WQ0002857_NOV-2024-PC-0452_20240722

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
July 22, 2024
Delivered electronically via email to: dmoore(d_)pied montcustommeats. com
Donna Moore, Owner
Chapel Road Properties, LLC
430 NC Highway 49 S
Asheboro, NC 27205
SUBJECT: Notice of Violation (NOV-2024-PC-0452)
Compliance Evaluation Inspection
Piedmont Custom Meats WWTF
Permit No. WQ0002857
Caswell County
Dear Ms. Moore:
On July 11, 2024, Division of Water Resources staff Caitlin Williams and Brooke Stevens
conducted a routine compliance inspection of the Piedmont Custom Meats WWTF. Glenn
Price, ORC, was present during the entire inspection. Larry Moore, Owner, was present
at the end of the inspection. A review of treatment facilities, storage structures, irrigation
fields, monitoring wells, and available records was completed. This review reflected non-
compliance with the subject permit.
Mrs. Williams requested digital records on July 1, 2024, prior to the inspection. The
following items have not been provided to date: residuals removal records, groundwater
monitoring reports, and soil reports. Please provide these records within fifteen (15) days
of receipt of this Notice.
The following violation was noted:
1. A fourth spray head was installed in Zone 4 when the zone was repaired in March
2022. The site map provided in the November 5, 2021 application package showed
four risers. The associated staff report noted that all material located by Mrs.
Williams and Mr. Moore showed three risers in Zone 4, as depicted on the original
facility site map. During previous site visits, Mrs. Williams discussed finding and
replacing a third riser in Zone 4, as only two were present. The fourth spray head
was originally noted in a follow up site visit completed August 8, 2022 to review
system repairs.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
NoanicaaouNn
oep.m.m or em�nmen� Qualm
336.776.9800

The fourth riser appears to have been installed without prior approval from the
Division. In addition, this riser was installed within 100ft of a stream. Per Permit
Condition 11.11.a. all irrigation sites shall have a setback of 100ft from surface
waters. A review of available records shows Zone 4 was initially irrigated on in July
2022 after several years of inactivity. Based on a review of available records, Zone
4 has been irrigated on twelve times since March 2022. At the time of inspection,
the fourth riser was capped due to previous operational issues.
The installation of a spray head without approval from the Division represents a
violation of the subject permit. General Statute 143-215.1(a)(3) states that to alter,
extend, or change the construction or method of operation of any sewer system,
treatment works, or disposal system within the State a valid permit must be
received. Zone 4 was extended without a valid permit and was installed in such a
way to violate the setbacks set forth in the subject permit. Immediately cap the
supply line to the fourth riser and remove the riser.
The following deficiencies were noted:
A. At the time of inspection, several maintenance items were noted. Per Permit
Condition V.1, the Permittee shall provide adequate inspection and maintenance
to ensure proper operation of the wastewater treatment and irrigation facilities.
a. Two new distribution boxes were installed in 2022 for irrigation Zones 1, 2,
and 3. Staff observed one of the distribution boxes was broken and
collapsing. Replace the distribution box to ensure the valve and supply
lines contained within are not damaged.
b. The irrigation zones have not been mowed this summer and a significant
amount of broadleaf weeds are still present. See Figure 1. The spray pattern
of Zone 3 #1 was impacted by broadleaf weeds, although this spray head
was not operational at the time of inspection. Mrs. Williams discussed the
use of broadleaf weed management methods with Mr. Moore. Mow the
spray zones as soon as possible and remove the weeds surrounding
Z3-1.
c. Along with Z3-1, several other spray heads were clogged or not operating
properly in all zones. Repair the faulty spray heads and continue to
monitor the spray heads during irrigation to ensure all spray heads
are spraying properly.
d. At the time of inspection, runoff from the bar screen catch basin was clearly
visible. See Figure 2. This was also mentioned in NOV-2022-PC-0004
dated January 10, 2022. Make efforts to clean the bar screen as needed
to ensure influent flow is not impeded, and staff are trained
appropriately to handle screenings.
NORTH CARCLINAD ��R
o.o+ro..m m EnNmnmenfnl n..i�
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

The following items of concern were noted:
• At the time of inspection, the freeboard of the lagoons was three feet. The 3ft
marking on the staff gauge was almost illegible. Per Permit Condition 111.13, the
staff gauge shall have readily visible permanent markings, at inch or tenth of a foot
increments, indicating the following elevations: maximum liquid level at the top of
the temporary liquid storage volume; minimum liquid level at the bottom of the
temporary liquid storage volume, and the lowest point on top of the dam. Install a
freeboard marker with the described markings in the secondary lagoon as
soon as possible.
• The three monitoring wells on site did not have clearly marked identification
numbers corresponding with the numbers in Attachment C, or well identification
plates. Per Permit Condition 11.3 all wells constructed for purposes of
groundwater monitoring shall be constructed in accordance with 15A NCAC 02C
.0108, which includes specific information that must be included on the
identification plate. Clearly mark all monitoring wells with the assigned
number in Attachment C and install well plates and include all information
required in 15A NCAC 02C .0108(p).
• The log book on site now includes the time and observations from the BUORC and
other Pace staff when they shut off the irrigation system. Pace staff will send Mr.
Price photos when on site. Please designate the additional Pace staff as
BUORCs as they are performing operational tasks.
Please refer to the enclosed inspection report for additional comments and observations.
Note the requested information and corrective actions outlined above. If you have any
questions, please contact Caitlin Williams at the letterhead address and phone number,
or by email at caitlin.williams(a)_deg.nc.gov.
Sincerely,
Docu Signed by:
OD2D3CE3F1 B1456_.
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enc: Inspection Report
Figures
Cc: Larry Moore, Owner (electronic copy)
Glenn Price, ORC (electronic copy)
Caswell County Environmental Health (electronic copy)
NORTH CAROLINAD � ��
oeo+ro�.m m F,mro���w n�si�
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

Figure 1. Broad leaf weeds in irrigation field.
Figure 2. Runoff from bar screen.
D North Carolina Department of Environmental Quality I Division of Water Resources
✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAROLINA 336.776.9800
onparhnem of EmironmanW 9uallly

Compliance Inspection Report
Permit: WQ0002857 Effective: 04/29/16 Expiration: 03/31/21 Owner : Chapel Road Properties LLC
SOC: Effective: Expiration: Facility: Piedmont Custom Meats WWTF
County: Caswell 9683 Kerr Chapel Rd
Region: Winston-Salem
Gibsonville NC 27249
Contact Person: Donna M Moore Title: 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: S1,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 07/11/2024 Entry Time 09:30AM Exit Time: 01:OOPM
pocuSigned by:
Primary Inspector: Caitlin i liams ,11 Phone: [phone]
Secondary Inspector(s):L6±834VU wtws
968199D49D...
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions Treatment Barscreen Record Keeping
Treatment Lagoons End Use -Irrigation Treatment Disinfection
Storage Wells
(See attachment summary)
Page 1 of 6

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 07/11/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On July 11, 2024, Division of Water Resources staff Caitlin Williams and Brooke Stevens conducted a routine compliance
inspection of the Piedmont Custom Meats WWTF. Glenn Price, ORC, was present during the entire inspection. Larry
Moore, Owner, was present at the end of the inspection. A review of treatment facilities, storage structures, irrigation fields,
monitoring wells, and available records was completed. This review reflected non-compliance with the subject permit.
Mrs. Williams requested records digitally before the inspection on July 1, 2024. The following items have not been provided
to date: residuals removal records, groundwater monitoring reports, and soil reports. Please provide these records within
fifteen (15) days of receipt of this Notice.
The following violation was noted:
1. A fourth spray head was installed in Zone 4 when the zone was repaired in March 2022. The site map provided in the
November 5, 2021 application package showed four risers. The associated staff report noted that all material located by Mrs.
Williams and Mr. Moore showed three risers in Zone 4, as depicted on the original facility site map. During previous site
visits, Mrs. Williams discussed finding and replacing a third riser in Zone 4, as only two were present. The fourth spray head
was originally noted in a follow up site visit completed August 8, 2022 to review system repairs.
The fourth riser appears to have been installed without prior approval from the Division. In addition, this riser was installed
within 100ft of a stream. Per Permit Condition 11.11.a. all irrigation sites shall have a setback of 100ft from surface waters. A
review of available records shows Zone 4 was initially irrigated on in July 2022 after several years of inactivity. Based on a
review of available records, Zone 4 has been irrigated on twelve times since March 2022. At the time of inspection, the fourth
riser was capped due to previous operational issues.
The installation of a spray head without approval from the Division represents a violation of the subject permit. General
Statute 143-215.1(a)(3) states that to alter, extend, or change the construction or method of operation of any sewer system,
treatment works, or disposal system within the State a valid permit must be received. Zone 4 was extended without a valid
permit and was installed in such a way to violate the setbacks set forth in the subject permit. Immediately cap the supply
line to the fourth riser and remove the riser.
The following deficiencies were noted:
A. At the time of inspection, several maintenance items were noted. Per Permit Condition V.1, the Permittee shall provide
adequate inspection and maintenance to ensure proper operation of the wastewater treatment and irrigation facilities.
a. Two new distribution boxes were installed in 2022 for irrigation Zones 1, 2, and 3. Staff observed one of the distribution
boxes was broken and collapsing. Replace the distribution box to ensure the valve and supply lines contained within are not
damaged.
b. The irrigation zones have not been mowed this summer and a significant amount of broadleaf weeds are still present.
See Figure 1. The spray pattern of Zone 3 #1 was impacted by broadleaf weeds, although this spray head was not
operational at the time of inspection. Mrs. Williams discussed the use of broadleaf weed management methods with Mr.
Moore. Mow the spray zones as soon as possible and remove the weeds surrounding Z3-1.
c. Along with Z3-1, several other spray heads were clogged or not operating properly in all zones. Repair the faulty spray
heads and continue to monitor the spray heads during irrigation to ensure all spray heads are spraying properly.
d. At the time of inspection, runoff from the bar screen catch basin was clearly visible. See Figure 2. This was also
mentioned in NOV-2022-PC-0004 dated January 10, 2022. Make efforts to clean the bar screen as needed to ensure influent
flow is not impeded, and staff are trained appropriately to handle screenings.
The following items of concern were noted:
• At the time of inspection, the freeboard of the lagoons was three feet. The 3ft marking on the staff gauge was almost
illegible. Per Permit Condition 111.13, the staff gauge shall have readily visible permanent markings, at inch or tenth of a foot
increments, indicating the following elevations: maximum liquid level at the top of the temporary liquid storage volume;
Page 2 of 6

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 07/11/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
minimum liquid level at the bottom of the temporary liquid storage volume, and the lowest point on top of the dam. Install a
freeboard marker with the described markings in the secondary lagoon as soon as possible.
• The three monitoring wells on site did not have clearly marked identification numbers corresponding with the numbers in
Attachment C, or well identification plates. Per Permit Condition 11.3 all wells constructed for purposes of groundwater
monitoring shall be constructed in accordance with 15A NCAC 02C .0108, which includes specific information that must be
included on the identification plate. Clearly mark all monitoring wells with the assigned number in Attachment C and install
well plates and include all information required in 15A NCAC 02C .0108(p).
• The log book on site now includes the time and observations from the BUORC and other Pace staff when they shut off
the irrigation system. Pace staff will send Mr. Price photos when on site. Please designate the additional Pace staff as
BUORCs as they are performing operational tasks.
Other observations:
• Zones 1-3 have four spray heads present in each zone. The original site map shows that five spray heads were installed
for each zone. Mr. Price stated only four spray heads were present when R&A, now Pace Analytical, originally started
managing the system.
• The acreage listed in Att B is not being used as a spray head has been removed from Z1-3. This will be addressed with
the permit renewal.
• The old risers were not removed after the new irrigation equipment was installed.
• The tall risers observed in Zone 4 during the August 8, 2022, site visit were lowered to a reasonable height.
• The tannery operations have been suspended. The "salt burned" area downslope of the building is still visible with no
vegetation.
• The concrete surrounding the grease trap, bar screen, and catch basin has not been replaced.
• The gut bin was repaired, not replaced.
• Valley Protein is still taking solids from the bar screen and gut bin.
• The lagoon embankments have been repaired. The dry weather has prevented grass from being established. The
disturbed areas are covered with straw.
• The manure capture basin was in good shape. The manure capture area is uncovered, and it may pose a risk from
stormwater entering the system. If this area begins to impact the freeboard of the lagoons, further action may be taken.
• Irrigation volumes are determined by multiplying the run time of the pump by the gpm rating.
• The irrigation system has not been calibrated since 2021 as a new permit has not been issued since the most recent
permit expired in 2021. The irrigation system was last calibrated 4/15/2021.
• Fecal coliform results have been >2,000 MPN/g five times in 2022, 2023, and 2024.
• Mr. Moore has requested an in -person meeting as part of the permit renewal process.
• Effluent, MW, and surface water samples were collected as part of the permit renewal process.
• The pump house repairs are still in good shape.
• The new spray heads are Irrigation King RK-41 with'/" nozzles.
Page 3 of 6

Permit: WQ0002857
Inspection Date: 07/11/2024
Owner - Facility: Chapel Road Properties LLC
Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Yes No NA NE
Reuse (Quality)
❑
Infiltration System
❑
Single Family Spray, LR
❑
Activated Sludge Spray, LR
❑
Activated Sludge Spray, HR
❑
Activated Sludge Drip, LR
❑
Single Family Drip
❑
Recycle/Reuse
❑
Lagoon Spray, LR
Treatment Barscreen Yes No NA NE
Is it free of excessive debris? ❑ ❑ ❑
Is disposal of screenings in compliance? ❑ ❑ ❑
Are the bars spaced properly? ❑ ❑ ❑
Is the unit in good condition? ❑ N ❑ ❑
Comment: See summary.
Treatment Disinfection
Yes No NA NE
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: See summary.
Page 4 of 6

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 07/11/2024 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes No NA NE
Is a copy of current permit available?
❑ ❑ ❑
Are monitoring reports present: NDMR?
❑ ❑ ❑
NDAR?
❑ ❑ ❑
Are flow rates less than of permitted flow?
❑ ❑ ❑
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: See summary.
End Use -Irrigation
Yes No NA NE
Are buffers adequate?
❑
0 ❑ ❑
Is the cover crop type specified in permit?
❑
❑ 0 ❑
Is the crop cover acceptable?
❑
0 ❑ ❑
Is the site condition adequate?
❑
0 ❑ ❑
Is the site free of runoff / ponding?
0
❑ ❑ ❑
Is the acreage specified in the permit being utilized?
❑
❑ ❑
Is the application equipment present?
❑ ❑ ❑
Is the application equipment operational?
0
❑ ❑ ❑
Page 5 of 6

Permit: WQ0002857 Owner - Facility: Chapel Road Properties LLC
Inspection Date: 07/11/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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?
Comment: See summary.
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Page 6 of 6