WQ0006594_Inspection_20200422

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 22, 2020
Lisa Haynes, Corporate Environmental Manager
Unifi, Inc.
P.O. Box 1437
Reidsville, North Carolina 27323
Subject: Review of 2019 Annual Report
Unifi, Inc., Distribution of Industrial Pretreatment Residuals
Permit No. WQ0006594
Rockingham County
Dear Ms. Haynes:
Division of Water Resources (DWR) staff person Justin Henderson has completed a
review of the 2019 Annual Report for the subject permit. While the report reflects
compliance with Permit No. WQ0006594, the following items of concern require your
attention:
1. Two nutrient and metals analyses results, obtained during April 2019, were averaged,
and the averaged results were utilized to calculate and report cumulative loading
totals for application sites that received residual application during the first half year
in 2019. In the future and prior to utilizing "averaged" analyses results to calculate
cumulative loading, Division approval to do so shall be requested and obtained. The
Division's historical guidance has consistently required that the most recent analyses
results be utilized to calculate cumulative loading within a specified monitoring
period, as this is considered the most representative method to determine loading
rates.
2. While a permit modification to increase the maximum dry tons per year limit was
received and approved during 2019, the previous maximum dry tons per year limit of
100 dry tons was exceeded prior to submission or approval of the permit modification
application, according to tracking records submitted within the subject annual report.
If future operations continue to expand, permit modification should be requested, and
approvals obtained prior to exceedance of existing permitted limits in order to remain
complaint.
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NOh r H CAROI.IN/+
^^ •^ �ku^m I u�•i` r 336.776.9800

If you have any questions regarding this correspondence, please contact Justin Henderson
or me at the letterhead address or phone number, or by email at
iustin.hendersonCa ncdenr.gov or lon.snidergncdenr.gov.
Sincerely,
DocuSigned by:
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ - WSRO
CC., Brent Collins, EMA Resources - via email
Laserfiche Files - (electronic copy)

Compliance Inspection Report
Permit: WQ0006594 Effective: 12/31/19 Expiration: 03/31/26 Owner : Unifi Manufacturing Inc
SOC: Effective: Expiration: Facility: Unifi Manufacturing DCAR
County: Rockingham 805 Island Dr
Region: Winston-Salem
Madison NC 27025
Contact Person: Timothy Cole Title: Phone: [phone]
Directions to Facility:
WSRO - US 52N - BUS 40E - HWY 158N - Left on Reid School Rd. - Right on Vance Street Ext. (Facility on left/ north side)
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0021873 Town of Mayodan - Mayodan WWTP
NC0024881 City of Reidsville - Reidsville WWTP
Inspection Date: 04/22/2020 Entry Time 09:OOAM
Primary Inspector: Justin L Henderson
Secondary Inspector(s):
Exit Time: 11:30AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0006594 Owner - Facility: Unifi Manufacturing Inc
Inspection Date: 04/22/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
Division of Water Resources (DWR) staff person Justin Henderson has completed a review of the 2019 Annual Report for the
subject permit. While the report reflects compliance with Permit No. W00006594, the following items of concern require
your attention:
1. Two nutrient and metals analyses results, obtained during April 2019, were averaged, and the averaged results were
utilized to calculate and report cumulative loading totals for application sites that received residual application during the first
half year in 2019. In the future and prior to utilizing "averaged" analyses results to calculate cumulative loading, Division
approval to do so shall be requested and obtained. The Division's historical guidance has consistently required that the most
recent analyses results be utilized to calculate cumulative loading within a specified monitoring period, as this is considered
the most representative method to determine loading rates.
2. While a permit modification to increase the maximum dry tons per year limit was received and approved during 2019, the
previous maximum dry tons per year limit of 100 dry tons was exceeded prior to submission or approval of the permit
modification application, according to tracking records submitted within the subject annual report. If future operations
continue to expand, permit modification should be requested, and approvals obtained prior to exceedance of existing
permitted limits in order to remain complaint.
If you have any questions regarding this correspondence, please contact Justin Henderson or me at the letterhead address
or phone number, or by email at [e-mail] or [e-mail].
Page 2 of 3

Permit: WQ0006594 Owner - Facility: Unifi Manufacturing Inc
Inspection Date: 04/22/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Page 3 of 3