WQCS00280_SOC Amendment Request_20230426

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To Whom it may concern,
RECEIVED
APR 2 6 2023
DIVISION OF WATER RESOURCES
Liberty has been under a Special Order of Consent since January 2021 and has been working
diligently to reduce over flows at our lift station and our wastewater treatment plant. We have
completed two grants (CDBG and GoldeLeaf) that were both geared towards reducing I&I into
our system. The Town of Liberty is working on our third grant that was mentioned in the SOC
(ASADRA grant). In our SOC it states that the ASADRA grant would have been completed by
September 30, 2023 which will not happen due to many factors. The silver lining, Liberty
received a supplemental grant to the ASADRA in the amount of $12.5 million which puts the
total ASADRA grant amount to $15.5 million.
The ASADRA grant will be used to rehab one of our lift stations and move an additional lift
station our of a 100 year flood plain. Once both lift stations are complete, the remaining funs
will be used to camera our system and then make a plan on what all needs to be slip lined, pipe
burst, or dig and replace. This grant will hope to reduce I&I to a minimal in our system.
Below are statements that coincide with the amendment application.
II. Liberty has completed all the SOC requirement timelines thus far and is seeking an
extension for the ASADRA project. The original date of completion for the ASADRA project
was September 30, 2023 and the Town of Liberty would like an extension until December 31,
2026. We are requesting this length of extension due to an increase in funding for our ASADRA
from SWIA. I have attached the funding letter and timelines. The construction contracts are to
be executed by December 31, 2024 and all funds must be spent by December 31, 2026.
IV. The Town of Liberty is seeing growth from the Toyota Battery Plant and the Wolfspeed
Plant, both being announced in our area. The anncoucements of both these plants are bringing a
combined 3,000+ jobs to our area and this is putting a huge demand on the Town of Liberty to
provide water and sewer to all the new growth in the area. Currently, Liberty is the only Town
that has water and sewer in the northeast part of Randolph County. There are many individuals
moving to the community who want new homes in the Liberty area. Currently, we have reduced
our spills dramatically and after reviewing last year's totals at the WWTP, we only used 57%
capacity. Liberty needs to be able to grow with all these economic developments and be able to

support the new growth in Randolph County. Our increase in flow would put us at 70% capacity
for our wastewater treatment plant.
All spills that have occurred since implementing the SOC are attached for 2021 and 2022.
2023 spills are as follows.
Collections Spills:
1/25/23 - Kinro Rd. manhole #50013, amount = 1,200 gallons, cause - I&I
3/2/23 - Kinro Rd. manhole #50013, amount = 310 gallons, cause - I&I
WWTP Spills:
1/26/23 — WWTP Lagoon Chlorination Chamber — 99,000 gallons — cause — I&I
2/l/23 — WWTP Lagoon Chlorination Chamber - 659,625 gallons — cause — I&I
2/13/23 — WWTP Lagoon Chlorination Chamber — 201,000 gallons - cause - I&I
3/2/23 - WWTP bypass station — 500 gallons — cause — equipment failure
The Town of Liberty is excited about all the growth and economic development in our area. The
additional grants that the Town of Liberty has received will help address any issues that Liberty
has with our collection lines. Thank you for the help to continue to make Liberty a great place to
live.
Scott Kidd
� �J
Town Manager — Liberty NC
239 S Fayetteville St, Liberty NC

I.
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR AN AMENDMENT TO A SPECIAL ORDER BY CONSENT
GENERAL INFORMATION:
1. Applicant (corporation, individual, or other): Town of Liberty_
2. Owner Phone: [phone] (or) _336-215-2339
3. Owner Email:
townmanager@townoflibertync.
4. Facility Name (must be the same as name on the original SOC):
Town of Liberty
5. Original SOC No. / Issuance Date: EMC SOC EQ S19-011
6. NPDES Permit No. (if applicable)
5. Application Date: 3/20/2023
NC Permits WQ0003090 & WQCS00280
II. SOC COMPLIANCE HISTORY:
Please attach a listing of all violations this facility has had under this Order. Include �Lny
violation of interim dates, relaxed permit parameters, and existing permit limits.
III. ADDITIONAL FLOW OR REALLOCATION OF EXISTING FLOW:
Only facilities owned by a unit of government may request to add additional flow to the
treatment system as part of this SOC Amendment in accordance with NCGS 143-215.67(b).
Additional flow may be allowed under an SOC amendment only in specific circumstances.
These circumstances may include eliminating discharges that are not compliant with an NPDES
or Non -discharge permit as specified in the original SOC. These circumstances do not include
failure to perform proper maintenance on treatment systems, collection systems or disposal
systems. When requesting additional flow, the facility must include its justification and
supporting documentation. If the requested additional flow is non -domestic, the facility must be
able to demonstrate the ability to effectively treat the waste and dispose of residuals. The
applicant must provide a detailed analysis of all constituents in the proposed non -domestic
wastewater.

The total domestic additional flow requested: 71,500 gallons per day.
The total non -domestic additional flow requested: 0 gallons per day.
The total additional flow (sum of the above): 71,500 gallons per day.
If a reallocation of existing additional flow is needed the facility must provide justification as to
why this reallocation is needed.
Any additional flow that may be allowed will be determined by an analysis of projected adverse
impacts on the wastewater treatment facility and/or surface waters.
IV. WHY AN SOC AMENDMENT IS NEEDED:
Please provide a detailed explanation as to why the SOC amendment is being requested. Include
actions already taken to avoid noncompliance with the existing SOC. Also provide details on
activities that were delayed.
THE `DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Reg uired Items:
a. One original and two copies of the completed and appropriately executed application
form, along with all required attachments.
• If the SOC Amendment is for a City / Town, the person signing the SOC must be
a ranking elected official or other duly authorized employee.
• If the SOC Amendment is for a Corporation / Company / Industry / Other, the
person signing the SOC must be a principal executive officer of at least the level
of vice-president, or his duly authorized representative.
• If the SOC Amendment is for a School District, the person signing the SOC must
be the Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00. A
check must be made payable to The Department of Environment and Natural
Resources.
2

APPLICANT'S CERTIFICATION:
(NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE)
I, Scott Kidd , attest this application for a Special Order by
Consent (SOC) amendment has been reviewed by me and is accurate and complete to the best of
my knowledge. I understand if all required parts of this application are not completed and if all
required supporting information and attachments are not included, this application package may
be returned as incomplete. (Please be advised that the return of this application does not prevent
DWR from collecting all outstanding penalties upon request). Furthermore, I attest by my
signature that I fully understand that an upfront penalty, which may satisfy as a full
settlement for past violations, may be imposed. {Note: Reference to upfront penalties in
Special Orders by Consent may be found in the North Carolina Administrative Code [T15A
NCAC 2H .1206(c)(3)].}
Date
Signaf0e­of Signing Official
Printed Name of Signing Official
THE COMPLETED AMENDMENT APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON -DISCHARGING SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER RESOURCES
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636
3

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
SHAD[ ESI<AF
Director
Mr. Scott Kidd, Town Manager
Town of Liberty
PO Box 1006
Liberty, NC 27298
Dear Mr. Kidd:
NORTH CAROLINA
L•nvironmental Quality
March 23, 2023
Subject: Letter of Intent to Fund
Town of Liberty
Collection System Improvements
September 2022 Application Cycle
Project No(s).: VUR-W-ARP-0106 and
existing SRF ASADRA CS370460-04
The Division of Water Infrastructure (Division) has reviewed your application, and the
State Water Infrastructure Authority (SWIA) has approved your project as eligible to receive an
additional funding amount of $12,500,000 from the following funding:
Viable Utility Reserve (VUR) grant from the American Rescue Plan Act (ARPA). Projects
funded from ARPA must meet applicable federal law and guidance. The VUR ARPA
Project Grant will be one hundred percent of eligible project costs up to a maximum of
$12,500,000.
The total funding for this project is now $15,500,000 as follows: VUR-W-ARP-0106 grant
of $12,500,000, and existing SRF-ASADRA CS370460-04 loan of $3,000,000 with principal
forgiveness of $3,000,000 (an SRF loan fee of 2% will be invoiced after bids have been
received).
Please note that this intent to fund is contingent meeting all of the following milestones:
Milestone*
Date
Engineering Report Submittal
July 3, 2023
Engineering Report Approval
September 1, 2023
Bid and Design Package Submittal
March 1, 2024
Bid and Design Package Approval
July 1, 2024
Advertise Project, Receive Bids, Submit Bid
Information, and Receive Authorit To Award
November 1, 2024
Execute Construction Contracts
December 31, 2024
*Failure to meet any milestone may result in the forfeiture of funding for the proposed project.
QNorth�� Carolina Department of Environmental Quality I Division of Water Infrastructure
D- E5I2 N. Salisbury Street 1 1633 Mail Service Center I Raleigh, North Carolina 27699-1633
M.
cv+anan
o"919.707.9160

Mr. Scott Kidd, Town Manager
March 23, 2023
Page 2 of 3
All costs incurred prior to March 3, 2021 are not eligible for ARPA funds and the
Division will make no reimbursements of ARPA funds after December 31, 2026.
The first milestone is the submittal of an Engineering Report on July 3, 2023. The
Engineering Report must be developed using the guidance found on our website
(h s:Hd .nc. ov/about/divisions/water-infrastructure/i-have-fundin en ineerin -
rMortenvironmental-information). Failure to meet any milestone may result in the forfeiture of
funding for the proposed project.
The State Environmental Policy Act exempts projects funded by the State Reserve from
state -mandated environmental review. Federal requirements may still apply. [NCGS 1I3A-
12(2)h.]
Upon detailed review of the project during the funding process, it may be determined that
portions of your project are not eligible for funding and the total funding amount may be
reduced. Additionally, changes in the scope or priority points awarded — based on additional
information that becomes apparent during project review — may also result in changes to the total
funding amount and loan terms.
Engineering Services Procurement
The Uniform Guidance 2 CFR 200.317 through 2 CFR 200.327 gives minimum requirements for
procurement, with 2 CFR 200.319(b) addressing engineering services procurement
guidelines. ARP -funded projects must also adhere to North Carolina State law. All projects must
also comply with North Carolina General Statute 143-64.31, Article 3D Procurement of
Architectural, Engineering, and Surveying Services. Projects cannot be exempted from
qualification -based selection of these services under N.C.G.S. 143-64.32. Any services provided
that were not selected in compliance with federal requirements will be ineligible for
reimbursement.
US Treasury Requirements
Projects with an expected total cost of ten million dollars or more must meet US Treasury
requirements for prevailing wage rates, project labor agreements, and related requirements.
Recipients can either certify meeting the requirements or provide plans and reports as the SLFRF
Compliance and Reporting Guidance (treasury.gov) specifies.
Requirements of Local Government Units Designated as Distressed
Additional information is required to be submitted in the Engineering Report for all distressed
systems, regardless of funding source, to demonstrate how the project moves the local
government unit towards viability. Guidance on these requirements can be found on the
Division's website on the "I Have Funding" page under the Engineering Report section. For
questions about these additional requirements, please contact Shane Beeson of the Viable Utility
Projects Unit at 919-707-3614 or at Shane.Beesop�a ncdenr.gov.

Mr. Scott Kidd, Town Manager
March 23, 2023
Page 3 of 3
Local government units designated as "distressed" under § 159G-45(b) must complete associated
requirements of the statute by:
1. Conducting an asset assessment and rate study.
2. Participating in a training and educational program.
3. Developing a short-term and long -teen action plan considering all of the following:
a. Infrastructure repair, maintenance, and management;
b. Continuing education of the governing board and system operating staff; and
c. Long-term financial management plan.
Davis -Bacon Requirements and American Iron and Steel Provisions
Projects funded through the State Revolving Fund (SRF) programs must comply with Davis -
Bacon wage requirements and American Iron and Steel provisions. You can find standard
specifications covering these requirements on our website.
Upon receipt of your letter of intent to fund, please fill out the attached Federal ID &
Unique Entity ID (UEI) form, attached and email it to Pam Whitley at [e-mail].
If you choose to decline this funding, the Authorized Representative as declared in the
application must directly contact the Division project manager via email or letter on the
applicant's letterhead.
We are offering a free permit assistance service to address any questions you have about
potential permitting requirements, pitfalls, fees, and timelines. If interested, please complete our
online form at htt s:Hde .nc. ov/ ermits-rules! ermit-assistance-and- , uidance/ ermit-
assistance-request-form and a regional environmental coordinator will contact you. When
applying for a permit; attach a copy of this letter to your permit application. We find this helpful
to identify ARPA projects to get your permit to you faster to assist with meeting the federal
expenditure deadline of December 31, 2026.
If you have any questions, please contact Adrian Eaton at [e-mail] or by
phone at [phone].
Sincerely,
� � i i
011 %,
Jon Risgaard, Chief
State Revolving Fund Section
EC: Monica Chevalier, WithersRavenel (via email)
Jack Fitzgerald, PE, WithersRavenel (via email)
Tesfu "Steve" Tsadwa (via email)
Shane Beeson (via email)
ARPA (COM_LOIF)

II. Performance
The Town's most recent Compliance Evaluation Inspection of the Wastewater Treatment Plant
was April 12, 2022. 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
01/03/2022
15,000
I/I due to rainfall of 3.5" in 1 day
11

Overflows in the Collection System
Date
Amount (gallons)
Location
Cause
1/3/2022
1,800
W. Kime Ave. Lift Station
Manhole #400
I/I
1/3/2022
1,800
W. Kime Ave. Manhole #400A
I/I
1/3/2022
4,320
Kinro Rd Manhole #500B
I/1
1/3/2022
4,800
Johnson Lift Station
Manhole #300
I/1
1/24/2022
950
S. Greensboro St.
Sewer Force Main
Pipe Failure
3/12/2022
1,200
Kinro Rd Manhole #500B
1/1
3/16/2022
5,400
Johnson Lift Station
Manhole #300
I/I
3/16/2022
3,000
Kinro Rd Manhole #500B
I/1
7/27/2022
495
Kinro Rd Manhole #500B
I/I
10/1/2022
1,800
Kinro Rd Manhole #500B
1/1
10/20/2022
5,400
Newberry Ave. Outfall Line
Manhole #99
Roots
Description of Corrective Measures
See Special Order By Consent
Liberty: A Great Place to Live

II. Performance
The Town's most recent Compliance Evaluation Inspection of the Wastewater Treatment Plant
was August 30, 2021. 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
01/01-01/14/2021
939,650
I/I due to rainfall of 2.6" in 2 day
01/03/2021
6,000
I/I due to rainfall of 2.0" in 1 day
01/31/2021
4,100
I/I due to rainfall of 1.7" in 1 day
01/28-02/10/2021
954,000
I/I due to rainfall of 4.9" in 5 day
02/12-03/10/2021
1,512,000
1/I due to rainfall of 6.4" in 9 day.
03/18-04/09/2021
1,605,550
I/I due to rainfall of 4.1" in 5 day
09/22/2021
660
I/I due to rainfall of 2.5" in 1 da
n

Overflows in the Collection System
Date
Amount (gallons)
Location
Cause
1/3/2021
3,360
W. Kime Ave. Lift Station
Manhole #400
I/I
1/3/2021
3,360
W. Kime Ave. Manhole #400A
I/I
1/3/2021
3,600
Kinro Rd Manhole #500B
I/1
1/31/2021
3,520
Kinro Rd Manhole #500B
I/1
1/31/2021
3,200
W. Kime Ave Manhole #400A
I/I
1/31/2021
3,200
W. Kime Ave. Lift Station
Manhole #400
I/I
2/15/2021
2,250
W. Kime Ave Manhole #400A
1/I
2/15/2021
1,350
Kinro Rd Manhole #500B
I/I
2/15/2021
2,250
W. Kime Ave. Lift Station
Manhole #400
I/I
2/15/2021
2,475
Johnson Lift Station
Manhole #300
8/7/2021
1,500
W. Kime Ave. Lift Station
Manhole #400
1/I
8/7/2021
1,500
W. Kime Ave. Manhole #400A
I/I
8/7/2021
2,100
Kinro Rd Manhole #500B
1/I
8/7/2021
4,800
Johnson Lift Station
Manhole #300
I/I
9/22/2021
900
W. Kime Ave. Manhole #400A
I/I
9/22/2021
900
Johnson Lift Station
Manhole #300
I/I
9/22/2021
900
W. Kime Ave. Lift Station
Manhole #400
I/I
9/22/2021
750
Kinro Rd Manhole #500B
1/1
Description of Corrective Measures
See Special Order By Consent
Liberty: A Great Place to Live