WQCS00031_NOV-2022-DV-0510 Response_20220208

Orange Water and Sewer Authority
OWASA is Carrboro-Chapel Hill's not -for -profit public service agency
delivering high quality water, wastewater, and reclaimed water services.
February 8, 2022
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, North Carolina Division of Environmental Quality
3800 Barrett Drive
Raleigh, North Carolina 27609
SUBJECT: Response to Notice of Violation (NOV-2021-DV-0510)
November 8, 2021 Self -Reported Sanitary Sewer Overflow
Collection System Permit No. WQCS00031
Dear Mr. Vinson:
As requested in your letter of January 18, 2022 (received on January 24, 2022) we are writing
to provide you information about the Sanitary Sewer Overflow (SSO) experienced on
November 8, 2021 at 705 N. Greensboro Street in Carrboro, NC.
Background
Orange Water and Sewer Authority (OWASA) provides water and sewer service to the
southern portions of Orange County, NC including the Town of Carrboro and the Town of
Chapel Hill. Our overall wastewater collection system includes approximately 350 miles of
gravity sewer mains, 21 lift stations, and 14 miles of pressurized sewer force mains.
SSO Incident Number 202102137 occurred at manhole 101496 on November 8, 2021
beginning at 10:30 am and ending on November 8, 2021 at 10:47 am.
Initial Response
On Monday, November 8th, 2021, OWASA Distribution and Collection team received a call
from a customer reporting water coming from a manhole in the area of 705 N. Greensboro St.
in Carrboro, NC. OWASA immediately dispatched field crews to investigate the issue.
OWASA staff arrived in the area at 10:30 AM and noticed manhole 101496 was in fact
overflowing and wastewater was entering Tanbark Branch, a small tributary creek. Staff
immediately alerted the Collection System Operator in Responsible Charge (ORC) and
mobilized remediation resources.
400 Jones Ferry Road. Carrboro NC 27510 919-968-442I
[e-mail] 0 CDOWASA1 • www.owasa.org

Mr. Scott Vinson
Response to Notice of Violation (NOV-2021-DV 0510)
February 8, 2022
Page 2
Investigations
OWASA staff investigated the incident by inspecting both the upstream and downstream
manholes in the area to determine the extents of the SSO. It was found that the blockage
was isolated to one segment of sanitary sewer main, at manhole 101496 which resulted in
wastewater surcharging in the infrastructure upstream from that segment. OWASA's
Collection System ORC, Nicholas Rogers, arrived on the scene at 10:45 AM and observed
the crews working to address the overflow and assisted them to stop the wastewater spill at
10:47 AM.
OWASA ORC collected a water sample from the creek and utilized our Wastewater
Treatment lab to confirm the presence of wastewater in the surface waters.
OWASA provided the initial spill response notification on November 8th, 2021 at 3:32 PM to
Joshua Brigham and completed the Collection System Sanitary Sewer Overflow Reporting
Form CS-SSO by Thursday November 11th, 2021.
Remediation
OWASA staff immediately began jetting the sewer main from the downstream manhole
towards the overflowing manhole to locate and dislodge any blockage in the line. The efforts
were successful, and the blockage was disencumbered at 10:47am.
Once the surcharged wastewater subsided within manhole 101496 and upstream
infrastructure, OWASA staff discovered a large basketball, tree limbs, and debris inside the
manhole which were blocking the flow of wastewater in the invert. The items and debris
were removed, and flow was immediately restored.
The impacted area was washed down and cleaned thoroughly. Hydrated lime and
deodorant were applied to disinfect the area and address odor issues. To prevent future
backup or blockage OWASA crews cleaned the sanitary sewer mains upstream and
downstream to remove any sediment or debris built up in the line from the incident.
To further remediate the situation, OWASA crews removed the pooled wastewater from the
creek in effort to lower the ammonia levels in the surface water. OWASA continued to
vacuum wastewater from the tributary and discharge into a nearby sanitary sewer manhole
until ammonia levels came back below 1.0 mg/I which is considered "untraceable" by our
Wastewater Treatment Plant laboratory.

Mr. Scott Vinson
Response to Notice of Violation (NOV-2021-DV-0510)
February 8, 2022
Page 3
Root Cause of the Overflow
The sanitary sewer overflow was believed to be caused by vandalism at manhole 101496.
This debris blocked a large portion of the sewer main causing solids to collect upstream and
resulted in a sewer backup that overflowed from the manhole. The size of the large
basketball and tree debris could not have traveled through the sewer main, therefore it is
suspected that the items were dumped into the manhole. The manhole ring and cover was
intact and secured upon our arrival and no other openings in the system would allow debris of
this size.
Continuous Improvement
Commitment to the highest level of environmental stewardship has been and continues to be
one of the fundamental principles of OWASA. We believe that OWASA's actions before,
during, and after the event reflect this commitment. OWASA requests that you consider
these key factors in any subsequent action the Division of Water Resources might take:
• OWASA staff addressed the issue immediately to minimize the impact
• OWASA met all reporting requirements
• OWASA is continuously improving and updating our sewer preventative maintenance
program.
o We have root -treated 56 miles (16%), cleaned 107 miles (32%), CCTV
inspected 32 miles (10%), and maintained and inspected approximately 112
Miles (33%) of our entire sanitary sewer system (335 miles) annually.
o This information gathered from our preventative maintenance program is used
to assist our Engineering Department with rehabilitation decision making which
has produced approximately 9.2 miles of sanitary sewer line replacement over
the past 5 years.
• OWASA ORC collected samples in the surface water to ensure that the dewatering
system removed all the wastewater in the area.
OWASA requests that you consider these key factors in any subsequent action the
Division of Water Resources might take:
• OWASA staff addressed the issue immediately to minimize the impact
• OWASA quickly identified the root cause of the initial SSO, which allowed the OWASA
team to implement a rapid response and make repair.
• OWASA met all reporting requirements

Mr. Scott Vinson
Response to Notice of Violation (NOV-2021-DV-0510)
February 8, 2022
Page 4
We hope that the information provided herein is helpful to you and please feel free to contact
us should you have any further questions.
Sincerely,
I..,(L____
%
Todd Taylor, P.E.
Executive Director
cc: Mary Darr, General Manager of Operations
Jesse DuClau, Distribution and Collection Systems Manager
Nicholas Rogers, Assistant Distribution and Collection Systems Manager and
Collection System ORC
Monica Dodson, Wastewater Treatment and Biosolids Recycling Manager
File
Attachments:
1. Notice of Violation (NOV-2021-DV-0510)
2. Collection System Sanitary Sewer Overflow Reporting Form CS-SSO
3. Site/Repair Photos

Attachment 1
ROY COOPER
Governor
EUZABETH S. BISER
Seaway
S. DANIEL SMITH
Director
Certified Mall # 7020 3150 0000 4115 666Z
sounasailanswintsd
Todd Taylor, Executive Director
Orange Water and Sewer Authority
400 Jones Ferry Road
Carrboro, NC 27510-2001
NORTH L
vironalaltal eh
January 18, 2022
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2021-DV-0510
Sanitary Sewer Overflows - November 2021
Collection System Permit No. WQCS00031
OWASA Collection System
Orange County
Dear Mr. Taylor:
riiEOW1
2 4 2022
By
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by Orange Water and Sewer Authority
indicates violations of permit conditions stipulated in the subject permit and North Carolina G.S. 143-215.1.
Violations include failing to effectively manage, maintain, and operate the subject collection system so that there is
no SSO to the land or surface waters and making an outlet to waters of the State for purposes of G.S.
143-215.1(a)(1), for which a permit Is required.
Spedfic inddent(s) cited in the subject report include the following:
Incident Start Duration
Number Date (Mina) Location
Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
202102137 11/8/2021 17 705 N. Greensboro St. Vandalism
340 340 Notice of Violation
Remedial actions, if not already implemented, should be taken to correct the above noncompliance. Please submit
a written response to this Notice of Violation. Your response is to be received by the regional office within 15
business days following receipt of this violation. Please include any additional documentation about this incident(s)
in the response. The submittal will be considered in determining whether the Division will assess a dvil penalty for
the cited violations.
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If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Sincerely,
Ecassiobse
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for Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Regional Office - WQS File
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Attachment 2
DWR
Dirlston of Water Resources
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
PART 1:
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00031 (WQCS# if active, otherwise use WQCSD#)
Facility: OWASA Collection System Incident #: 202102137
Owner: Orange Water and Sewer Authority
City: Carrboro
County: Orange Region: Raleigh
Source of SSO (check applicable): Sanitary Sewer ❑ Pump Station 1 Lift Station
SPECIFIC location of the SSO (be consistent in description from past reports or documentation - i.e. Pump Station 6,
Manhole at Westall & Bragg Street, etc): 705 N. Greensboro St.
Manhole #: 101496
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 11/08/2021 Time: 10:30 am Incident End Dt: 11/08/2021 Time: 10:47 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 340 gallons Estimated Duration (Round to nearest hour): 0:17 hours
Describe how the volume was determined: Estimate
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? [l Yes ❑ No ❑ Unknown
Surface water name: Tanbark Branch
Volume reaching surface waters (gals): 340
Did the SSO result in a fish kill? ❑ Yes QNo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
Q Vandalism
24 hour verbal notification (name of person contacted ): Joshua S Brigham
• DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 11/08/2021 Time (hh:mm AM/PM): 03:32:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director, Division of Water Resources, may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED. A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form
Page: 1

PART Ii:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Vandalism
Provide police report number:
Was the site secured? p Yes ❑ No ❑ NA ❑ NE
If Yes, how?
Manhole had a secured Tina and cover. and was in place when crews arrived.
Have there been previous problems with vandalism at the SSO location? ❑ Yes El No ❑ NA ❑ NE
If Yes, explain:
What security measures have been put in place to prevent similar occurrences in the ❑ Yes ❑ No p NA ❑ NE
future?
Comments:
System Visitation
ORC 0 Yes
Backup ❑ Yes
Name:
Nick Rollers
Cert#
998691
Date visited:
11/08/2021
Time visited:
10:45am
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Upon arrival OWASA crews observed wastewater coming out of a manhole ring and cover. OWASA utilized ietivac truck t
un-stop the SSO. OWASA staff removed a ball and tree debris from the affected manhole. There were no solids evident i
the affected area. so the area was washed down and cleaned thoroughly. Lime and deodorant were spread to address oc
issues. The SSO ran into a small creek but was contained in a pool area and sucked out with a Vac truck and hydrant
water was used while sucking to flush stream until a acceptable sample was obtained. Samples were taken upstream ant
downstream of spill site by OWASA ORC and no evidence of wastewater present.
As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Nicholas F Rogers Date: 11/09/21 09:50 am
Signature: Title:
Telephone Number:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of 1
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 3

Attachment 3
N GREENSBORO STAND ESTES DRIVE
SANITARY SEWER OVERFLOW
SAMPLE SITES
a.
(O3
•� }side
SAMPLE
SITE 1
• ,
x'
CONTAINMENT
AREA
OVER FLOW
LOCATION
SMH101496
•
i !-
This map contains sensitive information, not to be copied or
distributed without the express written permission of OWASA. This
data is being provided as a visual representation and at no time
should the data be considered exact. The data is not guaranteed to
be accurate and is not intended as a substitute for a field survey.
OWASA assumes no legal liability or responsibility for this data.
SAMPLE
SITE 2
ajo