WQCS00005_NOV-2020-DV-0047 Response_20200217

WATER MANAGEMENT
CITY OF DURHAM
February 17, 2020
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
NCDEQ, Division of Water Resources
3800 Barrett Drive
Raleigh, N.C. 27609
Subject: NOV-2019-DV-0047, Permit No. WQCS00005
City of Durham Collection System, Durham County
Dear Mr. Vinson,
NCDeptofEnvironmental Quality
FE8 2 0 2o2o
Raleigh Regional Office
This letter is in response to your notice dated February 3, 2020 which was received by the City on February 6,
2020. The February 3`d letter states that the City of Durham is provided an opportunity to present evidence and
justification to demonstrate that the proposed civil penalties for Notice of Violation/Notice of Intent to Enforce
(NOV-NOI) should not be assessed for the sanitary sewer overflows (SSOs) which occurred in the City's sewer
collection system between October 1, 2019 and December 31, 2019.
As requested, the City of Durham, Department of Water Management (DWM) is providing information about six
incidents which occurred during this timeframe which will support the City's position that despite meeting all the
conditions of the City's Collection System permit including site visits, inspections and easement maintenance,
these events were exceptional, unintentional, temporary and beyond the City's exercise of reasonable control.
Incident # 201901611 — 1616 Cooper Street — October 2, 2019
On October 2"d a 40-foot section of 18-inch concrete pipe collapsed into the creek at this location, releasing 10,000
gallons of sewage into a tributary of Third Fork Creek. Mainline crews responded and replaced the pipe with
ductile iron and repaired the infrastructure to return this area to proper service. An upstream manhole was
plugged and a 4-inch bypass pump was placed downstream to pump the fluids from the creek back into the
collections system.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the extent
of the spill and to advise when the site returned to normal conditions. There was no observed harm to plants,
animals, aquatic life or natural resources. No danger to public health or damage to private property occurred.
City of Durham crews have followed up by cleaning the lines above and below the incident location and using CCTV
trucks to be sure that there is no remaining debris inside the main that would cause additional issues.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $2,891.63
Incident # 201901614 — 2816 Ross Road — October 3 2019
On October 3`d a clean out plug at 2816 Ross Road overflowed, with an estimated 12,000 gallons of wastewater
discharging into the unnamed tributary of the Little Lick Creek. This overflow was caused by debris (roots) creating
a blockage inside the mainline pipe. Crews responded by using a high pressure jet to remove the blockage and

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then cleaned the line with a flush truck to force the blockage from the main and used a 4-inch pump downstream
to remove the fluids from the creek. Crews pumped the liquid contained in the creek back into the collections
system.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the extent
of the spill and to advise when the site returned to normal conditions. There was no observed harm to plants,
animals, aquatic life or natural resources. No danger to public health or damage to private property occurred.
City of Durham crews have followed up by cleaning the lines above and below the incident location and using CCTV
trucks to be sure that there is no remaining debris inside the main that would cause additional issues. Additionally,
when roots are found in the collection system, the area is noted and sent to the department's Utility Engineering
Division for inclusion in the contracted root control program. Through this process, pipes with root intrusion are
chemically treated to address root growth in the pipelines.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $5,956.92
Incident # 201901637 — 733 Rutherford Street — October 11, 2019
On October 11"' at 733 Rutherford Street, a blockage of grease caused the overflow from Manhole# 34436, with an
estimated 1,925 gallons of wastewater discharging into the unnamed tributary of Ellerbe Creek. Crews responded
by using a high pressure jet to remove the blockage and then cleaned the line with a flush truck to force the
blockage from the main and used a 4-inch pump downstream to remove the fluids from the creek. Crews pumped
the liquid contained in the creek back into the collections system.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the extent
of the spill and to advise when the site returned to normal conditions. There was no observed harm to plants,
animals, aquatic life or natural resources. No danger to public health or damage to private property occurred.
The City of Durham has an established FOG program; staff from this program distributed notices to the
neighborhood to inform and educate the customers of the City on the effects of grease on the collection system
and the appropriate disposal options. At this time the indicated series of reaches are on a Hot Spot program for
the immediate future, being checked by CCTV truck every two weeks until further notice.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $2,134.14
Incident # 201901637 --1012 Bluestone Road — November 5.2019
On November 51h at 1012 Bluestone Road, a blockage of debris in the line caused the overflow from Manhole#
07014, with an estimated 2,060 gallons of wastewater discharging into the unnamed tributary of Northeast Creek.
Crews responded by using a high pressure jet to remove the blockage (manhole insert) and then cleaned the line
with a flush truck to force the blockage from the main and used a 4-inch pump downstream to remove the fluids
from the creek. Crews pumped the liquid contained in the creek back into the collections system.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the extent
of the spill and to advise when the site returned to normal conditions. There was no observed harm to plants,
animals, aquatic life or natural resources. No danger to public health or damage to private property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $2,047.66

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Incident # 201901777 — 33 Jenee Lane — November 16, 2019
On November 161h at 33 Jenee Lane, a blockage of debris in the line caused the overflow from Manhole# 16600,
with an estimated 19,250 gallons of wastewater discharging into the unnamed tributary of Little Lick Creek. Crews
responded by removing a large tree limb (4 Foot) from the manhole, and then followed up by jetting the line.
Crews then used a 4-inch pump downstream to remove the fluids from the creek. Crews pumped the liquid
contained in the creek back into the collections system. Because of suspected vandalism at this site, crews
installed bolt down manhole covers to prevent non authorized access. It is noted that in October of 2019, a
manhole was removed from the system upstream of this site and during that process discovered other sticks and
debris.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the extent
of the spill and to advise when the site returned to normal conditions. There was no observed harm to plants,
animals, aquatic life or natural resources. No danger to public health or damage to private property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $5,680.42
Incident # 201901813 — 413 Farintosh Valley Lane — November 25, 2019
On November 25th at 413 Farintosh Valley Lane, a blockage of debris in the line caused the overflow from
Manhole# 50857, with an estimated 1,575 gallons of wastewater discharging into the unnamed tributary of Little
Briar Creek. Crews responded by using a high pressure jet to remove the blockage and then cleaned the line with a
flush truck to force the blockage from the main and used a 4-inch pump downstream to remove the fluids from the
creek. Crews pumped the liquid contained in the creek back into the collections system.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the extent
of the spill and to advise when the site returned to normal conditions. There was no observed harm to plants,
animals, aquatic life or natural resources. No danger to public health or damage to private property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $1,720.12
Ongoing City -Wide Measures to Reduce the Occurrence of SSOs
The City has several programs in place to reduce and/or prevent the occurrence of SSOs. The City has
implemented a CMOM plan that expands and enhances its existing programs.
System Flushing and Inspection: The City routinely contracts flushing, CCTV inspection, smoke testing and
manhole inspections of portions of the sewer collection system. The City is completing the inspection of the
collection system systematically through City defined basins.
Additionally, the City ensures the requirements of the collection system permit are met by deploying City
crews to flush at least 10% of the collection system annually with a goal of exceeding the requirement by at
least 2 to 5% each year. The City measures the flushing on a fiscal year basis. For the FY 2020 year to date, the
City has cleaned 10.86% of the system.
Sewer Rehabilitation Program: The City has an active Sewer Rehabilitation Program. The program includes
flow monitoring (25 permanent monitors), CCTV inspection, manhole inspection, easement mowing, field
inspections and investigations, point repairs, line replacement, root and grease abatement and cured -in -place
manhole and line rehabilitation. There are 4 employee positions dedicated to the City's system rehabilitation
programs in the Utility Engineering Division of the Department of Water Management (DWM). This workgroup
handles flow monitoring and system data management and contract preparation, administration and

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inspections. There are 16 employee positions in our Sewer Rehabilitation workgroup in the Water & Sewer
Maintenance (WSM) Division of DWM. This group performs CCTV inspections, hydraulic cleaning activities,
mowing and manhole inspection and repair. They respond to blockages and overflows. WSM does contract
inspections as well. In addition, crews from the Main Line workgroup of WSM perform point repairs, line
replacements and some cured -in -place lining. The City spends more than $5,000,000 on Sewer Rehabilitation
projects annually as a part of its Capital Improvements Programs.
Fat. Oils and Grease Program (FOG): The department's FOG education and outreach effort is conducted by 3.0
FTEs (staff shared 50/50 with the Industrial Waste Control Program). In addition to working closely with the
Durham County Health Department, staff routinely inspect over 800 food service establishments (FSEs)
annually to ensure appropriate cleaning and maintenance of grease interceptors. Staff participates in a
number of community events (Earth Day, CenterFest, and Landlord Workshops) as well as neighborhood
meetings to increase awareness of what is appropriate to put in the sewer system. FOG staff conducts post-
SSOs follow-up education and enforcement as necessary. The City also invests more than $35,000 per year in
advertising (TV commercials, social media, etc.) regarding the proper disposal of FOG.
Summary
Based upon the documented information provided above regarding these incidents, the City believes that
overflows were exceptional, unintentional, temporary and caused by factors beyond the City's/department's
reasonable control. The City actively manages, operates and maintains its system in such a manner as to meet all
the requirements of the Collection System permit. As detailed above, the City systematically inspects, flushes and
rehabilitates its wastewater collection system. The department works actively to educate the community
regarding what should and should not be discharged into the City's sewer collection system.
Department staff welcomes the opportunity to meet with you and your staff to review our program and discuss
constructive ways to improve what we are already doing in the City of Durham. If you have any questions or need
any additional information please do not hesitate to contact me at [phone] or via email at
[e-mail].
Sincer, , 4Vic i Westbrook
Assistant Director
Attachments
C: Danny Smith, Regional Supervisor, DEQ/Water Quality Regional Operations Section, Raleigh Regional Office
Jason Robinson, DEQ— Water Quality Regional Operations Section, Raleigh Regional Office
Junior Mobley, Superintendent, Water & Sewer Maintenance
Vicki Westbrook, Assistant Director
Stephen Buchanan, Assistant Director
Jerry Morrone, Engineering Supervisor