WQ0003090_Staff Report_20240321

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
March 21, 2024
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00003090
Attn: Leah Parente Facility name: Liberty WWTF
From: Caitlin Caudle
Winston-Salem Regional Office
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 3/12/2024
b. Site visit conducted by: C. Caudle
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Tremaine Fike
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Tremaine Fike Certificate #: 98290 Backup ORC: Todd Kellam Certificate #: 1011878
2. Are the design, maintenance, and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
5. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ N/A
8. Are there any setback conflicts for existing treatment, storage, and disposal sites? ❑ Yes or ® No
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
11. Has a review of all self -monitoring data been conducted (e.g., AR, NDMR, NDAR, GW)? ❑ Yes or ❑ No
12. Has a review of compliance history been completed (CEI's)? ® Yes or ❑ No
13. Are there any permit changes needed in order to address ongoing BIMS violations? ® Yes or ❑ No
If yes, please explain: The freeboard marker has not been reinstalled as required bypreviousDWR
correspondence.
FORM: WQROSSR 04-14 Page 1 of 2

14. Check all that apply:
❑ No compliance issues
® Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
® Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) See most
recent inspection report.
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? Yes, the RO has worked with the Town on
compliance issues. Bypasses have been ongoing issues, covered under the SOC, and operation and maintenance
issues.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
® Yes ❑No❑N/A
If yes, please explain: DV-2023-0030 has not been paid to date.
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item
Reason
Clarification of industrial
sources.
Staff requested this as part of the most recent CEI, but the information has not
been provided to date.
3. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
A freeboard marker has not been reinstalled to date based on a recent survey of
Install a freeboard marker.
the lagoon embankments. Staff discovered that the existing freeboard marker is
not installed to accurately represent the lowest elevation of the lagoon
embankment. See attached survey.
4. Recommendation: ® Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny
5. Signature of report preparer:
Signature of regional supervisor:
Date: 3/21/2024
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
145B49E225C94EA...
Mr. Fike stated that to his knowledge, no stormwater is treated by the WWTF and any stormwater in the system is a
result of I&I. A more accurate representation of WW composition is 40% industrial and 60% domestic.
The acreage entered in Section IX is from the original design specifications, not the updated acreage provided in the
letter included with the application.
Staff calculated the hydraulic capacity as 68% and average flows as 375,690 GPD. See attached flow study document.
Is there certification needed to complete the sludge survey?
FORM: WQROSSR 04-14 Page 2 of 2

P.O. Box 1086
Liberty, NC 27298
Phone: [phone]
Fax:[phone]
Email: moore,ols@rtelcomet
Mr. Lon Snider
State Department of Environment
217 W. Jones Street
Raleigh, NC 27603
Mr. Snider:
August 01, 2022
This letter is to certify elevations at the Town of Liberty wastewater facilities. My findings
are that the lowest point on the concrete apron is 0.5 feet above the top of the concrete pad
intake located at the Northeast corner of the lagoon as labeled treatment facility, making
the freeboard requirement of 1.5 feet,1.0 feet below the top of the concrete pad.
If you have any questions, please do not hesitate to call me.
Thank you.
Joseph D. Moore
Professional Land Surveyor
P.O. Box 1086
Liberty, NC 27298
336-622-4638
M��

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
March 20, 2024
CERTIFIED MAIL No. 7022 2410 0003 1826 9142
RETURN RECEIPT REQUESTED
Mr. Scott Kid, Town Manager
Town of Liberty
P.O. Box 1006
Liberty, NC 27298
SUBJECT: Notice of Violation and Intent to Enforce (NOV-2024-PC-0203)
Compliance Evaluation Inspection
Liberty WWTF
Permit No. WQ0003090
Randolph County
On March 12, 2024, Division of Water Resources staff Caitlin Caudle conducted a routine
compliance inspection of the Town of Liberty Wastewater Treatment Facility. Tremaine
Fike, ORC, was present during the entire inspection. This review reflected noncompliance
with the subject permit.
The following violations were noted-
1 . To date, a staff gauge has not been installed to accurately represent the lowest
elevation in the lagoon embankment. Per Permit Condition 111.14 a gauge to
monitor the waste levels in the 15 acre stabilization storage lagoon shall be
provided. This was also listed as a violation in the Notice of Violation and Intent to
Enforce NOV-2023-PC-0406 dated July 27, 2023. You are required to install a
staff gauge within thirty (30) days of receipt of this Notice.
2. At the time of inspection, the chlorine contact chamber was actively bypassing and
visibly discharging to the Rocky River. This bypass was reported to Emergency
Management by Mr. Fike on March 10, 2024. Per Permit Condition 1.1, the
Permittee shall maintain and operate the subject non -discharge facilities so there
is no discharge to surface waters... All efforts should be made to stop the
bypass, and the affected area cleaned once the bypass stops. Additional
correspondence will be sent at a later date concerning this event.
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

The following items of concern were noted:
A. Irrigation was reviewed in Zone 5 and several spray heads were clogged. Per
Permit Condition V.1, the Permittee shall perform inspections and maintenance
to ensure proper operation of the wastewater treatment and irrigation facilities.
Continue to repair the spray heads and standpipes as needed. Additional
action seems necessary to prevent trash, rags, and other material from
entering the chlorine contact chamber and the irrigation pumps.
B. Mr. Fike calibrated the irrigation system by measuring the pressure of multiple
spray heads in each zone and comparing that to the designed pressure and flow
rate for the given spray head type. The flow rate at the time of measurement was
not documented, and the uniformity of the sprinkler system was not calculated. Per
Permit Condition 111.7 the irrigation equipment shall be tested and calibrated once
per permit cycle. Additional information is needed to confirm the irrigation
system is performing as designed.
Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact Caitlin Caudle at the letterhead address and
phone number, or by email at caitlin.caudle(a�deg.nc.gov.
Sincerely,
Docu Signed by,
OD2D3CE3F1 B1456_.
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Enc: Inspection Report
Cc: Tremaine Fike, ORC (electronic copy)
Joe Walsh, Utilities Director (electronic copy)
Randolph County Environmental Health (electronic copy)
NORTH CAROLINAD � ��
oeo+ro�.m m F,mro���w n�si�
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0003090 Effective: 05/01/19 Expiration: 08/31/24 Owner : Town of Liberty
SOC: S19011 Effective: 01/01/24 Expiration: 12/31/26 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: Certification:
Secondary ORC(s):
Elix Tremaine Fike 989290
On -Site Representative(s):
Related Permits:
WQCS00280 Town of Liberty - Liberty Collection System
Phone:
336-215-8795
Inspection Date: 03/12/2024 Entry Time 09:OOAM Exit Time: 11:45AM
Primary Inspector: Caitlin auffd b?4c'Signedd bb"��: Phone: [phone]
Secondary Inspector(s): """'ru'
8B834968199D49D_
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
Storage Wells
(See attachment summary)
Page 1 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 03/12/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On March 12, 2024 Division of Water Resources staff Caitlin Caudle conducted a routine compliance inspection of the Town
of Liberty Wastewater Treatment Facility. Tremaine Fike, ORC, was present during the entire inspection. This review
reflected noncompliance with the subject permit.
Ms. Caudle requested a residuals removal record for activities on February 14, 2024.
The following violations were noted:
1. Per Permit Condition 111.14 a gauge to monitor the waste levels in the 15 acre stabilization storage lagoon shall be
provided. To date, a staff gauge has not been installed to accurately represent the lowest elevation in the lagoon
embankment. This was also listed as an item of violation in the Notice of Violation and Intent to Enforce NOV-2023-PC-0406
dated July 27, 2023.
2. At the time of inspection, the chlorine contact chamber was actively bypassing and visibly discharging to the Rocky
River. This bypass was reported to Emergency Management by Mr. Fike on March 10, 2024. Per Permit Condition 1.1, the
Permittee shall maintain and operate the subject non -discharge facilities so there is no discharge to surface waters... All
efforts should be made to stop the bypass, and the affected area cleaned once the bypass stops. Additional
correspondence will be sent at a later date concerning this event.
The following items of concern were noted:
A. Irrigation was reviewed in Zone 5 and several spray heads were clogged. Per Permit Condition V.1, the Permittee shall
perform inspections and maintenance to ensure proper operation of the wastewater treatment and irrigation facilities.
Continue to repair the spray heads and standpipes as needed. Additional action may be needed to prevent trash, rags, and
other material from entering the chlorine contact chamber, and in turn the irrigation pumps.
B. Mr. Fike calibrated the irrigation system by measuring the pressure of multiple spray heads in each zone can comparing
that to the designed pressure and flow rate for the given spray head type. The flow rate at the time of measurement was not
documented, and the uniformity of the sprinkler system was not calculated. Per Permit Condition 111.7 the irrigation
equipment shall be tested and calibrated once per permit cycle. Additional information is needed to confirm the irrigation
system is performing as designed.
Other observations:
• Mr. Fike calibrated the irrigation system by measuring the pressure of multiple spray heads in each zone can comparing
that to the designed pressure and flow rate for the given spray head type.
• No runoff was observed from irrigation activities.
• The concrete riser around MW7 was repaired and in good condition.
• Select irrigation zones were not reseeded last fall. They are scheduled to be reseeded this spring.
• The chlorine contact chamber surface has been skimmed when solids float to the top. The skimmed material is returned
to the plant at the bar screen. Mr. Fike stated the chlorine contact chamber has not been cleaned to remove any solids from
the bottom.
• A new road will be built to access the WWTF.
• Ms. Caudle discussed monitoring an area in Zone 7 where a ditch was beginning to form, and additional spray heads are
capped. Ms. Caudle recommended that the two uncapped spray heads above the ditch be monitored for directional flow.
• Mr. Fike stated that when influent flow is greater than 3,000 gpm the lift station pumps are outpaced, and the lift station
will bypass.
• Mr. Fike stated that the most recent effluent sample had a pH > 8.0.
• Mr. Fike stated that the chlorine contact chamber was cleaned 2/14/2024 due to an algal growth.
• At the time of inspection, the effluent in the lagoon and bypassing the chlorine contact chamber was visibly green.
• The influent and effluent flowmeters were calibrated 11/30/2023.
• The lift station pumps are not grinder pumps and are large enough to send rags, trash, and other material to the lagoon.
• During and immediately following rainfall events, the average GPD flow exceeds the permitted limit.
• Ms. Caudle discussed the importance of maintaining Plant Available Nitrogen records when considering adding
additional nutrients to the irrigation zones. Additional nitrogen and other nutrients may be added as long as the crop's
Page 2 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 03/12/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
nitrogen rate is not exceeded within a 12 month rolling period. Ms. Caudle can be contacted if there are additional questions.
• Soil samples were collected 10/12/2023.
• Monitoring wells 5, 4, 2, and 7 were reviewed.
• Ms. Caudle discussed the importance of preventing runoff and ponding from the irrigation fields.
• A culvert was replaced on the property to cross the UT between Z813 and Z7. Stormwater was standing on the upstream
side of the culvert and Ms. Caudle recommended the stormwater be diverted or ditched away from the culvert.
• The downstream side of the culvert is perched above the stream bed.
Page 3 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 03/12/2024 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Reuse (Quality)
❑
Infiltration System
❑
Lagoon Spray, LR
❑
Single Family Spray, LR
❑
Activated Sludge Drip, LR
❑
Activated Sludge Spray, HR
❑
Recycle/Reuse
❑
Single Family Drip
❑
Activated Sludge Spray, LR
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? 0 ❑ ❑ ❑
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?
❑ ❑ ❑
Are all pumps present?
❑ ❑ ❑
Are all pumps operable?
❑ ❑ ❑
Are floats/controls operable?
❑ ❑ ❑
Are audio and visual alarms available?
0
❑ ❑ ❑
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?
❑ ❑ ❑
Does flowmeter appear to monitor accurately?
❑ ❑ ❑
Comment:
Treatment Flow Measurement -Water Use Records Yes No NA NE
Page 4 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 03/12/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is water use metered? ❑ ❑ 0 ❑
Are the daily average values properly calculated? ❑ ❑ 0 ❑
Comment:
Treatment Flow Measurement -Effluent
Yes No NA NE
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:
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?
❑ ❑ ❑
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?
0
❑ ❑ ❑
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-
If yes, then when was the RMP last updated?
Comment: See summary.
Page 5 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 03/12/2024 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes No NA NE
Is a copy of current permit available?
❑ ❑ ❑
Are monitoring reports present: NDMR?
❑ ❑ ❑
NDAR?
❑ ❑ ❑
Are flow rates less than of permitted flow?
❑0
❑ ❑
Are flow rates less than of permitted flow?
❑0
❑ ❑
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 summary.
End Use -Irrigation
Yes No NA NE
Are buffers adequate?
0
❑ ❑ ❑
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?
❑ ❑ ❑
Is the application equipment present?
❑ ❑ ❑
Is the application equipment operational?
❑ ❑ ❑
Page 6 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 03/12/2024 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
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?
❑
❑ ❑
# 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:
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, concrete
Baffles/curtains
❑
❑ ❑
Freeboard Marker
❑
0 ❑ ❑
Required freeboard
1.5
Feet
Actual freeboard
0
Feet
Are increments clearly marked on gauge at adequate intervals?
❑
0 ❑ ❑
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall?
❑
0 ❑ ❑
No Evidence of overflow
❑
0 ❑ ❑
Acceptable color
❑
❑ ❑
Floating mats
❑
❑ ❑
Excessive solids buildup
❑
❑ ❑
Aerators/mixers
❑
❑ ■ ❑
Page 7 of 8

Permit: WQ0003090 Owner - Facility: Town of Liberty
Inspection Date: 03/12/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Effluent structure
■❑❑❑
Lagoon cover ❑ ❑ 0 ❑
Page 8 of 8