WQCS00280_Liberty_Collection_System_CEI_Letter_&_NOI_NOV2023PC0114_20230330

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
March 30, 2023
CERTIFIED MAIL7020 3160 0002 0860 9918
RETURN RECEIPT REQUESTED
Town of Liberty
Attn: Scott Kidd, Town Manager
P.O. Box 1006
Liberty, NC 27298-1006
SUBJECT: Compliance Evaluation Inspection and Notice of Violation with Intent to Enforce
NOV #: NOV-2023-PC-0114
Town of Liberty Wastewater Collection System
Wastewater Collection System Permit #: WQCS00280
Randolph County
Dear Mr. Kidd:
Ron Boone and Jesse Barnes, of the Winston-Salem Regional Office (WSRO) of the NC Division of Water
Resources (DWR or the Division), conducted a compliance evaluation inspection of the Town of Liberty's
wastewater collection system on March 8t'', 2023. Mr. Boone and Mr. Barnes met with Kevin Coble,
Tremaine Fike, Joe Walsh, and Scott Kidd for the inspection. Inspection findings are summarized below
and detailed in the attached compliance inspection report.
Violations noted by Mr. Boone during the inspection were:
1. There is currently no distribution of Fats, Oils, and Greases (FOG) educational materials as required
by Part I, Paragraph 4, of the collection system permit. FOG educational materials are only posted
on the town's website and in the town hall reception area. This is insufficient to meet the intent of
this permit condition.
2. The annual general observation of the entire wastewater collection system is not being documented
as required by Part V, Paragraph 3 and Part III, Paragraph 1. It is believed the entire system is
observed over the course of each operational year, but the observation is not being documented as
required.
You are reminded that in accordance with NC General Statute 143-215.6A, a civil penalty of not more than
twenty-five thousand dollars ($25,000) may be assessed by the Secretary of the Division of Water
Resources against any person who is required but fails to apply for or to secure a permit required by NCGS
143-215.1, or who violates or fails to act in accordance with the terms, conditions, ore requirements of such
permit.
As such you must take immediate steps to correct the violations noted above. Please reply in writing to this
notice within 10 days of receiving it. Your written response should detail the corrective actions you have
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
oan caaouNn
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
oep.m.m or em�nmen� Qualm

taken and/or plan to take to correct each of the listed violations. If you anticipate corrective actions taking
longer than 10 days, you must provide an estimated completion date for each corrective action that takes
longer than 10 days to complete. Failure to reply in writing, as directed, or to satisfactorily correct the listed
violations, may result in a recommendation by this office to proceed with the above -mentioned enforcement
procedures.
If you have any questions or concerns, please contact Mr. Boone by phone at 336.776.9690 or by email at
ron.boone(c�ncdenr.gov. Thank you for your time and immediate attention to these issues.
Sincerely,
I D-ocu Siiggned by:
•n. l S'atf'
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
Compliance Inspection Report
REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAROLINA 336.776.9800
naparMeM of EmironmanW 9uallly

Compliance Inspection Report
Permit: WQCS00280
SOC: S19011
County: Randolph
Region: Winston-Salem
Contact Person: Scott Kidd
Directions to Facility:
Effective: 07/20/21 Expiration: 06/30/29 Owner : Town of Liberty
Effective: 01/01/21 Expiration: 12/31/23 Facility: Liberty Collection System
PO Box 1006
System Classifications: CS2,
Primary ORC: Kevin Gene Coble
Secondary ORC(s):
On -Site Representative(s):
Title: Interim Town Manager
Certification: 992762
Related Permits:
WQ0003090 Town of Liberty - Town of Liberty WWTF
Liberty NC 272981006
Phone: [phone]
Phone: [phone]
Inspection Date: 03/08/2023 Entry Time 09:30AM Exit Time: 01:OOPM
Primary Inspector: Ron Boone Docusi9ned by: Phone: [phone]
� anaed Boom 3/29/2023
Secondary Inspector(s):
B20F8DD5F2A3460...
Jesse Barnes
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions General Sewer & FOG Ordinances
Capital Improvement Plan Map Reporting Requirements
Inspections Spill Response Plan Spills
Lines Manholes Pump Stations
(See attachment summary)
Page 1 of 7

Permit: WQCS00280 Owner - Facility: Town of Liberty
Inspection Date: 03/08/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Ron Boone and Jesse Barnes, of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Resources (DWR
or the Division), conducted a compliance evaluation inspection of the Town of Liberty's wastewater collection system on
March 8th, 2023. Mr. Boone and Mr. Barnes met with Kevin Coble, Tremaine Fike, Joe Walsh, and Scott Kidd, for the
inspection. Inspection findings are summarized below and detailed in the attached compliance inspection report.
Violations noted by Mr. Boone during the inspection were:
1. There is currently no distribution of Fats, Oils, and Greases (FOG) educational materials as required by Part I,
Paragraph 4, of the collection system permit. FOG educational materials are only posted on the town's website and in the
town hall reception area. This is insufficient to meet the intent of this permit condition.
2. The annual general observation of the entire wastewater collection system is not being documented as required by Part
V, Paragraph 3 and Part III, Paragraph 1. It is believed the entire system is observed over the course of each operational
year, but the observation is not being documented as required.
You are reminded that in accordance with NC General Statute 143-215.6A, a civil penalty of not more than twenty-five
thousand dollars ($25,000) may be assessed by the Secretary of the Division of Water Resources against any person who
is required but fails to apply for or to secure a permit required by NCGS 143-215.1, or who violates or fails to act in
accordance with the terms, conditions, ore requirements of such permit.
As such you must take immediate steps to correct the violations noted above. Please reply in writing to this notice within 10
days of receiving it. Your written response should detail the corrective actions you have taken and/or plan to take to correct
each of the listed violations. If you anticipate corrective actions taking longer than 10 days, you must provide an estimated
completion date for each corrective action that takes longer than 10 days to complete. Failure to reply in writing, as directed,
or to satisfactorily correct the listed violations, may result in a recommendation by this office to proceed with the
above -mentioned enforcement procedures.
If you have any questions or concerns, please contact Mr. Boone by phone at 336.776.9690 or by email at
[e-mail]. Thank you for your time and immediate attention to these issues.
Page 2 of 7

Permit: WQCS00280 Owner - Facility: Town of Liberty
Inspection Date: 03/08/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade? 0 ❑ ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis? 0 ❑ ❑ ❑
# What is that frequency? As generated
# Are there any issues being addressed currently or any in the planning stages? 0 ❑ ❑ ❑
Is there a specific pump failure plan available for all pump stations? 0 ❑ ❑ ❑
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory? 0 ❑ ❑ ❑
Are new/significantly upgraded pump stations equipped with anti -corrosion materials? 0 ❑ ❑ ❑
Does the permittee have a copy of their permit? 0 ❑ ❑ ❑
# Is permit expiring within the next 6 months? ❑ 0 ❑ ❑
If Yes, has the Permittee applied for renewal? ❑ ❑ 0 ❑
Comment: None
Sewer and FOG Ordinances Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available? 0 ❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced? 0 ❑ ❑ ❑
Is there a Grease Control Program that legally requires grease control devices? 0 ❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance? 90 days
Is Grease Control Program enforced via periodic inspections/records review? 0 ❑ ❑ ❑
Is action taken against violators? 0 ❑ ❑ ❑
# Have satellite systems adopted an equivalent or more stringent ordinance? ❑ ❑ 0 ❑
Is grease/sewer education program documented with req'd customer distribution? ❑ 0 ❑ ❑
# Are other types of education tools used like websites, booths, special meetings, etc? 0 ❑ ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
Website, posted in town hall
Comment: FOG information on website and posted in town hall but no other distribution of any type is
being done.
Capital Improvement Plan Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted? ❑ ❑ ❑
Is it designated for wastewater only or does it have a dedicated section? ❑ ❑ ❑
Does CIP cover three to five year period of earmarked improvements? ❑ ❑ ❑
Does CIP include description of project area? ❑ ❑ ❑
Does CIP include description of existing facilities? ❑ ❑ ❑
Does CIP include known deficiencies? ❑ ❑ ❑
Does CIP include forecasted future needs? 0 ❑ ❑ ❑
Comment: None
Page 3 of 7

Permit: WQCS00280 Owner - Facility: Town of Liberty
Inspection Date: 03/08/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Map
Yes No NA NE
Is there a overall sewer system map?
0
❑ ❑ ❑
Does the map include:
Pipe Type (GS/FM)
0
❑ ❑ ❑
Pipe sizes
0
❑ ❑ ❑
Pipe materials (PVC, DIP, etc)
0
❑ ❑ ❑
Pipe location
0
❑ ❑ ❑
Flow direction
0
❑ ❑ ❑
Approximate pipe age
0
❑ ❑ ❑
Pump station ID, location and capacity
0
❑ ❑ ❑
# Force main air release valve location & type
0
❑ ❑ ❑
# Location of satellite connections
0
❑ ❑ ❑
Is the map being updated for changes/additions within 1 year of activation?
M
❑ ❑ ❑
Comment: None
Reporting Requirements Yes No NA NE
# Have there been any sewer spills in the past 3 years? ❑ ❑ ❑
If Yes, were they reported to the Division if meeting the reportable criteria? ❑ ❑ ❑
If applicable, is there documentation of press releases and public notices issued? ❑ ❑ ❑
Is an Annual Wastewater Performance Report being filed with the Division, if required? ❑ ❑ ❑
Is the report being made available to all its sewer customers? ❑ ❑ ❑
# How is it being made available? Website
Comment: None
Inspections
Yes No NA NE
Are adequate maintenance records maintained?
0
❑ ❑ ❑
Are pump stations being inspected at the required frequency?
0
❑ ❑ ❑
# Is at least one complete functionality test conducted weekly per pump station?
0
❑ ❑ ❑
Is there a system or plan in place to observe the entire system annually?
0
❑ ❑ ❑
Is the annual inspection documented?
❑
0 ❑ ❑
# Does the system have any high -priority lines/locations?
❑ ❑ ❑
Are inspections of HPL documented at least every 6 months?
❑ ❑ ❑
Are new lines being added to the HPL list when found or created?
0
❑ ❑ ❑
Comment: No documentation of the annual general observation of the system.
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available? 0 ❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑
Page 4 of 7

Permit: WQCS00280 Owner - Facility: Town of Liberty
Inspection Date: 03/08/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Does the plan include:
24-hour contact numbers ❑ ❑ ❑
Response time ❑ ❑ ❑
Equipment list and spare parts inventory ❑ ❑ ❑
Access to cleaning equipment ❑ ❑ ❑
Access to construction crews, contractors, and/or engineers ❑ ❑ ❑
Source of emergency funds ❑ ❑ ❑
Site sanitation and cleanup materials ❑ ❑ ❑
Post-overflow/spill assessment ❑ ❑ ❑
Does the Permittee appear to respond within 2 hours of first knowledge of a spill? 0 ❑ ❑ ❑
Comment: None
$pills Yes No NA NE
Is system free of known points of bypass? ❑ ❑ ❑
If No, describe type of bypass and location
Are all spills or sewer related issues/complaints documented? ❑ ❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ ❑ ❑
# If Yes, is there a corrective action plan? ❑ ❑ 0 ❑
Comment: None
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Smith Street outfall right-of-way and aerial line and Beaver Dam aerial
Are right-of-ways/easements maintained for full width for access by staff/equipment? ❑ ❑ ❑
If No, give details on temporary access:
Is maintenance documented? ❑ ❑ ❑
Are gravity sewer cleaning records available? ❑ ❑ ❑
Has at least 10% of lines older than 5 yrs been cleaned annually? ❑ ❑ ❑
Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑
Comment: None
Manholes Yes No NA NE
Please list the Manholes Inspected:
Manhole downstream of Smith Smith outfall and aerial
Are manholes accessible? ❑ ❑ ❑
# Are manhole covers/vents above grade? ❑ ❑ ❑
Are manholes free of visible signs of overflow? ❑ ❑ ❑
Are manholes free of sinkholes and depressions? ❑ ❑ ❑
Are manhole covers present? ❑ ❑ ❑
Page 5 of 7

Permit: WQCS00280 Owner - Facility: Town of Liberty
Inspection Date: 03/08/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
# Are manholes properly seated?
0
❑ ❑ ❑
# Are manholes in good condition?
0
❑ ❑ ❑
# Are inverts in good condition?
0
❑ ❑ ❑
Is flow unrestricted in manholes?
0
❑ ❑ ❑
Are manholes free of excessive amounts of grease?
0
❑ ❑ ❑
Are manholes free of excessive roots?
0
❑ ❑ ❑
Are manholes free of excessive sand?
0
❑ ❑ ❑
Are manhole vents screened?
0
❑ ❑ ❑
Are vents free of submergence?
0
❑ ❑ ❑
Are manholes free of bypass structures or pipes?
0
❑ ❑ ❑
Comment: None
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Starmount and Johnson's Mobile Home Park
# Number of duplex or larger pump stations in system
8
# Number of vacuum stations in system
0
# Number of simplex pump stations in system
0
# Number of simplex pump stations in system serving more than one building
0
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?
6
# A simple one-way telemetry/communication system (auto -dialer) installed?
1
For pump stations inspected:
Are they secure with restricted access?
0
❑ ❑ ❑
Were they free of by-pass structures/pipes?
0
❑ ❑ ❑
Were wet wells free of excessive grease/debris?
0
❑ ❑ ❑
# Do they all have telemetry installed?
0
❑ ❑ ❑
Is the communication system functional?
0
❑ ❑ ❑
Is a 24-hour notification sign posted ?
0
❑ ❑ ❑
Does the sign include
Owner Name?
0
❑ ❑ ❑
Pump station identifier?
0
❑ ❑ ❑
# Address?
0
❑ ❑ ❑
Instructions for notification?
0
❑ ❑ ❑
24-hour emergency contact numbers?
0
❑ ❑ ❑
Are audio and visual alarms present?
0
❑ ❑ ❑
Are audio and visual alarms operable?
0
❑ ❑ ❑
Page 6 of 7

Permit: WQCS00280 Owner - Facility: Town of Liberty
Inspection Date: 03/08/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# Is there a backup generator or bypass pump connected?
If tested during inspection, did it function properly?
Is the back-up system tested at least bi-annually under normal operating conditions?
# Does it have a dedicated connection for a portable generator?
# Is the owner relying on portable units in the event of a power outage?
# If Yes, is there a distribution plan?
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
N/A
# Does Permittee have the approved percentage of replacement simplex pumps?
Is recordkeeping of pump station inspection and maintenance program adequate?
Do pump station logs include at a minimum:
Inside and outside cleaning and debris removal?
Inspecting and exercising all valves?
Inspecting and lubricating pumps and other equipment?
Inspecting alarms, telemetry and auxiliary equipment?
Comment: None
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Page 7 of 7