NC0043320_Compliance Evaluation Inspection_20220126

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Ed Cox
Robert Long
Burlington Industries LLC
PO Box 250
Cordova, NC 28330-0250
NORTH CAROLINA
Environmental Quality
January 26, 2022
SUBJECT: Compliance Inspection Report
Richmond Plant
NPDES WW Permit No. NC0043320
Richmond County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Richmond Plant on
1/11/2022. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in NPDES WW Permit No. NC0043320. The findings and comments
noted during this inspection are provided in the enclosed copy of the inspection report entitled
"Compliance Inspection Report".
There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.
The facility submitted a renewal application in 2020. Until the new permit is issued, they are to continue
operating under the previous permit. Disinfection type has changed to liquid sodium hypochlorite. This
change is reflected in the permit renewal application submitted in 2020. The facility plans to refurbish the
inoperable aeration basin.
The backup ORC is Tim Holland. Chris Hatcher is to be added as an additional backup. The inspector
provided an ORC designation form to facility staff. Information can also be submitted online at
https://deq. nc.gov/ww-orc-designation-expiration-or-resignation-form.
Two months of DMRs were reviewed during the inspection. No discrepancies were noted in Aug. 2020. In
the Feb. 2020 DMR several dates appeared to have pH and another parameter switched. Staff mentioned
that they may have already filed an amended DMR, but if not would make corrections immediately.
The field laboratory was well -kept and organized. NIST digital thermometers are purchased yearly from
Hach or Cole Palmer. Bench sheets could be updated to remove parameters that are no longer required
by the NPDES permit. Reagent bottles should be labeled when opened. The TRC calibration curve is
created in house. During file review it was discovered that daily sheets and bench sheets
from May 2020-Dec. 2020 are missing.
D_Q
Northcarnlma Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 225 Green Street, Suite 714 I Fayetteville. North Carolina 21130t
910.431.1300

The facility's composite sampler was not working at the time of the inspection. Staff has installed a
portable sampler while awaiting the arrival of a new ISCO sampler. The portable sampler appeared to
be in good condition. Samples are collected hourly; however, sampling is normally flow proportional.
Upstream and downstream sampling is not required by the permit. However, as a member of the
Yadkin-Peedee Basin Association sampling occurs once per year.
Internet access in the WWTP building is strongly recommended. Currently records must be taken to the
main building for encoding data needed for monthly reporting. In addition to increasing efficiency,
problems like missing data sheets may be easily avoided if records did not need to be removed from the
site.
If you should have any questions, please do not hesitate to contact Stephanie Zorio with the Water
Quality Regional Operations Section in the Fayetteville Regional Office at 910-433-3300 or via email at
[e-mail].
Sincerely,
l
DocuSigned by:
`—A99704FAED5D494...
Dr. Stephanie D. Zorio, Environmental Specialist
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Fayetteville Regional Office - Laserfiche
NPDES Compliance/Enforcement Unit - Laserfiche
D_E QyA North Carolina Department of Envlronmen al Quail Division of WaterResonrces
Fayetteville Neglonal 717:1225 Creen Street, sulte]141 Fayetteville, North Carotlna 2„Ot
91114313300

United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code
1 IN I 2 IL
21IIIIII
I
NPDES yr/mo/day Inspection
3 I NC0043320 111 121 22/01/11 117
Type
1810I
IIIIIIIIIII
Inspector Fac Type
19I S I 2011
IIIIIIIIIII IIIIIII I IIIIII
P6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 I 70I I 711 172 I N I 73I 1 74 71
I I
I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Richmond Plant
740 Old Cheraw Hwy
Rockingham NC 28379
Entry Time/Date
10:OOAM 22/01/11
Permit Effective Date
15/06/01
Exit Time/Date
01:15PM 22/01/11
Permit Expiration Date
20/05/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Robert Gerald Long/ORC/910-417-2242/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Ed Cox, /Plant Manager/910-417-2297/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran Sludge Handling DispoFacility Site Review Effluent/Receiving Wate
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s)
Stephanie Zorio
of Inspector(s) Agency/Office/Phone and Fax Numbers Date
�p iynedby: DWR/FRO WQ/910-433-3322/
1/27/2022
"-A99704FAED5D494...
Signature of Man
Mark Brantle
emBR`t°a9glgiew r Agency/Office/Phone and Fax Numbers Date
kart_ br
R/FRO WQ/910-433-3300 Ext.727/ 1/26/2022
E4E1A9691 DB248E...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

31
NPDES yr/mo/day
NC0043320 111 121 22/01/11
117
Inspection Type
18 [j
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The facility submitted a renewal application in 2020. Until the new permit is issued, they are to
continue operating under the previous permit. Disinfection type has changed to liquid sodium
hypochlorite. This change is reflected in the permit renewal application submitted in 2020. The facility
plans to refurbish the inoperable aeration basin.
The backup ORC is Tim Holland. Chris Hatcher is to be added as an additional backup. The inspector
provided an ORC designation form to facility staff. Information can also be submitted online at
https://deq.nc.gov/ww-orc-designation-expiration-or-resignation-form.
Two months of DMRs were reviewed during the inspection. No discrepancies were noted in Aug.
2020. In the Feb. 2020 DMR several dates appeared to have pH and another parameter switched.
Staff mentioned that they may have already filed an amended DMR, but if not would make corrections
immediately.
The field laboratory was well -kept and organized. NIST digital thermometers are purchased yearly
from Hach or Cole Palmer. Bench sheets could be updated to remove parameters that are no longer
required by the NPDES permit. Reagent bottles should be labeled when opened. The TRC calibration
curve is created in house. During file review it was discovered that daily sheets and bench sheets
from May 2020-Dec. 2020 are missing.
The facility's composite sampler was not working at the time of the inspection. Staff has installed a
portable sampler while awaiting the arrival of a new ISCO sampler. The portable sampler appeared to
be in good condition. Samples are collected hourly; however, sampling is normally flow proportional.
Upstream and downstream sampling is not required by the permit. However, as a member of the
Yadkin-Peedee Basin Association sampling occurs once per year.
Internet access in the WWTP building is strongly recommended. Currently records must be taken to
the main building for encoding data needed for monthly reporting. In addition to increasing efficiency,
problems like missing data sheets may be easily avoided if records did not need to be removed from
the site.
Page# 2

Permit: NC0043320
Inspection Date: 01/11/2022
Owner - Facility: Richmond Plant
Inspection Type: Compliance Evaluation
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Yes No NA NE
❑ • ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
•
•
•
•
• ❑ ❑ ❑
• ❑ • ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
Comment: During file review it was discovered that daily sheets and bench sheets from May
2020-Dec. 2020 are missing.
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new El ❑ • ❑
application?
Is the facility as described in the permit? El • ❑ ❑
# Are there any special conditions for the permit? El ❑ • El
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑
Comment: Disinfection type has changed to liquid sodium hypochlorite. This change is reflected in
the permit renewal application submitted in 2020.
Operations & Maintenance Yes No NA NE
Page# 3

Permit: NC0043320
Inspection Date: 01/11/2022
Owner - Facility: Richmond Plant
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ▪ ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Process controls include MLSS, pH, DO, ans sludge judge.
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Yes No NA NE
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Surface
Is the basin free of dead spots? • ❑ ❑ ❑
Are surface aerators and mixers operational? • ❑ ❑ ❑
Are the diffusers operational? • ❑ ❑ ❑
Is the foam the proper color for the treatment process? • ❑ ❑ ❑
Does the foam cover less than 25% of the basin's surface? • ❑ ❑ ❑
Is the DO level acceptable? • ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mg/I) • ❑ ❑ ❑
Comment: The facility plans to refurbish the inoperable aeration basin.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ •
Page# 4

Permit: NC0043320
Inspection Date: 01/11/2022
Owner - Facility: Richmond Plant
Inspection Type: Compliance Evaluation
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Comment: The sludge blanket was approximately 6 in. thick.
Disinfection -Liquid
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? • El El El
Is sample collected below all treatment units? • ❑ ❑ ❑
Is proper volume collected? ❑ ❑ ❑ •
Is the tubing clean? ❑ ❑ El •
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 ❑ ❑ El •
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type ❑ ❑ ❑ •
representative)?
Page# 5

Permit: NC0043320
Inspection Date: 01/11/2022
Owner - Facility: Richmond Plant
Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Comment: The facility's composite sampler was not working at the time of the inspection. Staff has
installed a portable sampler while awaiting the arrival of a new Isco sampler. The
portable sampler appeared to be in good condition. Samples are collected hourly.
Sampling is normal flow proportional.
Page# 6

Regional Inspectors' Checklist for Field Parameters
]This checklist is to be completed during regional plant inspections for Field Laboratories, denoted by certification numbers in the 5000s.]
Facility Name: Richmond Plant
Regional Plant Inspector: Stephanie Zorio
Permit #: NC0043320
Regional Inspector Contact #: 919-368-6077
Field Lab Certification #: 5061
Region:FRO
Lab Contact: Robert Long 910-417-2242
Date: 1/11/2022
I. Check the parameter(s) performed at this site for reporting purposes.
❑ Total Residual Chlorine (TRC) ❑ Temperature (TEMP) ❑ Specific Conductance (SC)
❑ pH ❑ Dissolved Oxygen (DO) ❑ Settleable Residue (SETT)
II. General Laboratory (note any exceptions in section XI
Are instruments, meters, probes, photometric cells, etc. maintained in good condition?
11 Yes ❑ No
Are standards, reagents and consumables used within manufacturer expiration dates?
[TRC gel standard is exempt.]
M Yes
❑ No
Are the following items documented (-\I where applicable):
Item
TRC
pH
TEMP
DO
SC
SETT
Date of sample collection*
X
X
X
X
X
N/A
Time of sample collection*
X
X
X
X
X
N/A
Sample collector's initials or signature
X
X
X
X
X
N/A
Date of sample analysis*
X
X
X
X
X
N/A
Time of sample analysis*
X
X
X
X
N/A
N/A
Analyst initials or signature
X
X
X
X
X
N/A
Sample site (i.e., facility name, location, ID, etc.)
X
X
X
X
X
N/A
Instrument ID
X
X
X
X
X
N/A
Parameter
X
X
X
X
X
N/A
Data qualifiers, when required
N/A
N/A
N/A
N/A
N/A
N/A
*Date and time of sample collection and analysis may be the same for in situ or on -site measurements.
III. Total Residual Chlorine — reference method:
Total Residual Chlorine meter make and model: Hach DR 1900
Is a check standard analyzed each day of use? (Circle one: gel or liquid standard)
0 Yes
❑ No
Does the check standard recover within ±10% of the known value?
/1 Yes
❑ No
What is the assigned/observed value of the daily check standard? 180/186
Is a 5-standard calibration verification performed? Note date of last verification:
❑ Yes
/1 No
Alternatively, does the lab construct a linear regression, using 5 standards, to calculate
results? Note date of last calibration curve constructed: 1/2020
❑ No
r Yes
True values: 1/ pg/L ❑ mg/L 20 40 50 200 400
Obtained values: 1/ pg/L ❑ mg/L 16 36 47 191 388
What program are samples analyzed on? 80
Are results reported in proper units? Check one: pg/L ❑ mg/L
Yes
❑ No
Are results reported between the facility's permit limit and the compliance limit of 50 pg/L?
Yes
❑ No
Are results less than the low standard reported as "<x", where x=low standard conc.?
Yes
❑ No
Is DPD/buffer added within 15 minutes of collection?
Yes
❑ No
Is a post -analysis check standard analyzed if samples are analyzed at multiple sites? N/A
❑ Yes
❑ No
IV. pH — reference method:
pH meter manufacturer and model: Oaklan pH 700
Is the pH meter calibrated with at least 2 buffers per mfg's instructions each day of use?
Note buffers used: 4, 10
❑ No
y Yes
Is the pH meter calibration checked with an additional buffer prior to sample analysis?
Note check buffer used: 7
❑ No
y Yes
Does the check buffer read within ±0.1 S.U. of the known value?
A Yes
❑ No
Are the following items documented:
Meter calibration?
A/ Yes
❑ No
Check buffer reading(s)?
A/ Yes
❑ No
Are samples analyzed within 15 minutes of collection?
A/ Yes
❑ No

Are sample results reported to 0.1 pH units on the eDMR?
1/ Yes
❑ No
Is a post -analysis check buffer analyzed if samples are analyzed at multiple sites? N/A
❑ Yes
❑ No
V. Temperature — reference method:
What
A
instrument(s) is used to measure
DO meter ❑ Conductivity meter
a
temperature? Check all that apply:
Digital thermometer ❑ Glass thermometer
pH meter
Is the instrument/thermometer calibration checked at least annually against a NIST
traceable thermometer? *see note in comments
►1 Yes ❑ No
Is NIST traceability documentation maintained on site?
L
Yes ❑ No
Are samples measured within 15 minutes?
L
Yes ❑ No
Are sample results reported in de•rees C?
L
Yes ❑ No
VI. Dissolved Ox • en — reference method:
DO meter make and model: YSI 550A
Is the air calibration of the DO meter performed each day of use?
L Yes ❑ No
Is meter calibration documented?
L Yes ❑ No
Are samples analyzed within 15 minutes of collection?
/1 Yes ❑ No
Are results reported in mg/L?
a Yes ❑ No
If samples are analyzed at multiple sites, is the meter recalibrated at each site or a post-
analysis calibration verification performed? N/A
Yes No
Does the post -analysis verification theoretical value agree within 0.5 mg/L of the meter
calibration reading?
Yes No
VII. Conductivity — reference method:
Conductivity meter make and model: Myron Company TechPro II
Is the meter calibrated daily according to the manufacturer's instructions? Note standard
used (this is generally a one -point calibration):
a Yes No
Is a daily check standard analyzed? Note value: 1413- main 147- optional second std.
a Yes ❑ No
Is meter calibration documented?
a Yes ❑ No
Are samples analyzed within 28 days of collection?
a Yes ❑ No
Is a post -analysis check standard analyzed if multiple samples are analyzed? N/A
Are results reported in pmhos/cm (some meters display equivalent pS/cm units)?
a Yes ❑ No
VIII. Settleable Residue — reference method:
N/A
Does the laboratory have an Imhoff Cone in good condition?
❑ Yes ❑ No
Is the sample settled for 1 hour?
❑ Yes ❑ No
Is the sample agitated after 45 minutes?
❑ Yes ❑ No
Are the following items documented:
Volume of sample analyzed? Note volume analyzed (must use 1 L):
❑ Yes ❑ No
Date and time of sample analysis (settling start time)?
❑ Yes ❑ No
Time of agitation after 45 minutes of settling?
❑ Yes ❑ No
Sample analysis completion (settling end time)?
❑ Yes ❑ No
Are samples analyzed within 48 hours of collection?
❑ Yes ❑ No
Are results reported in ml/L?
❑
Yes
❑
No
IX. Was a paper trail (comparing contract lab and on -site data to DMRs)
performed? If so, list months reviewed: Feb & Aug 2020
Yes
❑
No
X. Is follow-up by the Laboratory Certification program recommended?
❑ Yes No
XI. Additional comments:
The facility purchases NIST digital thermometers from Hach or Cole Palmer yearly. Bench sheets could be
updated to remove parameters that are no longer required by the NPDES permit. Reagent bottles should be
labeled when opened. The TRC calibration curve is created in house.
Please submit a copy of this completed form to the Laboratory Certification program at:
DWR Lab Certification, Water Sciences Section, 1623 Mail Service Center, Raleigh NC, 27699-1623
Electronic copies may be emailed to [e-mail].
Revision 3/2021