NC0024244_SOC responce on NOV's_20200327

February 27, 2020
Mr. W. Corey Basinger
Regional Supervisor, Water Quality Regional Operations Section
NCDEQ Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Response to Notices of Violation
NOV-2019-LV-0332 (dated 5/8/2019)
NOV-2019-LV-0570 (dated 8/6/2019)
NOV-2019-TX-0039 (dated 8/22/2019)
NOV-2019-LV-0862 (dated 11/15/2019)
NOV-2019-LV-0292 (dated 11/26/2019)
NOV-2019-LV-0187 (dated 11/26/2019)
NOV-2019-LC-0916 (dated 12/10/2019)
NOV-2020-LV-0019 (dated 1/14/2020)
Dear Mr. Basinger:
This letter is to provide supplemental response to the Notices of Violation received by Albemarle as listed
above. Our firm is assisting Albemarle with several ongoing and planned sewer rehabilitation projects,
and we have a thorough understanding of the challenges they face during rain events.
The Albemarle utility staff, City Manager, and City Council recognize they have an inflow and infiltration
problem in their sewer collection system. Inflow and infiltration are difficult challenges to solve, and it is
not one that can be solved quickly. The Albemarle leadership is committed to improving the issues you
presented in the NOV's, and that commitment takes the form of significant capital improvement projects
aimed at reducing inflow and infiltration. Since 2012 Albemarle has committed to nearly $10,000,000 in
sewer rehabilitation capital projects, and together with City staff we are planning additional sewer
upgrades as listed below.
Please note #1 through #4 below were also included in a March 28, 2019 letter from LKC addressing a
previous NOV. They have been updated based on present status.
1. Sanitary Sewer Rehabilitation, Phase 1 (CS370522-04): This $3,500,000 project was completed in
2014 and featured digging and replacing approximately 15,000 feet of 36" and 24" gravity sewer.
The rehabilitated sewer line is the primary gravity sewer outfall that serves the majority of the
City.
2. 2018 Wastewater Collection and Treatment Improvements (CS370522-06): This $6,400,000
project features the digging and replacing of 7,000 feet of 24" gravity sewer and pump station
and electrical renovations at the treatment plant. Presently, the construction is approximately
75% complete and is on schedule for a Spring 2020 closeout.
LKC Engineering, PLLC, 140 Aqua Shed Court, Aberdeen, North Carolina 28315
PH: 910/420-1437 * FAX: [phone] * License No. P-1095

3. Sanitary Sewer Rehabilitation, Phase 3A: This project replaces approximately 700 feet of 24"
gravity sewer at the downstream side of the City's west side outfall. This leg was videoed in
January 2019 and several sags and pipe failures were identified. The was completed in April of
2019 using the City's utility crews. The cost of the material and the bypass pumping is estimated
at $150,000.
4. Sanitary Sewer Rehabilitation, Phase 313: Albemarle applied for $6,156,000 in CWSRF funding in
the Fall of 2020 cycle. The project features the rehabilitation of approximately 10,000 feet of
gravity sewer ranging from 24" to 8" in size, and continued, significant electrical upgrades at the
wastewater treatment plant. The SWIA is expected to decide on the funding at their February
2020 meeting.
Gravity sewer flow monitoring: LKC installed three flow monitoring devices on Albemarle's three
primary sewer outfalls in mid -January 2020. Those devices are set to be removed on February 11,
2020. There have been three significant rainfall events while the devices were in place. Pending
the results of the trackers, they may be re -installed at different locations to continue monitoring.
The purpose is to determine if the significant I&I is originating from concentrated area, and if so
where.
6. Potential WWTP process conversion: in December 2019 and January 2020 LKC performed
detailed process modeling of the Long Creek WWTP, and we shared the results with the City in
January. The model indicates there could be value to transitioning the aeration process to help
the plant remain in compliance during a broad regime of flow and loading. LKC and Albemarle
are still vetting the results, and final recommendations are expected by April 2020. If a process
change is the recommendation, we will discuss with DEQ staff and Albemarle will consider
methods to fund the capital investment.
Albemarle's leadership remains committed to implementing capital projects to reduce inflow and
infiltration and maintain compliance at the Long Creek WWTP. These projects require time to plan, secure
funding, design, and implement. We understand a Special Order by Consent is being prepared to
formalize Albemarle's commitment to resolving these issues and to assist with Notices of Violation in the
meantime (SOC No. SOC _WQ_519_007). The SOC application was submitted in September of 2019, with
additional information provided in November of 2019.
If you have any questions, please do not hesitate to contact me by phone at [phone] or by email
at [e-mail].
Very Best,
Adam P. Kiker, P.E.