74
489
5422
0p054
69
7.45
<5
3/1/2006 to
02/28/07
11/1/2006
0.6
3.48
33
W53?
0.28
0.03
114
7.6
<5
Outfa113
- Lowground
03/01/03 to
02/29/04
11/19/2003
1.24
1.87
98
03
0.79
0.011
03/01/04 to
02/28/05
12/6/2004
0.2
3.55
<5
20
0.39
<.003
156
6.87
<5
03/01/05 to
O2/28/06
11/21/2005
1.9
13
51
19
0.078
<.03
96
7.2
<6
3/1/2006 to
02/28/07
11/1/2006
0.6
3.48
75
178
0.03
0.021
93
7.38
<5
Over Current Benchmark
Data Not Collected
Page 5 of 8

04011I1][1111
Revised Permit Recommendations: Analytical Monitoring:
1. Maintain monitoring for COD, TSS, Phosphorus and Lead.
2. pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part lI
Section B. The permittee.must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
stone events as defined in Part II Section B. Qualitative monitoring is required regardless of representative
outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The, 'total rainfall parameter is in
this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part Il Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and
activities are not exposed to precipitation or runoff as described in 40 CFR § 122.26(g), the facility may qualify
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
is provided in Part I Section A.
Page 6 of 8

NICS000106
Discussions with permittee: Neal Davis 252-533-6295, 02/19/09
1. General description of industrial activities. Kraft Paper Mill. The kraft paper is used for grocery bags, concrete
bags, and lining for boxes. Bring in logs and wood chips.
2. Have there been any changes since filing the application? No
3. There are high values for COD, TSS, P, and Lead. Any reason why? No sure. For TSS the water is move
quickly at the sampling point during a rain event.
4. The visual monitoring shows colors that include brown, tan, gray and orange. What do you think this is from?
Because of the high turbidity. The water is always tan or red clay color.
5. What do you have stored outside that drains to the stormwater outfalls? No
6. Do you have vehicle maintenance onsite? Yes
Page 7 of 8

NCS000106
Recommendations: Based on the documents reviewed, the application information submitted on October 15, 2007
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) �• /�%� ✓Q Date Z Z a
Stormwater Permitting Unit Supervisor Date 2l2 + o
for Bradley Bennett
Concurrence by Regional Office
RO Water Quality
Regional Office Staff Comments (attach additional pages as necessary)
Page 8 of 8

l
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 24, 2009
Mr. Neal Davis
KapStone Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000106
KapStone Kraft Paper Corporation
Halifax County
Dear Mr. Davis:
Dee Freeman
Secretary
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft
very carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from this facility's current permit:
Analytical monitoring changes:
1. Analytical monitoring parameters, COD, TSS, Phosphorus and Lead, have been maintained in this permit.
_ _ 2`pH.has been added to the analytical monitoring requirements.
3. The outfall from the Lowground Landfill will no longer be covered by this permit.
4. All analytical monitoring has been set to semi-annually during a representative storm event as defined in
Part lI SectionB., The permittee must also document the total precipitation for each event. If no discharge
occurs during the sampling period, the permittee must submit a monitoring report indicating "No Flow"
--within 30 days of the end of the six-month sampling period. Additionally, samples must be taken a
minimum of 60 days apart, as specified in Table 2.
5. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark
values require the permittee to increase monitoring, increase management actions, increase record
keeping, and/or install stormwater Best Management Practices (BMPs) in a tiered program. If the
sampling results are above a benchmark value, or outside of the benchmark range, for any parameter at
any outfall then the facility shall follow the Tier 1 guidelines which require a facility inspection within
two weeks and implementation of a mitigation plan within two months. If during the term of this permit,
the sampling results are above the benchmark values, or outside of the benchmark range, for any specific
parameter at a specific discharge outfall two times in a row (consecutive), then the facility shall follow the
Tier 2 guidelines which require a repetition of the steps listed for Tier 1 and also immediately institute
monthly monitoring for all parameters at every outfall where a sampling result exceeded the benchmark
value for two consecutive samples.
6. You are required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II Section B. Qualitative monitoring is required regardless of
representative outfall status.
7. You are responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
Wetlands and Slormwaler Branch - 1�rQlte NoahCarolina
1 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 i v QPtlll. ai�1111�i
Location: 9-8 N. Salisbury St. Raleigh, North Carolina r SeNi - Natural
Phone: [phone] FAX: 919$07-64941 Customer Service: 1-877-623-6748 Natural
(4
Internet: vnmv.nmaterquality.org
An Equal Opportunity \ Affirmative Action Employer

Mr. Neal Davis
KapStone Kraft Paper Corporation
Permit No. NCS000106
8. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall
parameter is in this permit, however.)
9. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical
and qualitative monitoring. This requirement appears in all Individual Stormwater permits, however it
only applies to facilities that do vehicle maintenance. If the facility begins vehicle maintenance during the
permitted timeframe then the requirements shall apply.
Other permit changes:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants
in each outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of
significant spills that have occurred in the past three years and also must certify that the outfalls have
been inspected to ensure that they do not contain non-stormwater discharges. , Additional information is
provided in Part II Section A:
2. Additional requirements for the Stormwater Management Plan have been specified in Part lI Section A.
More details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II
Section A. The plan must also be updated annually to include a list of significant spills and to certify that
the outfalls do not contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial
materials and activities are not exposed to precipitation or runoff as described in 40 CFR §122.26(g), the
facility may qualify for a No Exposure Exclusion from NPDES stormwater discharge permit
requirements. Additional information is provided in Part I Section A.
Please submit any comments to me no later than thirty (30) days following your receipt of the draft.
Comments should be sent -to the address listed at the bottom of this page. If no adverse comments are
received from the public or from you, this permit will likely be issued in about two months.
If you have any questions or comments concerning this draft permit, contact me at [phone] or
[e-mail]
Sincerely, l
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
cc: Raleigh Regional Office
Stormwater Permitting Unit
Attachments: Draft Permit

NCS000106
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
� '�`. 17
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the.North Carolina Environmental
Management Commission, and the Federal Water,P.ollution'Control Act, as amended,
KapStone Kraft,Papei= Corporation
is hereby authorized todi"scharge stormwater from a facility located at
Kraft Paper Corporation
00 Gaston Road
,anoke Rapids, NC
Halifax County
to receiving waters designated as Roanoke River, a class C stream in the Roanoke River Basin, in
accordance with the discharge limitations, monitoring requirements, and other conditions set
forth in Parts I, H, III, IV, V and VI hereof.
Note: Draft Permit Dates are Approximate
This permit shall become effective [June 1, 20091.
This permit and the authorization to discharge shall expire at midnight on [May 31, 20141.
Signed this day [May 15, 2009].
for Coleen H. Sullins Director
Division of Water Quality
By the Authority of the Environmental Management Commission

1
NOTES:
1. DRAINAGE AREA MAP, MILL LAYOUT, AND UTILITIES
PROVIDED BY KAPSTONE
2, WATER QUALITY MEASURES PRESENTED IN THE
FEBRUARY 2010 BMP MANAGEMENT PLAN ARE SHOWN
ON THIS DRAINAGE AREA EXHIBIT TO DEMONSTRATE
APPROXIMATE LOCATIONS AND GENERAL AREAS FOR THE
PROPOSE MEASURES. FINAL LOCATIONS, INSTALLATIONS,
AND NUMBERS OF INSTALLED MEASURES MAY VARY
FROM WHAT IS SHOWN ON THIS CONCEPTUAL EXHIBIT.
U
CHECK
DAM/FOREBAY
® CATCH BASIN a
INSERT/ INLET
PROTECTION
FILTER BERM/
SILT DIKE
"TENT" SUB -BASIN
DRAINAGE AREA
BOUNDARY
I i
EMPLOYEE PARKING
SEWER KEY
PLUG
0 MANHOLE
❑ CATCH BASIN
• STORM WATER SAMPLING POINT
COLOR KEY
CITY WATER
PROCESS SEWER
STORM SEWER
SANITARY SEWER
NON -CONTACT COOLING WATER
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it 11 POMjt tiUD r'
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STC.�NE PAPER
ROANOKE RAPIDS, NORTH CAROLINA
OWNER:
KAP ST 0 NE KRAFT PAPER
100 GASTON ROAD
ROANOKE RAPIDS, NORTH CAROLINA
REVISIONS:
Ec 0Engineeringw
A division of The John R. McAdams Company, Inc.
C
ENGINEERS ■PLANNERS ■SURVEYORS ■ENVIRONMENTAL
RESEARCH TRIANGLE PARK ■CHARLOTTE
2905 Meridian Partcnay, Durham NC 27713
800-733-5646 r www.jobmmeadams.com ■ Iaeense No.: C-0293
PLAN / DRANAGE AREAS

Permit No. NCS000106
PART
Section A:
Section B:
Section C:
TABLE OF CONTENTS
INTRODUCTION
Individual Permit Coverage
Permitted Activities
Location P
PART It
MONITORIN
DISCHARGE
Section A:
Stormwat¢
Section B:
Analytical
Section C:
Qualitativ,
Section D:
On -Site V
PART III STANDARD
PERMITS
Section A: Compliance and Liability
PERMITTED
-R INDIVIDUAL
1.
Compliance Schedule
2.
Duty to Comply
3.
Duty to Mitigate
4.
Civil and Criminal Liability
5.
Oil and Hazardous Substance Liability
6.
Property Rights
7.
Severability
8.
Duty to Provide Information
9.
Penalties for Tampering
10.
Penalties for Falsification of Reports
Section B: General
Conditions
1.
Individual Permit Expiration
2.
Transfers
i

Permit No. NCS000106
3. Signatory Requirements
4. Individual Permit Modification, Revocation and Reissuance, or
Termination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Faciliti
11
Section D: Monitoring and Records f r
I. Representative Sampling Gu
2. Recording Results \
3. Flow MeasurementJJfs
4. Test Procedures VC,
5. Representative O6tfall
6. Records Retention\
N\'
7. Inspection ancl\Enntry
Section E: Reporting Re"qu� meetncs
d
1. Discharge, omtonng Reports
2. Submitting Reports
3. Availability of Reports
4. Non-Stormwater Discharges
5. Planned Changes
6. Anticipated Noncompliance
7. Bypass
8. Twenty-four Hour Reporting
9. Other Noncompliance
10. Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
11

Permit No. NCS000106
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit.
If industrial materials and activities are not exposed to precipitation or runoff as described in 40
CFR § 122.26(g), the facility may qualify for a No Exposure Exclusion from NPDES stormwater
discharge permit requirements. Any owner or operator wishing to obtain a No Exposure
Certification must submit a No Exposure Certification NOI formto the Division; must receive
approval by the Division; must maintain no exposure conditions unless authorized to discharge
under a valid NPDES stormwater, permit; and must reapply for the No Exposure Exclusion once
t
every five (5) years. ) '\
SECTION B: PERMITTED
Until this permit expires or modified or re"voked,.the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system that has been
adequately treated and managed in -accordance with the terms and conditions of this individual
permit. All stormwater discharges shall be.itraccordance with the conditions of this permit.
)'11`J j
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or approval.
The stormwater discharges allowed by this individual permit shall not cause or contribute to
violations of Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
Part11 Page 1 of 10

SECTION C: LOCATION MAP
Permit No. NCS000106
NCS000106
Map Scale 1,24,000
KapStone Kraft Paper Corporation
Lab wde: 360 28' 19" N
Longitude: 770 38' 14" W
County: Hdifax
Reca+nng Stream: Roanoke River
Stream Class: C
Sub -basin: 03-02-08 (Roanoke River Basin)
b�.yy__ 1�'"+ ,
\�� 01 ���re'_ r�.4 y%
willlln oKt�_`1tr�;:
Facility Location
Part II Page 2 of 10

Permit No. NCS000106
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The Permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part 111, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
Site Plan. The site plan shall provide a description of
potential pollutant sources which may be expected to
stormwater discharges. The site plan shall contain the
(a) A general location map (USGS
equivalent map), showing the fi
routes and surface waters, the n
stormwater outfall(s) discharge
storm sewer system, the name/(
waters, and accurate latitude an
general location�/map,(onaltem,
receiving water is
located in a watei
parameter(s) of ec
North Carolina's
http://h2o.enr.sti
North Carolina V
id for
al facility and the
to contamination of
1 or appropriately drafted
in relation to transportation
ving water(s) to which the
arge is to a municipal separate
ty and the ultimate receiving
longitude of the point(s) of discharge. The
ively the site map) shall identify whether each
the state's 303(d) list of impaired waters) or is
�h a TMDL has been established, and what the
List can be found here:
e."ne.us/tindl/General 303d.htm#Downloads
DL documents can be found here:
http://h2o.enr.state.ne.us/tmdl/TMDL list.htm#Final TMDLs.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices. A narrative description of the potential pollutants which
could be expected to be present in the stormwater discharge from each outfall.
(c) A site map drawn to scale (including a distance legend) showing: the site property
boundary, the stormwater discharge outfalls, all on -site and adjacent surface
waters and wetlands, industrial activity areas (including storage of materials,
disposal areas, process areas, loading and unloading areas, and haul roads), site
topography, all drainage features and structures, drainage areas for each outfall,
direction of flow in each drainage area, industrial activities occurring in each
drainage area, buildings, existing BMPs, and impervious surfaces. The site map
must indicate the percentage of each drainage area that is impervious.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the three (3) previous years and any corrective actions taken to mitigate
spill impacts.
Part 11 Page 3 of 10

Permit No. NCS000106
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part I1I, Standard Conditions, Section
B, Paragraph 5. The permittee shall re -certify annually that the stormwater
outfalls have been evaluated for the presence of non-stormwater discharges.
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
(a) Feasibility Study. A review of the technical and'economic feasibility of changing
the methods of operations and/or storage practices to -eliminate or reduce exposure
of materials and processes to stormwater Wherever practical, the permittee shall
prevent exposure of all storage areas, m'aterial.handlingoperations, and
manufacturing or fueling operation<—Ih areas/where elimination of exposure is
not practical, the stormwater management•plan shall document the feasibility of
it
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment<Requir m(edts and Records. Secondary containment is
required for: buhstorage of liquid materials; storage in any amount of Section
313 of Title III of the Superfund Amendments and Reauthorization Act (SARA)
water priority chemicals; and storage in any amount of hazardous substances, in
order to prevent leaks and spills from contaminating stormwater runoff. A table
or summary of all.suchtanks and stored materials and their associated secondary
containment areas shall be maintained. If the secondary containment devices are
connected directly to stormwater conveyance systems, the connection shall be
controlled by manually activated valves or other similar devices (which shall be
secured closed with a locking mechanism), and any stormwater that accumulates
in the containment area shall be at a minimum visually observed for color, foam,
outfall staining, visible sheens and dry weather flow, prior to release of the
accumulated stormwater. Accumulated stormwater shall be released if found to
be uncontaminated by the material stored within the containment area. Records
documenting the individual making the observation, the description of the
accumulated stormwater, and the date and time of the release shall be kept for a
period of five years.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMP) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
selected site BMPs. The BMP Summary shall be reviewed and updated annually.
Part I I Page 4 of 10

Permit No. NCS000106
Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or the team) responsible for implementing the
SPRP shall be identified in a written list incorporated into the SPRP and signed and dated
by each individual acknowledging their responsibilities for the plan. A responsible
person shall be on -site at all times during facility operations that have the potential to
contaminate stormwater runoff through spills or exposure of materials associated with the
facility operations. The SPRP must be site stormwater specific. Therefore, an oil Spill
Prevention Control and Countermeasure plan (SPCC) may be a component of the SPRP,
but may not be sufficient to completely address the stormwater aspects of the SPRP. The
common elements of the SPCC with the SPRP may be incorporated by reference into the
SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A,preventative
maintenance and good housekeeping programfshall;be developed. The program shall list
all stormwater control systems, stormwater discharge outfalls, all on -site and adjacent
surface waters and wetlands, industrial activity areas -(including material storage areas,
material handling areas, disposal areas, pr cess.a`reas„loading and unloading areas, and
haul roads), all drainage features and structures, and'existing structural BMPs. The
program shall establish schedules of inspection's; inaintenance, and housekeeping
activities of stormwater control systems,, as well as facility equipment, facility areas, and
facility systems that present,a potential for-stormwater exposure or stormwater pollution.
Inspection of material handling.areas and regular cleaning schedules of these areas shall
be incorporated into the program. ,Timely compliance with the established schedules for
inspections, maintenanc , and housekeeping shall be recorded in writing and maintained
in the SPPP.
5. Employee Training. Training/programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill response
and cleanup, preventative maintenance activities, and for any of the facility's operations
that have the potential to contaminate stormwater runoff. Facility personnel (or team)
responsible for implementing the training shall be identified, and their annual training
shall be documented by the signature of each employee trained.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the discharge of pollutants to surface waters. All aspects of the Stormwater
Pollution Prevention Plan shall be reviewed and updated on an annual basis. The annual
update shall include an updated list of significant spills or leaks of pollutants for the
previous three years, or the notation that no spills have occurred. The annual update shall
include re -certification that the stormwater outfalls have been evaluated for the presence
of non-stormwater discharges. Each annual update shall include a re-evaluation of the
Part II Page 5 of 10

Permit No. NCS000106
effectiveness of the BMPs listed in the BMP Summary of the Stormwater Management
Plan.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 5) to the Director that the changes
have been made.
8. Facility Inspections. Inspections of the facility and all stormwater systems shall occur as
part of the Preventative Maintenance and Good Housekeeping Program at a minimum on
a semi-annual schedule, once during the first half of the.y`ear (January to June), and once
during the second half (July to December), with at least`60 days separating inspection
dates (unless performed more frequently than semi=armually)�These facility inspections
are different from, and in addition to, the sto mwater discharge characteristic monitoring
required in Part 11 B and C of this permit.
9. Implementation. The permittee shall implement the -Plan. Implementation of the Plan
shall include documentation of all monitoring, measurements, inspections, maintenance
activities, and training provided to employees., including the log of the sampling data and
of actions taken to implement BMPs associated with the industrial activities, including
vehicle maintenance activities\Such\documentation shall be kept on -site for a period of
five years and made available.to the Director or the Director's authorized representative
immediately upon request. �lv>
Part 11 Page 6 of 10

Permit No. NCS000106
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1. All
analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of ten analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO).
A representative storm event is a storm event that measures greater than 0.1 inches of rainfall
and that is preceded by at least 72 hours in which no storm event measuring greater than 0.1
inches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation. For example, if it rains for 2 hours without producing any collectable discharge,
and then stops, a sample may be collected if a rain producing a discharge begins again within the
next 10 hours. A �%
Table 1. Analytical Monitorin
Discharge
Characteristics
Units
Measurement
Fre uenc 1
Sample
Type2
Sample
Location3
Total Suspended Solids
mg/L %f
1semt-annual
Grab
SDO
Chemical Oxygen Demand (COD)
m�/L�� ,
/ semi-annual
Grab
SDO
Total Phosphorus (TP) <\\
\ mgX_
semi-annual
Grab
SDO
Lead, total recoverable
mg%L
semi-annual
Grab
SDO
H
),,standard
semi-annual
Grab
SDO
Total Rainfall° 1 J
l inches
I semi-annual
ain Gauge
Footnotes:
I Measurement Frequency: Twice per year during a representative storm event, for each year until either another
permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle
*the permittee has submitted the appropriate paperwork for a renewal permit before the submittal deadline, the
permittee will be considered for a renewal application. The applicant must continue semi-annual monitoring until
the renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting
cycle.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative
outfall status has been granted.
4 For each sampled representative storm event the total precipitation must be recorded. An on -site rain gauge or
local rain gauge reading must be recorded.
Part 11 Page 7 of 10

Permit No. NCS000106
The permittee shall complete the minimum ten analytical samplings in accordance with the
schedule specified below in Table 2. A minimum of 60 days must separate Period l and
Period 2 sample dates unless monthly monitoring has been instituted under a Tier Two
response.
Table 2. Monitoring Schedule
Monitoring periodt'z
Sample Number
Start
End
Year 1 — Period 1
1
June 1, 2009
November 30, 2009
Year 1— Period 2
2
December 1, 2009
May 31, 2010
Year 2 — Period l
3
June 1, 2010
November 30, 2010
Year 2 — Period 2
4
December 1, 2010
May 31, 2011
Year 3 — Period 1
5
. June 1, 201.1�
November 30, 2011
Year 3 — Period 2
6
Decerriber)l; Ml 1
1 May 31, 2012
Year 4 —Period 1
7
June,l; 2012,
November 30, 2012
Year 4 — Period 2
8
December, 1, 2012
May 31, 2013
Year 5 — Period 1
9
June`l, 2013
November 30, 2013
Year 5 — Period 2
10
December i, 2013
May 31, 2014
Footnotes: 4, / )/--'
I Maintain semi-annual monitoring during permit renewal process. The applicant must continue semi-annual
monitoring until the renewed perntiNis issued\f
2 If no discharge occurs during the sampling period, `he permittee must submit a monitoring report indicating "No
Flow" within 30 days of the end of the siz=month sampling period.
I
The permittee shall report the lyticalrresults from the first sample with valid results within the
monitoring period. The perrnanaittee,shaall compare monitoring results to the benchmark values in
able 3. The benchmark val`ues-in Table 3 are not permit limits but should be used as guidelines for
the permittee's Stormwater Pollution Prevention Plan (SPPP). Exceedences of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping,
and/or install stormwater Best Management Practices (BMPs) in a tiered program. See below the
descriptions of Tier One and Tier Two.
Table 3. Benchmark Values for Analytical Monitoring
Discharge Characteristics
Units
Benchmark
Total Suspended Solids
mg/L
100
Chemical Oxygen Demand
mg/L
120
Total Phosphorus (TP)
mg/L
2
Lead, total recoverable
mg/L
0.03
pH
standard
6-9
Part I I Page 8 of 10

Permit No. NCS000106
Tier One
if: The first valid sampling results are above a benchmark value, or outside of the benchmark
for
at anv outtali:
Then: The permittee shall:
1. Conduct a stormwater management inspection of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedence.
3. Identify potential, and select the specific: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters f concern, or to bring
concentrations to within the benchmark range.
4. Implement the selected actions within two months.of the.inspection.
5. Record each instance of a Tier One response in -the Stormwater Pollution Prevention Plan.
Include the date and value of the benclmark exceedence, the inspection date, the personnel
conducting the inspection, the selected acfion's" and;the date the selected actions were
implemented. % T
Tier Two
If: During the term of this peimi�he first valid sampling results are above the benchmark values,
or outside of the benchmark range, for any specific parameter at a specific discharge outfall two
times in a row (consecutive):
Then: The permittee shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for all parameters at every outfall where a
sampling result exceeded the benchmark value for two consecutive samples. Monthly
(analytical and qualitative) monitoring shall continue until three consecutive sample results
are below the benchmark values, or within the benchmark range, for all parameters at that
outfall.
3. If no discharge occurs during the sampling period, the permittee is required to submit a
monthly monitoring report indicating "No Flow."
4. Maintain a record of the Tier Two response in the Stormwater Pollution Prevention Plan.
Part II Page 9 of 10

Permit No. NCS000106
During the term of this permit, if the valid sampling results required for the permit monitoring
periods exceed the benchmark value, or are outside the benchmark range, for any specific
parameter at any specific outfall on more than four occasions, the permittee shall notify the DWQ
Regional Office Supervisor in writing within 30 days of receipt of the fourth analytical results.
DWQ may, but is not limited to:
• require that the permittee increase or decrease the monitoring frequency for the remainder
of the permit;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures; or
• require that the permittee implement site modifications<o qualify for the No Exposure
Exclusion. i� �� �\ '11
This site discharges to impaired waters e
Advisory. If a Total Maximum Daily Load
River, the permittee may be required to m
submit results to the Division of Water.01
results in determining whether
to the maximum extent practic
with Mercury and have a Fish
iL)'is approved for this segment of the Roanoke
for the pollutant(s) of concern in the future and
The`Division will consider the monitoring
are needed to control the pollutant(s) of concern
If additional BMPs are needeed,"to achieve the required level of control, the permittee will be
required to (1) develop a strategy forimplementing appropriate BMPs, and (2) submit a timetable
for incorporation of those BMPsjnto the permitted Stormwater Pollution Prevention Plan.
Part 11 Page 10 of 10

Permit No. NCS000106
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified in Table 4, during the analytical
monitoring event. [If analytical monitoring is not required, the permittee still must conduct scmi-
annual qualitative monitoring.] Qualitative monitoring is for the purpose of evaluating the
effectiveness of the Stormwater Pollution Prevention Plan (SPPP) and assessing new sources of
stormwater pollution.
In the event an atypical condition is noted at a stormwater discharge outfall, the permittee shall
document the suspected cause of the condition and any actions taken in response to the
discovery. This documentation will be maintained with the SP,PP.
Table 4. Qualitative Monitoring Requirements
Discharge Characteristics
Frequencyt
Monitoring
Location2
Color
semi-annual ��
SDO
Odor
It
semi-annual /�
�r �SDO
Clarity
semi-annual%E
f SDO
Floating Solids
semi-annual
SDO
Suspended Solids
l `semi-annual
SDO
Foam
i/ semi -,,annual
SDO
Oil Sheen
semi-annual
SDO
Erosion or deposition at the
----semi-annual
SDO
outfall
Other obvious indicators
semi-annual
SDO
of stormwater pollution
Footnotes:
I Measurement Frequency: Twice per year during a representative storm event, for each year until either another
permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle
the permittee has submitted the appropriate paperwork for a renewal permit before the submittal deadline, the
permittee will be considered for a renewal application. The applicant must continue semi-annual monitoring until
the renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting
cycle.
2 Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall (SDO)
regardless of representative outfall status.
SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on -site which uses more than 55
gallons of new motor oil per month when averaged over the calendar year shall perform
analytical monitoring as specified below in Table 5. This monitoring shall be performed at all
Part II Page 11 of 10

Permit No. NCS000106
stormwater discharge outfalls which discharge stormwater runoff from vehicle maintenance
areas, and in accordance with the schedule presented in Table 2 (Section B). All analytical
monitoring shall be performed during a representative storm event.
Table 5. Analytical Monitoring Requirements for On -Site Vehicle Maintenance
Discharge Characteristics
Units
Measurement
Fre uenc I
Sample
Type2
- Sample
Location3
H
standard
semi-annual
Grab
SDO
Oil and Grease
m I
semi-annual
Grab
SDO
Total Suspended Solids
m I
semi-annual
Grab
SDO
Total Rainfall4
inches
semi-annual
Rain gauge
New Motor Oil Usage
gallons/month
1 "!
semia=annual\
Estimate
Footnotes:
1 Measurement Frequency: Twice per year during a re
permit is issued for this facility or until this permit is
the permittee has submitted the appropriate paperwoi
permittee will be considered for a renewal applicatio
the renewed permit is issued. See Table 2 for schedu
cycle. /`i
2 If the stormwater runoff is contro
pond shall be collected within the
3 Sample Location: Samples shall
stormwater runoff from area(s) v
4 For each sampled repr
gauge reading must be
n event'for each year until either another
tded. If at the end of this permitting cycle
iermit before the submittal deadline, the
must continue semi-annual monitoring until
periods through the end of this permitting
i pond a grab sample of the discharge from the
from the pond.
stormwater discharge outfall (SDO) that discharges
lance activities occur.
the total precipitation must be recorded. An on -site or local rain
Monitoring results shall be compared to the benchmark values in Table 6. The benchmark
values in Table 6 are not permit limits but should be used as guidelines for the permittee's
Stormwater Pollution Prevention Plan (SPPP). Exceedences of benchmark values require the
permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs), as provided in Part II Section B.
Table 6. Benchmark Values for Vehicle Maintenance Analytical Monitoring
Discharge Characteristics
Units _
Benchmark
pH
standard
6-9
Oil and Grease
mg/L
30
Total Suspended Solids
mg/L
100
Part II Page 12 of 10

Permit No. NCS000106
PART 111. STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
2.
Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The Stormwater
Pollution Prevention Plan shall be developed and implemented within 12 months of the effective date of the
initial permit and updated thereafter on an annual basis. Secondary containment, as specified in Part 11,
Section A, Paragraph 2(b) of this permit, shall be accomplished within,12 months of the effective date of
the initial permit issuance..,
New Facilities applying for coverage for the first time avid existing,facilitiespreviously_permitted and
applying for renewal under this permit: The Stormwate�r Pollution Prevention Plan shall be developed and
implementedpriorto the beginning of discharges from the operation of the industrial activity and be
updated thereafter on an annual basis. Secondary containment, as,specified in Part 11, Section A, Paragraph
2(b) of this permit shall be accomplished prior t/o-the,/beeginni o,of discharges from the operation of the
industrial activity.
Duty to Comply ^ I,�✓!//1J{
The permittee must comply with all conditions of this individual permit. Any permit noncompliance
constitutes a violation of the Clean Water Accand is grounds for enforcement action; for permit
termination, revocation and reiss nu nce, o�r`modification; or denial of a permit upon renewal application.
a. The permittee shall comply,with standards or prohibitions established under section 307(a) of the
Clean Water Act for toxicpollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
b. The Clean Water Act provides that any person who violates a permit condition is subject to a civil
penalty not to exceed $25,000 per day for each violation. Any person who negligently violates any
permit condition is subject to criminal penalties of $2,500 to 25,000 per day of violation, or
imprisonment for not more than 1 year, or both. Any person who knowingly violates permit
conditions is subject to criminal penalties of $5,000 to $50,000 Per day of violation, or
.imprisonment for not more than 3 years, or both. Also, any person who violates a permit condition
may be assessed an administrative penalty not to exceed $10,000 per violation with the maximum
amount not to exceed $125,000. [Ref: Section 309 of the Federal Act 33 USC 1319 and 40 CFR
122.41(a).]
C. Under state law, a daily civil penalty of not more than ten thousand dollars ($10,000) per violation
may be assessed against any person who violates or fails to act in accordance with.the terms,
conditions, or requirements of a permit. [Ref: NC General Statutes 143-215.6A].
d. Any person may be assessed an administrative penalty by the Director for violating section 301,
302, 306, 307, 308, 318 or 405 of the Act, or any permit condition or limitation implementing any
of such sections in a permit issued under section 402 of the Act. Administrative penalties for Class
1 violations are not to exceed $10,000 per violation, with the maximum amount of any Class I
penalty assessed not to exceed $25,000. Penalties for Class 11 violations are not to exceed
Part I II Page 1 of 8

Permit No. NCS000106
$10,000 per day for each day during which the violation continues, with the maximum amount of
any Class 11 penalty not to exceed $125,000.
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
individual permit which has a reasonable likelihood of adversely affecting human health or the environment.
4. Civil and Criminal Liabilitv
Except as provided in Part 111, Section C of this permit regarding bypassing of stormwater control facilities,
nothing in this individual permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6A, 143-215.613, 143-
215.6C or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the \ responsibility for effective compliance may be
/I temporarily suspended. ; ,q
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to-preclhde the institution of any legal action or relieve
the permittee from any responsibilities, liabilities,,or penalties to which the permittee is or may be subject to
under NCGS 143-215.75 et seq. or Section 3111of the:Federal,Act, 33 USC 1321.
6. Property Right4 �,� r
The issuance of this individw permit does no convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement'of Federal, State or local laws or regulations.
7. Severability
The provisions of this individuafpermit are severable, and if any provision of this individual permit, or the
application of any provision of this individual permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this individual permit, shall not be affected
thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time, any information which the Director
may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the
permit issued pursuant to this individual permit or to determine compliance with this individual permit. The
permittee shall also furnish to the Director upon request, copies of records required to be kept by this
individual permit.
9. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate,
any monitoring device or method required to be maintained under this individual permit shall, upon
conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more
than two years per violation, or by both. If a conviction of a person is for a violation committed after a first
conviction of such person under this paragraph, punishment is a fine of not more that $20,000 per day of
violation, or by imprisonment of not more than 4 years, or both.
Part I II Page 2 of 8

Permit No. NCS000106
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this individual
permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be
punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two years
per violation, or by both.
SECTION B: GENERAL CONDITIONS
Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date/In order to receive automatic
authorization to discharge beyond the expiration date, the permittee;shall submit forms and fees as are
required by the agency authorized to issue permits no later,than)l80'days prior to the expiration date. Any
permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not
have a permit after the expiration and has not requested. renewal at least-180 days prior to expiration, will be
subjected to enforcement procedures as provided in NCGS,§ 143-2153.6 and 33 USC 1251 et. seq.
2. Transfers
This permit is not transferable to any
Director may require modification or
incorporate such other requirements
required to notify the Division in H
3. Signatory Requirements
All applications, reports,
a. All applications
t`after'notice to and approval by the Director. The
id.reissuance of the permit to change the name and
essary under the Clean Water Act. The Permittee is
event the permitted facility is sold or closed.
submitted to the Director shall be signed and certified.
under this individual permit shall be signed as follows:
(1) In the case of a corporation: by a principal executive officer of at least the level of vice-
president, or his duly authorized representative, if such representative is responsible for
the overall operation of the facility from which the discharge described in the permit
application form originates;
(2) In the case of a partnership or limited partnership: by a general partner;
(3) In the case of a sole proprietorship: by the proprietor;
(4) In the case of a municipal, state, or other public entity: by a principal executive officer,
ranking elected official, or other duly authorized employee.
b. All reports required by the individual permit and other information requested by the Director shall
be signed by a person described above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
PartIll Page 3 of 8

Permit No. NCS000106
responsibility, or an individual or position having overall responsibility for environmental
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for;knowing violations."
4.
The issuance of this individual permit does not prohibi't.the Director from reopening and modifying the
individual permit, revoking and reissuing the individual permit; or terminating the individual permit as
allowed by the laws, rules, and regulations contained;in Title 40, Code of Federal Regulations, Parts 122
and 123; Title ISA of the North Carolina Adiriinist�ative Code, Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et al. �% {(ter✓
5. - Permit Actions
The permit may be modified,.revoked and'reissued, or terminated for cause. The notification of planned
changes or anticipated noncompliance does not stay any individual permit condition.
SECTION C: OPERATION AND -MAINTENANCE OF POLLUTION CONTROLS
Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment and
control (and related appurtenances) which are installed or used by the permittee to achieve compliance with
the conditions of this individual permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation
is necessary to achieve compliance with the conditions of this individual permit.
Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this individual permit.
3. Bypassing of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
Part III Page 4 of 8

Permit No. NCS000106
b- There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal
periods ofequipment downtime or preventive maintenance; and
C. The permittee submitted notices as required under, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may approve an
anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
1. Representative Samoline
Samples collected and measurements taken, as required/
hereinll be'characteris[ic of the volume and
nature of the permitted discharge. Analytical sampling�shall be performed during a representative storm
event. Samples shall be taken on a day and time that is.characteristic of the discharge. All samples shall be
taken before the discharge joins or is diluted by any other waste stream, body of water, or substance.
Monitoring points as specified in this permit shall not be changed without notification to and approval of
the Director.
2. Recordine Results
For each measurement, sample;�mspection or maintenance activity performed or collected pursuant to the
requirements of this individual permit the permittee shall record the following information:
a. The date, exact place, and time of sampling, measurements, inspection or maintenance activity;
i\ /
b. The individual(s) werf?ted the sampling, measurements, inspection or maintenance activity;
C. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges.
Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to
NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant
to Section 304(g), 33 USC 13 14, of the Federal Water Pollution Control Act, as Amended, and Regulation
40 CFR 136.
Part III Page 5 of 8

Permit No. NCS000106
To meet the intent of the monitoring required by this individual permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the minimum
detection or lower reporting level of the procedure.
5. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that are
required to be sampled, the permittee may petition the Director for representative outfall status. If it is
established that the stormwater discharges are substantially identical and the permittee is granted
representative outfall status, then sampling requirements may be performed at a reduced number of outfalls.
6. Records Retention
Visual monitoring shall be documented and records maintained at
Pollution Prevention Plan. Copies of analytical monitoring result:
permittee shall retain records of all monitoring information; inc'lue
records and all original strip chart recordings for continuous mom
reports required by this individual permit for a period of at least 5
measurement, repon.or application. This period may be'extended
Inspection and Entry
:ility along with the Stormwater
also be maintained on -site. The
I calibration and maintenance
orinb instrumentation, and copies of all
years -from the date of the sample,
by request of the Director at any time.
The permittee shall allow the Director, or an authorized representative (including an authorized contractor
acting as a representative of the Director), or in the case of a facility which discharges through a municipal
separate storm sewer system, an authorized representaiive of a municipal operator or the separate storm
sewer system receiving the discharge, upon the presentation of credentials and other documents as may be
required by law, to;
a. Enter upon the per rt�s premises where a regulated facility or activity is located or conducted,
or where record sj"m be kept under the conditions of this individual permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this individual permit;
C. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),
practices, or operations regulated or required under this individual permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring individual permit compliance
or as otherwise authorized by the Clean Water Act, any substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director. Submittals shall be delivered to the
Division no later than 30 days from the date the facility receives the sampling results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee is required to
submit a discharge monitoring report within 30 days of the end of the six-month sampling period, giving all
required information and indicating "NO FLOW" as per NCAC T15A 02E .0506. .
Part I I I Page 6 of 8

Permit No. NCS000106
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report (QMR) form provided by the Division, and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon DWQ's specific
requirement to do so.
Submitting Reports
Duplicate signed copies of all reports required herein, shall be submitted to the following address:
Division of Water Quality
Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 �.
3. Availability of Reports Y
Except for data determined to be confidential under NCGS J/2'I 5.31a)(2)Z Section 308 of the Federal
Act, 33 USC 1318, all reports prepared in accordance with -[he terms shall be available for public inspection
at the offices of the Division of Water Quality. As required by,the Act, analytical data shall not be
considered confidential. Knowingly making any false -statement on any such report may result in the
imposition of criminal penalties as provided for in'NCGS143-2 .15.613 or in Section 309 of the Federal Act.
4. Non-Stormwater Discharges
If the storm event monitored
discharge, the permittee shall
discharge permit and provide
5. Planned Changes f /
6.
his individual permit coincides with a non-stormwater
all parameters as required under the non-stormwater
th the stormwater discharge monitoring report.
The permittee shall give hotice-to the Director as soon as possible of any planned changes at the permitted
facility which could significantly alter the nature or quantity of pollutants discharged. This notification
requirement includes pollutants which are not specifically listed in the individual permit or subject to
notification requirements under 40 CFR Part 122.42 (a).
Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which may result in noncompliance with the individual permit requirements.
Bypass
Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of an
unanticipated bypass.
8, Twenty-four Hour Reporting
The permittee shall report to the central office or the appropriate regional office any noncompliance which
may endanger health or the environment. Any information shall be provided orally within 24 hours from
Part 111 Page 7 of 8

Permit No. NCS000106
U
M
the time the permittee became aware of the circumstances. A written submission shall also be provided
within 5 days of the time the permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the period of
noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case -by -case basis if the oral report has been received
within 24 hours.
Other Noncompliance
The permittee shall report all instances of noncompliance not
monitoring reports are submitted.
Other Information
Where the permittee becomes aware that it failed to
individual permit or in any report to the Director, it
24 hour reporting at the time
facts in an application for an
it such facts or information.
Part I I I Page 8 of 8

NCS000106
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively, revoked and reissued, to comply with any applicable
effluent guideline or water quality standard issued or approved under Sections 302(b) (2) (c), and (d), 304(b) (2) and
307(a) of the Clean Water Act, if the effluent guideline or water quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in the individual
permit; or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or reissued under this
Act then applicable.
PART V ADMINISTERING AND
REQUIREI
The pennittee must pay the administering and compliar
the Division. Failure to pay the fee in�[iinely manner in
Division to initiate action to revoke the. Individual Fern
Act
See Clean Water Act.
2. Arithmetic Mean
other requirements in the
MONITORING FEE
ig fee within 30 (thirty) days after being billed by
with 15A NCAC 2H .0105(b)(4) may cause this
DEFINITIONS
The arithmetic mean of any set of values is. the summation of the individual values divided by the number of
individual values.
Allowable Non-Stormwater Discharees
This permit regulates stormwater discharges. Non-stormwater discharges which shall be allowed in the
stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs; discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, flows from riparian habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training.
Best Manaeement-Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may take the
form of a process, activity, or physical structure.
Parts IV, V and VI Page I of 5

Permit No. NCS000106
5.
M
II
8.
9.
10.
l 1.
12.
13.
14.
15.
Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility including
the collection system, which is not a designed or established operating mode for the facility.
Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above ground
storage container having a capacity of greater than 660 gallons or with multiple above ground storage
containers located in close proximity to each other having a total combined storage capacity of greater than
1,320 gallons.
Clean Water Act
The Federal Water Pollution Control Act, also known
USC 1251, et. seq.
Division or DW
The Division of Water Quality, Department of Envirm
Director "I,"
The Director of the Division of Water,0uaiity, the.pe`r
EMC
The North Carolina
Grab Sample
(CWA), as amended, 33
Resources.
issuing authority.
Commission.
An individual sample collected instantaneously. Grab samples that will be directly analyzed or qualitatively
monitored must be taken within the first 30 minutes of discharge.
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 31 I of the Clean Water Act.
Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a land
treatment facility, a surface impoundment, an injection well, a hazardous waste long-term storage facility or
a surface storage facility.
Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such as a city or town.
No Exposure
A condition of no exposure means that al I industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or runoff.
Industrial materials or activities include, but are not limited to, material handling equipment or activities,
Part VI Page 2 of 5 Pages

Permit No. NCS000106
Ir
17.
18.
®'
20.
21
22.
23
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
DWQ may grant a No Exposure Exclusion from NPDES Stormwater Permitting requirements only if a
facility complies with the terms and conditions described in 40 CFR § 122.26(g). -
Overburden.
Any material of any nature, consolidated or unconsolidated, that overlies a mineral deposit, excluding
topsoil or similar naturally -occurring surface materials that are not disturbed by mining operations.
Permtttee
The owner or operator issued a permit pursuant to this individual permit.
Point Source Discharee of Stormwater
Any discernible, confined and discrete conveyance including, but notspecifically limited to, any pipe, ditch,
channel, tunnel, conduit, well, or discrete fissure from which stop nwatter,islo'r may be discharged to waters
of the state.
Representative Storm Event O} \\
A storm event that measures greater than 0.1 inches ofiainfall'and that is preceded by at least 72 hours in which no
storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive
hours of no precipitation. For example, if it rains for,2.hours without producing any collectable discharge, and then
stops, a sample may be collected if a rain proodcing,a discharge begins again within the next 10 hours.
Representative Outfall Status
When it is established that the d�rge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall
status allows the permitteee to perform analytical monitoring at a reduced number of curtails.
Rinse Water Discharee
The discharge of rinse water from equipment cleaning areas associated with industrial activity. Rinse
waters from vehicle and equipment cleaning areas are process wastewaters and do not include washwaters
utilizing any type of detergent or cleaning agent.
Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus sufficient
-
freeboard to allow for the 25-year, 24-hour storm event.
Section 313 Water Priority Chemical
A chemical or chemical category which:
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA Title 111, Section 313 reporting
requirements; and
C. That meets at least one of the following criteria:
Part VI Page 3 of 5 Pages

Permit No. NCS000106
(1) Is listed in Appendix D of 40 CFR part 122 on Table 11 (organic priority pollutants),
Table III (certain metals, cyanides, and phenols), or TableIV(certain toxic pollutants and
hazardous substances);
(2) Is listed as a hazardous substance pursuant to section 31 1(b)(2)(A) of the C WA at 40
CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality criteria.
24. Severe Property Damage
Means substantial physical damage to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused
by delays in production.
25. Significant Materials
Includes, but is not limited to: raw materials; fuels; materialssuch,as solvents, detergents, and plastic
pellets; finished materials such as metallic products; -raw materials used in food processing or production;
11 hazardous substances designated under sectiond 01(14) of CERCLA; any chemical the facility is required to
if
report pursuant to section 313 of Title III of SARA;tfertilizers; pesticides; and waste products such as ashes,
slag and sludge that have the potential to%be,relea'sed-with stormwater discharges.
26. Significant Spills
Includes, but is not limited to:
,releases of ii or hazardous substances in excess of reportable quantities
under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 117.21) or section 102 of
CERCLA (Ref: 40 CFR 3Q2,4).�
27. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall or as a
-- result ofsnowmelt.
28. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and which is
directly related to manufacturing, processing orrawmaterial storage areas at an industrial site. Facilities
considered to be engaged in "industrial activities" include those activities defined in 40 CFR 122.26(b)(14).
The term does not include discharges from facilities or activities excluded from the NPDES program.
29. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce stormwater pollution and
is based on an evaluation of the pollution potential of the site.
30. Ten Year Design Storm
The maximum 24 hour precipitation event expected to be equaled or exceeded on the average once in ten
years. Design storm information can be found in the State of North Carolina Erosion and Sediment Control
Planning and Design Manual.
Part VI Page 4 of 5 Pages

Permit No. NCS000106
31
32
Total Flow
The flow corresponding to the time period over which the entire storm event occurs. Total flow shall be
either; (a) measured continuously, (b) calculated based on the amount of area draining to the outfall, the
amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the
measurement of flow at 20 minute intervals during the rainfall event.
Total Maximum Dailv Load (TMDL)
A TMDL is a calculation of the maximum amount of a pollutant that a waterbody can receive and still meet
water quality standards, and an allocation of that amount to the pollutant's sources. A TMDL is a detailed
water quality assessment that provides the scientific foundation for an implementation plan. The
implementation plan outlines the steps necessary to reduce pollutant loads in a certain body of �Jater to
restore and maintain water quality standards in all seasons. Thebean Water Act, Section 303, establishes
the water quality standards and TMDL programs. 1� �_ 11\1 ri
33. Toxic Pollutant
34.
35.
36.
37
Any pollutant listed as toxic under Section 3
Upset
Act.
Means an exceptional incident in which there is unintentional and temporary noncompliance with
technology based permit eftluenT'limitahons because of factors beyond the reasonable control of the
permittee. An upset does not include noncompliance to the extent caused by operational error, improperly
designed treatment or control facilities inadequate treatment or control facilities, lack of preventive
maintenance, or careless or improper operation. _
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations, or
airport deicing operations.
Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by water, air,
gravity, or ice from its site of origin which can be seen with the unaided eye.
25-year, 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once in 25
years.
Part VI Page 5 of 5 Pages

44,4
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Coleen H. Sullins
Director
Dee Freeman
Secretary
March 17, 2009
i6. z Li�Cs,
To:
Brian Lowther
)> i
Through:
Barry Herzberg
From:
Dave Parnell
a
Subject:
KapStone Kraft Paper Corporation
Permit: NCS000106
Permittee Contact:
Neal Davis, Environmental Engineer
100 Gaston Road, Roanoke Rapids, NC 27870,
Phone [phone]
Brian:
I have reviewed the subject renewal application and other pertinent information and offer the
following comments:
1. The permit and its requirements are deemed adequate for this facility.
2. The Stormwater Pollution Prevention Plan is adequate for this facility.
3. Staff supports the removal of the third outfall, as it is not now owned by the permittee.
4. High TSS sample readings represent areas for improvement.
Based on the information provided, the Raleigh Regional Office has no objection to the
issuance of the NPDES Stormwater Permit NCS000106 to I apStope Kraft Paper Corporation.
Signature Report Preparer
Signature of Regional Supervisor
Cc: RRO files
Date
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone]
Internet: v .ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50 % Recycled/10Y Post Consumer Paper
NorthCarolina
Naturally
Customer service
877-623-6748

w �
IdC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
FEB 2 6 2009
( DENR RAL613H REI]
1._
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor I Director Secretary
February 24, 2009
Individual NPDES Stormwater Permit Renewal Transmittal Cover Page
To: Raleigh Regional Office
Subject: NPDES Stormwater Permit No. NCS000106
KapStone Kraft Paper Corporation
Roanoke Rapids, NC (Halifax County)
Attachment Description
® Staff Report
® Draft Permit
® Renewal Application
Please sign Staff Report and provide comments.
Return to Brian Lowther at the Central Office by March 24, 2008.
Brian Lowther
Division of Water Quality
Stormwater Permitting Unit
Post -Construction Application
1617 Mail Service Center
Raleigh, NC 27699-1617
0�'
Nonhcarohna
wnturnl/Y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Customer Service
Internet: wvvw nnvaterouali1v ore Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
1-877-623-6748
An Equal Opportunity/Affirmative Action Employer — 50% Recycledl10% Post Consumer Paper

NCS000106
1 y . Beverly Eaves Perdue, Governor
!: FF�
�6 p2p Dee Freeman, Secretary
North Carolina Department of Environment and Natural Resources
lleen H. Sullins Director
y DES N_RALE1GH REt3 — 1 Division of water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
Kapstone Kraft Paper Corporation.
NPDES Permit Number:
NCS000106
Facility Location:
100 Gaston Road, Roanoke Rapids, NC (Halifax County)
Type of Activity:
Paper Mill
SIC Code:
2621
Receiving Streams:
See Figure 1
River Basin:
Roanoke River Basin, Sub -basin 03-02-08
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1 .
Response Requested by (Date):
03/2l/09
Central Office Staff Contact:
Return to: Brian Lowther, [phone]
Special Issues:
Issue
Rating Scale: 1 eas to 10 hard
Compliance history
6
Benchmark exceedance
7
Location,(TMDL, T&E
species, etc
7
Other Challenges:
• Outfall Status of
Lowground
3
Difficulty Rating:
23/40
Special Issues Explanation:
• One storm water monitoring location at the Low -Ground requires amendment. The Lowgound SW
sampling point is currently in permit held by Kapstone Paper. In the renewal application they requested
removal of the Lowground point because Kapstone no longer is the owner, but IP is. An email from Myrl
Nisely of the RRO that based on his knowledge of the site and from occasional observations in the last
couple of years, as well as conversations with the Environmental Staff at the paper mill he recommends that
the closed Lowground Landfill not require a permit. There is no industrial activity at this location, 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 water from 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 comer, from which point it would go though 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. (See email in
�rc
Page 1 of 8

NCS000106
file)
Description of Onsite Activities:
• The mill is an integrated pulp and paper mill producing unbleached Kraft paper for packaging.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File
• Central Files
• EPA General Sector -Specific Permit, 2008, Sector B — Paper and Allied Products.
• 2006 303(d) List
• 2006 Roanoke Basinwide Plan
History:
• December 19, 1994: Date permit first issued. Analytical monitoring included TSS, COD, Total
Phosphorous and Total Lead. Sampling was to be done annually.
• June 15, 1999: Reminder Letter to renew permit was sent.
• March 7, 2003: Permit re -issued. Analytical monitoring included COD, TSS, Total Phosphorous and Total
Lead. Sampling was to be done in years 1, 2, 3 and 4. The permittee asked to not do quarterly sampling.
• November 21, 2006: Request for Name Change sent back because they did not include sufficient legal
documents.
• February 23, 2007: Transfer of coverage from Intemational Paper to KapStone Kraft Paper Corporation.
• September 12, 2007: Reminder Letter to renew permit was sent.
• October 15, 2007: Date permittee submitted renewal application.
• September 25, 2008: Email correspondence Ken Pickle and Mryl Nisley referring to how to handle a
landfill the International Paper owns that is covered in the expired permit for KapStone.
• December 10, 2008: Compliance Inspection done by Autumn Hoban. The inspection report notes that one
of the three sotrmwater outfalls should be removed from the permit. The stormwater runoff at this location
comes from the closed and capped ash landfill area owned by Intemational Paper and is not part of Kapstone
Paper. .
Page 2 of 8

rNWIIII17[IL'.
Figure 1: Map of Facility
-tI^ �/ -�t � f �.. r `Z�- �i ,Ic ♦ 1 Iv!„+ � ! r-es„��„�''.�� ) 1l �} �. � y:�?.
,' )\ 3
�>!_
Y�r14��n".� i♦\ \r �S� •'i�'-. )
=. �' \ ;i \ L
�7'!,� '�� f�•-•�-�'_- •i ,: � r� �1�, -♦Y
�itq�♦f (�r
" �/!,�
n� r,41P: \ �,,,�t
am_r*
\
�((�y��\.♦.
� Ll�'.� �=:..: +r�'l1(-Y--�'J� ! r1t)1 4 ( T � 1 ;�
yj,y; J'1''\�'.1 'i
-T+-�e'�Yrir'�s_�'7 ir'rb-"^ � -r�
f���yl, 1� jj� S r �•.j'
"�. � - �f .�, J^yay�.t�;-^ f \',' `, ii .��{i% ;(. i- c` �.�� � l•� .}.mot
�'o- a sS {:.jfa^�-�2 �4a''�-a,J r•� C�fj �. • 4
'Sy-9 s f t \ '�pi[i {� ',
«•. I ♦ \.
�.��r� �*°, "• � � ' :; f r '�`�,�V ; 4 �` is i ��, r�� y, �t y �. _�; � -�,
h,
"✓
}'' a
KapStone Kraft Paper Corporation
�,�stR 4�f. iT+l
J 1(, `\..•
�
,F�
use ,
.� . -' .. c �ti„t *Sty +r ,�1.
� �
� n l,l\i r, �
�x t r: u .'� \ 7`l �riz ,il
�� r ? e -•.
i ♦i f 7-- s[w.n �' N�Y .. 1 r '-1 �Y,�t ° F} � 1 '
XKr\j' � �'(�i -
: y
a
�>3,
NCS000106
KapStonei Kraft Paper Corporation
Lad W de: 360 28' 19" N
t
Long bide: 770 38' 14" W
tr.
\ ^-
County: Ha ifax
Rece ing Stream: Roanoke River
Stream (lass: C
S
Sub -basin: 03-02-08 (Roanoke River Basin)
AW Scale 1.,24,6W
Facility Location
Page 3 of 8

NCS000106
Central Office Review Summary:
Owner's Other Permits:
• NC0000752 — KapStone Kraft Paper Corp. The process waste water outfall has limits for BOD,
Conductivity, Copper, Dissolved Oxygen, Flow, Total Nitrogen, Ammonia, Ceriodaphnia,
Pentachlorophenol, pH, Total Phosphorus, TSS, Temperature, and Trichlorophenol.
• AFS 3708300007 - KapStone Kraft Paper Corporation
2. Gen eralObservations:
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, North Carolina and Ride Rite® Converting,
an inflatable dunnage bag manufacturer located in Fordyce, Arkansas with aggregate 2005 revenues of
approximately $223 million. The transaction was approved by the shareholders of Kapstone Paper on December
29, 2006 and was consummated on January 2, 2007.
Kraft Paper: 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.
3. Impairment: The Roanoke River, 23-(26)a and 23-(26)b, are both on the 303(d) for a Fish Advisory for
Mercury. Basinwide Plan shows that Roanoke River 23-(26)a has TSS and habitat degradation as stressors. The
Basinwide Plan noted that severe bank erosion is occurring on the Roanoke River. River flows are managed for
flood control by the US Army Corp of Engineers and for hydropower generation by private industries. These
managed flows are not similar to natural seasonal flow conditions and subsequently extend the length of time
flooding occurs on the floodplain and in backswamps. In addition, frequent managed high flows at bankfull
heights further accelerate river bank erosion.
4. Threatened and Endangered: There were no Federally threatened or endangered species within two miles of the
facility based on the Natural Heritage Virtual Workroom. There are some State protected species (see file for
details).
5. Location: Located on the Roanoke River.
6. Industrial Changes Since Previous Permit: In September of 2007 a round wood (log) lay down area was added
north of the Landfill site where runoff drains directly to the treatment plant basin. In 2005 a lay down area for
round wood logs was added on the East side of the mill near the back side of the Emergency pond. All run off
from that area goes into the emergency pond and is pumped to the head of the mill's wastewater plant.
In 2002, a car rinse area was taken out of service and removed from the wastewater permit NC0000752.
7. Analytical Monitoring Notes: The analytical monitor was done annually at 3 outfalls. There were exceedances
of the benchmarks for TSS, COD, Phosphorus and Lead. The permittee also included conductivity, pH, and oil
& grease for 3 storm events even though this was no required in their permit.
The EPA General Sector -Specific Permit, 2008, Sector B — Paper and Allied Products does not have any
recommended monitoring for SIC 2621.
8. Qualitative Monitoring Notes: 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 other signs of pollution at the
outfalls.
Page 4 of 8

NCS000106
Revised Permit Recommendations: Analytical Monitoring:
1. Maintain monitoring for COD, TSS, Phosphorus and Lead.
2. pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II Section B. Qualitative monitoring is required regardless of representative
outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part II Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and
activities are not exposed to precipitation or runoff as described in 40 CFR § I22.26(g), the facility may qualify
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
is provided in Part I Section A.
Page 6 of 8

NCS000106
Table 1: Analytical Monitoring
Required
Sampling
Range
Sample
Date
Total
Flow
(MGD)
Precipitation
(in)
Duration
(hours)
COD
TSS
Phosphorous
Lead
ConductivityH
Oil&Grease
Benchmark:
120 mg/L
Benchmark:
100 mg/L
Benchmark:
2 mg/L
Benchmark:
.03 mg/L
Benchmark:
X mg/L
Benchmark:
6-9 so
Benchmark:
30 mg/L
Outfall 1 - Tent
03/01/03 to
02/29/04
11/19/2003
1.24
1.87
432
1280
3!4
0.111
03/01/04 to
02/28/05
12/6/2004
0.2
3.55
51
40
0.15
0.006
573
6.48
<5
03/01/05to
02/28/06
11/21/2005
1.9
13
51
232
0.96
0.026
69
7.75
<5
3/1/2006 to
02/28/07
11/1/2006
0.6
3.48
120
404
0.73
0!035
248
7.05
12
Outfall 2 - N. Storeroom
03/01/03 to
02/29/04
11/19/2003
1.24
1.87
57
622
0.44
0.11;3
03/01/04 to
02/28/05
12/6/2004
0.2
3.55
408
40
1.09
0%37I
322
6.94
7
03/01/05 to
02/28/06
11/21/2005
1.9
13
74
69
7.45
<5
3/1/2006 to
02/2 8/07
11/1/2006
0.6
3.48
33
153
0.28
0.03
114
7.6
<5
Outfa113 - Lowground
to
11/19/2003
1.24
1.87
98
103
0.79
0.011
to
12/6/2004
0.2
3.55
<5
20
0.39
<.003
156
6.87
<5
to
E311/20O6
11/21/2005
1.9
13
51
19
0.078
<.03
96
7.2
<6
to
11/1/2006
0.6
3.48
75
178
0.03
0.021
93
7.38
<5
- Over Current Benchmark
Data Not Collected
Page 5 of 8

Beverly Eaves Perdue, Governor
Dec Freeman, Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
January 21, 2009
Ms. Anitra Collins
KapStone Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: NPDES Permit Renewal Application
KapStone Kraft Paper Corporation
Permit Number NCS000106
Individual Stormwater Permit
Halifax County
Dear Ms. Collins:
The Division of Water Quality's Stormwater Permitting Unit (SPU) acknowledges receipt of
your renewal application for coverage under NPDES Permit Number NCS000106 on October 15, 2007.
We apologize for the lengthy delay in responding to your submittal and are now making every effort to
review your permit renewal as expeditiously as possible. Our Unit anticipates making significant
progress on individual permits over the next six months to reduce our backlog.
We are currently beginning our review of your renewal application. Please continue to comply
with all conditions and monitoring requirements in your expired NPDES stormwater permit. As
long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the
Division issues a renewal permit or notifies you of an alternative action.
No additional information is required at this time, but we may contact you in the future. Please
notify us if any significant changes have taken place at this facility since you submitted the renewal
package. If you have any questions about this matter, please contact me at [phone],
[e-mail].
cc: Raleigh Regional Office
Stormwater Permitting Unit Files
Central Files
North Carolina Division of Water Quality 1617 Mail Service Center
Internet: h2o.ennstate.nc.us 512 N. Salisbury St.
Sincerely,
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
NoiihCarolina
Raleigh, NC 27699-1617 Phone [phone] Customer Service
Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50 % Recycled110% Post Consumer Paper

Elemci ee(s)
fi I e:///C:/Documents%20and°/o2OSett i ngs/Brian_Lowther/My"/�20 Documents/Permits/Ind i vi dua...
I
Element Occurrence(s)
Found 11 Element Occurrence(s) within 2 miles of selected point
EO Date Last EO State Federal State Global
Scientific Name Nb Common Name Observed Rank
nk Accuracy protection Protection Rank Rank Habitat Comments
Status Status
Alasmidonta 34 Triangle Floater
undulata
Anodonta implicata S Alewife Floater
Brownwater Levee
Hardwood Forest 4
Landscape/Habitat
Indicator Guild
Brownwater Levee
Hardwood Forest
Landscape/Habitat
Indicator Guild
1996-11-06
E
Medium
T
S2
G4
2004-06-09
E
Medium
T
SI
GS
Elliptio 15 Roanoke Slabshell 1996-11-06 E Medium T
roanokensis
S3S4 GNR
S1 G3
Most river systems in
Piedmont and Coastal
Plain
Chowan, Meherrin, lower
Roanoke, and Pee Dee
rivers
Communities associated
with high mineral -content
sediments and non -acidic
waters and tolerant of
frequent over -bank
flooding. Characteristic
tree species include
Platanus occidentalis,
Celtis laevigata, Ulmus
americana, Acer negundo,
and Fraxinus
pennsylvanica. In the
Northern Coastal Plain, this
group includes primarily
levee forests on
brow nwater rivers but also
includes other waters -edge
habitats, such as the
shores of natural lakes and
oxbows and the edges of
backwater sloughs, where
they are associated with
brownwater rivers or
otherwise possess rich
soils. Other levee species,
particularly Betula nigra,
occur in blackwater
habitats or bottomlands
away from the waters edge
and are not considered
characteristic of this
particular habitat type.
Cape Fear north to
Roanoke river systems
I oft
1/16/2009 11:26 AM

Hlcmcn'. :c(s)
file:///C:/Documents%20and%20Settings/Brian Lowther/My"/o20Docunrents/Permits/Individua...
Lampsilis cariosa
`%4
Yellow
2004-06-09 E
Medium E
FSC S3
G3G4
A number of river systems;
Lampmussel
mainly near the Fall Line
Lampsilis radiata
27
Eastern
Lampmussel
2004-06-09 E
Medium T
SIS2
GS
A number of river systems
A number of systems,
Leptodea ochracea
7
Tidewater Mucket
2004-06-09 E
Medium T
S3
G3G4
primarily in the Coastal
Plain; abundant in Lake
Waccamaw
Ligumia nasuta
12
Eastern
2004-06-09 E
Medium T
S1
G4G5
Chowan, Roanoke, and
Pondmussel
Cape Fear systems
Rich Bottomland
Rich Bottomland
and Basic-Mesic
and Basic-Mesic
Hardwood Forest
1
Hardwood Forest
S3S4
GNR
Landscape/Habitat
Landscape/Habitat
Indicator Guild
Indicator Guild
Wet-Mesic
Wet-Mesic
Hardwood Forest
I
Hardwood Forest
Landscape/Habitat
Landscape/Habitat
S5
GNR
Indicator Guild
Indicator Guild
Wet Hardwood
Wet Hardwood
Forest
1
Forest
Landscape/Habitat
Landscape/Habitat
S5
GNR
Indicator Guild
Indicator Guil
2 of 1/16/2009 11:26 AM

Re: [Fwd: Low Ground Landfill Stonnwaterl
f
NCSlrQ0Adao
Subject: Re: [Fwd: Low Ground Landfill Stormwater]
From: Ken Pickle <[e-mail]>
Date: Thu, 25 Sep 2008 13:02:41 -0400
To: Myrl Nisely <[e-mail]>
CC: Danny Smith <[e-mail]>, Bethany Georgoulias
<bethany. georgoul ias@n email. net>
Hi Myrl,
Thanks for helping us with this site. It seems to me the necessary results/actions
are as follows.
a) For Kapstone: I'll put a copy of this email in the Kapstone file (NCS000106), and
when we work through our backlog, our staff will recognize via this note that the Low
Ground Landfill should be dropped from Kapstone's permit. A closed landfill is not
covered in our NPDES stormwater permit program, Kapstone doesn't own it, and there is
no discharge from it. - - An altogether helpful set of circumstances. The expeditious
way to cut through whatever bureaucratic and procedural red tape might otherwise be
considered, is just to consider the physical facts, and act accordingly. We will drop
the LGL discharge point from the renewed permit, when we get to it.
b) Further for Kapstone: As to continuing to sample, or to report "No Flow This
Period" for the Low Ground Landfill, DWQ should advise Kapstone that continued
sampling/reporting at this outfall is waived until SPU can re -write their permit,
based on Kapstone's report and RRO's (your) site visit and corroboration of site
conditions. Do you want to notify them of this waiver, or do you want SPU to do that?
c) For IP: While it's true that IP still owns the property, the fact that the landfill
is closed out makes it a little easier to deal with, administratively. The landfill
is closed out and so is not subject to NPDES stormwater permitting; there is no reason
to suspect water quality impacts on the receiving water due to stormwater from the
LGL; and IP is not our permittee at this site. It seems to me that no official permit
action for IP is required. A courtesy communication with Mr. Slowiak (IP) might help
to prevent any subsequent confusion., Do you want to do that, or do you want SPU to do
that?
d) Any additional ideas? If it suits you, you can just forward this email to the two
other parties. (IP and Kapstone)
Ken Pickle
DWQ Stormwater Permitting Unit
[phone]
Myrl Nisely wrote:
Hello, Ken,
My message is below the following message. Please pick up down there.
Myrl
-------- Original Message --------
Subject: Low Ground Landfill Stormwater
Date: Thu, 25 Sep 2008 09:03:48 -0500
From: Philip J Slowiak <[e-mail]>
To: [e-mail]
CC: [e-mail]
I of 3 9/25/2008 1:35 PM

Re: [Fwd: Low Ground Landfill Stormwater]
41
M
Mr. Nisely,
To confirm our telephone conversation of Wednesday, 9/24/08, Chris Puryear
at Kapstone referred us to you with regards to the stormwater permitting
status of the Low Ground Landfill. As indicated in Kapstone's Stormwater
Permit Renewal Application, October, 2007, ownership of the Roanoke Rapids
will changed from International Paper (IP) to Kapstone Kraft Paper
Corporation in January, 2007. A portion of the property, known as the Low
Ground Landfill, an industrial landfill closed in 1998, was not transferred
and remains the property of IP. In their permit renewal application,
Kapstone has requested the Low Ground stormwater outfall be removed from
the Kapstone permit (NCS000106) as they are no longer the owner of the
property.
IP has been evaluating stormwater conditions at the Low Ground site and
believes a credible case can be presented that a stormwater permit is no
longer necessary for this mature, inactive industrial waste landfill.
There is no exposure of significant materials to stormwater and data
supports that even during significant storm events, as recent as Hurricane
Hannah, no flow has been recorded at the outfall. IP is seeking the
Department's concurrence regarding the inapplicability of a permit and is
looking for some guidance as to how best move forward in this matter.
Any assistance you could offer would be appreciated.
Thanks!
Philip J Slowiak, CSP, CHCM
Senior Project Manager
Remediation Group
Environment Health & Safety
INTERNATIONAL PAPER
6400 Poplar Avenue
Memphis, TN 38197
1: 901.419.3845 C: 901.604.1952 F: 901.214.9550
e-mail: [e-mail]
Ken,
As explained above,this Lowground SW sampling point is currently in permit
NCS000106 held
by Kapstone Paper. Their application for renewal (in the SWPU backlog
list) requests removal of the Lowground point because Kapstone no longer
is the owner, but IP is.
If this email may serve as a Staff Report from PRO, I wish to express my
opinion that the closed Lowground Landfill does not require a stormwater
permit. This is based upon my knowledge of the site and from occasional
observations in the last couple of years, as well as conversations with
the Environmental staff at the paper mill. There is no industrial activity at this
location, isolated at "the back 40" of the
paper mill property. The site is everywhere heavily vegetated, and the capping
materials soak up rain so well that there has never been any water observed flowing
from the 5 or 6 down comers built into the site to remove water from the
turtlebacked top surface. Any water observed at the toe of the landfill travels
through vegetation and is likewise
absorbed before it is able to collect at one corner, from which point it
would go through a culvert into a channel to the Roanoke River. Even in
heavy rain, there is no flow at the downstream end of the culvert.
Therefore, I support the contention of IP that application for a
stormwater permit for the Lowground is unnecessary.
Attached is a diagram of the original Soil and Erosion Plan showing the
drain pipes (I today added the black arrows). Also attached is an old
photo showing the status of the shallow ditch just before it would
2 of 3 9/25/2008 1:35 PM

Re: [Fwd: Low Ground Landfill Stormwater]
discharge into the culvert under the road.
Please call to discuss further if you have questions.
Myrl
3 of 9/25/2008 1:35 PM

Kapstone Next Steps
L'
Subject: Kapstone Next Steps
From: Myrl Nisely <[e-mail]>
Date: Thu, 25 Sep 2008 13:24:19 -0400
To: Ken Pickle <[e-mail]>
Ken, thanks a million for such a rapid reply. I will be pleased to simply forward
your email response to both parties. That should satisfy every aspect of the
situation for both companies. Glad we can work it out so easily.
Myrl
Myrl A. Nisely <°))))><
Environmental Chemist
NO DENR - Div. Water Quality Raleigh Regional Office 1628 Mail Service Center Raleigh,
NO 27699-1628 Telephone: [phone] or x4255
Fax: [phone]
[e-mail] ><((((°>
I of 1 9/25/2008 1:34 PM

--I
s �C
September 12, 2007
ROANOKE RAPIDS MILL
ATTN: JAMES R JACKSON, JR, OR SUCCESSOR
100 GASTON RD
ROANOKE RAPIDS, NC 27870
Dear Permittee:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Subject: NPDES Stormwater Permit Renewal
Roanoke Rapids Mill
Permit Number NCS000106
Halifax County
Coleco H. Sullins, Director
Division of Water Quality
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000106. This permit will
expire on March 31, 2008. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires that an
application for permit renewal be filed at least 180 days prior to expiration of the current permit. In order to assure
your continued coverage under your permit, you must apply to the Division of Water Quality (DWQ) for renewal
of your permit. To make this renewal process easier, we are informing you that your permit will be expiring.
Enclosed you will find an individual permit renewal application form, supplemental information request, and
Stormwater Pollution Prevention Plan certification.
Filing the application form along with the requested supplemental information will constitute your application for
renewal of your permit. As stated above, the application form must be completed and returned along with all
requested information by October 12, 2007 in order for the permit to be renewed. The Division currently has a
backlog of unissued, expired individual permits. Should your permit expire before the renewed permit can be
reissued continue to operate following the terms and schedule of the expired permit.
Failure to request renewal by October 12, 2007 may result in a civil assessment of at least $500.00. Larger
penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility
without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $25,000 per day.
If you have any questions regarding the permit renewal procedures please contact Aisha Lau of the Stormwater
Permitting Unit at [phone], ext. 578.
Sincerely,
Bradley Bennett, Supervisor
Stormwater Permitting Unit
cc: Central Files
Stormwater Permitting Unit Files
Raleigh Regional Office
N""M��nnCarolina
wWmrally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: nim n—aterquality org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50%Recycied/10% Post Consumer Paper

VA7F
Q
4 1 V r
R
Mr. Antra J. Collins
KapStone Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Dear Ms. Collins:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
February 23, 2007
Subject: Permit No. NCS000106
KapStone Kraft Paper Corporation
Formerly International Paper
Halifax County
Division personnel have reviewed and approved -your request to transfer coverage under the individual permit,
received on January 8, 2007.
Please find enclosed the revised permit. The terms and conditions contained in the permit remain unchanged and
in full effect. This revised permit is issued under the requirements of North Carolina General Statutes 143-215.1 and
the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at [phone], extension 502.
Sincerely,
ORIGINAL SIGNED BY
KENPICKLE
Alan W. Klimek P. E.
cc: DWQ Central Files
Raleigh Regional Office, Water Quality Section
,�-Stormwater Permitting Unity
No hCarolina
�!!f!!Cl1��f
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/l0% Post Consumer Paper
Phone [phone] Customer Service
FAX [phone]

11f, 3
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT NO. NCS000106
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended, -
-- - -KAPSTONE KRAFT PAPER CORPORATION -
is hereby authorized to discharge stormwater from a facility located at
ROANOKE RAPIDS MILL
100 GASTON ROAD
ROANOKE RAPIDS
HALIFAX COUNTY
to receiving waters designated as the Roanoke River and a tributary to Roanoke River, both class C streams in the
Roanoke River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts 1, II, 111, IV, V, and VI hereof.
This permit shall become effective February 2, 2007.
This permit and the authorization to discharge shall expire on March 31, 2008.
Signed this day February 2, 2007. ORIGINAL SIGNED BY
KEN PICKLE
Alan W. Klimek, Director
Division of Water Quality
By Authority of the Environmental Management Commission

W A7F' 4 Michael F. Easley, Governor
�� (r William G. Ross Jr., Secretary
VJ [ North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Ms. Mary Lee Ransmeier
KapStone Kraft Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27871
Subject: Permit name or ownership change request
Permit NCS000106
Your request for a permit name change or ownership change received on 112- l 106 , is being
returned due to:
❑ Permit Name/Ownership Change Form is missing.
❑ Permit Name/Ownership Change Form is incomplete.
❑ Permit Name/Ownership Change Form signatures missing.
Missing legal document of the transfer of ownership (such as a contractor a deed).
fSYOther lirl:�vt iti� v,, ,y-.:� /� i�,• f te'Vx-l'/fCZL l-cornP�<. -
1 s I n LAA -f-"
Please return the informal ion so we can continue processing your request. If you have any
additional questions, please contact Sarah Young at [phone] extension 502. Our mailing
address is as follows: Wetlands and Stormwater Branch
1617 Mail Service
Raleigh, NC 27699-1617
DWQ Stormwater Permitting Unit
Cc:
DWQ Central Files
<SPU
NorthCarolina
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.encstale.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal OpportunitylARrmative Action Employer -50%Recycledll0% Post Consumer Paper -

s State of North Carolina
(: Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
June 15, 1999
JIM COOPER
CHAMPION INTERNATIONAL CORP.
POST OFFICE BOX 580
ROANOKE RAPIDS. NC 27870
o
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Stormwater Permit Renewal
Champion International Corp.
Permit Number NCS000106
Halifax County
Dear Permittee:
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000106. This permit expires
on December 31, 1999. In order to assure your continued coverage under your permit, you must apply to the
Division of Water Quality (DWQ) for renewal of your permit. To make this renewal process easier, we are
informing you in advance that your permit will be expiring. Enclosed you will find an individual permit renewal
application form, supplemental information request, and Stormwater Pollution Prevention Plan certification. Filing
the application form along with the requested supplimental information will constitute your application for renewal
of your permit. The application form must be completed and returned along with all requested information by July
19, 1999 in order to constitute a timely renewal filing.
Recent legislation modified the fee structure for DWQ permits. Renewal fees have been eliminated and annual fees
have been changed. The new annual fee for your permit is now $715.00 (you will be invoiced later this year for
your annual fee.) A copy of the new fee schedule is enclosed in this package.
Failure to request renewal by July 19, 1999 may result in a civil assessment of at least $250.00. Larger penalties
may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to $10,000 per day.
If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater and
General Permits Unit at [phone], ext. 548.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files
Raleigh Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
PERMIT COVERAGE RENEWAL APPLICATION
National Pollutant Discharge Elimination System
Stormwater NPDES Permit NCS000106
Champion International Corp.
Permit Number NCS000106
Halifax County
THIS APPLICATION MUST BE SIGNED AND RETURNED ALONG WITH THE REQUESTED
SUPPLEMENTAL INFORMATION TO THE DIVISION OF WATER QUALITY IN ORDER FOR YOUR
FACILITY TO QUALIFY FOR RENEWAL OF YOUR STORMWATER PERMIT NCS000106
PERMIT RENEWAL INFORMATION
The following is the information currently in our database for your facility. Please review this information carefully
and make all corrections as necessary in the space provided to the right of the current information.
Facility Name: Champion International Corp.
Mailing Address*: POST OFFICE BOX 580
ROANOKE RAPIDS, NC 27870
Location Address: NORTH ROANOKE AVENUE
ROANOKE RAPIDS, NC 27870
Facility Contact:
JIM COOPER
Phone Number:
[phone]
Fax Number:
No number on file
E-mail address:
No address on file
* This is the address to which all permit correspondence will be mailed
CERTIFICATION
I 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
Print or type name of person signing above
Date
Title
Please return this completed renewal form, the information as requested on the next page, and any relevant
documentation to:
Individual Permit Renewal
Division of Water Quality/ WQ Section
Stormwater and General Permits Unit
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Attn: Bill Mills