WQ0002857_NOV-2022-PC-0004_20220110

ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
January 10, 2022
CERTIFIED MAIL NUMBER 7018 1130 0000 1612 8090
RETURN RECIEPT REQUESTED
Donna M. Moore — President
Chapel Road Properties, LLC
43 NC 49 South
Asheboro, North Carolina 27205
SUBJECT: Notice of Violation with Intent to Enforce
NOV-2022-PC-0004
Compliance Evaluation Inspection
Permit No. WQ0002857
Piedmont Custom Meats WWTF
Wastewater Irrigation System
Caswell County
Dear Ms. Moore:
On December 20, 2021, Division of Water Resources staff Caitlin Caudle and Tricia
Lowery conducted an announced compliance inspection at the above -mentioned facility.
Glenn Price, ORC, of Pace Analytical was present during the initial review of the facility
and records; and Larry Moore of Piedmont Custom Meats was present to review the
facility. A review of records, irrigation zones, lagoons, bar screen and grease trap, pump
house, animal waste collection area, and tannery were completed. This review reflects
non-compliance with the subject permit.
The following violations were noted:
1. The distribution box for Zones 1, 2, and 3 has not been repaired. A PVC pipe was
installed in the corner of the box to mark the location. The lid was broken in two
pieces and the distribution box was still broken (Figure 1). This violation was also
referenced in NOV-2020-PC-0392 (Item 6). Mr. Moore stated that he is waiting on
a plumber to become available to repair the distribution box.
This is a violation of Permit Condition 111.1 "the facilities shall be properly
maintained ... at all times," and Permit Condition V.I "the Permittee shall
provide adequate inspection and maintenance to ensure proper operation of
the wastewater treatment and irrigation facilities." Repair the distribution
box within sixty (60) days of receipt of this letter.
NORTH
D E
Dopartmem of Envimnmomni au.i`
North Carolina Department of Environmental Quality Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

2
2. There was no standing water present in the pumphouse at the time of the
inspection. The permit renewal application stated, "the plumber has been selected
and is scheduled to install the sump pump by the end of November 2021." Mr.
Moore stated that he cannot locate a plumber or electrician to install the sump
pump, but the new pump is on site.
The hole beside the door to the pumphouse caused by stormwater erosion is still
present. This hole was referenced in NOV-2020-PC-0392 (Item 6). There was also
evidence of several other holes and damage around the interior of the pumphouse
walls caused by erosion, standing water, and potentially infiltration (Figure 2).
This is a violation of Permit Condition 111.1 "the facilities shall be properly
maintained ... at all times," and Permit Condition V.I "the Permittee shall
provide adequate inspection and maintenance to ensure proper operation of
the wastewater treatment and irrigation facilities." Repair the hole beside the
door within sixty (60) days of receipt of this letter and take measures to repair
and prevent further damage to the interior walls.
3. Residual removal records were not available at the time of inspection. Mr. Moore
stated that he could provide the date of when residuals were removed and the
destination of residuals removed by Valley Protein, Inc. but not the volume, and
the date of residuals removal by 64 Portables but not the volume or the facility that
is accepting the residuals. Lack of residuals removal records was also referenced
in NOV-2020-PC-0392 (Item 4).
Failure to maintain residuals removal records is a violation of Permit Condition
IV.8 "a record shall be maintained of all residuals removed from this facility
... At a minimum, this record shall include: a. name of the residual hauler, b.
non -discharge permit number authorizing the residuals disposal, or a letter
from a municipality agreeing to accept the residuals, c. date the residuals
were hauled; and d. volume of residuals removed. Moving forward, maintain
a record of residuals removed with, at a minimum, the information listed
above.
The Residuals Management Plan was available for review at the time of inspection.
The Residuals Management Plan was inadequate. The following information
should be included:
a. A solids removal schedule should be added.
b. A detailed explanation as to how residuals will be collected, handled,
processed, stored, and disposed should be added.
c. An evaluation of the residuals storage requirements for the treatment facility
based upon the maximum anticipated residuals production rate and the
ability to remove residuals should be added.
d. A written commitment to the permittee of a Department -approved residuals
management program accepting the residuals that demonstrates that the
approved program has adequate capacity to accept the residuals should be
included.

3
e. If oil, grease, or screenings removal and collection is a designed unit
process, a detailed explanation as to how these materials will be collected,
handled, process, stores, and disposed of should be included.
i. This includes the residuals removed from the bar screen and grease
trap. An example would be: The bar screen will be inspected once a
day. Bar screenings will be placed in a container in the catch basin.
When the container is full it will be stored on the concrete
surrounding the bar screen. These containers will be emptied once
a week by Valley Protein, Inc.
f. A method for determining the amount of sludge in the lagoons or a regular
schedule for removing sludge should be added.
Please submit an updated Residuals Management Plan within thirty (30) days
of receipt of this letter.
4. At the time of inspection, several of the more severe holes on the lagoon
embankments had been filled. The large holes on the south side of Lagoon 1, an
area between the two lagoons, and an area on the east side of Lagoon 2 had been
filled (Figure 3). Mr. Moore stated that fill dirt was placed in the holes and packed
down with a skid steer four to five months ago by the contractor who did some
grading work around the facility. Several holes have yet to be repaired on the south
side of Lagoon 2, and other small holes on both lagoon embankments. The ground
hog holes on the exterior embankment of Lagoon 1 have not been refilled. Mr.
Moore stated that efforts are ongoing to remove the animals responsible.
This is an ongoing violation as referenced in NOV-2020-PC-0392 (Item 6) and
correspondence dated December 29, 2020. Animal burrow holes were previously
noted in correspondence from DWR dated April 15, 2015. Current design
standards (15 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 1 x10-6 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." Finish
repairing the remaining holes on both lagoons within sixty (60) days of
receipt of this letter and continue to make efforts to remove the nuisance
animals. Make efforts to establish vegetation on the repaired areas of the
embankments.
5. The risers in the irrigation zones have not been repaired. The permit renewal
application states that "plumbers will be on -site in approximately two to four weeks
to make these repairs." Mr. Moore stated that they have been unable to contract a
plumber or pipe runners to repair the irrigation system, but when someone is hired
all risers that need attention will be repaired and he has ordered 24 spray heads.
Ms. Caudle requested that Mr. Moore provide an invoice or proof of purchase
of the spray heads, and it has not been received to date. The following
necessary repairs were noted and labeled on the attached site map:

4
o A groundhog hole is present beside the riser of #1 in Z1, and the spray head
is clogged. Mr. Price has been unable to repair it, a more detailed repair is
needed. This riser was flagged for repair.
o #2 in Z1 is broken at the shut-off valve, and as a result is spraying a fan of
wastewater around the riser. The ball valve needs to be repaired. This riser
was flagged for repair.
o #3 and #4 in Z1 both have small depressions around the bottom of the riser
and are retaining water, and potentially wastewater. These depressions
need to be filled to prevent ponding water from damaging the riser.
o #4 in Z2 has a slight depression around the base of the riser. Some water
was present in the depression, unlike #3 and #4 in Z1. This could be
rainwater from the -0.5 inches received the previous weekend. This
depression needs to be filled to prevent ponding water from damaging the
riser.
o #1 in Z3 is broken off underground. There is evidence that runoff from this
riser is present. There is a patch of vibrant green grass directly downslope
of the riser. The supply line and riser need to be excavated and repaired.
This riser was flagged for repair.
o #3 in Z3 has a slight depression around the base of the riser. This
depression needs to be filled to prevent ponding water from damaging the
riser.
o #1 in Z4 could not be located. Mr. Moore stated that they will tie #1 back to
#2 and install new piping and a new riser. If this is not done, the acreage of
this zone will need to be updated. Ms. Caudle emphasized that Mr. Moore
should ensure that there is not a broken, un-capped pipe present before re-
installing the riser.
o #3 in Z4 has a hole in the riser pipe. This hole needs to be repaired before
this zone can be used again.
Failure to repair the above items is preventing the irrigation facility from operating
correctly as at least one riser in each zone needs repair. Failure to repair the above
items is a violation of Permit Condition 111.1 "the facilities shall be properly
maintained ... at all times," and Permit Condition V.I "the Permittee shall
provide adequate inspection and maintenance to ensure proper operation of
the wastewater treatment and irrigation facilities." Repair the spray zones
within sixty (60) days of receipt of this letter.
The following deficiencies were noted:
I. The Maintenance log is not maintained at the facility as required by the permit. Mr.
Price stated that he always keeps the maintenance log with him due to animals
damaging previous inspection logs kept in the pump house. Mr. Price also stated
that the back up ORC, Garrett Dreyer, will turn off the irrigation system and walk
the fields after irrigation. Mr. Dreyer's observations are not included in the
maintenance log as a result.
This is a violation of Permit Condition IV.9 "a maintenance log shall be
maintained at this facility. This log shall be maintained at the facility ... At a
minimum, this log shall include: a. Visual observations of the plant and plant

5
site, and b. record of preventative maintenance (e.g., changing of equipment,
adjustments, testing, inspections and cleanings, etc.). Moving forward,
maintain an inspection log on site with all observations and maintenance
performed at the facility.
II. At the time of inspection, the Operation and Maintenance Plan and Spill Plan were
available for review but were found to be inadequate. This was also referenced in
NOV-2020-PC-0392 (Item C). The following corrections and updates for the
Operations and Maintenance Plan should be completed:
a. Language needs to be added stating that WSRO must be notified when
freeboard < 2ft.
b. The operational procedures also include notifying Jerry of certain things.
Jerry Matkins was the previous owner; the O&M plan should be updated
to remove Jerry.
c. The effluent parameters listed are incorrect based on the most recent
Attachment A. The following parameters should be added: pH, total
phosphorus, and total nitrogen.
d. The monitoring well parameters listed are incorrect based on the most
recent Attachment C. Conductivity should be removed, and pH added.
e. The soil parameters are missing pH. This should be added.
f. The responsibilities of staff at Piedmont Custom Meats should also be
included, such as notifying the operator in emergency situations or
removing vegetation from the spray zones.
g. A mowing schedule should be added to the operational procedures.
The Spill plan provided in the permit renewal application listed information that
applies to collection system overflows, but Mr. Price had updated it by the time of
inspection to reflect non -discharge spill response procedures. The following
information is still needed:
a. Response to upsets and bypasses, including control, containment, and
remediation.
b. Contact information for plant personnel, emergency responders, and
regulatory agencies.
Please submit updated Operation and Maintenance Plan and Spill Plan within
thirty (30) days of receipt of this letter.
III. The most recent Non Discharge Monitoring Report and Non Discharge Application
Report forms are not in use. This was referenced in NOV-2020-PC-0392. Permit
Condition IV.5 lists all parameters that must be recorded during irrigation events
and the forms currently being used do not include all information listed in this permit
condition. Please begin using the most recent NDMR and NDAR forms within
thirty (30) days of receipt of this letter. Custom forms can be requested.
The following items of concern were noted:
A. A copy of the most recent permit was not available for review at the time of
inspection. The permit contains all performance standards, operation and
maintenance requirements, monitoring and reporting requirements, and general

6
information relating to the system. Moving forward, a copy of the most recent
permit must be maintained on site and readily available.
B. Freeboard was 2ft at the time of inspection. As a reminder, Permit Condition 111.12
states "freeboard in the primary and secondary lagoons shall not be less
than two feet at any time." Please take measures to lower the freeboard and
maintain it at an acceptable level.
C. The tannery on site was in operation at the time of the inspection. The tannery was
returned to operations within the past two years. A new pipe had been installed to
drain leachate from the tannery building to the derelict storage tanks outside of the
building since the last site visit. The storage tank that wastewater is currently being
drained to has several holes at ground level. The second storage tank is in better
condition but the pipe to transfer wastewater between the storage tanks is above
the holes in the first storage tank. There is a clear path where the leachate is
traveling downslope towards the on -site freshwater pond (Figure 4). The area
downslope of the storage tanks is in worse condition than it was at previous site
visits.
Tannery wastewater can have organic and inorganic compound, nitrogenous
compounds, chromium, sulfides, and suspended and dissolved solids.
Ms. Caudle discussed repairing or replacing the storage tank to prevent continued
runoff. Ms. Caudle advised that piping the wastewater to the lagoons could
negatively impact the quality of the effluent sprayed, and eventually negatively
impact the spray zones due to the high salt content of the wastewater in question.
Please work with Ms. Caudle to develop a Plan of Action to address these
issues within (30) days of receipt of this letter.
D. The containers used to hold bar screenings before they are hauled away did not
have any cracks or holes visible. A total of four containers were present. Mr. Moore
stated that Valley Protein, Inc. empties the containers weekly. It appeared that the
drain in the catch basin area had been jetted and now operated properly, but the
drain cover was broken. There was some evidence of runoff and other solids in the
grass surrounding the bar screen. The containers are being stored on the concrete
surrounding the bar screen. Improper storage and handling of bar screenings was
also referenced in NOV-2020-PC-0392 (Item 4). The permit renewal application
stated that gravel or a concrete pad would not be installed because it was
"cosmetic in nature and would not serve any real purpose."
Moving forward, please use the catch basin area to transfer bar screenings
from the bar screen to the containers, rather than placing the containers
outside of the containment walls surrounding the bar screen and catch basin.
The containers that aren't actively being used may be stored on the concrete
beside the bar screen.
E. The drain from the manure capture area is piped into the lagoons. The concrete
pad that collects manure and other leachate is not covered and may pose a risk to
introducing stormwater to the lagoons. Mr. Moore stated that as of right now, there
has been no issue with stormwater and the lagoons. Please continue to monitor
this area to ensure that excessive stormwater runoff from the roof of the

7
animal containment area is not entering the lagoons. If this area begins to
impact the freeboard of the lagoons, further action may be taken.
F. Permit Condition 111.1, Permit Condition 111.6, Permit Condition IV.5, Permit
Condition IV.6, Permit Condition IV.8, Permit Condition IV.9, Permit
Condition IV.13, and Permit Condition V.2 require various records, inspection
logs, and maintenance information be maintained on site at all times for at least
five year. Please review these permit conditions and maintain the appropriate
information on site.
Your immediate attention to the items listed above is needed. If you wish to provide
additional information regarding the noted violations, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) days after receipt of
this Notice. Failure to address the items listed in this Notice in the allotted time frame
could result in enforcement action. A follow up inspection will be scheduled within one
hundred and twenty (120) days of receipt of this letter.
Please refer to the enclosed site map and inspection report for additional observations
and information. If you have any questions regarding this Notice, please contact Caitlin
Caudle or me at the letterhead address or phone number, or by email at
caitlin.caudle©ncdenr.gov.
Sincerely,
DocuSigned by:by�
%ig
A. l . 5/4.1kr
"- 145B49E225C94 EA.
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ- WSRO
Enc: Inspection Report
Site Map
Photos
Cc: Caswell County Environmental Health (electronic)
Glenn Price, Pace Analytical (electronic)
WSRO Electronic Files
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: [phone]
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: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 12/20/2021
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Entry Time 10:10AM
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
▪ Treatment Flow Measurement -Effluent
▪ Treatment Flow Measurement -Water
Use Records
▪ Record Keeping
▪ End Use -Irrigation
▪ Wells
(See attachment summary)
Exit Time: 01:15PM
Phone: [phone]
Inspection Type: Compliance Evaluation
▪ Treatment Flow Measurement -Influent
▪ Treatment
▪ Treatment Lagoons
▪ Treatment Disinfection
▪ Miscellaneous Questions
▪ Treatment Barscreen
▪ Treatment Sludge Storage/Treatment
▪ Treatment Flow Measurement
Page 1 of 9

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 12/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On December 20, 2021, Division of Water Resources staff Caitlin Caudle and Tricia Lowery conducted an announced
compliance inspection at the above -mentioned facility. Glenn Price, ORC, of Pace Analytical was present during the initial
review of the facility and records; and Larry Moore of Piedmont Custom Meats was present to review the facility. A review of
records, irrigation zones, lagoons, bar screen and grease trap, pump house, animal waste collection area, and tannery were
completed. This review reflects non-compliance with the subject permit.
The following violations were noted:
1. The distribution box for Zones 1, 2, and 3 has not been repaired. A PVC pipe was installed in the corner of the box to
mark the location. The lid was broken in two pieces and the distribution box was still broken (Figure 1). This violation was
also referenced in NOV-2020-PC-0392 (Item 6). Mr. Moore stated that he is waiting on a plumber to become available to
repair the distribution box.
This is a violation of Permit Condition 111.1 "the facilities shall be properly maintained ... at all times," and Permit Condition
V.I "the Permittee shall provide adequate inspection and maintenance to ensure proper operation of the wastewater
treatment and irrigation facilities." Repair the distribution box within sixty (60) days of receipt of this letter.
2. There was no standing water present in the pumphouse at the time of the inspection. The permit renewal application
stated, "the plumber has been selected and is scheduled to install the sump pump by the end of November 2021." Mr.
Moore stated that he cannot locate a plumber or electrician to install the sump pump, but the new pump is on site.
The hole beside the door to the pumphouse caused by stormwater erosion is still present. This hole was referenced in
NOV-2020-PC-0392 (Item 6). There was also evidence of several other holes and damage around the interior of the
pumphouse walls caused by erosion, standing water, and potentially infiltration (Figure 2).
This is a violation of Permit Condition 111.1 "the facilities shall be properly maintained ... at all times," and Permit Condition
V.I "the Permittee shall provide adequate inspection and maintenance to ensure proper operation of the wastewater
treatment and irrigation facilities." Repair the hole beside the door within sixty (60) days of receipt of this letter and take
measures to repair and prevent further damage to the interior walls.
3. Residual removal records were not available at the time of inspection. Mr. Moore stated that he could provide the date of
when residuals were removed and the destination of residuals removed by Valley Protein, Inc. but not the volume, and the
date of residuals removal by 64 Portables but not the volume or the facility that is accepting the residuals. Lack of residuals
removal records was also referenced in NOV-2020-PC-0392 (Item 4).
Failure to maintain residuals removal records is a violation of Permit Condition IV.8 "a record shall be maintained of all
residuals removed from this facility ... At a minimum, this record shall include: a. name of the residual hauler, b.
non -discharge permit number authorizing the residuals disposal, or a letter from a municipality agreeing to accept the
residuals, c. date the residuals were hauled; and d. volume of residuals removed. Moving forward, maintain a record of
residuals removed with, at a minimum, the information listed above.
The Residuals Management Plan was available for review at the time of inspection. The Residuals Management Plan was
inadequate. The following information should be included:
a. A solids removal schedule should be added.
b. A detailed explanation as to how residuals will be collected, handled, processed, stored, and disposed should be added.
c. An evaluation of the residuals storage requirements for the treatment facility based upon the maximum anticipated
residuals production rate and the ability to remove residuals should be added.
d. A written commitment to the permittee of a Department -approved residuals management program accepting the
residuals that demonstrates that the approved program has adequate capacity to accept the residuals should be included.
e. If oil, grease, or screenings removal and collection is a designed unit process, a detailed explanation as to how these
Page 2 of 9

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 12/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
materials will be collected, handled, process, stores, and disposed of should be included.
i. This includes the residuals removed from the bar screen and grease trap. An example would be: The bar screen will be
inspected once a day. Bar screenings will be placed in a container in the catch basin. When the container is full it will be
stored on the concrete surrounding the bar screen. These containers will be emptied once a week by Valley Protein, Inc.
f. A method for determining the amount of sludge in the lagoons or a regular schedule for removing sludge should be
added.
Please submit an updated Residuals Management Plan within thirty (30) days of receipt of this letter.
4. At the time of inspection, several of the more severe holes on the lagoon embankments had been filled. The large holes
on the south side of Lagoon 1, an area between the two lagoons, and an area on the east side of Lagoon 2 had been filled
(Figure 3). Mr. Moore stated that fill dirt was placed in the holes and packed down with a skid steer four to five months ago
by the contractor who did some grading work around the facility. Several holes have yet to be repaired on the south side of
Lagoon 2, and other small holes on both lagoon embankments. The ground hog holes on the exterior embankment of
Lagoon 1 have not been refilled. Mr. Moore stated that efforts are ongoing to remove the animals responsible.
This is an ongoing violation as referenced in NOV-2020-PC-0392 (Item 6) and correspondence dated December 29, 2020.
Animal burrow holes were previously noted in correspondence from DWR dated April 15, 2015. Current design standards (15
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." Finish repairing the remaining holes on both lagoons within sixty (60) days of receipt of this letter and
continue to make efforts to remove the nuisance animals. Make efforts to establish vegetation on the repaired areas of the
embankments.
5. The risers in the irrigation zones have not been repaired. The permit renewal application states that "plumbers will be
on -site in approximately two to four weeks to make these repairs." Mr. Moore stated that they have been unable to contract
a plumber or pipe runners to repair the irrigation system, but when someone is hired all risers that need attention will be
repaired and he has ordered 24 spray heads. Ms. Caudle requested that Mr. Moore provide an invoice or proof of purchase c
the spray heads, and it has not been received to date. The following necessary repairs were noted and labeled on the
attached site map:
o A groundhog hole is present beside the riser of #1 in Z1, and the spray head is clogged. Mr. Price has been unable to
repair it, a more detailed repair is needed. This riser was flagged for repair.
o #2 in Z1 is broken at the shut-off valve, and as a result is spraying a fan of wastewater around the riser. The ball valve
needs to be repaired. This riser was flagged for repair.
o #3 and #4 in Z1 both have small depressions around the bottom of the riser and are retaining water, and potentially
wastewater. These depressions need to be filled to prevent ponding water from damaging the riser.
o #4 in Z2 has a slight depression around the base of the riser. Some water was present in the depression, unlike #3 and
#4 in Z1. This could be rainwater from the —0.5 inches received the previous weekend. This depression needs to be filled to
prevent ponding water from damaging the riser.
o #1 in Z3 is broken off underground. There is evidence that runoff from this riser is present. There is a patch of vibrant
green grass directly downslope of the riser. The supply line and riser need to be excavated and repaired. This riser was
flagged for repair.
o #3 in Z3 has a slight depression around the base of the riser. This depression needs to be filled to prevent ponding water
from damaging the riser.
o #1 in Z4 could not be located. Mr. Moore stated that they will tie #1 back to #2 and install new piping and a new riser. If
this is not done, the acreage of this zone will need to be updated. Ms. Caudle emphasized that Mr. Moore should ensure
that there is not a broken, un-capped pipe present before re -installing the riser.
o #3 in Z4 has a hole in the riser pipe. This hole needs to be repaired before this zone can be used again.
Failure to repair the above items is preventing the irrigation facility from operating correctly as at least one riser in each zone
needs repair. Failure to repair the above items is a violation of Permit Condition 111.1 "the facilities shall be properly
Page 3 of 9

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 12/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
maintained ... at all times," and Permit Condition V.I "the Permittee shall provide adequate inspection and maintenance to
ensure proper operation of the wastewater treatment and irrigation facilities." Repair the spray zones within sixty (60) days of
receipt of this letter.
The following deficiencies were noted:
I. The Maintenance log is not maintained at the facility as required by the permit. Mr. Price stated that he always keeps
the maintenance log with him due to animals damaging previous inspection logs kept in the pump house. Mr. Price also
stated that the back up ORC, Garrett Dreyer, will turn off the irrigation system and walk the fields after irrigation. Mr.
Dreyer's observations are not included in the maintenance log as a result.
This is a violation of Permit Condition IV.9 "a maintenance log shall be maintained at this facility. This log shall be
maintained at the facility ... At a minimum, this log shall include: a. Visual observations of the plant and plant site, and b.
record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections and cleanings, etc.).
Moving forward, maintain an inspection log on site with all observations and maintenance performed at the facility.
II. At the time of inspection, the Operation and Maintenance Plan and Spill Plan were available for review but were found to
be inadequate. This was also referenced in NOV-2020-PC-0392 (Item C). The following corrections and updates for the
Operations and Maintenance Plan should be completed:
a. Language needs to be added stating that WSRO must be notified when freeboard < 2ft.
b. The operational procedures also include notifying Jerry of certain things. Jerry Matkins was the previous owner; the O&M
plan should be updated to remove Jerry.
c. The effluent parameters listed are incorrect based on the most recent Attachment A. The following parameters should be
added: pH, total phosphorus, and total nitrogen.
d. The monitoring well parameters listed are incorrect based on the most recent Attachment C. Conductivity should be
removed, and pH added.
e. The soil parameters are missing pH. This should be added.
f. The responsibilities of staff at Piedmont Custom Meats should also be included, such as notifying the operator in
emergency situations or removing vegetation from the spray zones.
g. A mowing schedule should be added to the operational procedures.
The Spill plan provided in the permit renewal application listed information that applies to collection system overflows, but
Mr. Price had updated it by the time of inspection to reflect non -discharge spill response procedures. The following
information is still needed:
• Response to upsets and bypasses, including control, containment, and remediation.
• Contact information for plant personnel, emergency responders, and regulatory agencies.
Please submit updated Operation and Maintenance Plan and Spill Plan within thirty (30) days of receipt of this letter.
III. The most recent Non Discharge Monitoring Report and Non Discharge Application Report forms are not in use. This was
referenced in NOV-2020-PC-0392. Permit Condition IV.5 lists all parameters that must be recorded during irrigation events
and the forms currently being used do not include all information listed in this permit condition. Please begin using the most
recent NDMR and NDAR forms within thirty (30) days of receipt of this letter. Custom forms can be requested.
The following items of concern were noted:
A. A copy of the most recent permit was not available for review at the time of inspection. The permit contains all
performance standards, operation and maintenance requirements, monitoring and reporting requirements, and general
information relating to the system. Moving forward, a copy of the most recent permit must be maintained on site and readily
available.
B. Freeboard was 2ft at the time of inspection. As a reminder, Permit Condition 111.12 states "freeboard in the primary and
Page 4 of 9

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 12/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
secondary lagoons shall not be less than two feet at any time." Please take measures to lower the freeboard and maintain it
at an acceptable level.
C. The tannery on site was in operation at the time of the inspection. The tannery was returned to operations within the
past two years. A new pipe had been installed to drain leachate from the tannery building to the derelict storage tanks
outside of the building since the last site visit. The storage tank that wastewater is currently being drained to has several
holes at ground level. The second storage tank is in better condition but the pipe to transfer wastewater between the
storage tanks is above the holes in the first storage tank. There is a clear path where the leachate is traveling downslope
towards the on -site freshwater pond (Figure 4). The area downslope of the storage tanks is in worse condition than it was at
previous site visits.
Tannery wastewater can have organic and inorganic compound, nitrogenous compounds, chromium, sulfides, and
suspended and dissolved solids.
Ms. Caudle discussed repairing or replacing the storage tank to prevent continued runoff. Ms. Caudle advised that piping the
w
Page 5 of 9

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 12/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Reuse (Quality)
Infiltration System
Single Family Spray, LR
Activated Sludge Spray, LR
Activated Sludge Spray, HR
Activated Sludge Drip, LR
Recycle/Reuse
Single Family Drip
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.)
Yes No NA NE
•
Yes No NA NE
❑ • ❑ ❑
• ❑ ❑ ❑
Comment: A manure capture area is piped into the system now. This adds manure leachate into the
system.
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: A water meter is used to measure influent flow.
Treatment Flow Measurement -Water Use Records
Is water use metered?
Are the daily average values properly calculated?
Comment:
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?
Yes No NA NE
▪ •
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❑ • ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
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• ❑ ❑ ❑
Yes No NA NE
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
Comment: A flowmeter is not used to measure effluent. Effluent irrigated is measured by using the GPM of
the pump and the time irrigated.
Page 6 of 9

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 12/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Treatment Barscreen
Is it free of excessive debris?
Is disposal of screenings in compliance?
Are the bars spaced properly?
Is the unit in good condition?
Comment:
Treatment Sludge Storage/Treatment
Is the aeration operational?
Is the aeration pattern even?
If required, are Sanitary "Ts" present in tankage?
Comment:
Treatment Disinfection
Is the system working?
Do the fecal coliform results indicate proper disinfection?
Is there adequate detention time (>=30 minutes)?
Is the system properly maintained?
If gas, does the cylinder storage appear safe?
Is the fan in the chlorine feed room and storage area operable?
Is the chlorinator accessible?
If tablets, are tablets present?
Are the tablets the proper size and type?
Is contact chamber free of sludge, solids, and growth?
If UV, are extra UV bulbs available?
If UV, is the UV intensity adequate?
# Is it a dual feed system?
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
Comment: The chlorinator was not accessible for review.
Record Keeping
Is a copy of current permit available?
Are monitoring reports present: NDMR?
NDAR?
Are flow rates less than of permitted flow?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ • ❑ ❑
❑ ❑•❑
❑ ❑•❑
❑ ❑ ❑•
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑•❑
❑ ❑•❑
Yes No NA NE
▪ •
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 7 of 9

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 12/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Are flow rates less than of permitted flow?
Are application rates adhered to?
Is GW monitoring being conducted, if required (GW-59s submitted)?
Are all samples analyzed for all required parameters?
Are there any 2L GW quality violations?
Is GW-59A certification form completed for facility?
Is effluent sampled for same parameters as GW?
Do effluent concentrations exceed GW standards?
Are annual soil reports available?
# Are PAN records required?
# Did last soil report indicate a need for lime?
If so, has it been applied?
Are operational logs present?
Are lab sheets available for review?
Do lab sheets support data reported on NDMR?
Do lab sheets support data reported on GW-59s?
Are Operational and Maintenance records present?
Were Operational and Maintenance records complete?
Has permittee been free of public complaints in last 12 months?
Is a copy of the SOC readily available?
No treatment units bypassed since last inspection?
Comment: Soils had not been sampled at the time of inspection.
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?
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
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• ❑ ❑ ❑
❑•❑ ❑
❑ ❑ • ❑
❑ ❑ ❑•
❑ ❑ ❑•
• ❑ ❑ ❑
• ❑ ❑ ❑
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• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
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A copy of the permit was not available.
Yes No NA NE
• ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑•❑ ❑
• ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑•❑ ❑
❑•❑ ❑
❑ ❑ ❑•
Page 8 of 9

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 12/20/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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?
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: A cover crop is not specified. All acreage in the permit is not being used because the irrigation
zones are in need of repair. All irrigation equipment is not operational. The monitoring wells
were in good condition.
Page 9 of 9

Bar Screen
Grease Removal Chambers
Lagoon No.1
NOTE: Site map sketch is NOT drawn to scale, and is intended for WSRO reference purposes enly_
SOURCES: Aerial photo, roads layer, and parcel boundaries provided by Caswell County GIS dept. E
4}81
911028, E: 1845578
k: 35°15' 07.0", Lng:-79°31' 25.3"

December 20, 2021
Figure 1

December 20, 2021
Figure 2
March 17, 2021
7

mow
Lagoon 1
. Center Embankment
December 20, 2021
Figure 3
March 25, 2021 I
Lagoon 2
March 17, 2021
December 20, 2021

December 20, 2021 December 20, 2021
March 17, 2021
Figure 4
December 20, 2021