WQ0002857_Follow Up Inspection 2_20201229

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
December 29, 2020
CERTIFIED MAIL No. 7018 1130 0000 1608 2439
RETURN RECIET REQUESTED
Ms. Donna M. Moore
Piedmont Custom Meats
430 NC Highway 49 S
Asheboro, NC 27205
SUBJECT: Notice of Continued Violation (NOV-2020-PC-0392)
Follow Up Inspection
Permit No. WQ0002857
Caswell County
On December 17, 2020 Division of Water Resources (DWR) staff Caitlin Caudle
performed an announced follow up inspection to review progress on addressing violations
and concerns listed in the Notice of Violation (NOV-2020-PC-0392) dated August 31,
2020. Larry Moore of Piedmont Custom Meats was present during the entire inspection.
The inspection included a review of the wastewater treatment facility, irrigation fields, and
permit renewal efforts. The facility is still noncompliant with the subject permit.
Staff asked Mr. Moore about permit renewal efforts and informed him that the permit
annual fee is overdue. A copy of the invoice was sent via email dated December 18, 2020.
During the inspection Items 1 — 6, D, E, and F included in NOV-2020-PC-0392 were
discussed. Please note that some items of concern have not been addressed and will be
reviewed during the next compliance inspection. In addition to the corrective actions
listed in the above referenced Notice, please complete the following corrective
actions as requested by the Division:
Violation #2
• Having cleared the immediate area around Monitoring Well #4, please review the
well and ensure no maintenance or repairs are needed
• With the next use of Zone 4, please review the zone while in use to ensure there
are not leaks and no further repairs are needed.
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North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
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• Ms. Caudle requested that Mr. Moore share any correspondence or other
documentation regarding the monitoring wells for Office files by the end of the
calendar year, but no later than March 31, 2021. Based on any correspondence
found, monitoring requirements may be reevaluated with the upcoming permit
renewal. Otherwise, permit conditions must be followed or a request for permit
modification to modify monitoring well requirements must be made.
Violation #4
• Please provide Ms. Caudle with any construction plans regarding the area
immediately surrounding the bar screen and grease trap before construction
begins. If construction involves any alterations in treatment units or addition of new
treatment units, permit modification is required prior to any construction.
Vinintinn #A
• It is the opinion of the Division that the holes in both lagoon embankments
pose a serious risk to the structural integrity of the lagoon liners and
embankments. At the time of inspection, freeboard in Lagoon 2 was at two feet
and effluent was visible in many of the burrow holes on the interior of both lagoon
embankments. This can cause a potential bypass to the wastewater treatment
system by allowing effluent to infiltrate the ground prior to final treatment. As the
aerators in both lagoons are in constant use per system design, the resulting
turbulence of wastewater is likely continuing to erode the holes on the interior of
the lagoon embankments.
Animal burrow holes and unsuitable vegetation were previously noted in
correspondence dated April 14, 2015. The unsuitable and overgrown vegetation
likely contributed to the continued animal disturbances by providing favorable
habitat. Failure to take corrective action now could result in continued degradation
of the lagoon embankments and potential adverse impacts to groundwater and
surface waters.
Permit Condition 111.11 states "diversion or bypassing of untreated or partially
treated wastewater from the treatment facilities is prohibited" and Permit
Condition 11.1 states "non -discharge facilities shall be effectively maintained and
operated at all times so there is no discharge to surface waters, nor any
contravention of groundwater or surface water standards."
The Division requests that Mr. Moore complete repairs with the guidance of
a NC licensed engineer, prior approval of the Division, and obtain an
engineer certification once any necessary repairs are completed within
ninety (90) days of receipt of this Notice. Current design standards (15A NCAC
02T .0505(f)) require that lagoons "shall have either a liner of natural materials at
least one foot in thickness and having a hydraulic conductivity of no greater than

1x10-6 centimeter per second when compacted, or a synthetic liner of sufficient
thickness to exhibit structural integrity and an effective hydraulic conductivity no
greater than that of the natural material liner."
Please repair the exterior walls of the pump house and continue efforts to exclude
stormwater from the pump house.
Concern Item D:
• Please send a photo once public access restriction signs are installed.
The Division appreciates the repairs completed so far and the continued efforts to bring
the subject facility back into compliance. Please provide a written response within
thirty (30) days of receipt of this Notice. Your response should include the following:
actions proposed to address remaining violation and concerns, a timeline for completion,
and any proposed plans to prevent future violations from occurring.
Please be mindful that any extensive repairs or modifications to the system may require
Division approval. A follow up inspection will be scheduled within sixty (60) days
following receipt of this notice.
Please refer to the enclosed inspection report for additional observations and comments.
If you have any questions, please contact Caitlin Caudle or me at the letterhead address
or phone number, or by email at caitlin.caudle(a)ncdenr.gov or Ion.snider(a)ncdenr.gov.
Sincerely,
EDocuSigned by:
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145849E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
enc: Inspection Report
cc: Caswell County Health Department — Electronic Copy
Glenn Price — R&A Laboratories — Electronic Copy
Larry Moore — Piedmont Custom Meats — Electronic Copy
WSRO Electronic Files
DWR Laserfiche File WQ0002857