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Home My WebLink AboutWQ0002857_Follow Up Inspection 1_20201023ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality October 23, 2020 CERTIFIED MAIL No. 7018 1130 0000 1612 9530 RETURN RECEIPT 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 Dear Ms. Moore: On October 22, 2020, Division of Water Resources staff Caitlin Caudle and Rebecca Chandler performed a scheduled, announced follow up inspection to review progress on addressing the violations and concerns listed in the Notice of Violation (NOV-2020-PC-0392) dated August 31, 2020. Larry Moore, owner 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 reminded Mr. Moore that the permit renewal application is overdue according to Permit Condition 1.5. Please submit the permit renewal application as soon as possible, if you have not done so already. During the inspection, Items 1 — 6, A, B, D, E, and F included in NOV-2020-PC-0392 were discussed. Please note that the majority of violations and concerns in the previous letter still need to be addressed, and the following additional corrective actions are requested: Violations #1 and #2 • When operating the irrigation system, please have the ORC or other personnel inspect the area directly downslope of the irrigation Zone 3 to ensure there is no runoff being generated. • Please continue to clear Zone 4, being careful of a potential third riser. • Please clear the area immediately surrounding Monitoring Well 4. • When first operating Zone 4 again, please review the risers and sprinklers to ensure all equipment is operational. D_E NOk t U CARCI.INA Department el Environmental ouai� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 • Please be mindful not to damage the risers or underground piping when drilling the irrigation zones. When operating the irrigation zones after drilling, please inspect the irrigation zones carefully for any damages to irrigation equipment. Violation #3 • Staff requested Mr. Moore share any correspondence or other documentation regarding the monitoring wells for WSRO files. Ms. Caudle could only find information that confirmed the installation of two monitoring wells. Based on any correspondence found, monitoring well requirements may be reevaluated with the upcoming permit renewal. Violation #4 • Please maintain any invoices provided by Valley Protein, Inc. moving forward for at least five years per Permit Condition IV.8. Please ensure that a record of the volume of residuals removed from the grease trap is recorded. • Please replace the cracked bin used to store residuals from the bar screen. Concern item B • Staff requested Mr. Moore share any updated map that may be found by the facility or contract operators. Concern item D: • Staff requested signs restricting public access be places around the irrigation zones and around the wastewater treatment facility. Concern item E: • Please notify WSRO when vegetation on Lagoon 1 embankment is cleared in order to schedule a follow up inspection. Based on the follow up inspection, Staff will determine if the lagoons will need an engineer certification when repaired. Concern item F: • Staff reminded Mr. Moore that the newest Division approved reporting forms must be used. A written response that addresses all violations and concerns listed in NOV-2020-PC-0392 dated August 31, 2020 is still required. Please provide a written response that included actions taken to remedy all violations and concerns, actions proposed within a timeline for completion, and any proposed plans to prevent further violations from occurring within fifteen (15) days following receipt of this notice. 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@ncdenr.gov or lon.snider@ncdenr.gov. Sincerely, DocuSigned by: 0D2D3CE3F1B7456... 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 Compliance Inspection Report Permit: WQ0002857 SOC: County: Caswell Region: Winston-Salem Effective: 04/29/16 Expiration: 03/31/21 Effective: Expiration: Contact Person: Donna M Moore Title: Owner : Chapel Road Properties LLC Facility: Piedmont Custom Meats WWTF 9683 Kerr Chapel Rd Gibsonville NC 27249 Phone: 336-584-8247 Directions to Facility: From Winston-Salem, take 1-40 east to 1-85 north Rt. 29 north to Brown Summit exit (left, then immediate right onto Rt. 150) 7.3 miles to Toxler Mill Road (no turns), then proceed 3.1 miles to Kerr Chapel Road 0.8 miles. System Classifications: SI, Primary ORC: Glenn Fredrick Price Certification: 987931 Phone: 336-996-2841 Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 10/22/2020 Primary Inspector: Caitlin Caudle Secondary Inspector(s): Entry Time 10:OOAM Reason for Inspection: Follow-up Permit Inspection Type: Wastewater Irrigation Facility Status: ❑ Compliant Not Compliant Question Areas: ▪ Treatment Flow Measurement -Effluent ▪ Treatment Flow Measurement -Water Use Records ▪ Treatment Lagoons ▪ Treatment Flow Measurement (See attachment summary) Exit Time: 12:OOPM Phone: 336-776-9699 Inspection Type: Compliance Evaluation ▪ Treatment Flow Measurement -Influent ▪ Treatment ▪ Treatment Sludge Storage/Treatment ▪ Storage ▪ Miscellaneous Questions ▪ Treatment Barscreen ▪ End Use -Irrigation Page 1 of 6 Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC Inspection Date: 10/22/2020 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up Inspection Summary: On October 22, 2020 Division of Water Resources staff Caitlin Caudle and Rebecca Chandler preformed a scheduled announced follow up inspection for the violations and concerns addressed in correspondence dated August 31, 2020. Larry Moore of Piedmont Custom Meats was present during the entire inspection. To date a full response requested in the violation letter has yet to be received. Email correspondence dated September 24, 2020 has been received from Mr. Moore indicating that some violations had been addressed and other corrections are in the planning process. The inspection included a review of the wastewater treatment facility, irrigation fields, and permit renewal efforts. The facility has continued to be noncompliant with the subject permit. Staff reminded Mr. Moore that the permit renewal application was overdue per Permit Condition 1.5. Staff provided Mr. Moore with a hard copy of the Division permit renewal application with no modification. Mr. Moore stated he had a completed copy waiting to be signed and mailed. The inspection will be summarized following the items listed in the violation letter dated August31, 2020. Violation 1: Clearing Zones 1, 2, 3, and 4 of excess vegetation, manage broadleaf weeds and other unsuitable vegetation, and begin weed management practices to maintain suitable year-round vegetative cover. At the time of inspection, Zones 1, 2, and 3 had been bushhogged to clear vegetation and vines had been removed from sprinkler risers. The zones were bushhogged approximately 10 days prior according to Mr. Moore. A fair amount of vegetation was present, but there were areas of bare ground and dying vegetation throughout the zones. Vegetation was present upslope from the onsite freshwater pond. The irrigation system will need to be reviewed in action to ensure no ponding or runoff is occurring as a result of the bare ground. It is a requirement of the permit that the ORC inspect the entire system during/after event to ensure no runoff may occur. When operating the system after removing vegetation, please have the ORC or other personnel walk the area directly downslope of the irrigation zones to ensure there is no runoff entering the pond. Mr. Moore stated a mix of fescue and rye grass will be drilled within the next month to start establishing a suitable vegetative cover. Mr. Moore also stated 24-D will be used in the spring to manage any weeds that are present in the zones. Please be mindful that the equipment required to drill the irrigation zones could be heavy enough to damage the undergrounc piping of the irrigation system. Please carefully inspect the irrigation system during the first use after drilling to ensure that no damages occurred to the underground piping or risers. Violation 2: Removing the saplings and other woody vegetation from Zone 4 and establishing a suitable vegetative cover. At the time of inspection Zone 4 was in the process of being cleared of saplings and other vegetation. Mr. Moore stated all vegetation within the wettable area that may impede the sprinklers was being removed. Two risers were visible at the time of inspection, and the third riser marked on the map was discussed. WSRO maps indicate that 3 risers are present in Zone 4, and Mr. Moore stated to his knowledge there were only 2 risers in the zone. It appeared that saplings an inch or greater in diameter were removed from the zone. Staff requested that as Mr. Moore continues to clear the zone, be aware of a potential third riser, and please clear the area immediately area surrounding Monitoring Well 4. Mr. Moore stated a mix of fescue and rye grass will also be drilled in this zone, and 24-D will be used to manage weeds and other woody vegetation. Mr. Moore stated the facility wishes to maintain Zone 4 in the permit. Irrigation has not been reported in the zone since April of 2018. Staff request that risers and sprinklers in the zone be reviewed in use to ensure all equipment is operational. Violation 3: Justification for why a new upgradient monitoring well was not installed. Staff and Mr. Moore discussed why this was included in the violation letter. When preparing for the August compliance inspection Ms. Caudle was only able to find documentation that supported the installation of two monitoring wells, as required by Permit Condition 1.3. Mr. Moore stated there was an understanding among the Division, contract hydrogeologists, and the contract operating company that only a new downgradient monitoring well needed to be installed. Mr. Moore stated the contract hydrogeologist was searching for documentation that supported the installation of only one monitoring well. Staff requested Mr. Moore share any correspondence or other documentation regarding the monitoring wells for WSRO files. Monitoring well requirements may be reevaluated with the upcoming permit renewal. Violation 4: Residuals removal records, repairing drain in solids collection area, properly storing bar screen solids, scheduling regular solids removal from the grease trap to prevent nuisance conditions, and maintaining solids removal records for at least 5 years. Page 2 of 6 Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC Inspection Date: 10/22/2020 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up At the time of inspection, the solids in the grease trap had been removed. Mr. Moore stated by November the facility will have negotiated a contract with Valley Protein, Inc. to have more control of solids removal. Mr. Moore stated byproducts from the kill room are being removed once a week, the grease trap is being cleaned once every two weeks, and the blood bin is being emptied once every three weeks. Mr. Moore stated that plumbers will be clearing and scoping all pipes within the facility, including the drain in the solids collection area of the grease trap, and new bins had been bought for storing bar screen solids. Staff requested that Mr. Moore maintain invoices from Valley Protein, Inc. for removal of solids from the grease trap. These invoices should be kept for at least five years per Permit Condition IV.8. Permit Condition IV.8 requires that residuals removal records include the name of residuals hauler (Valley Protein, Inc.), the facility permit number, the date the residuals were hauled, and the volume of residuals removed. Staff requested, if possible, that invoices include the volume of solids removed. If this is not possible a separate record for the volume of residuals removed is acceptable. Volume can be listed as number of trucks or containers used to remove solids. Staff requests that Mr. Moore replace the cracked bin currently being used, and the drain in the solids collection area be repaired to properly store bar screen solids until collected by Valley Protein, Inc. Violation 5: Installing a new flowmeter or replacing the current flow meter. Mr. Moore stated that a new flowmeter is being installed that will be connected to their internal network. Violation 6: Repair aerator in Lagoon #2, preventing erosion of embankments and repairing animal holes, removing nuisance animal, repairing pump house roof, divert stormwater from structural wall, replace lid on distribution box next to Zones 1, 2, and 3, review distribution box for damage after mowing. At the time of inspection, the aerator in Lagoon 2 had been repaired and was in working order. Freeboard in Lagoon 2 was at a level that the holes on the interior of the embankment were partially covered. While inspecting Lagoon 1 embankment another hole was found on the top of the south embankment, and several groundhog holes were found on the southwest side of the embankment. Mr. Moore stated a groundhog had been removed from the area several years ago, but have not seen evidence of any other animals. The roof to the pump house had been repaired, but it appeared that water was still standing it the pump house. The lid on the distribution box had not been repaired to date, and standing water was present in the box. The sides of the box were broken and caving inward, preventing the lid from sealing correctly. Mr. Moore stated he will request contract graders review and provide a quote to divert stormwater from the pump house, repair the holes in both lagoon embankments, and repair the distribution box by replacing the plastic lid and installing an above ground riser. Staff requested that Mr. Moore obtain these quotes and provide a timeline of the intended repairs in the response to the violation letter. Concern item A: Updated site map with stormwater management features or written explanation of stormwater management. During the August compliance inspection, the ORC was not able to provide an explanation for stormwater management or the location of a stormwater retention pond that is mentioned during a routine compliance inspection from March 15, 2018. Mr. Moore was able to provide an explanation of stormwater management, and the location of the stormwater retention pond that is no longer in use. All gutters and stormwater drains leading to the wastewater system have been disconnected or capped. Concern item B: Updated site map. Mr. Moore stated it was his understanding that the Division had received an updated map. Ms. Caudle was able to find a map from 2017 that did not include all requirements from Permit Condition 1.4. Staff requested Mr. Moore resubmit an updated site map to the Division. Concern item D: Restricting public access to wastewater treatment facilities. Mr. Moore stated signs are being printed to restrict public access at all entry points to the irrigation zones and wastewater treatment facility. Concern item E: Clearing vegetation from Lagoon 1 embankment. During the August compliance inspection the southside of the embankment on Lagoon 1 was inaccessible for inspection. At the time of the follow up inspection some of the vegetation had died back and Staff were able to see several groundhog holeE on the embankment. Staff were not able to determine the extent of the holes or damage caused. Mr. Moore stated when the vegetation is removed he will have the contract graders assess the holes and provide a quote to fix them. Please notify WSRO when the embankment is cleared for a follow up inspection that will occur within 60 days of the previous follow up inspection. Based on the 60 day follow up inspection, Staff will determine if the lagoons will need to be engineer certified when repaired. Concern item F: Use of updated Division reporting forms. Page 3 of 6 Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC Inspection Date: 10/22/2020 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up Staff reminded Mr. Moore that the newest Division approved reporting forms should be used. Other observations: • When reviewing the distribution box there was no standing water downslope. There was evidence that there had been standing water between the distribution box and the pond. There was also standing water in a lowland draw above the head of the pond. There are wet areas upslope of the pond that are not included in the wetted area of the irrigation zones. Photos are in WSRO electronic files. • Above slope of the grease trap there is a PVC pipe with a hole in it. Mr. Moore stated the pipe is capped off and no longer in use. There was an area of dead grass surrounding the pipe and hooves on the ground beside it. At the time of inspection the pipe appeared to be dry. Staff will continue to monitor the state of the pipe in future inspections. Photos are in WSRO electronic files. • There was a damp area between the pump house and the pond. • There appeared to be a film of water on the pond directly below the lagoons. Photo in WSRO electronic files. • Photos of the grease trap from this inspection are in WSRO electronic files. Page 4 of 6 Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC Inspection Date: 10/22/2020 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up Type Activated Sludge Spray, HR Single Family Spray, LR Single Family Drip Infiltration System Activated Sludge Drip, LR Reuse (Quality) Activated Sludge Spray, LR Recycle/Reuse Lagoon Spray, LR Treatment Are Treatment facilities consistent with those outlined in the current permit? Do all treatment units appear to be operational? (if no, note below.) Comment: Treatment Flow Measurement -Influent Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Does flowmeter record flow? Does flowmeter appear to monitor accurately? Comment: New flow meter is being installed Treatment Flow Measurement -Water Use Records Is water use metered? Are the daily average values properly calculated? Comment: New flow meter is being installed Treatment Flow Measurement -Effluent Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Does flowmeter record flow? Does flowmeter appear to monitor accurately? Comment: Treatment Barscreen Is it free of excessive debris? Yes No NA NE • Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE ❑ • ❑ ❑ Yes No NA NE ❑ • ❑ ❑ ❑ • ❑ ❑ Yes No NA NE ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • Yes No NA NE Page 5 of 6 Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC Inspection Date: 10/22/2020 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up Is disposal of screenings in compliance? Are the bars spaced properly? Is the unit in good condition? Comment: Bin needs to be replaced and storage area repaired Treatment Sludge Storage/Treatment Is the aeration operational? Is the aeration pattern even? If required, are Sanitary "Ts" present in tankage? Comment: End Use -Irrigation Are buffers adequate? Is the cover crop type specified in permit? Is the crop cover acceptable? Is the site condition adequate? Is the site free of runoff / ponding? Is the acreage specified in the permit being utilized? Is the application equipment present? Is the application equipment operational? Is the disposal field free of limiting slopes? Is access restricted and/or signs posted during active site use? Are any supply wells within the CB? Are any supply wells within 250' of the CB? How close is the closest water supply well? Is municipal water available in the area? # Info only: Does the permit call for monitoring wells? Are GW monitoring wells located properly w/ respect to RB and CB? Are GW monitoring wells properly constructed, including screened interval? Are monitoring wells damaged? ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • Comment: No cover crop is specified and irrigation zones need to be reseeded. Zone 4 is currently not being used. Public access restriction signs are not currently posted. Only reviewed MW2. MW4 needs to be reviewed after vegetation is cleared around it. Page 6 of 6 North Carolina Department of Environmental Quality Division of Water Resources Water Quality Section General Information Facility Name: Piedmont Custom Meats NON -DISCHARGE COMPLIANCE INSPECTION REPORT WASTEWATER IRRIGATION al, t (AA \ LCc ri 4 Me V Permit No.: W000 02857 Owner: Donna M Moore ORC Name: Glenn Price Other Contact: Larry Moore County: Caswell Issuance Date: 04129/2016 Expiration Date: 03/31/2021 Telephone No.: 336-996-2841 (o) 336-408-7924 (c) Backup ORC: Don Kidney Telephone No.: Telephone No.: 336-584-8247 (o) 704-619-7337 (c) Location (address, gps or directions): 9683 Kerr Chapel Road, Gibsonville, NC 27249 Jeff Bellspar 336-782-9725 Reason for Inspection D ROUTINE ® FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other: Comments (attach additional pages as necessary) ase trap been cleaned out? -� Uplvi A h'on - eduled pick ups to clean out th reaese� rease trap drain fixed? Using the storage area pro y fields been cleared? What does the ground look like? Ovegetation left standing between the pond and sprinkler nnsfor Zone 4? '%1A)1N%%IAY14- ```' 'i tribution box lid in irrigation zone$ epaired? 'Y 5 AS Cfirm (AyS (O m to y wet spots down slope of the box?")ps 11 '�►1�ce 4Uo Says w r ow does the lagoon dam look? 5 �(� wa bi A� jV , ns'i1Q ar OwV abovc -Vegetation c eare on lagoon one . q Animal disturbance? What are plans to fix that- \t e l ,Q6� �` eS installed?s' b 'b� g I' ptSbPj i 9(IL i-bl Sc.l �ig tS Or Iyw meter being Flow i n t eln a rte re if cdn nuin to r Port vo ume rI ated. Q v tatus of permit renewal application? If an application is not submitted and the permit expires an illegal system will be operated, could result in further violations or enforcements. t rrigation equipment calibrated? Once per permit cycle �Iublic access restircted? i117 GA S } inb ill Ol.�.) Fu}hresponse to NOV? �J �J ��p tp5 Will looking for MW16 justification/explanaition i. evil ntt .A . t' �G-Pump house roof? Any plans to repair the roof, ref air the ails, and divers storm water from $Yorm water management?' SAW cok." DO45 f� ( CAWfc + ihASea IA Updated site map? VA Wpl yeA ej VAI 1tk oei l3 Updated O&M plan? Q �1 Using the newest NDMR/NDAR forms? it 11A ` V tat cleared properlyI IS Week -� & f 6_6.1 PeI,d en .ntor cert. Na n� ak.c_ ►tl po it? cle (6ns�y A C--a)y1 :)t S 1 oa\L c -l- ;+ *Chapter 4 of EPA Process Design Manual Land Treatment of Municipal Wastewater Effluent New permit owner address: 430 NC Hwy 49 S, Asheboro, NC 27205 Permit Modification: Explicitly state what the crop is Is a follow-up inspection necessary ❑ Yes ❑ No Primary Inspector: Caitlin Caudle Date of Inspection: 10/22/2020 Secondary Inspector: Rebecca Chandler 10 00 A Entry Time: Exit Time: 11,Oi 7 SbT vl9 e1.6 I 4ivi r-+° I (\ 2 (osS bean d LA)% ►,1 Z wttS,Qt%ki\ caf 1 weiAs t,.w imp ►n SOn j (J1.O n) \ G darn t 'o V-- , (on`-i th rlock co �n�Ee ho� 3 CON\VO-Orirrs 0.1emi G q(tArnbim co Orachrs w i lock ak- rCaSe k,raip c ouA also i n l-colt. -ROW Mew 4Se \e1.e.Yvv,41 3f 0&1'S 1oov (\ c ostiwAk holes 5(a )oo\V 1, asr 800-4\o‘A--Volf\ \DOx I w;11')rek(c3 / k othoM ( L(