WQ0003090_Compliance Evaluation Inspection_20230728

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
July 27, 2023
CERTIFIED MAIL No. 7019 1120 0001 5504 9791
RETURN RECEIPT REQUESTED
Scott Kidd — Town Manager
Town of Liberty
P.O. Box 1006
Liberty, NC 27298
SUBJECT: Notice of Violation and Intent to Enforce (NOV-2023-PC-0406)
Compliance Evaluation Inspection
Liberty WWTF
Permit No. WQ0003090
Randolph County
izx�a►�r�:frraa
On July 20, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora
completed a routine compliance inspection. Mr. Tremaine Fike, ORC, was present during
the entire inspection. A review of records, treatment facilities, irrigation fields, and
monitoring wells was completed. This review reflected non-compliance with the subject
permit. The following violations were noted:
1. At the time of inspection, a spray head was damaged in field 8 upstream of the
stream crossing between fields 7 and 8B. The broken spray head could not be
located at the time of inspection due to the irrigation system being off. Staff were
able to track the ponding and runoff visible to the unnamed tributary between fields
7 and 8. Staff tracked the effluent in the unnamed tributary to the North Fork Rocky
River. Effluent was visible entering the North Fork Rocky River. Staff collected
upstream, downstream, and discharge surface water samples during this
inspection. See attached map and photos for reference. This discharge is a
violation of Permit Condition 11.1, which states "the Permittee shall maintain and
operate the subject non -discharge facilities so there is no discharge to surface
waters..." Based on the 5-day report provided by Mr. Fike, 9,000 gallons of effluent
entered the North Fork Rocky River.
The collected samples were analyzed for fecal coliform. Sample results are listed
below. The sample results show Drooer disinfection may not be occurring.
Upstream
Downstream
Discharge v
327 CFU/100mL
12,000 CFU/100mL
12,000 CFU/100mL
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
NoanicaaouNn
oep.m.m or em�nmen� Qualm
336.776.9800

2. At the time of inspection, a spray head was broken upslope of the North Fork Rocky
River in field 8B at a different location. Effluent was ponded at the edge of the
spray field and Staff tracked effluent runoff to a small depression adjacent to the
North Fork Rocky River. See attached map for reference. This is a violation of
Permit Condition 111.1 which states "the Permittee shall take measures to prevent
effluent ponding in or runoff from the irrigation sites..."
3. As mentioned in the Notice of Deficiency dated May 2, 2022, the freeboard marker
must be resurveyed by May 30, 2022. A letter was provided to this Office dated
August 1, 2022. To date, the freeboard marker has not been reinstalled based on
the survey findings. Per Permit Condition 111.14 a gauge to monitor waste levels
in the 15-acre stabilization and storage lagoon shall be provided. As it is currently
installed, the freeboard marker does not accurately measure freeboard.
The following item of concern was noted:
A. The hinge on Monitoring Well 7 was repaired at the time of inspection. Staff
observed erosion around the footing of the well cap and noted that the well casing
was loose. The erosion around the footing of the well casing can potentially serve
as a conduit of pollutants to groundwater. Per Permit Condition V.2, the permittee
shall inspect the wastewater treatment facilities to prevent malfunctions, facility
deterioration, and operator errors that may result in discharges of wastes to the
environment, threats to human health, or public nuisances. As described in 15A
NCAC 02C .0108, groundwater monitoring well construction requirements, repair
or replace the footing or well casing.
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 above.
Additionally, you are required to schedule an on -site meeting with staff from the Winston
Salem Regional Office to discuss the proposed corrective actions.
Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact me or Caitlin Caudle at the letterhead address
and phone number, or by email at lon.snider(a_deg.nc.gov or Caitlin.caudle(c_deg.nc.gov.
Sincerely,
DocuSiTgned by:
145B49E225CMEA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Att: 1. Inspection Map Cc: Tremaine Fike, ORC (electronic copy)
2. Inspection Photos Randolph County Environmental Health (electronic
3. Inspection Report copy)
North Carolina Department of Environmental Quality I Division of Water Resources
D ��� Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
NCRTH CARCLINA ^ 336.776.9800
0_p Mo Emimnmen quay

Att 1: Inspection Map
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NC CGIA, Maxar, Esri Community Maps Contributors, Chatham County, NC,
State of North Carolina DOT, Esri, HERE, Garmin, SafeGraph,

Attachment 2: Inspection Photos
Figure 1. Discharge from Field 8
Figure 3. Discharge channelizing from Field 8
NORTH CAROLINAD � ��
oeo+ro�.m m F,mro���w n�si�
Figure 2. Discharge channelizing from Field 8
F uJw .SRa ?M Figure 4. Discharge entering UT to Rocky River
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
336.776.9800

Figure 5. UT before entering Rocky River
Figure 6. Discharge entering Rocky River
D North Carolina Department of Environmental Quality I Division of Water Resources
✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
NORTH CAROLINA 336.776.9800
onparhnem of EmironmanW 9uallly

Compliance Inspection Report
Permit: WQ0003090 Effective: 05/01/19 Expiration: 08/31/24 Owner : Town of Liberty
SOC: Effective: Expiration: Facility: Town of Liberty WWTF
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: 07/20/2023 Entry Time 10:OOAM
Primary Inspector: Caitlin C 768B834968199D49D_.
g,ocuSigned by:
Secondary Inspector(s): ""'ruv' (""""� &
Certification:
Phone:
Exit Time: 01:30PM
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 Barscreen Record Keeping
Use Records
Treatment Lagoons End Use -Irrigation Treatment Influent Pump Station
Treatment Disinfection Treatment Flow Measurement Storage
Standby Power Wells
(See attachment summary)
Page 1 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 07/20/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On July 20, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora completed a routine compliance
inspection. Mr. Tremaine Fike, ORC, was present during the entire inspection. A review of records, treatment facilities,
irrigation fields, and monitoring wells was completed. This review reflected non-compliance with the subject permit. The
following violations were noted:
1. At the time of inspection, a spray head was damaged in field 8 upstream of the stream crossing between fields 7 and
8B. The broken spray head could not be located at the time of inspection due to the irrigation system being off. Staff were
able to track the ponding and runoff visible to the unnamed tributary between fields 7 and 8. Staff tracked the effluent in the
unnamed tributary to the North Fork Rocky River. Effluent was visible entering the North Fork Rocky River. Staff collected
upstream, downstream, and discharge surface water samples during this inspection. See attached map and photos for
reference. This discharge is a violation of Permit Condition 11.1, which states "the Permittee shall maintain and operate the
subject non -discharge facilities so there is no discharge to surface waters..." Based on the 5-day report provided by Mr.
Fike, 9,000 gallons of effluent entered the North Fork Rocky River.
The collected samples were analyzed for fecal coliform. Sample results are listed below. The sample results show proper
disinfection may not be occurring.
Upstream Downstream Discharge
327 CFU/100mL12,000 CFU/100mL 12,000 CFU/100mL
2. At the time of inspection, a spray head was broken upslope of the North Fork Rocky River in field 8B at a different
location. Effluent was ponded at the edge of the spray field and Staff tracked effluent runoff to a small depression adjacent to
the North Fork Rocky River. See attached map for reference. This is a violation of Permit Condition 111.1 which states "the
Permittee shall take measures to prevent effluent ponding in or runoff from the irrigation sites..."
3. As mentioned in the Notice of Deficiency dated May 2, 2022, the freeboard marker must be resurveyed by May 30,
2022. A letter was provided to this Office dated August 1, 2022. To date, the freeboard marker has not been reinstalled based
on the survey findings. Per Permit Condition 111.14 a gauge to monitor waste levels in the 15-acre stabilization and storage
lagoon shall be provided. As it is currently installed, the freeboard marker does not accurately measure freeboard.
The following item of concern was noted:
A. The hinge on Monitoring Well 7 was repaired at the time of inspection. Staff observed erosion around the footing of the
well cap and noted that the well casing was loose. The erosion the footing of the well casing can potentially serve as a
conduit of pollutants to groundwater. Per Permit Condition V.2, the permittee shall inspect the wastewater treatment
facilities to prevent malfunctions, facility deterioration, and operator errors that may result in discharges of wastes to the
environment, threats to human health, or public nuisances. As described in 15A NCAC 02C .0108, groundwater monitoring
well construction requirements, repair or replace the footing or well casing.
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 above.
Additionally, you are required to schedule an on -site meeting with staff from the Winston Salem Regional Office to discuss
the proposed corrective actions.
Other observations:
• Trees were trimmed and pushed back from the edge of the irrigation fields. Mr. Fike stated that the contracted farmer
will be reseeding any bare areas.
• Maintenance events completed by the contracted farmer were recorded in the operations and maintenance log.
• Mr. Fike stated that areas of the spray field will likely be reseeded this fall by the contracted farmer.
• The mobile home park close to the spray fields has a single water supply well and the rest of the area is served by
public water.
Page 2 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 07/20/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
• Mr. Fike stated he is irrigating for a longer period of time once a week instead of a shorter amount of time twice a week.
This has allowed him to repair more spray heads.
• The contracted farmer has applied chicken litter to the spray fields. Mr. Fike provided a nutrient analysis of the chicken
litter. The chicken litter had a PAN rate of 24.7 Ibs/ton and 3200 Ibs/ac were applied, based on staff calculations this is a
loading rate of 40 Ibs/ac. Based on submitted monthly monitoring reports and this information, below is table of 12-month
nitrogen loading in each field as of May 2023. Values were calculated using the more conservative seasonal acreage of
December through March
Zone 1 2 3 4 5 6 7 8
PAN Limits 204 204 204 204 204163.2 163.2 188
(Ibs/ac)
PAN Loading
(Ibs/ac) 95.1 90.9 86.1 102.1 110.4 84.6 75.3 95.1
• The irrigation system has not been calibrated to date. This must be completed by August 31, 2024.
• Fecal values exceed 1/100mL.
• Flow values exceeded monthly limits in April 2023, this was addressed in a separate NOD.
• Soil samples were collected in November 2022.
• Metering equipment was calibrated November 2022.
• The high water alarm at the lift station calls out to the ORC and BUORC.
• The chlorine contact chamber still had floating solids in it. Mr. Fike stated that they are cleaning the surface of the
chlorine contact chamber once a month with a vacuum truck. Solids continue to enter the chlorine contact chamber when
freeboard is above the concrete riser in the lagoon.
• Freeboard was 6" below the concrete riser in the lagoon. Based on the survey report, this would be 0" freeboard.
Field 8 irrigation was viewed in progress.
Page 3 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 07/20/2023 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Reuse (Quality)
❑
Infiltration System
❑
Activated Sludge Spray, LR
❑
Single Family Spray, LR
❑
Activated Sludge Spray, HR
❑
Activated Sludge Drip, LR
❑
Recycle/Reuse
❑
Single Family Drip
❑
Lagoon Spray, LR
Treatment Influent Pump Station
Yes No NA NE
Is the pump station free of bypass lines or structures?
❑ ❑ ❑
Is the general housekeeping acceptable?
❑ ❑ ❑
Are all pumps present?
❑ ❑ ❑
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?
❑
❑ ❑
Are SCADA/Telemetry operational?
❑
❑ 0 ❑
Comment:
Treatment Flow Measurement -Influent
Yes No NA NE
Is flowmeter calibrated annually?
❑ ❑ ❑
Is flowmeter operating properly?
❑ ❑ ❑
Does flowmeter monitor continuously?
❑ ❑ ❑
Does flowmeter record flow?
0
❑ ❑ ❑
Does flowmeter appear to monitor accurately?
0
❑ ❑ ❑
Comment:
Treatment Flow Measurement -Water Use Records Yes No NA NE
Is water use metered? ❑ ❑ 0 ❑
Are the daily average values properly calculated? ❑ ❑ 0 ❑
Comment:
Treatment Flow Measurement -Effluent Yes No NA NE
Page 4 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 07/20/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is flowmeter calibrated annually? 0 ❑ ❑ ❑
Is flowmeter operating properly? 0 ❑ ❑ ❑
Does flowmeter monitor continuously? 0 ❑ ❑ ❑
Does flowmeter record flow? 0 ❑ ❑ ❑
Does flowmeter appear to monitor accurately? 0 ❑ ❑ ❑
Comment:
Standby Power Yes No NA NE
Is automatically activated standby power available? ❑ ❑ ❑
Is generator tested weekly by interrupting primary power source? ❑ ❑ ❑
Is generator operable? ❑ ❑ ❑
Does generator have adequate fuel? ❑ ❑ ❑
Comment:
Treatment Barscreen Yes No NA NE
Is it free of excessive debris? 0 ❑ ❑ ❑
Is disposal of screenings in compliance? 0 ❑ ❑ ❑
Are the bars spaced properly? 0 ❑ ❑ ❑
Is the unit in good condition? 0 ❑ ❑ ❑
Comment:
Treatment Disinfection
Yes No NA NE
Is the system working?
0
❑ ❑ ❑
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?
❑
❑ ❑
If UV, is the UV intensity adequate?
❑
❑ ❑
# Is it a dual feed system?
❑
❑ ❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
❑
❑ ❑
If yes, then is there a Risk Management Plan on site?
❑
❑ ❑
If yes, then what is the EPA twelve digit ID Number? (1000-
Page 5 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 07/20/2023 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
If yes, then when was the RMP last updated?
Comment: See summary.
Record Keeping
Yes No NA NE
Is a copy of current permit available?
0
❑ ❑ ❑
Are monitoring reports present: NDMR?
0
❑ ❑ ❑
NDAR?
0
❑ ❑ ❑
Are flow rates less than of permitted flow?
0
❑ ❑ ❑
Are flow rates less than of permitted flow?
❑ ❑ ❑
Are application rates adhered to?
❑ ❑ ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
❑ ❑ ❑
Are all samples analyzed for all required parameters?
❑ ❑ ❑
Are there any 2L GW quality violations?
❑
❑ ❑
Is GW-59A certification form completed for facility?
❑ ❑ ❑
Is effluent sampled for same parameters as GW?
❑ ❑ ❑
Do effluent concentrations exceed GW standards?
❑ ❑ ❑
Are annual soil reports available?
❑ ❑ ❑
# Are PAN records required?
❑ ❑ ❑
# Did last soil report indicate a need for lime?
❑
❑ ❑
If so, has it been applied?
❑
❑ ❑
Are operational logs present?
❑ ❑ ❑
Are lab sheets available for review?
❑ ❑ ❑
Do lab sheets support data reported on NDMR?
❑ ❑ ❑
Do lab sheets support data reported on GW-59s?
❑ ❑ ❑
Are Operational and Maintenance records present?
❑ ❑ ❑
Were Operational and Maintenance records complete?
❑ ❑ ❑
Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑
Is a copy of the SOC readily available?
❑ ❑ ❑
No treatment units bypassed since last inspection?
❑
❑ ❑
Comment: See summa
End Use-Irriqation
Yes No NA NE
Are buffers adequate?
❑ ❑ ❑
Is the cover crop type specified in permit?
❑ ❑ ❑
Is the crop cover acceptable?
❑ ❑ ❑
Is the site condition adequate?
❑ ❑ ❑
Is the site free of runoff / ponding?
❑
❑ ❑
Is the acreage specified in the permit being utilized?
0
❑ ❑ ❑
Page 6 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 07/20/2023 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Is the application equipment present?
0
❑ ❑ ❑
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?
0
❑ ❑ ❑
Are any supply wells within the CB?
❑
❑ ❑
Are any supply wells within 250' of the CB?
❑
❑ ❑
How close is the closest water supply well?
❑
❑ ❑
Is municipal water available in the area?
0
❑ ❑ ❑
# Info only: Does the permit call for monitoring wells?
0
❑ ❑ ❑
Are GW monitoring wells located properly w/ respect to RB and CB?
0
❑ ❑ ❑
Are GW monitoring wells properly constructed, including screened interval?
0
❑ ❑ ❑
Are monitoring wells damaged?
0
❑ ❑ ❑
Comment: See summary.
001
Treatment Lagoons
Yes No NA NE
Lagoon Type
None
Primary/Secondary
Primary
Influent structure
❑ ❑ ❑ ❑
Banks/berms (seepage and erosion) ❑ ❑ ❑ ❑
Vegetation (excessive vegetation on banks/berms) ❑ ❑ ❑ ❑
Liner ❑ ❑ ❑ ❑
Liner Type Apron, clay
Baffles/curtains ❑ ❑ ❑ ❑
Freeboard Marker ❑ ❑ ❑ ❑
Required freeboard 1.5
Feet
Actual freeboard 0
Feet
Are increments clearly marked on gauge at adequate intervals? ❑ ❑ ❑ ❑
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall? ❑ ❑ ❑ ❑
No Evidence of overflow ❑ ❑ ❑ ❑
Acceptable color ❑ ❑ ❑ ❑
Floating mats ❑ ❑ ❑ ❑
Page 7 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 07/20/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Excessive solids buildup ❑ ❑ ❑ ❑
Aerators/mixers ❑ ❑ ❑ ❑
Effluent structure ❑ ❑ ❑ ❑
Lagoon cover ❑ ❑ ❑ ❑
Page 8 of 8