WQCS00280_NOI_NOV2020DV0003_Response_20200116

Town of Liberty
P.O. Box1006
239 South Fayetteville Street
Liberty, North Carolina 27298
[phone] phone [phone] fax
www.Liberty-NC.com
January 16, 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 - Wastewater Surface Irrigation
NOV--2020-DV-0003
Wastewater Surface Irrigation Permit No. W00003090
Town of Liberty - Wastewater Surface Irrigation
Randolph County
Dear Mr. Snider,
We are in receipt of your letter dated January, 9 2020 in which you request a response to our violation of
Permit Condition III. 12. and Permit Condition III. 13. of the above referenced permit. Please consider
this our official response to the above referenced NOV.
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 have a follow up meeting about this SOC on Wednesday, January 22, 2020.
2.. This fiscal year 19-20, we have set aside additional funds to implement solutions to the findings
of the Golden LEAF funded inflow and infiltration study.
3. We have been awarded $2M in CDBG-1 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 should begin no later than late
2020 or early 2021.
4. On February 7, 2019 we were awarded $100,000 from Golden LEAF to complete a
comprehensive study of or I&I problems in order to make two determinations, 1. whether our
existing I&I problems were made materially worse by Hurricane Florence, and 2. determine the

priority and impact of phased repairs to spots and lines. The study results will be used for either a
Golden LEAF application or the USDA application. We have contracted with WithersRavenel to
complete smoke testing, flow monitoring and CCTV monitoring of our collection system. This
report showed us many areas in our system that have issues and the full study is available upon
request.
5. After completing the study, Golden Leaf awarded us another 5495,000 to rehab six locations that
are approximately 2,500 linear feet of sewer.
6. We have contacted and am working with the North Carolina Rural Water Association, of which
we are members, to assist with assessing and prioritizing issues we are experiencing with our
system.
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 system. 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, and in 2018 we recorded almost double our annual rainfall totals at
approximately 77 inches of rain and 19_ inches of snow. Preliminary 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 is overwhelming our wastewater treatment facility in many ways including
overloading our lift station located at the wastewater treatment facility and continuing to raise our lagoon
level.' The continued rain is not helping us lower our lagoon level due to rain every other day which is not
allowing us to use our irrigation to spray the treated water.
I appreciate your thoughtful'considemtion of this additional information. I stand ready to discuss Liberty's
wastewater surface irrigation issues at your convenience.
Sincere regards,
-
William Doerfer,
Town manager
Liberty, NC