WQ0006594_2021 Annual Report Review_20220706

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
July 6, 2022
Ms. Lisa Haynes — Corporate Environmental Manager
Unifi Manufacturing, Inc.
Post Office Box 1437
Reidsville, North Carolina 27323
SUBJECT: 2021 Annual Report Review
Unifi Manufacturing, Inc., Distribution of Class A Residuals
Permit No. WQ0006594
Rockingham County
Dear Ms. Haynes:
The Division of Water Resources (DWR) acknowledges receipt of your 2021 Annual Report for the
subject permit. A review of this report conducted by DWR staff person Jim Gonsiewski reflects
compliance with Permit Number No. WQ0006594.
A routine compliance evaluation inspection is planned to occur within the next 12 months. If you or
your staff have any questions regarding this letter, please contact Mr. Gonsiewski or me at (336) 776-
9800 or via email at [e-mail].
Sincerely,
CDocuSlgned by:
L.-ON T. 6442 s
145B49E225C94EA..
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
encl: Compliance Inspection Report
cc: Rockingham County Environmental Health (Electronic Copy)
Brent Collins — EMA Resources (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
oewmmort of Erw11 ,mamm ou,
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

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: 07/05/2022
Entry Time 03:15PM Exit Time: 05:OOPM
Primary Inspector: Jim J Gonsiewski Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: 1.1 Compliant Not Compliant
Question Areas:
II Miscellaneous Questions Mi Record Keeping Treatment
1111 Sampling
(See attachment summary)
Page 1 of 4

Permit: WQ0006594 Owner - Facility: Unifi Manufacturing Inc
Inspection Date: 07/05/2022 Inspection Type : Annual Report Review
Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) received the 2021 Annual Report for the subject permit. A review of this report
conducted by DWR staff person Jim Gonsiewski reflects compliance with Permit Number No. WQ0006594. A routine
compliance evaluation inspection is planned to occur within the next 12 months.
Page 2 of 4

Permit: WQ0006594 Owner - Facility: Unifi Manufacturing Inc
Inspection Date: 07/05/2022 Inspection Type : Annual Report Review
Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: Manufacturing process treatment
Yes No NA NE
Yes No NA NE
❑ ❑•❑
❑ ❑•❑
❑ ❑■❑
❑ ❑■❑
• ❑❑■
▪ ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
❑❑■❑
• ❑ ❑ ❑
❑ ❑❑■
❑ ❑ ❑•
❑ ❑•❑
❑ ❑ ❑•
❑ ❑ ❑ U
• ❑ ❑ ❑
❑ ❑ ❑•
❑ ❑ ❑ U
• ❑ ❑ ❑
❑ ❑ ❑•
Yes No NA NE
Page 3 of 4

Permit: WO0006594
Owner - Facility: Unifi Manufacturing Inc
Inspection Date: 07/05/2022 Inspection Type : Annual Report Review
Reason for Visit: Routine
Sampling
Describe sampling:
TCLP, residual analyses, metals
Is sampling adequate?
Is sampling representative?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 4 of 4

Annual Report Review Class A Distribution Permit No. WQ00 O Co V c�
Reporting Period: 1
Permit Details:
• Is 503? FIYeslo
• ClassA or B?
• Maximum Dry Tons Per Year: S O
• Number of acres permitted: "
• Number of fields in permit:
• Counties that land is permitted for:
• Monitoring Frequency for TCLP: RcvwciiKt,
• Monitoring Frequency for Residuals Analysis:Phr\u )
• Monitoring Frequency for Pathogen & Vector Attraction Reduction 6M C
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted? des
• Was distribution conducted during the reported period?s
• How many dry tons were produced and distributed? 1 S'°i t a7
• Were the distributions with the permitted amount? `R-s
• Were recipients information listed? 7 S
• Did it indicate compliance?
• Was form complete?
• Was it signed by the appropriate people?
2. Monitoring
• Were the analyses conducted at the required frequency? I INo
• Was an analyses taken for each source that was distributed? es _ No
• Were the metals analyses reported on the Residual Sampling Summary Form? [t„�'�s I—INo
• Were the results reported in mg/kg? ( es No
• Were the pH's 6.0 or greater for each residual sample? es No
• Were the heavy metals within ceiling concentration permit limits?es No
o Were the lab analyses attached? ���'('i's No
• Were all the required parameters tested? I rY"e I INo
• Was TCLP analysis conducted? s FIND
• Were the TLCP contaminants within regulatory limits? [1'' I INo
• Was a corrosivity, ignitability, and reactivity analysis conducted? es I INo
Hs
es
HYes
No
No
No
No
No

3. Pathogen : nd Vector Attraction Reduction
• Was a sined copy of the Pathogen and Vector Attraction Reduction Form submitted?' 'Yes I INo
• Did the fo 1 indicate the period of coverage, the residual class, and the pathogen reduction alternative
and the vector attraction reduction option used? Yes ❑No
• Was the appr•.riate documentation to show pathogen and vector attraction reduction included in the
report? 1 ]Yes No
• Was pathogen anvector attraction reduction demonstrated according to 40 CFR Part 503?I 'Yes' INo
Class A Pathogen view
To be Class A, residuals . hall meet either fecal Coliform density or salmonella density,
❑Fecal Coliform density
• Was the sampling conduct&. at the required frequency?
• Were multiple samples take ?
• Was each sample less than 100 MPN/gram of total solids?
OR
Yes
Yes
Yes
1 'Salmonella density
• Was the sampling conducted at the required frequency? Yes
• Were multiple samples taken? ❑Yes
• Was each sample Tess than 3 MPN/4 grams of total solids? 1 'Yes
To be Class A, residuals shall meet oneof the following alternatives:
1 'Alternative 1 — Time/Temperature
• Were the residuals maintained for correcti,me and temperature?
• Were logs submitted showing time and temperature?
• Were temperatures within range for complete,time period?
❑Alternative 2 — Alkaline Treatment
• Were logs submitted showing time and temperat6 e?
• Was the pH raised to 12 or greater and maintained or 72 hours or longer?
• Was the temperature 52°C (126°F) for 12 hours or I nger while the pH was 12 or
• Were logs submitted showing time and pH?
• Was the temperature corrected to 25°C (77°F)?
Alternative 5 — Process To Further Reduce Pathogens
PFRP Composting
• Were the within -vessel method or static aerated pile methods used? Yes 1 No
• Was the residuals temperature maintained at 55°C (131°F) or igher for three consecutive days or
longer in the within -vessel method or static aerated pile method?.\ ❑Yes El No
OR
• Was the windrow composting method used? ❑Yes
❑Yes
Yes
IllYes
II
Yes
Yes
greater?
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
• Was the residuals temperature maintained at 55°C or higher for 15' consecutive days or longer in the
windrow method, and the windrow turned a minimum of five times during this time? Yes No
PFRP Heat Drying
• Was the residuals dried by direct or indirect contact with hot gases and the moisture content of
residuals reduced to 10% or lower? 1 1Yes 1 INo
• Did the temperature of the residuals or the of the wet bulb temperature of the gas in contact with the
residuals as the residuals leave the dryer exceed 80°C (176°F)? Yes No

❑Option 6 — Alkaline Stabilization
• Was the pH of the residuals raised to 12 or higher by the addition of alkali? Yes ❑No
• Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
['Yes No
• Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours without the
addition of more alkali? ❑Yes
• Was the pH corrected to 25°C (77°F)? ❑Yes
nOption 7 — Drying of Stabilized Residuals
• Does the residuals contain any unstabilized residuals?
• Were the residuals mixed with any other materials?
• Were the residuals dried up to 75% total solids?
nOption 8 — Drying of Unstabilized Residuals
• Were the residuals mixed with any other materials?
• Were the residuals dried to 90% total solids?
II
No
nNo
['Yes I INo
❑Yes ❑No
❑Yes nNo
❑Yes ❑No
❑Yes UNo
Option 9 — Infection
• Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
❑Yes ❑No
• Was injection done on pasture or hay field? nYes ❑No
• Was injection done at time that crop was growing? ❑Yes ❑No
• If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? ❑Yes No
4. General
• Was the report in the proper format? es ❑No
• Was the annual report complete? UNo
• Was the report submitted on time? lEtYlegs ❑No
Pollutant
Ceiling
Concentration
Below
Limit
Cumulative
Pollutant
Loading Rate
Below
Limit
Arsenic
75
41
Cadmium •
85
39
Copper
4300
V
1500
Lead
840
300
Mercury
57
✓
17
Molybdenum
75
. /2
N/A
t /
Nickel
420
'l/
/
420
Selenium
100
v.
100
i/
Zinc
7500
2800

Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency?
Option 1 — 38% Volatile Solids Reduction
• Was there 38% reduction?
• Were lab sheets/calculations in report?
• Was the reduction on volatile solids (not total solids)?
• Were the samples taken at beginning of digestion process
• Were calculations correct?
❑Yes
No
['Yes ❑No
❑Yes ❑No
❑Yes ❑No
and before application (Inspection)?
❑Yes No
['Yes fNo
1 IOption 2 — 40-Day Bench Scale Test
• Were residuals from anaerobically digested treatment (Inspection)?
• Were residuals anaerobically digested in lab?
• Was the 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%?
• Were lab sheets/calculations in report?
• Were calculations correct?
nOption 3 — 30-Day Bench Scale Test
• Were residuals from aerobically digested treatment (Inspection)?
• Were residuals aerobically digested in lab?
• Were residuals 2% or less total solids?
• If not 2% total solids, was the test ran on a sample diluted to 2%
• Was the test run for 30 days?
• Was the test done at 20°C (68°F)?
• Was the reduction of on volatile solids (not total solids)?
• Was the reduction Tess than 15%?
• Were lab sheets/calculations in report?
• Were calculations correct?
❑Yes ❑No
Yes ❑ No
Yes ❑ N o
with unchlorinated effluent?
Yes No
❑Yes ❑No
❑Yes [i]No
❑Yes I INo
❑Yes ❑No
❑Yes I I No
❑Yes No
['Yes
['Yes
['Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑No
No
❑No
UNo
No
❑No
ONO
❑No
II
II
II
II
lI
nOption 4 — Specific Oxygen Uptake Rate(SOUR)
• Were residuals form aerobically digested treatment (Inspection)? ❑Yes
• Were residuals 2% or less total solids (dry weight basis) (not diluted)? ['Yes
• Was the test done between 10°C (50°F) and 30°C (86°F)? ❑Yes
• Was the temperature corrected to 20°C (68°F)? ❑Yes
• Was the SOUR equal to or Tess than 1.5 mg of oxygen per hour per gram of total residual
weight basis)? ❑Yes
• Was the sampling holding time two hours? ['Yes
• Was the test started within 15 minutes of sampling or aeration maintained? ❑Yes
lOption 5 — 14-Day Aerobic Process
• Were the residuals from aerobically digested treatment (Inspection)?
• Were the residuals treated for 14 days?
• Was the residuals temperature higher than 40°C (104°F) for a 14-day period?
• Was the average residuals temperature higher than 45°C (113°F)?
❑Yes
❑Yes
❑Yes
['Yes
❑No
❑No
No
❑No
solids (dry
❑No
UNo
FNo
II
❑No
❑No
❑ No
❑No

TCLP
Parameter
Below
LimJt
Parameter
Below
Limit
Parameter
Below
Limi
Arsenic (5.0)
V
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100,0)
✓1
1,2-Dichloroethane (0.5)
\✓
Pentachlorophenol (100.0)
✓/
Benzene (0.5)
Y
1,1-Dichloroethylene (0.7)
✓
Pyridine (5.0)
�/
Cadmium (1.0)
✓
2,4-Dinitrotoluene (0.13)
L/
Selenium (5.0)
✓,
Carbon tetrachloride (0.5)
✓
Endrin (0.02)
Silver (5.0)
Chlorodane (0.03)
/
L.,
Hepatachlor (and its
epoxide) (0.008)
✓
Tetrachloroethylene (0.7)
/
Chlorobenzene (100.0)
i.J
Hexachlorobenzene (0.13)
`--
Toxaphene (0.5)
t/
Chloroform (6.0)
✓
Hexachlorobutadiene (0.5)
c/
Trichloroethylene (0.5)
A......)""Chromium
(5.0)
Hexachloroethane (3.0)
c-2,4,5-Trichlorophenol
(400.0)
Y f
m-Cresol (200.0)`-
Lead (5.0)
✓
2,4,6-Trichlorophenol (2.0)
L/
o-Cresol (200.0)
(0.4)
k✓
2,4,5-TP (Silvex) (1.0)
1.�
i/
p-Cresol (200.0)
VLindane
Mercury (0.2)
1/
Vinyl Chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0) j
Methyl ethyl Ketone (200.0)
Residuals Analysis
Parameter
Analyzed For
Parameter
Anal zed For
Parameter
Analyzed For
Aluminum
L%
Mercury
Potassium
\✓
Ammonia-✓
Nitrogen
/
Molybdenum
Selenium
Arsenic
✓
Nickel
Sodium
✓
Cadmium
✓
Nitrate-
Nitrite
Nitrogen
L.)
SAR
/
/
Calcium
✓
% TS
✓
TKN
S/�
Copper
✓
pH
✓
Zinc
Lead
✓✓
Phosphorus
✓
Magnesium
PAN
✓