WQCS00280_NOV-2019-PC-0682_20191010

October 10, 2019

William Doerfer, Town Manager
Town of Liberty
PO Box 1006
Liberty, NC 27298-3212

Subject: Compliance Evaluation Inspection Report and Notice of Violation
NOV Tracking No. NOV-2019-PC-0682
Wastewater Collection System Permit WQCS00280
Liberty Collection System, Randolph County
Dear Mr. Doerfer:
On September 5, 2019, Paul DiMatteo of the Division of Water Resources (Division), Winston-
Salem Regional Office met with Kevin Coble, Operator in Responsible Charge (ORC), Tremaine Fixe,
backup-ORC, and William Doerfer to conduct a Compliance Evaluation Inspection of the above
referenced Wastewater Collection System.
This inspection consists of (1) a review of the permit and accompanying documentation
to determine compliance with permit conditions, and (2) an on-site inspection of several
collection system components. The attached inspection form notes the areas that were
evaluated for the inspection, with notable findings outlined as follows.
Summary of Noncompliance
1. Line Cleaning – Records showed that the 10% gravity sewer line cleaning requirement has not
been met. Condition II.8 of the Permit requires that at least 10% of the wastewater collection
system be cleaned each year. The Permit indicates that the Liberty Collection System has
approximately 23 miles of gravity sewer. Therefore, approximately 12,144 feet of sewer must be
cleaned each year. Records showed that 11,671 feet was cleaned in 2017, 9,359 feet in 2018,
and approximately 8,300 feet to date in 2019.

2. Fats, Oils and Grease (FOG) Education Program – Condition I.5 requires development and
implementation of an educational FOG program “that shall include at least bi-annual
distribution of educational material targeted at both residential and non-residential users.”
Operators said that they were unaware of recent distributions. However, it was later revealed
that the Town’s Billing Department does occasionally send educational material with the utility
bill. Detailed documentation was not available. Operators should coordinate with the Billing
Department to ensure that material is sent twice per year and properly documented. A
prominent statement on the Town’s website can reduce the distribution requirement to once
per year. Please note that a violation of this requirement was also noted during the previous
inspection in 2017.

Site Inspections
1. Pump Stations – The Kinro Road, New and Starmount Avenue pump stations were inspected.
a. At Kinro Road, the SCADA was tested but the call did not reach operators in the field. On
calling their office operators confirmed that a call did go through to their office, but not
to the operators in the field. Please verify that the system is operating as expected.
b. The New pump station is not yet in use, but the pump station is checked regularly. The
station is missing an emergency contact sign. A sign should be installed and the function
of the alarms should be verified before the pump station is put into use.
2. High Priority Lines – A sub-waterway-crossing line near East Teague Street was inspected and
no issues were noted.
3. Manholes – A manhole near the high priority line noted above was inspected and no issues
were noted.
Please take steps to ensure the deficiencies noted above are corrected. If you should have any
questions, please do not hesitate to contact Paul DiMatteo at [phone] or our office at (336) 776-
9800.

Sincerely,

Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ

Enclosures – Inspection Report

CC: DWR e-Docs
Compliance Inspection Report
Permit:WQCS00280 Effective:06/01/13 Expiration:05/31/21 Owner :Town of Liberty
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Randolph
Winston-Salem
William Doerfer
Effective:Expiration:Facility:Liberty Collection System
PO Box 1006
Liberty NC 272981006
Title:Phone:[phone]Town Manager
Secondary ORC(s):
336-622-4276Phone:992762Certification:Kevin Gene CoblePrimary ORC:
CS2,System Classifications:
On-Site Representative(s):
Related Permits:
WQ0003090 Town of Liberty - Town of Liberty WWTF
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
09/05/2019 10:20AM 01:20PM
Paul DiMatteo 336-776-9691
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Collection system management and operation
Collection System Inspect Non Sampling
Question Areas:
Miscellaneous Questions General Sewer & FOG Ordinances
Capital Improvement Plan Map Reporting Requirements
Inspections Spill Response Plan Spills
Lines Manholes Pump Stations
(See attachment summary)
Page 1 of 7
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00280
09/05/2019 Collection System Inspect Non Sampling
Town of Liberty
Routine
Inspection Summary:
Page 2 of 7
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00280
09/05/2019 Collection System Inspect Non Sampling
Town of Liberty
Routine
General Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade?
Are logs being reviewed by the system management or owner on a regular basis?
# What is that frequency?Every 2-3 months
# Are there any issues being addressed currently or any in the planning stages?
Is there a specific pump failure plan available for all pump stations?
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
Are new/significantly upgraded pump stations equipped with anti-corrosion materials?
Does the permittee have a copy of their permit?
# Is permit expiring within the next 6 months?
If Yes, has the Permittee applied for renewal?
Comment:
Sewer and FOG Ordinances Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
Does it appear that the Sewer Use Ordinance is enforced?
Is there a Grease Control Program that legally requires grease control devices?
What is the standard grease trap cleaning requirement in the FOG ordinance?Serviced every 90
days
Is Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators?
# Have satellite systems adopted an equivalent or more stringent ordinance?
Is grease/sewer education program documented with req'd customer distribution?
# Are other types of education tools used like websites, booths, special meetings, etc?
If Yes, what are they? (This can reduce mailing to annual.)
There's some information on the website, but it's pretty buried.
On grease education - the billing department apparently does send a flyer out in the bills
periodically. But, more detailed information was not available. I requested that they coordinate
with billing to document when mailings are done, and ensure it's done at least 2x/year, or maybe
make the information on the website more visible.
Comment:
Capital Improvement Plan Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted?
Is it designated for wastewater only or does it have a dedicated section?
Does CIP cover three to five year period of earmarked improvements?
Does CIP include description of project area?
Does CIP include description of existing facilities?
Does CIP include known deficiencies?
Page 3 of 7
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00280
09/05/2019 Collection System Inspect Non Sampling
Town of Liberty
Routine
Does CIP include forecasted future needs?
New CIP adoped 6/2019.Comment:
Map Yes No NA NE
Is there a overall sewer system map?
Does the map include:
Pipe Type (GS/FM)
Pipe sizes
Pipe materials (PVC, DIP, etc)
Pipe location
Flow direction
Approximate pipe age
Pump station ID, location and capacity
# Force main air release valve location & type
# Location of satellite connections
Is the map being updated for changes/additions within 1 year of activation?
Approximate age available for newer lines. Pump station information available. Operators say
there's a digital version of the map that has more information than their printed copy but we
weren't set up to view it during the inspection.
Comment:
Reporting Requirements Yes No NA NE
# Have there been any sewer spills in the past 3 years?
If Yes, were they reported to the Division if meeting the reportable criteria?
If applicable, is there documentation of press releases and public notices issued?
Is an Annual Wastewater Performance Report being filed with the Division, if required?
Is the report being made available to all its sewer customers?
# How is it being made available?On website and at
town hall
Checked public notices for 9/16/18 E Lowe Ave SSO and 9/16/19 Starmount SSO.Comment:
Inspections Yes No NA NE
Are adequate maintenance records maintained?
Are pump stations being inspected at the required frequency?
# Is at least one complete functionality test conducted weekly per pump station?
Is there a system or plan in place to observe the entire system annually?
Is the annual inspection documented?
# Does the system have any high-priority lines/locations?
Are inspections of HPL documented at least every 6 months?
Are new lines being added to the HPL list when found or created?
Page 4 of 7
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00280
09/05/2019 Collection System Inspect Non Sampling
Town of Liberty
Routine
Looked at mowing and cleaning records. LS are inspected 3x/week. Only LS not on telemetry is
Ultracraft, which is checked 5x/week and not in service on weekends. HPL inspections ok. We
talked about somehow documenting that an annual general observation is completed.
Comment:
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available?
Is a Spill Response Action Plan available for all personnel?
Does the plan include:
24-hour contact numbers
Response time
Equipment list and spare parts inventory
Access to cleaning equipment
Access to construction crews, contractors, and/or engineers
Source of emergency funds
Site sanitation and cleanup materials
Post-overflow/spill assessment
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
Comment:
Spills Yes No NA NE
Is system free of known points of bypass?
If No, describe type of bypass and location
Are all spills or sewer related issues/complaints documented?
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
# If Yes, is there a corrective action plan?
Complaint log has location, date, action taken, inspected by, and problem. They said they look at
repeated issues as they come up.
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Teaque buried stream crossing.
Are right-of-ways/easements maintained for full width for access by staff/equipment?
If No, give details on temporary access:
Is maintenance documented?
Are gravity sewer cleaning records available?
Has at least 10% of lines older than 5 yrs been cleaned annually?
Were all areas/lines inspected free of issues?
Permittee didn't hit 10% cleaning requirement in 2018.Comment:
Manholes Yes No NA NE
Page 5 of 7
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00280
09/05/2019 Collection System Inspect Non Sampling
Town of Liberty
Routine
Please list the Manholes Inspected:
Near Teague line
Are manholes accessible?
# Are manhole covers/vents above grade?
Are manholes free of visible signs of overflow?
Are manholes free of sinkholes and depressions?
Are manhole covers present?
# Are manholes properly seated?
# Are manholes in good condition?
# Are inverts in good condition?
Is flow unrestricted in manholes?
Are manholes free of excessive amounts of grease?
Are manholes free of excessive roots?
Are manholes free of excessive sand?
Are manhole vents screened?
Are vents free of submergence?
Are manholes free of bypass structures or pipes?
Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Kinro Road, Starmount, "New"
# Number of duplex or larger pump stations in system 8
# Number of vacuum stations in system 6
# Number of simplex pump stations in system 0
# Number of simplex pump stations in system serving more than one building 0
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?7
# A simple one-way telemetry/communication system (auto-dialer) installed?1
For pump stations inspected:
Are they secure with restricted access?
Were they free of by-pass structures/pipes?
Were wet wells free of excessive grease/debris?
# Do they all have telemetry installed?
Is the communication system functional?
Is a 24-hour notification sign posted ?
Does the sign include:
Owner Name?
Page 6 of 7
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00280
09/05/2019 Collection System Inspect Non Sampling
Town of Liberty
Routine
Pump station identifier?
# Address?
Instructions for notification?
24-hour emergency contact numbers?
Are audio and visual alarms present?
Are audio and visual alarms operable?
# Is there a backup generator or bypass pump connected?
If tested during inspection, did it function properly?
Is the back-up system tested at least bi-annually under normal operating conditions?
# Does it have a dedicated connection for a portable generator?
# Is the owner relying on portable units in the event of a power outage?
# If Yes, is there a distribution plan?
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
# Does Permittee have the approved percentage of replacement simplex pumps?
Is recordkeeping of pump station inspection and maintenance program adequate?
Do pump station logs include at a minimum:
Inside and outside cleaning and debris removal?
Inspecting and exercising all valves?
Inspecting and lubricating pumps and other equipment?
Inspecting alarms, telemetry and auxiliary equipment?
New Pump Station doesn't yet have a sign, telemetry or an operable AV alarm, but it's also not
yet in service.
Comment:
Page 7 of 7