NC0024244_NOV-2019-PC-0188 Response_20190402

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ALBEMARLE
NORTH CAROLINA
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April 3, 2019
W. Corey Basinger ,4egeonal Sulwviser
Water Quality Regional Operations Section
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
SUBJECT: Notice of Violation
NOV-2019-PC-0188
Compliance Inspection Report
Long Creek WWTP-NPDES Permit No. NCO024244
Dear Mr. Basinger:
www.albemarlenc.gov
PO Box 190
Albemarle, NC 28002
APR V) q ?"ll"
The purpose of this letter is to provide additional information for the consideration in the above
referenced matter in accordance with your letter dated March 12, 2019. 1 would like to thank you and
your staff of the Mooresville Regional Office for the opportunity to respond to the NOV listed above.
I asked Adam Kiker, LKC Engineering, PLLC, to write you a letter stating the past and future of
Albemarle's sanitary sewer rehabilitation projects. City of Albemarle staff has worked closely with this
firm for many years. LKC Engineering knows the history of Albemarle's I&I and Long Creek WWTP issues
and problems.
Albemarle is open to all suggestions from you and your staff
If you have further concerns or need additional information, please feel free to contact me at
[e-mail] or by phone at [phone].
Sincerely, _
,Yl
Judy Redwine
City of Albemarle
Public Utilities Director

March 28, 2019w1„
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Mr. W. Corey Basinger
Regional Supervisor, Water Quality Regional Operations Section
NCDEQ Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Response to Notice of Violation
NOV-2019-PC-0188
Dear Mr. Basinger:
This letter is to provide supplemental response to the Notice of Violation letter sent to Albemarle dated
March 12, 2019. Our firm is assisting Albemarle with several sewer rehabilitation projects, and we have
a thorough understanding of the challenges they face during rain events.
The Albemarle utility staff, City Manager, and City Council recognize they have an inflow and infiltration
problem in their sewer collection system. However, inflow and infiltration is a difficult challenge to solve,
and it is not one that can be solved quickly. The Albemarle leadership is committed to improving the
issues you presented in the March 12, 2019 Notice of Violation, and that commitment takes the form of
significant capital improvement projects aimed at reducing inflow and infiltration. Since 2012 Albemarle
has committed to nearly $10,000,000 in sewer rehabilitation capital projects, and they are planning more:
1- Sanitary Sewer Rehabilitation, Phase 1(CS370522-04): This $3,500,000 project was completed in
2014 and featured digging and replacing approximately 15,000 feet of 36" and 24" gravity sewer.
The rehabilitated sewer line is the primary gravity sewer outfall that serves the entire city.
2. 2018 Wastewater Collection and Treatment Improvements (CS370522-06): This $6,400,000
project features the digging and replacing of 7,000 feet of 24" gravity sewer and pump station
and electrical renovations at the treatment plant. The project has received construction bids and
is scheduled to start construction in July of 2019. The gravity sewer rehabilitation in this project
is a continuation of the outfall replaced in Phase 1.
3. Sanitary Sewer Rehabilitation, Phase 3A: This project replaces approximately 700 feet of 24"
gravity sewer at the downstream side of the City's west side outfall. This leg was videoed in
January 2019 and several sags and pipe failures were identified. The replacement is being
implemented immediately (April of 2019) using the City's utility crews. The cost of the material
and the bypass pumping is estimated at $150,000.
4. Sanitary Sewer Rehabilitation, Phase 313: This project is in the planning phase and consists of
digging and replacing 8,000 feet of 24" and 18" gravity sewer that drains the western part of the
city. It also includes significant electrical upgrades at the treatment plant. The City plans to apply
for $4,300,000 in funding in the Fall 2019 CWSRF cycle.
LKC Engineering, PLLC, 140 Aqua Shed Court, Aberdeen, North Carolina 28315
PH: 910/420-1437 * FAX: [phone] * License No. P-1095

East Side Inflow and Infiltration Study: The City has budgeted $35,000 in their FY2020 budget to
perform an I&I Study in the eastern collection system. The infrastructure in this region shows
signs of significant inflow, and the intent of the study is to identify operational and capital projects
to reduce the issue.
Albemarle's leadership is committed to implementing capital projects to reduce inflow and infiltration.
These projects require time to plan, secure funding, design, and implement.
Like many other sewer utilities across North Carolina, the rain events of the Fall of 2018 created major
challenges for Albemarle's collection system and treatment plant. Albemarle does not have flow
equalization at their plant, and the significant high flow events result in solids wash out and loss of
nitrifiers, creating other compliance challenges.
Albemarle recognizes the bulk of the problem is outside the gates of the wastewater treatment plant, and
they are committing millions of dollars to replace and rehabilitate their gravity sewer collection system to
reduce the peak flow events at the plant.
If you have any questions, please do not hesitate to contact me by phone at [phone] or by email
at [e-mail].
Very Best,
Adam P. Kiker, P.E.