WQCS00110_Response to Notice_20230223

MAYOR
Jody L. McLeod
MAYOR PRO TEM
Jason Thompson
TOWN MANAGER
Richard D. Cappola, Jr.
TOWN ATTORNEY
Cauley Pridgen, P.A.
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
3800 Barrett Drive
Raleigh, NC 27609
COUNCIL MEMBERS
Andria Archer
Porter Casey
Avery Everett
Michael Sims
SUBJECT: Notice of Violation NOV-2023-DV-0068
Town of Clayton Collection System Permit Number WQCS00110
Dear Mr. Vinson:
The following information is provided in response to your letter of February 10, 2023, that was received February 21,
2023, related to the Town of Clayton's actions to correct, and prevent future SSO occurrences:
Incident Number 202300059
Upon investigation, it was determined this SSO was caused by roots and debris in the line. Response to the
spill occurred 11 minutes after it was reported. Town staff was able to mobilize, install traffic control to shut down a
lane of traffic and stop the spill in a total time of 28 minutes. Once the spill was stopped, staff continued cleaning
efforts, captured the released untreated wastewater and returned it back to the collections system for proper treatment.
Town staff proceeded to flush 2000 gallons of fresh potable water into the affected storm drain and captured it
downstream to remove any potential contamination in the storm drainage system. Following the spill response, a
video inspection of the line was completed and revealed no major root intrusion in the 1930's era terra cotta line. This
line has since been added to our weekly inspections of trouble spots. The Town currently inspects all its lines in
easements at the same time as the high priority line inspections, every 3 months, which exceeds the twice a year
requirement by our permit. The line segment has also since been added to the trouble spots list, which is checked
monthly and cleaned every 6 months. This line was previously treated for roots by Duke's Root Control, Inc. on June
6, 2022, and is scheduled to be retreated in the first quarter of 2025.
Town staff are committed to improving its aging infrastructure and preventing harm to the environment with
more regular inspections, consistently cleaning more than the required 10% a year of its gravity sewer lines,
completing multi -million -dollar CIP projects on major trunk lines, and by taking the preventive and predictive
maintenance approach with our CCTV program, which has consistently videoed at least 10% of existing infrastructure
in the last few years.
The Town understands and accepts all permit conditions associated with our operations of a public sewer
system and strives to maintain open, cooperative communications with the Division of Water Resources. The
occurrence of any overflow is unfortunate, and our goal is to eliminate them. The Town believes that operational and
capital improvement plans, combined with our personnel and equipment resources support this goal. They also allow
us to minimize environmental impacts through a timely response on the occasions of an overflow. Please contact me
if any additional information is required at this time. Thank you for the attention provided to our response.
Sincerely, j
es Blalock
Water Resources Maintenance Superintendent
Enclosures
.UinYZ'V1V
PO Box 879 •Clayton, NC 27528 •919-553-5002 Fax [phone] • ClaytonNC.org •Page 1 of 2

Cc: Rich Cappola, PE, MPA, CFM, Town Manager
Collection System File
CEWNN
PO Box 879 •Clayton, NC 27528 •919-553-5002 Fax [phone] • ClaytonNC.org •Page 2 of 2

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7020 3160 0000 4115 5887
Return Receipt Requested
Rich Cappola, Town Manager
Town of Clayton
PO Box 879
Clayton, NC 27528-0879
NORTH CAROLINA
Environmental Quality
February 10, 2023
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2023-DV-0068
Sanitary Sewer Overflows - January 21123
Collection System Permit No. WQCS00110
Clayton Collection System
Johnston County
Dear Mr. Cappola:
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by Town of Clayton 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.
Specific incident(s) cited in the subject report include the following:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202300059 1/11/2023 29 Township of Clayton, Debris in line, Roots 600 600 Notice of Violation
NC,
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 civil penalty for
the cited violations.
D � North Carolina Department of Environmental Q+alRy 1 Division of water Resources
Rakto Regional Office 1 3600 Barrett Drive I Raleigh North Carolina 27609
a� "191.4200

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].
Laserfiche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
North Carotha Department of fmVon DMe Qn1hy I f North
r water Resarces
Raleigh R.egMnal Office 13800 Saran Dr!re ;Raleigh North Carolina 27609
�t77919.79142W

State of North Carolina
DWR
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
PART I:
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: WQCS00110 (WQCS# if active, otherwise use WQCSD#)
Facility: Clayton Collection System Incident #: 202300059
Owner: Town of Clayton
City: Clayton County: Johnston Region: Raleigh
Source of SSO (check applicable): 21 Sanitary Sewer ❑ Pump Station / 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): , Township of Clayton, NC,
Manhole #: c
Latitude (Decimal Degrees): 35.6538
Incident Started Dt: 01/11/2023 Time:
(mm-dd-yyyy)
Estimated Volume of the SSO: 600
Longitude (Decimal Degrees):
-78.46497
6.49 am Incident End Dt: J1!11/2023 Time
(hh:mm AM/PM) (mm-dd-yyyy)
gallons Estimated Duration (Round to nearest hour).-
07:18 am
(nn:mm HMii'M)
hours
Describe how the volume was determined: Est. flow out of MH multiplied by time
Weather conditions during the SSO event: Chilly and clear
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 600
Surface water name: Middle Creek
Did the SSO result in a fish kill? ❑ Yes QNo ❑ Unknown If Yes, what is the estimated number of fish killed? 0
SPECIFIC cause(s) of the SSO:
W Roots © Debris in line
24 hour verbal notification (name of person contacted ): Jane Bernard
Q DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 01/11/2023 Time (hh:mm AM/PM): 08:29:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 C(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 11:
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
Roots
Do you have an active root control program on the line / area in question? Wl Yes M No r7NA NE
Describe
Every year we treat different locations, this one included utilizing Dukes Root Control. They are warrantied for 3 years, w
retreat before the warranty expires.
Have cleaning and inspections ever been increased at this location because of roots ❑ Yes W No NA NE
Explain:
We check this line segment three times a year during hiqh priority line inspections.
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
We are adding this line segment to our trouble spots list. We videoed this line on 1-11-23 after the spill to determine what
else may be going on with the line other than it being old (1930's era) VCP pipe.
What corrective actions are planned at the SSO location to reduce root intrusion?
We cleaned the line, we are adding this line to our trouble spots list which means it will be checked at least once a montt
and cleaned every three months until a solution can be implented.
Has the line been smoke tested or videoed within the past year?
If Yes, when?
n/a
Comments:
n/a
Debris in line
What type of debris has been found in the line?
While cleaning the line to unstop it, we found small rocks and rags.
Suspected cause or source of debris_
Potential broken clay pipe to be determined by CCTV, which did not reveal that.
Are manholes in the area secure and intact?
When was the area last checked/cleaned?
Around Dec. 8, 2022 during high priority inspections. WO #49103
Have cleaning and inspections ever been increased at this location due to previous
problems with debris?
❑ Yes W No NA F7NE
�; Yes ❑ No ❑ NA n NE
CYes ONo [7NA [7]NE
CS-SSO Form Page: 2

Explain:
We will increase cleaning and inspections since the line is being added to our Trouble spots list
Are appropriate educational materials being developed and distributed to prevent futl [ Yes F No ❑ NA n NE
similar occurrences?
Comments:
We actively have a FOG program which we utilize those employees for handing out public information in our problem are
System Visitation
ORC Yes
Backup [F Yes
Name:
James E. Blalock
Cert#
1002021
Date visited:
01/11/2023
Time visited:
07:00 A.M.
How was the SSO remediated (i.e. Stopped and cleaned up)?
Upon arrival, we went to the downstream MH and ietted to clear the blockage Once we got the line to flowing we remov
the debris. We then cleaned the downstream line to ensure nothing went past us We then set up on a storm drain catch
basin downstream and flushed 2000 gallons of potable water and capture it to return to the collections system
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: James Ernest Blalock Date
Signature:
Telephone Number: S='�'"��'G'
01/11/23 08:29 am
NJ,4T,ic QESc;c'[ 5
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of i
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

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Town of Clayton
Cityworks Work Order
Work to be Performed:
Overflow Event - Manhole
WORK ORDER ID:
52553
Status:
8 — Waiting to be Closed]
Date Initiated: 1/11/2023 6:45:59 AM
Initiated By: Blalock, Jame
Projected Start Date: 1/11/2023 6:45:59 AM
Submit To: Blalock, Jame
Projected Finish Date: 1/12/2023 6:45:59 AM
Date Submit To: 1/11/2023 6:45:59 AM
Actual Start Date: 1/11/2023 6:45:00 AM
Priority: Emergent
Actual Finish Date: 1/11/2023 9:30:27 AM
Address or Intersection:
Location Details: Fire Rescue Dr.
Asset-
JEntity Type
IlLocation
SSMANHOLE
IFIRE RESCUE DR
Instructions:
Complete Custom Field.
Comments:
By Blalock, James : 1/11/2023 12:25:48 PM
Fire Chief called and said manhole behind Fire Station 1 on Fire Rescue Dr. was overflowing and running into
the stormdrain.
By Blalock, James
Notified at 0649
Arrived at 0700
Stopped at 0718
1/11/2023 12:33:48 PM
Jetted line found roots and debris.
Flushed storm drain twice for a total of 2000 gallons of fresh water flushed and collected in the down stream
storm drain basin. No sewer actually made it to a creek, stayed in storm drain system.
Notified DEQ at 0829, spoke with Jane Bernard, reported 600 gallons spilled.
By Blalock, James : 2/20/2023 2:43:58 PM
Waiting on NOV/NOI if any from the State.
1 ahnr-
Em to ee
Hours
Start Date
End Date
Blalock, James
2.750000
1/11/2023 6:45:00 AM
1/11/2023 9:30:00 AM
Norris, Stephen
2.750000
1/11/2023 6:45:00 AM
1/11/2023 9:30:00 AM
Callihan, Tim
2.750000
1/11/2023 6:45:00 AM
1/11/2023 9:30:00 AM
Carroll, Dylan
2.750000
1/11/2023 6:45:00 AM
1/11/2023 9:30:00 AM
Kyer, Jake
2.750000
1/11/2023 6:45:00 AM
1/11/2023 9:30:00 AM
Materials:
Part Number Description Units Account

Eauinment:
ID
Description
Hours
704
704-2020 Western Star Vactor 2100i
2.750000
79
79-2021 Ram 2500 4A Pickup
2.750000
73
73 - 2019 Ford F250 4WD
2.750000
75
75 - 2015 Ford F-250 PU Trk
2.750000
Cost•
Labor
IMaterials
JEquipment
$393.66
$0.00
$522.50
Custom Fields•
Custom Field Name
Custom Field Value
Location
Fire Rescue Dr.
Incident #
202300059
NOV #
NOV-2023-DV-0068
Case #
MH #
1016
Volume Estimatedgallons
600
Did it reach the surface?
YES
Volume Estimated Surface
600
Cause
roots/debris
Source
Collections system
Repairs
CLEANED

Town of Clayton
Cityworks Work Order WORK ORDER I
524
Work to be Performed:
Camera - Sewer Gravity Line Stal
Ci
Date Initiated: 1/3/2023 6:00:00 AM
Initiated By: Blalock, Jame
Projected Start Date: 1/3/2023 6:00:00 AM
Submit To: Blalock, Jame
Projected Finish Date: 1/31/2023 9:00:00 AM
Date Submit To: 2/6/2023 11:56:21 AM
ctual Start Date: 1/11/2023 1:00:55 PM
Priority: Medium
ctual Finish Date: 1/31/2023 12:00:00 PM
Address or Intersection:
Location Details: January 2023 CCTV
Entity Type
Location
SSMANHOLE
ROBERTSON ST
SSMANHOLE
FIRE RESCUE DR
SSGRAVITYMAIN
FIRE RESCUE DR
SSMANHOLE
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PRESTWICK DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR OFF ROW
SSMANHOLE
PARKRIDGE DR
SSMANHOLE
PARKRIDGE DR
SSMANHOLE
PARKRIDGE DR
SSMANHOLE
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSMANHOLE
PARKRIDGE DR
SSMANHOLE
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSMANHOLE
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSGRAVITYMAIN
PARKRIDGE DR
SSMANHOLE
PRESTWICK DR
SSGRAVITYMAIN
PRESTWICK DR
SSMANHOLE
PRESTWICK DR
SSGRAVITYMAIN
PRESTWICK DR
SSGRAVITYMAIN
PRESTWICK DR
SSMANHOLE
PRESTWICK DR
SSMANHOLE
PRESTWICK DR
Instructions:
Comments:
4/Nf St&n E"> dt ?wfe�
d�3
By Blalock, James : 1/6/2023 6:04:00 AM

Use this work order as monthly camera work order. Also utilize the inspections on each asset to score using
NASSCO system.
Labor:
Employe
Hours
Start Date
End Date
Carroll, Dylan
1.750000
1/11/2023 1:00:00 PM
1/11/2023 2:50:00 PM
Kyer, Jake
1.750000
1/11/2023 1:00:00 PM
1/11/2023 2:50:00 PM
Carroll, Dylan
4.000000
1/17/2023 8:00:00 AM
1/17/2023 12:00:00 PM
Kyer, Jake
4.000000
1/17/2023 8:00:00 AM
1/17/2023 12:00:00 PM
Carroll, Dylan
6.500000
1/19/2023 8:00:00 AM
1/19/2023 2:30:00 PM
Kyer, Jake
6.500000
1/19/2023 8:00:00 AM
1/19/2023 2:30:00 PM
Carroll, Dylan
3.000000
1/25/2023 7:15:00 AM
1/25/2023 10:15:00 AM
Satterwhite, James
3.000000
1/25/2023 7:15:00 AM
1/25/2023 10:15:00 AM
Norris, Stephen
2.000000
1/24/2023 12:45:00 PM
1/24/2023 2:45:00 PM
Carroll, Dylan
2.000000
EE]]1/24/2023
1/24/2023 12:45:00 PM
1/24/2023 2:45:00 PM
Satterwhite, James
2.000000
12:45:00 PM
1/24/2023 2:45:00 PM
Materials:
Part Number Description Units Account
Equipment:
ID
Description
Hours
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
1.750000
721
721, 2020 Leopald Trailer with Proteus Camera
1.750000
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
4.000000
721
721, 2020 Leopald Trailer with Proteus Camera
4.000000
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
6.500000
721
721, 2020 Leopald Trailer with Proteus Camera
6.500000
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
3.000000
721
721, 2020 Leopald Trailer with Proteus Camera
3.000000
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
2.000000
721
721, 2020 Leopald Trailer with Proteus Camera
2.000000
73
73 - 2019 Ford F250 4WD
2.000000
Cost:
Labor
IMaterials
E ui ment
$857.11
$0.00
$491.25
Custom Fields:
Custom Field Name ICustom Field Value

Project Name: 22-0640
Treated Dates: 06/06/22 - 06/06/22
Job# 22-0640
Report Date:06/10/22
Up
Up
Up
Down
Down
Down
Treated
Street
Type
Loc MH
Type
Loc
MH
Size
Feet
Guar End
06/06/22
OAKDALE AVENUE
M
F
1912
M
S
1306
8
397
06/06/25
06/06/22
PINELAND AVENUE
M
F
1304
M
D
1305
8
353
06/06/25
06/06/22
LAKE DRIVE
M
B
1714
M
B
2138
8
225
06/06/25
06/06/22
DAMON STREET
M
S
1889
M
S
1888
8
137
06/06/25
06/06/22
DAMON STREET
M
S
1888
M
S
1603
8
343
06/06/25
06/06/22
DAMON STREET
M
S
221
M
S
3443
8
158
06/06/25
06/06/22
DAMON STREET
M
S
3443
M
S
1603
8
144
06/06/25
06/06/22
POND STREET
M
E
1600
M
S
212
8
272
06/06/25
06/06/22
POND STREET
M
S
211
M
S
212
8
301
06/06/25
06/06/22
CARTER STREET
M
S
76
M
S
12
8
43
06/06/24
06/06/22
CARTER STREET
M
F
12
M
B
3006
8
243
06/06/24
06/06/22
CARTER STREET
M
B
3006
M
F
1098
10
128
06/06/24
06/06/22
WILLOW DRIVE
M
E
1747
M
E
4232
8
42
06/06/24
06/06/22
WILLOW DRIVE
M
E
4232
M
S
1745
8
200
06/06/24
06/06/22
FIRE RESCUE DRI
M
S
1016
M
S
1745
8
271
06/06/25
Manhole Type Codes:
Manhole Location Codes:
Break Down:
C Clean Out
A
Alley
10
128
H House Number
B
Backyard
8
3,129
L Line Number
E
Easement (woods or no building)
Total:
3,257
M Manhole Number
F
Front Yard
L
Left Side Yard(when facing front)
R
Right Side Yard(when facing front)
S
Street
U
Unknown