WQCS0028_Response_to_NOV2020DV0351_20200828

NC Department of
Environmental Quality
Received
SEP 0 3 2020
Pfi Pi VL..CP TO
Town of Liberty Winston-Salem
OL.yP
P.O. Box 1006
239 South Fayetteville Street Regional Office
Liberty, North Carolina 27298
(Gl [phone] phone [phone] fax
www.Liberty-NC.com
August 28, 2020
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
450 Hanes Mill Road
Suite 300
Winston-Salem, NC 27103
Subject: Response to Notice of Violation
NOV-2620-DV-2020
Sanitary Sewer Overflows - May 2020
Collection System Permit No. WQCS00280
Town of Liberty - Collection System
Randolph County
Dear Mr. Snider,
We are in receipt of your letter dated August 10, 2020 in which you request a response to our violation of
permit conditions stipulated in the subject permit and NC GS 143-215.1. The violations included failing
to effectively manage, maintain, and operate the subject collection system, so that there are no SSO to the
land or surface waters and making an outlet to waters.
We have been working on a detailed plan to address the inflow and infiltration problems that have
plagued this system for many years. The following steps have already been taken:
1. We have initiated discussion and had an inspection referencing our Special Order by Consent
(SOC) in order to assist the Town get back on the right footing with our collection and treatment
system. We had a follow up meeting about this SOC on Wednesday, January 22, 2020. We had a
follow up meeting on Tuesday, March 31, 2020 and made some good progress but due to
COVID-19 we have been slower to resolve the SOC. After a conference call week of June 29,
2020, it seems to be in the best interest of the Town to enter into a settlement agreement instead
of an SOC. This will continue to be a discussion until the best possible resolution is found.
2. We have been awarded $2M in CDBG-I funding to address severe I&I problems in the lines that
primarily feed the Kime Street lift station with the assistance of McGill Associates and the
Piedmont Triad Regional Council (PTRC). There is an environmental and engineering report
process that will commence in the coming months. Construction contracts will be awarded no

later than April 2021.
3. On February 7, 2019 we were awarded $100,000 from Golden LEAF to complete a
comprehensive study of or I&I problems. The results of this study have led to additional Golden
LEAF funding awards. This report showed us many areas in our system that have issues and the
full study is available upon request.
4. After completing the study, Golden Leaf awarded us another $495,000 to rehab six locations that
are approximately 2,500 linear feet of sewer that will be completed in July and August 2020. We
are in the final stages of this grant and have additional funds remaining after allocation of the first
2,500 linear feet was completed. We are requesting additional sections to be CCTV'ed to be
approved. We should hear soon if we can complete more linear feet with this grant to help reduce
I&I in our system.
5. More recently, we have been awarded $3,000,000 in a 100% loan forgiveness program through
the Division of Water Infrastructure under the Additional Supplemental Appropriations for
Disaster Relief Act 2019 (ASADRA). This project will relocate the Starmount Lift Station out of
the 100-year floodplain, rehabilitate Kinro Lift Station and rehabilitate approximately 8,900
linear feet of sewer collection lines that flow to Kinro lift station. A request for qualifications has
been released. Construction contracts should be signed no later than August 1, 2022. One
location that is on this SSO is Kinro Rd. That lift station will be rehabilitated and some enflow
lines will be rehabilitated.
As you can see, we have been diligently working towards an actionable plan to address a multitude of
issues facing our wastewater collection and treatment systems. We are severely impacted by
compounding problems including a less than one million dollar budget, aging and low-income populous,
aging and dilapidated collection system. Findings from the I&I study show that there are several NCDOT
stormwater collection lines that feed into our wastewater collection system. We will conduct additional
CCTV investigation to discover the root cause and develop an immediate solution to these issues. All of
the I&I and heavy rains continue to overwhelm our system in many ways including overloading all our
lift stations located around town. We are continuing to work on our I&I into our system because we
believe this is a huge reason we are continuing to have SSO's.
I appreciate your thoughtful consideration of this additional information. I stand ready to discuss Liberty's
Sanitary Sewer Overflow issues at your convenience.
Sincere regards,
U),&zp z Dea.: Z e/s
William Doerfer,
Town manager
Liberty, NC