WQCS00280_NOI_NOV2020DV0370_Response_20200904 (2)

Town of Liberty
P.O. Box 1006
239 South Fayetteville Street
Liberty, North Carolina 27298
[phone] phone [phone] fax
` www.Liberty-NC.com
September 4, 2020 _�(A e A �. - f
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-2020-DV-0370
Sanitary Sewer Overflows June 2020
Collection System Permit No. WQCS00280
Town of Liberty - Collection System
Randolph County
Dear Mr. Snider,
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We are in receipt of your letter dated August 25, 2020 in which you request a response toour violation of
permit conditions stipulated in the subject permit and NC GS 143-2IS. 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 Kline 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)=� pd
William Doerfer,
Town manager
Liberty, NC

CERTIFIED MAIL:
RETURN RECEIPT REQUESTED
August 20, 2020
Roger Davis
Town of Liberty
PO Box-1006
Liberty, NC27298-1006
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY I
Tracking No.: NOV-2020-DV-0370
Sanitary Sewer Overflows - June 2020
Collection System Permit No. WQCS00280
Liberty Collection System
Randolph County
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Dear Permittee:
A-reviewhas been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
Town of Liberty. The Division's Winston-Salem Regional Office concludes that the Town of Liberty violated Permit
Condition I (2) of Permit No. WQCS00280 by failing to effectively manage, maintain, and operate their collection
system so that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted
making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by
G.S. 143-215.1.
The Winston-Salem Regional Office is providing the Town of Liberty an opportunity to provide evidence and
justification as to why the Town of Liberty should not be assessed a civil penalty for the violation(s) that are
summarized below:
Total Vol f
^ Total Surface t
Incident start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202001842 6/11/2020 107 Kinro Road Inflow and Infiltration 2,400 2,400 Notice of Intent
202001843 6/11/2020
140 West Kime Avenue Lift Inflow and Infiltration 1,200
Station
1,200 Notice of Intent

Total Vol
Total
Surface
Incident
Start
Duration
Vol
Water
Number
Date
(Mins) Location
Cause (Gals)
(Gals) DWR Action
202001844
6/11/2020
140 West Kime Avenue
Inflow and Infiltration 1,200-
.1,200 Notice of Intent
202001845
6/11/2020
125 Johnson Lift Station
Inflow and Infiltration 6,000
• 6,000 Notice of Intent
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Ron Boone with the Water Quality Section in the
Winston-Salem Regional Office at 336-776-9800 or via email at ron.boone(alncdenr.00v.
Sincerely,
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Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
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