WQ0003090_NOV-2020-DV-0003 SSO Bypass_20200109

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
January 9, 2020
CERTIFIED MAIL # 7017 1450 0001 6450 0740
RETURN RECEIPT REQUESTED
Mr. William Doerfer, Town Manager
Town of Liberty
P.O. Box 1006
Liberty, North Carolina 27298
Subject: Notice of Violation (NOV-2020-DV-0003)
Town of Liberty — Wastewater Surface Irrigation
Permit No. WQ0003090
Randolph County
Dear Mr. Doerfer:
On January 6, 2020, the Winston-Salem Regional Office for the North Carolina Division of Water
Resources received a call from Mr. Tremaine Fike, ORC with the Town of Liberty. Mr. Fike self -
reported that the facility had experienced two non -compliant events: a bypass incident and an
exceedance of the minimum required freeboard level in the lagoon. The information described
below was provided on these two repeat violations.
1. Mr. Fike reported that approximately 3,600 gallons of partially treated wastewater
overflowed at the lift station located between the bar screen and the facultative lagoon.
According to Mr. Fike, the spill occurred in the evening of January 3, 2020. Mr. Fike
indicated that the wastewater that bypassed from the lift station during this event collected
in the "old sludge drying beds" associated with the previous NPDES wastewater system.
Mr. Fike also indicated that there was no discharge of wastewater to surface waters.
This bypass incident reportedly occurred due to high flow volumes resulting from inflow
and infiltration (I&I) impacts. This is a violation of Permit Condition III. 12., which
states, diversion or bypassing of untreated or partially treated wastewater from the
treatments facilities is prohibited. I&I has been reported as the cause of fifteen bypass
events occurring at the subject facility that have been reported to this office since July 10,
2013.
2. Mr. Fike reported that the freeboard level in the lagoon was at 5 inches. This is significantly
higher than the permit required freeboard of 18 inches. This is a violation of Permit
Condition III. 13. which states that freeboard level in the lagoon shall not be less than
one and one-half feet (18 inches) at any time. Exceedance of the minimum required
freeboard has been noted multiple times within the past 24 months.
D North Carolina Department of Environmental Quality I Division of Water Resources
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Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NORTH CAROLINA �
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Our office appreciates your prompt attention and action to the above described violations.
Please submit a written response within 10 days of receipt of this Notice. Your response
should include a detailed plan to address and reduce impacts related to I&I. Please provide an
explanation as to how partially treated wastewater collected by the "old sludge drying beds"
during a bypass event is processed, including where the sand filters drain. Please include an
outline for the steps to be taken to lower the freeboard in the lagoon, returning the freeboard to
the permitted level of 18 inches or greater. Please be advised that if the requested information
is not submitted to this office, and corrective actions implemented, these violations may result
in the issuance of a Civil Penalty Assessment.
A follow-up inspection is planned. If you or your staff have any questions concerning this
Notice, please contact Jim Gonsiewski or me at [phone].
Sincerely,
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Lon T. Snider - Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
cc: Tremaine Fike - Town of Liberty (Electronic Copy)
Randolph County Environmental Health (Electronic Copy)