WQ0003090_Annual Report_20210301

P altepT PLACE Tp
4o,,,x
C
Town of Liberty, AC
Wastewater Treatment PCant
and
CoCfection System
2020 AnnuaC Keport

Table of Contents
I. General Infonnation
Name of Regulated Facility
Responsible Persons
Permit Number
It. Performance
Permit Limit Violations 2019
Monitoring and .Reporting Violations
Overflows at the Wastewater Treatment Plant
Overflows in the Collection System
Description of Corrective Measures
III. Notification
IV. Certification

I. General Information
Name of Regulated Facility
Town of Liberty
The Town of Liberty is permitted through the State of North Carolina to operate a spray
irrigation wastewater treatment facility and operate the wastewater collection system..
Responsible Persons
Elix T. Fike is the treatment plant operator responsible in charge (ORC).
Kevin Coble is the collection system operator responsible in charge (ORC).
Scott Kidd, Interim Town Manager is the responsible person for the Town of Liberty facilities
and can be contacted at [phone].
Permit Number
Wastewater Treatment Facility Permit Number: WQ0003090
Wastewater Collection System Permit Number: WQCS00280.
The wastewater treatment facility is a spray irrigation system located at 7178 East Highfill
Avenue. The treatment process consists of a manual bar screen, a lagoon, chemical treatment,
and effluent pump station. The Town is permitted for 550,000 gallons per day of sewage. The
sewage enters the plant and goes through the bar screen which removes all solids. The solids
are removed and disposed of by Allied Waste. The flow then proceeds to a three (3) pump
influent station that pumps the sewage to the lagoon. The lagoon is a natural occurrence system
that separates the remaining solids from the liquid. The solids settle to the bottom of the lagoon
with the water staying to the top. After a 45 day detention time, the water is then treated with
chlorine to remove all fecal coliform bacteria. The next process is to spray the effluent onto the
spray fields. We maintain one hundred eighty (180) acres of spray field. The spray fields are
broken down into eight (8) zones. The Town of Liberty contracts the cutting and removal of the
fields for hay.
The Town of Liberty collection system consists of approximately 25 miles of sewer lines. The
lines vary in size from four (4") inch to twelve (12") inch in diameter. The collection system
also consists of eight (8) lift stations that carry the wastewater to the treatment facility.
Operators make daily checks on the outfall lines and lift stations. The public works crew along
with contracted maintenance is responsible for the mowing and clearing of the outfall lines for
easy access in case of any emergencies.
3

II. Performance
The Town's most recent Compliance Evaluation Inspection of the Wastewater Treatment Plant
was September 25, 2020. The inspection mostly reflects compliance with Permit No.
WQ0003090. The inspection results are included in this report. (See attached)
All items continue to be monitored by the ORC.
It is our goal to continue to find ways to improve the operations of the Wastewater Treatment
Facility and Collection System as we go forward.
Overflows at the Wastewater Treatment Plant
Date
Amount (gallon)
Cause
01/03/2020
3,600
I/I due to rainfall of 1.8" in 2 day
02/06/2020
400
I/I due to rainfall of 3.5" in 1 day
02/06/2020
200
I/I due to rainfall of 3.5" in 1 day
02/07/2020
6400
I/1 due to rainfall of 3.5" in 1 day
02/06-02/17/2020
4,752,000
1/I due to rainfall of 5.5" in 7 day
05/25-5/31/2020
348,000
I/I due to rainfall of 6.4" in 14 day
06/17-06/23/2020
1,837,500
I/I due to rainfall of 3.5" in 2 day
08/17-08/21/2020
360,000
1/I due to rainfall of 2.5" in 3 day
09/11/2020
20,000
1/I due to rainfall of 2.0" in 1 day
09/17/2020
12,000
1/I due to rainfall of 3.0" in 1 day
09/18-09/22/2020
454,000
I/I due to rainfall of 3.0" in 1 day
09/25-10/06/2020
1,572,000
I/1 due to rainfall of 1.5" in 2 day
10/12-10/20/2020
1,176,000
1/I due to rainfall of 2.5" in 2 day
10/29-11/24/2020
1,872,850
I/I due to rainfall of 3.5" in 2 day
11/12/2020
31,500
I/I due to rainfall of 3.5" in 2 day
11/27-12/10/2020
1,296,000
I/I due to rainfall of 2.5" in 11 day
12/15-12/29/2020
1,008,000
I/I due to rainfall of 2.7" in 8 day
*This spill spanned 12/29/2019 - 01/03/2020 - estimated gallons spilled in 2020 only
at 127 gallons per minute.
C!

Overflows in the Collection System
Date
Amount (gallons)
Location
Cause
1/3/2020
2,700
W. Kime Ave. Lift Station
Manhole #400
I/I
1/3/2020
2,700
W. Kime Ave. Manhole #401
I/I
1/3/2020
1,200
Kinro Rd Manhole #500B
I/I
1/24/2020
5,490
Kinro Rd Manhole #500B
I/I
1/24/2020
3,600
W. Kime Ave Manhole #401
I/I
1/24/2020
4,725
Johnson Lift Station
Manhole #300
I/I
1/24/2020
4,005
Starmount Outfall Line
Manhole #601
I/I
1/24/2020
3,000
W. Kime Ave. Lift Station
Manhole #400
I/I
2/6/2020
1,680
W. Kime Ave Manhole #401
Severe Natural
Condition
2/6/2020
3,000
Kinro Rd Manhole #500B
Severe Natural
Condition
2/6/2020
1,680
W. Kime Ave. Lift Station
Manhole #400
Severe Natural
Condition
2/6/2020
14,850
Johnson Lift Station
Manhole #300
Severe Natural
Condition
2/6/2020
6,480
W. Kime Ave. Lift Station
Manhole #400
Severe Natural
Condition
2/6/2020
6,600
W. Kime Ave. Manhole #401
Severe Natural
Condition
2/7/2020
2,340
Kinro Rd Manhole #500B
Severe Natural
Condition
4/30/2020
2,850
W. Kime Ave. Lift Station
Manhole #400
I/I
4/30/2020
2,850
W. Kime Ave. Manhole #401
I/I
4/30/2020
1,800
Johnson Lift Station
Manhole #300
I/I
4/30/2020
780
Kinro Rd Manhole #500B
I/I
5/21/2020
1,800
E. Lowe Ave. Manhole #506A
I/I

5/21/2020
6,300
Kinro Rd Manhole #500B
I/1
5/21/2020
6,600
Johnson Lift Station
Manhole #300
I/I
5/21/2020
4,200
W. Kime Ave. Lift Station
Manhole #400
I/I
5/21/2020
4,200
W. Kime Ave. Manhole #401
I/I
6/11/2020
1,200
W. Kime Ave. Manhole #401
I/I
6/11/2020
1,200
W. Kime Ave. Lift Station
Manhole #400
1/1
6/11/2020
2,400
Kinro Rd Manhole #500B
1/1
6/11/2020
6,000
Johnson Lift Station
Manhole #300
1/1
8/3/2020
1,800
W. Kime Ave. Lift Station
Manhole #400
I/1
8/3/2020
1,800
W. Kime Ave. Manhole #401
I/I
8/4/2020
1,200
Kinro Rd Manhole #500B
I/I
9/11/2020
900
W. Kime Ave. Manhole #400A
1/1
9/19/2020
600
S. Greensboro St.
Pipe Failure (Break)
11/12/2020
3,150
Kinro Rd Manhole #500B
I/I
11/12/2020
1,350
Johnson Lift Station
Manhole #300
I/I
11/12/2020
5,400
W. Kime Ave. Lift Station
Manhole 4400
1/1
11/12/2020
5,400
W. Kime Ave. Manhole #400A
1/1
11/14/2020
1,095
S. Greensboro St.
Pipe Failure (Break)
12/14/2020
900
Kinro Rd Manhole #500B
Pump Station
Equipment Failure
12/16/2020
807
W. Kime Ave. Lift Station
Manhole #400
1/I
12/16/2020
960
W. Kime Ave. Manhole #400A
I/I
12/16/2020
975
Kinro Rd Manhole #500B
I/I
Description of Corrective Measures
See Special Order By Consent
Liberty: A Great Place to Live
rel

III. Notification
The Town of Liberty will add a notation on the next water bill about the availability of this
report. The report will be at Liberty Town Hall for viewing at 239 South Fayetteville St.
The report will also be posted on the Town Website at http://www.liberty-nc.com, under
Departments, Public Works, Wastewater Department.

IV. Certification
2020 Annual Report Certification Form
System Name: Town of Liberty
Wastewater Permit # WQ0003090 Collection Permit # WQCS00280
Report Year: 2020 Population Served: _2,665`
The wastewater system operator named above hereby confirms that all provisions under the House Bill
1160 requiring the development of, distribution of, and notification of an annual report have been executed.
Further, the system operator certifies the information contained in the report is correct and consistent with
the compliance monitoring data previously submitted to the primacy agency by their NC certified
laboratory.
Certified by: Name: Scott Kidd Title: _Interim Town Manager
Signature:
Phone #: [phone] Date: March 1, 2021
M.

ROY COOPER
Governor
MICHAEL S. REGAN
secretary
S. DANIEL SMITH
Director
Mr. William Doerfer, Town Manager
Town of Liberty
P.O. Box 1006
Liberty, North Carolina 27298
NORTH CAROLINA
Environmental Quality
September 30, 2020
Subject: Compliance Evaluation Inspection
Town of Liberty — Wastewater Surface Irrigation
Permit No. WQ0003090
Randolph County
Dear Mr. Doerfer:
On September 25, 2020, Caitlin Caudle and Patrick Mitchell performed a scheduled routine
compliance inspection. Tremaine Fike, ORC, and Scott Kidd, Director of Public Works, were
present during the inspection. A review of records, treatment works, and monitoring wells was
completed. The ORC was present during the entire inspection, and Scott Kidd was present during
the records review and review of treatment components. An inspection of the irrigation system
actively irrigating was not completed due to weather and vegetation removal, but staff has
requested notification before the next irrigation event to schedule a follow up visit.
Upon arrival, the ORC notified staff that a bypass at the chlorine contact chamber started at 9:15
AM and was ongoing. Ms. Caudle recorded the incident upon her return to the office. Please be
aware that bypass events are a violation of Permit Condition 111.12 which states that
diversion or bypassing of untreated or partially treated wastewater from the treatment
facilities is prohibited. At the time of inspection, the freeboard level of the 15-acre lagoon was
also out of compliance. This exceedance is a violation of Permit Condition 111.13, which states
that freeboard in the lagoon shall not be less than one and one half (1.5) feet at any time.
These violations will be addressed in separate correspondence from this office.
Based on the review of records, treatments system components, and monitoring wells during the
inspection, the facility was determined to be mostly compliant with the subject permit. The
following items of concerns were noted:
The current staff gauge for the 15-acre storage lagoon appeared to be inaccurate based on
the location of the berm and the freeboard marking. Per Permit Condition 111.14, the staff
gauge "shall have readily visible permanent markings at inch or tenth of a foot increments,
indicating the following elevations: maximum liquid level at the top of the temporary storage
volume; minimum liquid level at the bottom of the temporary liquid storage volume; and the
lowest point on top of the dam." Considering the consistent overflow issues, this office
requests that the lagoon marker be resurveyed to ensure its accuracy.
The access road to the chlorine contact is in disrepair. Per Permit Condition V.2, "the
Permittee shall inspect the wastewater treatment and irrigation facilities to prevent
North Carolina Department or Environmental Quaitty t Division of Water Resources
Winston -Satan Regional office ; 450 West Hanes Mitt Read, Suite 30(} 1 Winston-Salem. north Carolina 27iOS
u am 336.776.4840

malfunctions, facility deterioration, and operator errors..." Please repair the access road as
soon as possible to prevent further deterioration of the road, and minimize the impact
to the lagoon liner.
As a reminder, Permit Condition IV.13 states that "the Permittee shall report to the Winston
Salem Regional Office, telephone number [phone], within 24 hours of first knowledge
of..." events that result in noncompliance with the subject permit. Please notify the Winston
Salem Regional office as soon as possible at first knowledge of a noncompliance event.
At the time of inspection, the flowmeter was recording over 2,000 GPM, which equates to a
daily average at the current flow rate at over 2,000,000 GPD. Daily flows of more than
1,000,000 GPD have been reported, and correspondence dated August 21, 2020 and
September 9, 2020 have addressed the exceedance of the permitted 550,000 GPD average
monthly limit. Please continue to closely monitor daily flows.
Please refer to the enclosed compliance inspection report for additional observations and
comments. If you have any questions regarding this notice, please contact Ms. Caudle or me at
the letterhead address or phone number, or by email at [e-mail] or
[e-mail].
Sincerely,
7 DocuSIgned by:
A t 5ml tt
t45B49M5CMEA.,.
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of water Resources, NCDEQ-WSRO
enc: Compliance Inspection Report
cc: Randolph County Environmental Health — Electronic Copy
Tremaine Fike — Electronic Copy
WSRO Electronic Files
DWR Laserfiche File WQ0003090

Compliance Inspection Report
Permit: W00003090 Effective: 05/01/19 Expiration: 08/31/24 Owner: Town of Liberty
SOC: Effective: Expiration: Facility: Town of Liberty WVVTF
County: Randolph 7187 E Highfill Ave
Region: Winston-Salem
Liberty NC 272981006
Contact Person: Sandra Dixon Title: Phone: [phone]
Directions to Facility:
System Classifications: SI,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/25/2020
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Certification:
Phone:
Entry Time 10:OOAM Exit Time: 12:OOPM
Phone: [phone]
Reason for Inspection: Routine inspection Type: Compliance Evaluation
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent Miscellaneous Questions
Treatment Flow Measurement -Water Treatment Treatment Barscreen
Use Records
Record Keeping Treatment Lagoons End Use -Irrigation
Treatment Influent Pump Station Treatment Disinfection Treatment Flow Measurement
Standby Power Wells
(See attachment summary)
Page 1 of 6

Permit: W00003090 Owner - Facility: Town of Liberty
Inspection Date: 09/25/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On September 25, 2020 staff Caitlin Caudle and Patrick Mitchell preformed an announced scheduled routine compliance
inspection. Tremaine Fike, ORC, and Scott Kidd, Director of Public Works, were present during the inspection. A review of
records, treatment works, and monitoring wells was completed. The ORC was present during the entire inspection, and
Scott Kidd was present during the records review and review of treatment works. A review of the irrigation system working
was not completed due to weather and vegetation removal.
Upon arrival ORC notified staff that a bypass at the chlorine contact chamber started at 9:15 AM and was ongoing. Caitlin
Caudle recorded the incident when returning to the office (#202002685). ORC provided the 2019 annual report during the
inspection. A sludge survey was completed September 26, 2019 per Permit Condition 1.1. The Residual Management Plan
was created August 17, 2017 and was not updated with the most recent sludge survey.
The influent flow meter was recording over 2,000 GPM, with the daily flow meter reporting over 3 MG per day average at the
current daily flow. Upon arrival the high water visual and audible alarms were working at the lift station after the bar screen.
When reviewing the bar screen, it was noted that the water level was very high, approximately six inches from the top of the
concrete containment wall. At the time of the inspection staff was not able to review the condition of the bar screen Staff
was not able to review the chlorine contact chamber during normal operations as there was an ongoing bypass from the
chlorine contact chamber. Algal and scum mats were present on the sidewalls of the chlorine contact chamber. It was found
that effluent was seeping into the chlorine storage room, bathroom, and pump room. Effluent was flowing out of the doors
and around the building, eventually reaching surface water. A hole in the pump room floor, which ORC described as a drain,
was allowing effluent to flow into the pump room. Videos are available in WSRO digital files. A review of the chlorine contact
chamber during normal operations is needed. Staff was not able to review the effluent flow meter. All monitoring wells, but
monitoring well six, were reviewed and in good condition.
Staff discussed the following items during the inspection:
• ORC stated that screenings from bar screen are placed in a dumpster, and the dumpster is emptied every other
Wednesday.
• Staff requested that ORC monitor the lowland area below the lift station after the bar screen Bypasses often occur at
this lift station and effluent flows into the lowland area. At the time of inspection it appeared there was water flowing towards
a closed culvert that leads directly to surface water. Photos are available in WSRO electronic files.
• ORC was reminded that irrigation equipment must be calibrated once per permit cycle, the last irrigation calibration was
completed on August 9, 2018.
• ORC was reminded that metered equipment must be calibrated annually. Calibration for the 2020 calendar year has not
been completed yet. The last calibration was completed November 11, 2019.
• Staff requested that a printed updated contact list be added to the Operations and Maintenance Plan
• ORC stated that trees overhanging the irrigation field will be trimmed this coming winter.
• ORC stated that lime was applied July 28, 2020.
• ORC stated that the town has a contract with a local farmer to maintain the irrigation fields, including removing
vegetation in a timely manner (before grass is 2 ft tall) and managing the Johnson Grass in irrigation fields.
• Staff requested that ORC repair the access road leading to the chlorine contact chamber. ORC stated that gravel is on
site to repair ruts. The ruts are not an issue now, but if they worsen it could impact the lagoon liner.
• ORC stated that effluent parameters are sampled for at the end of the chlorine contact chamber by R&A Labs, ideally
when the irrigation system is actively working. Sampling events are scheduled weekly on Thursday. Staff requested that
ORC schedule sampling events based on weather forecast in order to get an accurate effluent sample. If it is not possible to
irrigate when collecting an effluent sample, ORC was asked to make a comment on the NDMR.
• ORC stated that the irrigation system has to be manually turned on. The system has an emergency shut off in the form
of a float in the chlorine storage container. If chlorine levels get to low the irrigation system will shut off.
• Staff requested that ORC notify WSRO when irrigation fields were cleared to schedule another inspection to review the
system in operation.
• Staff requested that ORC notify WSRO as soon as possible at first knowledge of a spill or bypass in the treatment
works.
Staff discussed ORC installing a new staff gauge that marks the point of overflow from the chlorine contact chamber
Page 2 of 6

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 09/25/2020 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Single Family Drip
❑
Single Family Spray, LR
❑
Infiltration System
❑
Activated Sludge Drip, LR
❑
Recycle/Reuse
❑
Reuse (Quality)
❑
Activated Sludge Spray, HR
❑
Activated Sludge Spray, LR
❑
Lagoon Spray, LR
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? M ❑ ❑ ❑
Do all treatment units appear to be operational? (if no, note below.) 0 ❑ ❑ ❑
Comment:
Treatment Influent Pump Station
Yes No NA NE
Is the pump station free of bypass lines or structures?
0 ❑ ❑ ❑
Is the general housekeeping acceptable?
0 ❑ ❑ ❑
Are all pumps present?
0 ❑ ❑ ❑
Are all pumps operable?
❑ ❑ ❑
Are floats/controls operable?
❑ ❑ ❑
Are audio and visual alarms available?
❑ ❑ ❑
Are audio and visual alarms operational?
❑ ❑ ❑
# Are SCADA/Telemetry alarms required?
❑ ❑ ❑
Are SCADA/Telemetry available?
❑ ❑ N ❑
Are SCADA/Telemetry operational?
❑ ❑ 0❑
Comment: Visual and audible high water alarms were on during the inspection.
Treatment Flow Measurement -Influent
Yes
No NA NE
Is flowmeter calibrated annually?
0
❑ ❑ ❑
Is flowmeter operating properly?
0
❑ ❑ ❑
Does flowmeter monitor continuously?
0
❑ ❑ ❑
Does flowmeter record flow?
❑ ❑ ❑
Does flowmeter appear to monitor accurately?
❑ ❑ ❑
Comment:
Treatment Flow Measurement -Water Use Records Yes No NA NE
Page 3 of 6

permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 09/25/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Is water use metered?
Are the daily average values properly calculated?
Comment:
Treatment Flow Measurement -Effluent Yes No NA NE
Is flowmeter calibrated annually? ❑ ❑ ❑
Is flowmeter operating properly? ❑ ❑ ❑
Does flowmeter monitor continuously? ❑ ❑ ❑
Does flowmeter record flow? ❑ ❑ ❑
Does flowmeter appear to monitor accurately? ❑ ❑ ❑
Comment: Staff was not able to review effluent flow meter during the inspection because pump house was
floor was full of partially treated effluent.
Standby Power Yes No NA NE
Is automatically activated standby power available? 0 ❑ ❑ ❑
Is generator tested weekly by interrupting primary power source? M ❑ ❑ ❑
Is generator operable? M ❑ ❑ ❑
Does generator have adequate fuel? M ❑ ❑ ❑
Comment: Back up power is only at lift station
Treatment Barscreen Yes No NA NE
Is it free of excessive debris? ❑ ❑ ❑
Is disposal of screenings in compliance? ❑ ❑ ❑
Are the bars spaced properly? ❑ ❑ ❑
Is the unit in good condition? ❑ ❑ ❑ N
Comment: Influent flow was so high bar screen was completely covered, could not evaluate the state of bar
screen.
Treatment Disinfection
Is the system working?
Do the fecal coliform results indicate proper disinfection?
Is there adequate detention time (-30 minutes)?
Is the system properly maintained?
If gas, does the cylinder storage appear safe?
Is the fan in the chlorine feed room and storage area operable?
Is the chlorinator accessible?
If tablets, are tablets present?
Are the tablets the proper size and type?
Is contact chamber free of sludge, solids, and growth?
If UV, are extra UV bulbs available?
Yes No NA NE
Page 4 of 6

permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 09/25/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
If UV, is the UV intensity adequate? ❑ 110 ❑
# Is it a dual feed system? ❑ N ❑ ❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? ❑ ❑ N ❑
If yes, then is there a Risk Management Plan on site? ❑ ❑ 0 ❑
If yes, then what is the EPA twelve digit ID Number? (1 000-----)
If yes, then when was the RMP last updated?
Comment: Scum mats were present on the side walls of the chlorine contact chamber. It was currentl
overflowing.
Record Keeping
Yes No NA NE
Is a copy of current permit available?
0 ❑ ❑ ❑
Are monitoring reports present: NDMR?
N ❑ ❑ ❑
NDAR?
E ❑ ❑ ❑
Are flow rates less than of permitted flow?
❑ 0 ❑ ❑
Are flow rates less than of permitted flow?
❑ N ❑ ❑
Are application rates adhered to?
M❑ ❑ ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
0❑ ❑ ❑
Are all samples analyzed for all required parameters?
N❑ ❑ ❑
Are there any 2L GW quality violations?
❑ ❑ ❑
Is GW-59A certification form completed for facility?
E ❑ ❑ ❑
Is effluent sampled for same parameters as GW?
❑ 0 ❑ ❑
Do effluent concentrations exceed GW standards?
E ❑ ❑ ❑
Are annual soil reports available?
N ❑ ❑ ❑
# Are PAN records required?
❑ 0 ❑ ❑
# Did last soil report indicate a need for lime?
0 ❑ ❑ ❑
If so, has it been applied?
❑ ❑ ❑
Are operational logs present?
❑ ❑ ❑
Are lab sheets available for review?
0 ❑ ❑ ❑
Do lab sheets support data reported on NDMR?
M ❑ ❑ ❑
Do lab sheets support data reported on GW-59s?
0 ❑ ❑ ❑
Are Operational and Maintenance records present?
0 ❑ ❑ ❑
Were Operational and Maintenance records complete?
0 ❑ ❑ ❑
Has permittee been free of public complaints in last 12 months?
0 ❑ ❑ ❑
Is a copy of the SOC readily available?
❑ ❑ E ❑
No treatment units bypassed since last inspection?
❑ 0 ❑ ❑
Comment: High flow events have occurred.
End Use -Irritation
Yes No NA NE
Page 5 of 6

permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 09/25/2020 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Are buffers adequate?
N❑ ❑ ❑
Is the cover crop type specified in permit?
❑ ❑ M ❑
Is the crop cover acceptable?
0❑ ❑ ❑
Is the site condition adequate?
❑ ❑ ❑ 0
Is the site free of runoff / ponding?
❑ ❑ ❑
Is the acreage specified in the permit being utilized?
❑ ❑ ❑
Is the application equipment present?
❑ ❑ ❑
Is the application equipment operational?
0❑ ❑ ❑
Is the disposal field free of limiting slopes?
0 ❑ ❑ ❑
Is access restricted and/or signs posted during active site use?
❑ ❑ ❑
Are any supply wells within the CB?
❑ ❑ M ❑
Are any supply wells within 250' of the CB?
❑ ❑ N ❑
How close is the closest water supply well?
❑ ❑ 0 ❑
Is municipal water available in the area?
❑ ❑ ❑
# Info only: Does the permit call for monitoring wells?
❑ ❑ ❑
Are GW monitoring wells located properly w/ respect to RB and CB?
❑ ❑ ❑ ❑
Are GW monitoring wells properly constructed, including screened interval?
❑ ❑ ❑
Are monitoring wells damaged?
❑ M ❑ ❑
Comment: A follow up visit will be done to review irrigation.
Page 6 of 6

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMI NUSSION
COUNTY OF RANDOLPH
IN THE MATTER OF )
NORTH CAROLINA )
PERMITS
WQ0003090 & WQCS00280 )
HELD BY THE
TOWN OF LIBERTY )
SPECIAL ORDER BY CONSENT
EMC SOC WQ S19-011
Pursuant to provisions of North Carolina General Statutes (G.S.) 143-215.2 and 143-215.67, this
Special Order by Consent is entered into by the Town of Liberty, hereinafter referred to as the
Town, and the North Carolina Environmental Management Commission, an agency of the State of
North Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission:
The Town of Liberty and the Commission hereby stipulate the following:
(a) The Town holds North Carolina non -discharge permit number WQCS00280, for
management and operation of an existing wastewater collection system but is unable to
consistently comply with sanitary sewer overflow (SSO) prohibitions stipulated in
Condition I.2. of the permit, due primarily to the introduction of large volumes of
extraneous flow resulting from inflow and infiltration (I&I) throughout the collection
system. The Town reported 82 SSOs during the time period January 2018 through
September 2020, with some volume of untreated wastewater reaching unnamed
tributaries to the Rocky River, which are classified WS-III (water supply) waters of the
state within the Cape Fear River Basin, during the vast majority of those incidents.
(b) The Town holds North Carolina non -discharge pennit number WQ0003090, for the
management and operation of an existing non -discharge wastewater treatment facility
(WWTF) which employs wastewater irrigation for final disposal of the treated
wastewater. Due to high flows that reach the WWTF resulting from I&I to the collection
system, the WWTF periodically receives flows in excess of the volumes it can manage
and contain, resulting in 14 bypasses of nontreated or undertreated wastewater from
treatment units within treatment system during the time period January 2018 through
September 2020. Portions of the volumes spilled have entered the North Prong Rocky
River, which is currently classified a WS-III (water supply) water of the state within the
Cape Fear River Basin.
(c) A list of recent SSOs from the Town of Liberty collection system and unpermitted
bypasses of wastewater from the Town of Liberty WVi'TF is included in Attachment A
to this Special Order.

EMC SOC WQ S19-011
Town of Liberty
p. 2
(d) The unpermitted discharges of untreated and/or undertreated wastewater from the
Town's treatment system to surface waters constitutes causing and contributing to the
pollution of the waters of this State, named above, and the Town is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
(e) The Town has recently completed a study of its collection system that has identified and
categorized sources of I&I, and established a priority list of actions (repair, rehabilitation
and/or replacement of collection system infrastructure) the Town shall undertake to
reduce volumes of I&I.
(f) The Town has secured, through grants and funding, financing for planning, designing,
and improving the wastewater collection system which, once complete and properly
operated, will be sufficient to adequately convey all wastewater collected throughout the
Town to the WWTF, and reduce to the greatest practical extent the I&I flow it currently
receives. A listing of funding sources and projects for the Town's collection system
improvements is included in Attachment B to this Special Order.
(g) Since this Special Order is by Consent, neither party will file a petition for a contested
case or for judicial review concerning its terms.
2. The Town, desiring to comply with the permits identified in paragraph 1(a) and 1(b) above,
hereby agrees to do the following:
(a) Undertake the following activities in accordance with the indicated time schedule:
(1) Provide the Winston-Salem Regional Office with quarterly progress reports
regarding improvements being made to collection system infrastructure. Reports
are due within 30 days following the end of each calendar quarter. The first
report is due April 30, 2021 for the January through March (I,') quarter and shall
continue to be submitted throughout the life of this Special Order.
(2) On or before January 1, 2021, the Town shall commence construction on the
project funded by the $493,778 GLE, which was awarded in December 2019. This
project targets repair of six of the worse defects identified through the Town's I&I
study and calls for rehabilitation of approximately 3,231 linear feet of sewer main
repair or replacement of all manholes and laterals within these system areas.
(3) On or before April 30, 2021, the Town shall begin execution of the $2,000,000
CDBG-funded project, which was awarded in March 2019. This project includes
replacement and/or rehabilitation of—15,900 linear feet of 8" vitrified clay sewer
lines, 72 brick -constructed manholes and related appurtenances, and 150 lateral
line replacements, in the southwest quadrant of the Town.
(4) On or before August 1, 2022, the Town shall begin execution of the Additional
Supplemental Appropriations for Disaster Relief Act of 2019 (ASADRA) project
loan of $3,000,000, which was approved in August 2020. This project includes
the relocation of the Starmount lift station that is in a 100 year floodplain, the

EMC SOC WQ 519-011
Town of Liberty
p. 3
rehabilitation of the Kinro Road lift station, the rehabilitation of 8,000 linear feet
of sewer line, and CCTV of 18,000 linear feet of sewer line.
(5) On or before June 1, 2021, the Town shall complete the GLF grant -funded
rehabilitation and repair project noted in 2 (b)(2) above.
(6) On or before July 29, 2022, the Town shall complete the CDBG-funded project
noted in 2 (b)(3) above.
(7) On or before September 30, 2023, the Town shall complete the ASADRA-
funded project noted in 2 (b)(4) above.
(b) No later than fifteen 15 calendar dares after any date identified for accomplishment of
any activity listed in 2 b above, the Town shall submit to the Director of DWR written
notice of compliance or noncompliance therewith. In the case of noncompliance. the
notice shall include a statement of the reason( s ) for noncompliance. remedial actions )
taken, and a statement identifying the extent to which subsequent dates or times for
accomplishment of listed activities may be affected.
3. The Town, desiring to comply with the Permits identified in paragraph 1(a) above, hereby
agrees to the following settlement of outstanding civil penalties, an upfront penalty, and
stipulated penalties:
(a) The Town has outstanding civil penalty assessments that total $49,250. As settlement of
all alleged violations of non -discharge permit number WQCS00280 and non -discharge
permit number WQ0003090 prior to entering into this Special Order by Consent, the
Town agrees to pay an upfront penalty amount of $1,477.50, with the remaining amount
of $47,772.51.'i0 to be held in abeyance until the successful completion of this SOC.
(b) At the successful conclusion of this Special Order by Consent, the penalty amount held
in abeyance ($47,772.5 C 0) will be remitted. Should the Special Order by Consent not
reach a successful conclusion, the full remaining penalty amount will be due
immediately by check payable to the North Carolina Department of Environmental
Quality and forwarded to the Director.
(c) The Town agrees that unless excused under paragraph four (4), the Town will pay the
Director of DWR, by check payable to the North Carolina Department of Environmental
Quality, stipulated penalties according to the following schedule for failure to meet
deadlines set out in paragraph 2(a) and for SSOs and bypasses that discharge to surface
waters as described here:

EMC SOC WQ S19-011
Town of Liberty
p. 4
Violation Description
Stipulated Penalty
• $250 per SSO greater than 1,000 gallons
and less than 100,000 gallons (to be paid
Any reportable Sanitary Sewer Overflow
on a monthly basis)
(SSO) WQCS00280
$500 per SSO greater than 100,001
gallons (to be paid on a monthly basis)
• $250 per bypass greater than 1,000
gallons and less than 100,000 gallons (to
And reportable bypass WQ0003090
be paid on a monthly basis)
• $500 per bypass greater than 100,001
jeallons 'to be paid on a monthly basis)
Failure to meet a schedule date
$100.001day for the first 7 days,
$500.00lday thereafter
Failure to submit progress reports by
$1,000.001report
schedule date
Failure to complete any project as
$1,000A0lproject
described in this Special Order
(d) Checks are to be made payable to the North Carolina Department of Environmental
Quality and forwarded to the Director of DWR at 1617 Mail Service Center, Raleigh,
North Carolina 27699-1617.
4. The Town and the Commission agree stipulated penalties are not due if the Town satisfies
the Division of Water Resources noncompliance was caused solely by:
(a) An act of God;
(b) An act of war;
(c) An intentional act or omission of a third party, but this defense shall not be available if
the act or omission is that of an employee or agent of the defendant or if the act or
omission occurs in connection with a contractual relationship with the Town;
(d) An extraordinary event beyond the Town's control. Contractor delays or failure to
obtain funding will not be considered as events beyond the Town's control; or
(e) Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties or challenge
them by a contested case petition pursuant to G.S. 150B-23, will be grounds for a collection
action, which the Attorney General is hereby authorized to initiate. The only issue in such

EMC SOC WQ S 19-011
Town of Liberty
p. 5
an action will be whether the thirty (30) days has elapsed.
5. In accordance with the provisions of G.S. 143-215.67(b) the Commission allows the Town to
accept 0.0 MGD of additional wastewater (via permitted sewer extensions) to its waste
treatment system while improvements to the collection system are being made.
The nature of the additional flows is such that the waste characteristics do not exceed those
generally associated with domestic waste or are pretreated to domestic strengths. Waste of
greater than normal domestic strength may be accepted if it can be demonstrated to the
satisfaction of the Director the additional waste will not adversely affect the treatment
efficiency of the treatment system or result in the violation of any permit limitation. All new
and proposed industrial waste tributary to the system must be controlled using all needed
mechanisms including but not limited to adoption and implementation of industrial waste
control and pretreatment ordinances. No wastewater can be accepted that will add toxic
pollutants in quantities not generally associated with domestic wastewater characteristics
unless the acceptance of the additional wastewater can be supported through appropriate
analyses acceptable to the Director.
6. This Special Order by Consent and any terms or conditions contained herein, hereby
supersede any and all previous Special Orders, Enforcement Compliance Schedule Letters,
terms, conditions and limitations contained therein issued in connection with permits
WQ0003090 and WQCS00280.
7. Any violation of the terms of this Special Order by Consent may terminate paragraph five
(5) of this Order, and any authorized additional waste not previously connected to the
system shall not thereafter be connected until the necessary sewer collection system
improvements have been completed and placed in operation.
8. Noncompliance with the terms of this Special Order by Consent are subject to enforcement
action in addition to the above stipulated penalties, including injunctive relief pursuant to
G.S. 143-215.6.(C).
9. This Special Order may be modified at the Commission's discretion, provided the
Commission is satisfied that the Town has made good faith efforts to secure funding,
complete all construction, and achieve compliance within the dates specified.
10. Failure to pay the up -front penalty described in paragraph 3.(a) within thirty (30) days of the
execution of this Special Order may terminate this Special Order and require the Town to
comply with all terms and conditions contained in non -discharge permits WQ0003090 and
WQCS00280.
11. This Special Order shall become effective in accordance with state law; however, the Town,
upon signature of this Special Order by Consent, will be expected to comply with all
schedule dates, terms, and conditions within this document.
12. This Special Order by Consent shall expire December 31, 2023.

EMC SOC WQ S 19-01 I
Town of Liberty
p. 6
FOR THE TOWN OF LIBERTY
R
Date AI�A-w)—
William Doerfer
Town Manager
FOR THE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION:
yvti 1 /4/2021
Date
.
S. Daniel Smith
Director, Division of Water Resources

EMC SO►C WQ S19-011
ATTACHMENT A
Unauthorized Releases of Wastewater from
Town of Liberty NV WTF (Permit WQO003O90)
Start Date
/20 8
Location
Kinro Rd
Total Volume
Released (gal)
600
Volume Reaching
Surface Waters
600 1
2/4 /201 8
Kinro Road
205
205
8/6/2018
Kinro Lift Station
4,260 �
-m_ _. 1,800
9/4/2018
€ Newberry outfall
600
' 600
9/16/2018
W Kime Ave _
10,500
10,500
9/16/2018
W Kime Ave Pump Station
10,500
10,500
9/16/2018
Johnson Lift Station - W. Moffitt Rd�
28,560
28,560
9/16/2018
Starmount Ave Outfall
25,500
25,500
9/17/2018
E Brookwood Ave
2,400
2,400
9/1712018T
E Brookwood Ave-
µ 2,4001
2,400
9/17/2018
E Butler Ave
_ 1,800
9/1612018 :
Kinro Rd
13,680
13,680
9/16/2018 i
E Lowe Ave
21,600 1
21,600
10/11/201
i $
Kinro Rd., Liberty
900
900
1
11/512018
W Kime Ave Lift Station
1,200
1,200
11/5/2018
W Kime Ave Manhole
1,200
1,200
11/5/2018
Kinro Rd
1,200
- 1,200
11/_5/2018
_
Johnson Lift Station - 616 W Moffitt Ave
1,200
1,200
11/512018
Starmount Ave
2,400
2,400
11/5/2018
E Lowe Ave___
900
900
11/12/201
Starmount Ave Outfall Line
_
4,800
4,800
_8
11/12/201
8
Johnson Street Lift Station
1,350
1,350
11 /121201
8
West Kime Ave
3,780
3,780
11/12/201
8
West Kime Ave Lift Station
4,830
4,830 3
11/12/201
8
East Lowe Ave
8,400
8,40
11/122/201
Kinro Road
4,800
4,800
11/15/201
8
Starmount Ave Outfall
-Lowe
_ 3,600
3,600
I
11/15/201
8
E Ave
720
720
11/15/201
8
Kinro Rd
1,560
1,560
12/14/201
8
Kinro Rd
4,200
4,200
_
12/20/201
8
;Kinro Road
12,000
12,000
i
12/20/201
12/20/201
West Kime
West Kime Lift Station 1
2,160
4,050
2,160
_I
4,050

EMC SOC WQ S19-011
ATTACHMENT A
Unauthorized Releases of Wastewater from
Town of Liherty Cnllpetinn Q,'vefnm
8
"�
~
12/20/201
8
East Lowe Avenue
7,500
7 500
t
12/28/201
8
West Kime Ave
--
600
600
12/28/201
8
E Lowe Ave
975
975
12/28/201
8
Kinro Rd
2,8g0
_ 2,880
12/28/201
8
Kime Ave Lift Station
600
600
1/24/2019
Kinro Rd
1,500
1,500
2/18/2019
Kinro Rd
1,200
1,200
2/23/2019
Kinro Road
2,700
3/21/2019 °
Kinro Rd
1,---
1,800
Start Date
I
Location
Total Volume
Released (gal)
Volume
Reaching
Surface Waters
aI
4/12/2019
West Kime Avenue
1,650
1,650
4/12/2019
3 Kinro Road
2,160
2,160
4/13/2019
West Kime Avenue
4,680
4/13/2019
Kinro Road
11,040
_4.680
11,040
4/13/2019
Starmount Outfall Line
2,880
2,880
4/13/2019
Johnson Lift Station
675
0
5/29/2019
South Greensboro St
850
850
1/3/2020
W Kimes Ave MH
2,700
2,700
1/312020
W. Kime Ave LS
2,700
2,700
1 /3/2020
Kinro Rd
1,200
1,200
1/24/2020
; Kinro Rd
j 5,490
5,490
1/24/2020
West Kime Ave
6,600
6,600
1/24/2020
Johnson Lift Station
4,725
4,725
1/24/2020
Starmount Ave Outfall
4,005
4,005
1/24/2020
W. Kime Ave LS
3,000 i
3,000
2/6/2020
Johnson Lift Station
14,850
14,850
2/6/2020
Kime Street Lft Station 516 West Kime Street
6,480
6,480
2/6/2020
Kime Street Lift Station 516 West Kime Street
1,680
1,680
2/6/2020 i
West Kime Street
6,600
6,600
2/6/2020
West Kime Street
1,680
1,680
2/6/2020
Kinro Road
3,000
3,000
2/7/2020
Kinro Road
2,340
2,340
4/30/2020
West Kime Avenue
2,850
2 850 "
4/30/2020
West Kime Avenue Lift Station
2,850
2,850
4/30/2020 ;Kinro
Road
780
780
p. 2

EMC SOC'WQ S19-011
ATTACHMENT A
Unauthorized Releases of Wastewater from
Town of Liherty Callectinn S ctpm tPormit W(lf Q(N17Rnt
4/30/2020
Johnson Lift Station
1,800 1,800
5/21/2020
E Lowe Ave #506A
1,800 1,800
5/21/2020
W Kime Ave LS #400
4,200 4,200
5/21/2020
W Kime Ave. #401 _
4,200 4,200
5/21/2020
Johnson LS
6,600 6,600
5/21/2020
Kinro Rd
6,300 1 6,300
6/11/2020
Kinro Road _
2,400 2,400
6/11/2020
West Kime Avenue Lift Station
1,200 1,200
6/11/2020
West Kime Avenue
1,200 1,200
6/11 /2020
Johnson Lift Station
6,000 6,OR0
8/03/2020
W Kime Ave LS
1,800 r 1,800
8/03/2020
West Kime Ave
1,800 1,800
8/04/2020
Kinro Rd MH500-B
1,200 1,200
9/1112020
West Kime Ave
900 900
9/19 02020
South Greensboro St
600 400
p. 3

EMC SOC WQ Sig-011
ATTACHMENT A
Unauthorized Releases of Wastewater from
Town of Liberty Collection System (Permit WQCS00280)
Date
Estimated
' Estimated
Wastewater
Volume of
1 Volume
Release
Location of Release
Release
Reaching
Began
(gal)
Surface Waters
(gal }
1/30/2018
Pump Station between the bar screen
400
0
and treatment lagoon
9/17/2018
Pump Station between the bar screen
342
0
and treatment lagoon
4/13/2019
Chlorine Contact Chamber
180,000
' 180,000
4/14/2019
Pump Station between the bar screen
; 4,500
0
and treatment lagoon
1/03/2020
! Chlorine Contact Chamber
i
3,600
3,600
2105/2020
Pump Station between the bar screen
400
0
and treatment lagoon
i
2/06/2020
Pump Station between the bar screen
400
0
and treatment lagoon
2/06/2020
Chlorine Contact Chamber
10,000
10,000
2/06/2020
Pump Station between the bar screen
200
0
and treatment lagoon_
2/0612020
Pump Station between the bar screen
200
0
and treatment lagoon. _
2/07/2020
Pump Station between the bar screen
6,400
0
and treatment lagoon
2/21/2020
Chlorine Contact Chamber
996.000
996,000
5/26/2020
Chlorine Contact Chamber '
348,000
348,000
6/17/2020
Chlorine Contact Chamber
1,837,500
1,837,500
8/17/2020 j
Pump Station between bar screen
1,200
0
and treatment lagoon
8/17/2020
Chlorine Contact Chamber
360,000
360,000
9/11/2020
Pump Station between bar screen
20,000
0
and treatment lagoon
9/17/2020
Pump Station between bar screen
12,000
0
and treatment lagoon
=9/18/2020Chlorine
Contact Chamber
454,400 i
454,400

EMC SOC WQ S19-011
ATTACHMENT B
Secured Funding Sources
Town of Liberty Collection System (Permit WQCS00280)
Secured Funding Sources
Source
Amount
Golden Leaf Foundation (GLF)
$493,778
Community Development Block Grant (CDBG) for Infrastructure
$2,000,000
ASADRA - Additional Supplemental Appropriations for Disaster
Relief Act of 2019
$3,000,000