NC0065081_Inspection_20210817

August 17, 2021
Mark Sanford, Plant Manager
CPI USA North Carolina, LLC
331 Allie Clay Rd.
Roxboro, NC 27573

Subject: Compliance Evaluation Inspection
CPI USA North Carolina – Roxboro Plant
NPDES Permit No. NC0065081
Person County

Dear Mr. Caldwell:

On July 29, 2021 Jason Robinson of the Raleigh Regional Office (RRO) conducted a compliance evaluation
inspection of the subject facility located at 331 Allie Clay Rd, Roxboro. The assistance provided by Mr. Wright
Whitlow, Operator in Responsible Charge (ORC) was appreciated. Below is a list of findings developed from
the inspection:

1. The most recent permit expired on May 31, 2017. A renewal application was submitted in November
2016. However, the operator stated that the DWR Permitting Unit was told that the facility would be
shutting down in the future, and the permit was never renewed/reissued.

2. The permit authorizes the facility to discharge treated wastewater from the CPI Roxboro Plant to an
unnamed tributary to Mitchell Creek, classified as C waters in the Roanoke River Basin.

3. The plant is classified as a PC-1 (Grade I Physical/Chemical Water Pollution Control System). As listed
in the permit, the treatment components include an H-type flume, a chemical injection system (no
longer using liquid ferrous chloride-as stated in the permit, but a different flocculants and coagulant)
with a bubbler flow meter, metering pump, storage drums, and secondary containment, and two
concrete waste basins (act as settling basins).

Finding during the inspection were as follows:

4. The plant shut-down on March 31, 2021. They are currently decommissioning the plant and in the
planning stage of demolition. Demolition may begin in the second quarter of 2022. The facility will
need to work with the DWR Raleigh Regional Office and Central Permitting Unit to have the permit
rescinded.

5. An electronic copy of the operators log is kept on a computer, and was found to be complete and
thorough.

6. The Roxboro Plant lab is field certified for and self-reports monitoring data for the following











parameters (Certification Number 5458): Total Residual Chlorine, pH and Temperature. The meters
are calibrated weekly. Meter calibration logs were reviewed and found to be complete. CPI uses
Meritech Environmental Laboratories (Certification Number 165) to analyze other required
parameters. Commercial lab results, chain of custody records, and bench sheets were available for
review and found to be complete.

7. Discharge Monitoring Reports for September 2020 and February 2020 were reviewed and compared
to laboratory bench sheets. No discrepancies were noted.

8. The majority of the flow that passed through the treatment system when the plant was operational
was cooling water blowdown, which is no longer active. The treatment system continues to operate
and mainly treats storwater from the site. The units were as described in the permit, with the
exception of a flocculent and coagulant being injected in place of ferrous-chloride. The treatment
units were maintained and no apparent issues of concern were noted. Water in the concrete basins
appeared clean with no visible foam or sheens. Oil booms are located near the influent of both basins
and are routinely replaced. The basins are periodically drained down and solids are pumped by
Shamrock. Flow and composite samples are taken just before the water enters the effluent discharge
pipe.

9. The outfall was observed and was well maintained. There were no signs of a recent discharge.

This facility was found to be compliant with NPDES permit conditions as a result of this inspection. If you have
any questions regarding the attached reports or any of the findings, please contact Jason Robinson at
[e-mail]).

Sincerely,

Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS
Compliance Inspection Report

Cc: DWR Laserfiche
Raleigh Regional Office w/attachment
Wright Whitlow: [e-mail]
Randy Musselwhite: [e-mail]