WQ0006594_Unifi Compliance Inspection Report_20210517

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretory
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
May 17, 2021
Ms. Lisa Haynes — Corporate Environmental Engineer
Unifi Manufacturing, Inc.
Post Office Box 1437
Reidsville, North Carolina 27323
Subject: Compliance Evaluation Inspection
Unifi Manufacturing, Inc., Distribution of Class A Residuals
Permit No. WQ0006594
Rockingham County
Dear Ms. Haynes:
On April 20, 2021, staff of the North Carolina Division of Water Resources Winston-Salem
Regional Office (DWR) performed an announced routine compliance inspection of the Unifi
Manufacturing, Inc. distribution of Class A residuals program. This inspection was conducted
by DWR staff member Jim Gonsiewski. Mr. Brent Collins of EMA Resources was present during
this inspection. The inspection reflects compliance with the permit.
Please refer to the enclosed inspection report for additional observations and comments. If you
have any questions regarding this letter, please contact Jim Gonsiewski or me at [phone].
Sincerely,
DocuSignsd by:
l . Swat,
1451349E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc.: Compliance Inspection Report
cc: Brent Collins — EMA Resources (Electronic Copy)
Rockingham County Environmental Health (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

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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
Contact Person: Timothy Cole
Madison NC 27025
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: 04/20/2021 Entry Time 10:10AM
Exit Time: 12:15PM
Primary Inspector: Jim J Gonsiewski Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: is Compliant ❑ Not Compliant
Question Areas:
II Miscellaneous Questions El Sampling
II Storage El Transport
(See attachment summary)
111 Land Application Site
Page 1 of 4

Permit: WQ0006594 Owner - Facility: Unifi Manufacturing Inc
Inspection Date: 04/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On April 20, 2021, staff of the North Carolina Division of Water Resources Winston-Salem Regional Office (DWR) performed
an announced routine compliance inspection of the Unifi Manufacturing, Inc. distribution of Class A residuals program. This
inspection was conducted by DWR staff member Jim Gonsiewski. Mr. Brent Collins of EMA Resources was present during
this inspection.
Inspections of both the loading operations at the facility and the application of the residuals were conduected. No ponding
or runoff of residuals was observed. The fields were properly flagged and buffers were maintained. The inspection reflects
compliance with the permit.
Page 2 of 4

Permit: WQ0006594 Owner - Facility: Unifi Manufacturing Inc
Inspection Date: 04/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application ❑
Sampling Yes No NA NE
Describe sampling:
Metals, Nutrients, TCLP
Is sampling adequate? •❑ ❑ ❑
Is sampling representative? • 0 0 El
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? .000
Is a copy of the spill control plan in the vehicle? • ❑ ❑ ❑
Is the spill control plan satisfactory? • 0 ❑ 0
Does transport vehicle appear to be maintained? • ❑ ❑ ❑
Comment:
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? • 0 ❑ ❑
Is the application site in overall good condition? • ❑ ❑ ❑
Is the site free of runoff/ponding? • ❑ ❑ ❑
If present, is the application equipment in good operating condition? II❑ ❑ ❑
Are buffers being maintained? •❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application •❑ ❑ ❑
18% for subsurface application ❑ ❑ 0
Are there access restrictions and/or signs? 0 0 0
Is the application site free of odors or vectors? •❑ ❑ ❑
Have performance requirements for application method been met?
For injection? • 0 0 0
For incorporation? 0 0 • 0
Does permit require monitoring wells? 0 • 0 0
Have required MWs been installed? 0 ❑ • 0
Are MWs properly located w/ respect to RB and CB? 0 0 � ❑
Are MWs properly constructed (including screened interval)? 0 ❑ • 0
Is the surrounding area served by public water? 0 ❑ 0 II
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? 0 • 0 ❑
Page 3 of 4

Permit: WQ0006594
Owner - Facility: Unifi Manufacturing Inc
Inspection Date: 04/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Are soil types consistent w/ Soil Scientist reporUevaluation?
Is the water table greater than 1'/3' bls.
Is application occurring at the time of the inspection?
Comment: See comments
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑❑❑
Page 4 of 4

North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS A RESIDUALS DISTRIBUTION
General Information
Facility Name: Unifi Manufacturing, Inc. DCAR County: Rockingham
Permit No.: W000 06594
Owner: Unifi Manufacturing, Inc.
Permit Issuance Date: 12/31/2019
Permit Expiration Date: 3/31/2026
Plant ORC Name: Telephone No.:
Other Contact(s): Brent Collins - EMa,
Telephone No.: 336-399-3646
Facility Location (address, gps or directions): 2920 Vance Street Extension, Reidsville.
Reason for Inspection
® ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
On site at the Unifi facility in Reidsville at 10:10 AM. Met with Brent Collins, EMA. One operator and one
8,000-gallon tanker from EMS (#601) were loading residuals directly from the fascility 500,000-gallon aerobic
digester. Approximately 6,500 gallons of residuals were loader in the tanker to be transported to the field to be
spread. Left the facility to travel to the application site at 11:15 AM.
Arrived at the application field at 11:40 AM. The tanker truck transferred its load to a 4,500 gallon spreader
pulled by a tractor. No ponding or runoff of the residuals was observed. The field was properly flagged and
buffers were maintained. Samples had been collected but no laboratory data was available at the time of
the inspection. Left site at 12:15 PM.
Is a follow-up inspection necessary? ❑ Yes ® No
Primary Inspector: Jim Gonsiewski
Date of Inspection: 4/20/2021
Secondary Inspector:
Entry Time: 10.10 AM Exit Time: 12:15 PM

Non -Discharge Compliance Inspection Report
Record Keeping and Reporting Information: Y N NA NE
Is current permit and prior annual reports available upon request? x❑ ❑ ❑ ❑
Has the facility been free of public complaints for the last 12 months? EI
TCLP analysis conducted and results available? Frequency? annual(See permit for frequency) ❑ 0 ❑ ❑
Residuals metals and nutrient analysis conducted? Frequency? (See permit for frequency) x❑ ❑ ❑ ❑
Nutrient and metals loading calculations? (to determine most limiting parameter) DODE
Do lab sheets support data reported on Residuals Analysis Summary? ❑ DOE
Are distribution and/or hauling records available? ❑X ❑ ❑ ❑
Utilization Agreements established or Recipient Notifications available for review? ❑ ❑ ❑x ❑
Do the Utilization Agreements or Recipient Notifications contain minimum requirements? ❑ ❑ ❑ ❑
(Restrictions for land application, stockpiling, setback buffers, etc.)
If the Permittee applies bulk residuals, are field loading records available? © ❑ ❑ ❑
If the Permittee applies bulk residuals, are field inspections conducted and are records available? El ❑ ❑ ❑
Does residuals package label or Utilization agreement contain minimum info required by permit? El ONO
(Name & address of generator, statement of restrictions, nutrient contents)
Is an inspection log available containing record of residuals facility inspections, maintenance, ❑x ❑ ❑ ❑
and repairs?
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction: Requires both pathogen density demonstration and Class A treatment alternative.
❑ Fecal Coliform density or ❑ Salmonella density to demonstrate pathogen requirements. Y N NA NE
Was sampling conducted at the permit required frequency? (See permit for frequency) ❑ ❑ ❑ ❑
Were multiple samples taken? ❑ ❑ ❑ ❑
If Fecal Coliform, density <1,000 MPN/gram of total solids? ❑ ODD
If Salmonella, density <3 MPN/4 grams of total solids? ❑ ❑ ❑ ❑
Select which treatment Alternative below was used to demonstrate Class A compliance.
❑ Alternative 1 - Time/Temperature (See White House Manual for specific requirements) Y N NA NE
Were residuals maintained for correct time and temperature? ❑ ❑ ❑ ❑
Are logs present showing time and temperature? ❑ ❑ ❑ ❑
Are temperatures within range for complete time period? DODO
❑ Alternative 2 - Alkaline Treatment
Are logs present showing time and temperature? ❑ ❑ ❑ ❑
Was the pH raised to 12 or greater and maintained for 72 hours or longer? DODD
Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater? ❑ ❑ ❑ ❑
Are logs present showing time and pH? ❑ ❑ ❑ ❑
Was the temperature corrected to 25°C (77°F) by calculation, NOT autocorrect? ❑ ❑ ❑ ❑
❑ Alternative 5 - Process to Further Reduce Pathogens (PFRP) [Select the PFRP method below that was utilized]
❑ Composting, Select which method was used:
❑ Within -Vessel Method or Static Aerated Pile Method
Were residuals temperatures maintained at >55°C (131°F) for Y N NA NE
>3 consecutive days in the within -vessel or static aerated piles? ❑ ❑ ❑ ❑
❑ Windrow Composting Method
Were the residuals temperatures maintained at>55°C for at least
15 consecutive days in the windrow, and the windrow was turned a
minimum of five times during this time?
❑ ❑ ❑
❑ Heat Drying
Were the residuals dried by direct or indirect contact with hot gases and the ❑ ❑ ❑ ❑
moisture content of residuals reduced to <10%?
Did the temperature of the residuals or the wet bulb temperature of the gas DODO
in contact with the residuals as the residuals leave the dryer exceed 80°C (176°F)?
❑ Other Alternative, Specify: (See White House Manual)
Page 2 of 4

Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
❑ Option 1 - 38% Volatile Solids Reduction Y N NA NE
Are lab results and calculations present? ❑ ❑ ❑ ❑
Was the reduction on volatile solids (not total solids)? ❑ OLIO
Were samples collected at correct locations? ODDD
(beginning of digestion process & before land application)
Was there a >38% reduction? ❑ ❑ ❑ ❑
❑ Option 2 - 40-Day Bench Scale Test Y N NA NE
Were residuals from anaerobic digestion? ❑ ❑ ❑ ❑
Are lab results and calculations present? ❑ ❑ ❑ ❑
Was the test anaerobically digested in lab, and test run for 40 days? ❑ ❑ ❑ ❑
Was the test done between 30°C (86°F) and 37°C (99°F)? ❑ ❑ ❑ ❑
Was the reduction of on volatile solids (not total solids)? ❑ ❑ ❑ ❑
Was the reduction less than 17%? ❑ ❑ ❑ ❑
❑ Option 3 - 30-Day Bench Scale Test Y N NA NE
Were residuals from aerobic digestion? ❑ ❑ ❑ ❑
Are lab results and calculations present? DDD ❑
Were residuals 2% or less total solids? ❑ ❑ ❑ ❑
If not 2% total solids, was the test ran on a sample diluted to 2%
with unchlorinated effluent? ❑ ❑ ❑ ❑
Was the test run for 30 days? ❑ ❑ ❑ ❑
Was the test done at 20°C (68°F)? ❑ ODD
Was the reduction of on volatile solids (not total solids)? ❑ ❑ ❑ ❑
Was the reduction less than 15%? ODDD
❑ Option 4 - Specific Oxygen Uptake Rate (SOUR Test) Y N NA NE
Were residuals form aerobic digestion? ❑ ❑ ❑ ❑
Were residuals <2% total solids (dry weight basis) (not diluted)? DODO
Was the test done between 10°C (50°F) and 30°C (86°F)? ODDD
Was the temperature corrected to 20°C (68°F)? ❑ ❑ ❑ ❑
Was the sampling holding time <2 hours? ❑ ❑ ❑ ❑
Was the test started within 15 minutes of sampling or aeration maintained? ❑ ❑ ❑ ❑
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of
total residual solids (dry weight basis)? ❑ ❑ ❑ ❑
❑ Option 5 - 14-Day Aerobic Process Y N NA NE
Were the residuals from aerobic digestion? ❑ ❑ ❑ ❑
Was the average residuals temperature higher than 45°C (113°F)? ❑ ❑ ❑ ❑
Were the residuals treated for 14 days and temperature maintained higher
than 40°C (104°F) for the 14-day period? DODD
❑ Option 6 - Alkaline Stabilization Y N NA NE
Was the pH of the residuals raised to >12 and maintained for two hours
without addition of more alkali? ❑ ❑ ❑ ❑
Did the pH of residuals remain at > 11.5 an additional twenty-two hours
without the addition of more alkali? ❑ ❑ ❑ ❑
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? ❑ ❑ ❑ ❑
❑ Option 7 - Drying of Stabilized Residuals Y N NA NE
The residuals do not contain unstabilized residuals? DODD
Were the residuals mixed with any other materials? If so, what? DODD
Were the residuals dried >75% total solids? ❑ ❑ ❑ ❑
El Option 8 - Drying of Unstabilized Residuals Y N NA NE
Were the residuals mixed with any other materials? DODD
Were the residuals dried >90% total solids? ❑ ❑ ❑ ❑
❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual)
Page 3 of 4

Non -Discharge Compliance Inspection Report
Residuals Storage:
Describe storage: 500,000 gallon aerobic digester tank
Number of days/weeks/months of storage: 3 months
Residuals Sampling:
Is sampling adequate and representative?
Describe Sampling: TCLP, Metals, Nutrients
Transport Vehicle:
Is transport occurring at time of inspection?
Are necessary records (i.e. permit & spill plan) present in vehicle? ID of observed veliicle(s): 601
Application Site(s)
Were application site(s) inspected? If so, please complete info below. ® Yes
Is application occurring at the time of inspection? If no, note the date of the last event:
Weather Conditions:
❑ Sunny ® Partly Cloudy ❑ Cloudy
❑ Windy (wind direction: ) ® Breeze
❑ Overcast
❑ Calm
Y N NA NE
NODE
❑ No
❑ Stormy
N
NA
®Yes No
® No Precipitation ❑ Drizzle ❑ Rain ❑ Cloudburst (If applicable, precipitation measurement:
Weather Notes (i.e. Significant Changes, Forecasts, etc):
Temp. (° F): ❑ <32 ❑ 32 — 40 ❑ 40 — 60 ® 60 — 80 ❑ >80
NE
Permit and Spill Plan onsite during application? ® Yes
Application Observations: [Type of application: ® Liquid
El No
❑ Cake (> 15% total solids) ❑ Other
Site Owner(s): RC-128-Field 3
Intended Crop: Fescue PAN Requirement: 165 Ibs/ac
Application Rate (tons or gallons/acre): 6500 Gallons/Acre
Nutrient Content: Samples taken but lab results not available
Application occurring at time of visit: ® Yes ❑ No
Application Method: ® Surface ❑ Incorp/Injection
Incorporation/Injection during visit: 0 Yes 0 No IN N/A
Vegetative Buffer description: ❑None ❑Grass ❑Crop ❑ Shrub Lai
Tree ❑ Other
Current Field Conditions:
❑ Bare 0 Stubble 0 Planted (crop) IN Pasture
Soil Condition:
® Dry 0 Moist 0 Wet ❑ Saturated
0 Not -Frozen 0 Frost 0 Frozen 0 Snow -Covered
Slope: D 0-3% ® 3-6% 0 6-I0% ❑ 10-18% 0 >18%
Odor: ® None ❑ Mild ❑ Moderate 0 Strong
Vectors: ® None ❑ Few ❑ Many 0 Excessive
Application Details:
Application areas clearly marked?
Application within authorized area?
Application method appropriate?
Application is even (no ponding)?
Sufficient setbacks from wells?
Sufficient setbacks from surface waters?
Slopes >10% avoided (Surface App.) ?
Slopes >18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
No evidence of shallow GW?
Tracking is prevented?
Biosolids run-off is prevented?
Y N NA NE
© ❑ ❑ ❑
o ❑❑❑
® ❑ ❑ ❑
® ❑❑❑
2• 000
® ❑ ❑ ❑
O DNE
O • 000
Site Owner(s):
Intended Crop: PAN Requirement: lbs/ac
Application Rate (tons or gallons/acre):
Nutrient Content:
Application occurring at time of visit: ❑ Yes 0 No
Application Method: 0 Surface ❑ lncorp/Injection
Incorporation/Injection during visit: ❑ Yes 0 No 0 N/A
Vegetative Buffer description: ['None ❑Grass ['Crop 0 Shrub 0
Tree 0 Other
Current Field Conditions:
0 Bare 0 Stubble 0 Planted (crop) 0 Pasture
Soil Condition:
❑ Dry ❑ Moist ❑ Wet 0 Saturated
❑ Not -Frozen ❑ Frost ❑ Frozen 0 Snow -Covered
Slope: 0 0-3% 0 3-6% 0 6-10% 0 I0-18% 0 >18%
Odor: ❑ None 0 Mild ❑ Moderate 0 Strong
Vectors: ❑ None 0 Few 0 Many 0 Excessive
Application Details:
Application areas clearly marked?
Application within authorized area?
Application method appropriate?
Application is even (no ponding)?
Sufficient setbacks from wells?
Sufficient setbacks from surface waters?
Slopes>10% avoided (Surface App.) ?
Slopes>18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
No evidence of shallow GW?
Tracking is prevented?
Biosolids run-off is prevented?
Y N NA NE
0000
❑ ❑❑❑
O 000
O 000
❑ ❑ ❑ ❑
O 000
O 000
0000
O 000
O 000
❑ ❑❑❑
O 000
Page 4 of 4