WQ0003090_Response to NOV-2020-DV-0477_20210111

Filmore York
Mayor
William Doerfer
Town Manager
Jessica Brown
Town Clerk
William H. Flowe Jr.
Town Attorney
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 and Intent to Enforce
NOV-2020-DV-0477
Permit No. WQ0003090
Town of Liberty - Wastewater Surface Irrigation
Randolph County
Dear Mr. Snider,
COUNCIL MEMBERS
Tyson Nixon
Mayor ProTem
Larry Coble
Chris Compton
JR Beard
Don Herndon
January 11, 2021
NC Department of
Environmental Quality
Received
• JAN 1 4 2021
Winston-Salem
Regional Office
We are in receipt of your letter dated December 29, 2020 in which you request a response to our violation
of Permit Condition III.12 and 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 entered into a Special Order by Consent (SOC) in order to assist the Town get back on
the right footing with our collection and treatment system. The SOC has been finalized and is in
effect as of January 4, 2021.
2. We had NC Rural Water come March 17, 2020 and help us conduct a draw down test on Kime
lift station to ensure that the pumps and impellers are doing their job efficiently. We wanted to
ensure that this lift station was pumping the designed amount of water and not causing overflows
due to our equipment. -NC-Rural-Water ensured us that our lift Station was performing as it
should.
3. 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
Town of Liberty • P. 0. Box 1006. 239 South Fayetteville Street • Liberty, North Carolina
27298
Phone [phone] • Fax [phone] • www.Liberty-NC.com

process that will commence in the coming months. Per our SOC milestones, we will enter
construction contract no later than April 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 $495,000 to rehab six locations that
are approximately 2,500 linear feet of sewer that will be completed in October 2020.
6. The Town also resubmitted our application for a Sewer Asset Inventory & Assessment Grant in
September 2020 and we expect to receive an answer in the coming months..
7. We have contacted and are 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 and heavy rains continue to overwhelm our system in many ways including
overloading all our lift stations located around town. This is a continued discussion and we are diligently
working on the best solutions.
I appreciate your thoughtful consideration of this additional information. I stand ready to discuss Liberty's
collection and treatment issues at your convenience.
Sincere regards,
WS Visa
William Doerfer, ((//
Town manager
Liberty, NC
Town of Liberty • P. 0. Box 1006 • 239 South Fayetteville Street • Liberty, North Carolina
27298
Phone [phone] • Fax [phone] • www.Liberty-NC.com