WQCS00005_NOV-2020-DV-0185 Response_20200625

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S. DANIEL SMITH NORTH CAROL NA
Diwtur Environmental Quality
CERTIFIED MAIL: 7016 3560 0000 4428 4655
RETURN RECEIPT REQUESTED
April 30, 2020 a
Donald F Greeley, Water Management Director
City of Durham JUL - 21U10I
101 City Hall Plaza
Durham, NC 27701-3329'`''
NC MNR Raleigh R800r ! Odes
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2020-DV-0185
Sanitary Sewer Overflows — January, February, March 2020
Collection System Permit No. WQCS00005
Durham Collection System
Durham County
Dear Mr. Greeley:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Durham. The Division's Raleigh Regional Office concludes that the City of Durham violated Permit Condition
I (2) of Permit No. WQCS00005 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Durham an opportunity to provide evidence and justification as
to why the City of Durham should not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Minn) Location Cause (Gals) (Gals) DWR Action
202000044 1/8/2020 150 1201 Vintage Hill Pkwy. Pipe failure 7500 7500 Notice of Violation —
Notice of Intent
202000114 1/16/2020 220 4023 Wake Forest Rd. Grease & Debris 158,075 168,075 Notice of Violation -
Notice of Intent
202000158 1/26/2020 113 2321 Stroller Ave. Roots 970 970 Notice of Violation
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Total Vol
Total
Surface
Incident
Start
Duration
Vol
Water
Number
Date
�y(.Mins)
Location
Cause
(Gals)
(Gals)
DWR Action
202000246
2/4/2020 ' ` "45`*�-
904 Lambeth Cir
Other
225
225
Notice of Deficiency
202000305
2/6/2020 "
491 ,r
Rockwood Park
Severe Natural
168,075
168,075
Notice of Violation
Condition
202000309
2/6/2020
481
3201 Coachman Way
Severe Natural
24,050
24,050
Notice of Violation
Condition
202000313
2/6/2020
678
1912 Essex road
Severe Natural
67,800
67,800
Notice of Violation
Condition
202000635
2%1f/2020
A
3014 Sparger Rd Lift
Power Outage, Pump
3,000
-1
Notice of Violation
Station
station equipment
Notice of Intent
failure
,. 202000699
2/15/2020
115
707 W Murray Avenue
Debris in line, Grease
18,370
18,370
Notice of Violation
Notice of Intent
202000704
2/17/2020
147
1101 Hamlin Road
Pipe Failure (Break)
176,400
176,400
Notice of Violation
Notice of Intent
202000714
2/19/2020
30
309 W. Morgan Street
Debris in line
4,000
4,000
Notice of Violation
Notice of Intent
202000771
2/21/2020
251
2917 5alvone court
Vandalism
12,500
12,500
Notice of Violation
Notice of Intent
202000772
2/21/2020
76
24 Phauff Court
Vandalism
11,400
11,400
Notice of Violation
Notice of Intent
202000841
3/2/2020
90
5210 Peppercorn St.
Debris
3,250
3,250
Notice of Violation —
Notice of intent
202000991
3/12/2020
70
Hillandale Golf Course
Grease
4,900
4,900
Notice of Violation -
Notice of Intent
202001115
3/29/2020
80
1600 Hillandale Rd.
Grease
4,800
4,800
Notice of Violation -
Notice of Intent
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 60 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
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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].
Cc: Raleigh Regional Office - WQS File
Laserfiche
Sincerely,
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Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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WATER MANAGEMENT
CITY OF DURHAM
June 25, 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-0185, Permit No. WQCS00005
City of Durham Collection System, Durham County
Dear Mr. Vinson,
JUL _ p 20ZO
NC Devn *9h Iq f
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This letter is in response to your notice dated April 30, 2020 which was received by the City on May 7, 2020. The
April 3011 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-NO]) should
not be assessed for the sanitary sewer overflows (SSOs) which occurred in the City's sewer collection system
between January 1, 2020 and March 31, 2020.
As requested, the City of Durham, Department of Water Management (DWM) is providing information about
twelve 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.
DWM staff think that it is especially important to note that the attached map shows that the SSOs are dispersed
throughout Durham's service area.
Incident # 20200044 —1201 Vintage Hill Parkway— January 8, 2020
On January 8"' the Lift Station Maintenance crews responded to a report of a leaking Air Release Valve (ARV) along
Vintage Hill Parkway. Upon arrival, they discovered the ARV was not leaking, however a section of the 12-inch
force main had collapsed and had begun to leak into the creek at this location. Additional crews were called in to
assist; staff shut down the receiving pump station, placed a 12-inch full seal clamp over the leak and mobilized
several Jet/Vac trucks to clean up the wastewater on the ground. The spill released 7,500 gallons of sewage into
an unnamed tributary of Little River.
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $2,748.40.
As a follow-up, the City hired a contractor to replaced approximately 200 linear feet of pipeline and approximately
132 feet of encasement pipe for a road crossing at a cost of $160,298.02. This cost also included the reinstallation
of the existing ARV and bypass pumping during the project.

Page 2 of 8
Incident # 2020000114 — 4023 Wake Forrest Road — January 16 2020
On January 1611, a manhole at 2816 Ross Road overflowed, with an estimated 7,400 gallons of wastewater
discharging into the unnamed tributary of the Little Lick Creek. This overflow occurred due to a blockage in the
sewer main caused by a buildup of rags and grease. Crews responded by using a high pressure jet to remove the
blockage, 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 dammed the creek and flushed a nearby hydrant into the
creek to and then 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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
City of Durham crews have followed up by cleaning the lines above and below the incident location and using CCTV
trucks. The City's FOG Program staff distributed notices to the neighborhood regarding proper grease, fats and oils
disposal options. This section of sewer line has been added to the Hot Spot program and will be checked by CCTV
truck crews every two weeks.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $4,112.76
Incident # 202000158 — 2321 Stroller Ave — January 26 2020
On January 26'h two manholes near 2321 Stroller Avenue overflowed with approximately 970 gallons of
wastewater discharging into the unnamed tributary of Ellerbe Creek. Crews determined the spill occurred due to a
blockage caused by tree roots growing into the sewer main. Staff used 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. No immediately visible adverse
environmental impacts or hazards to persons or 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. Because the
blockage was related to a root issue the area will be included on a future root control contract to try to prevent
any reoccurring issues in the future.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $1,431.36
Incident # 202000246 — 904 Lambeth Circle — February 4 2020
On February 4'h an overflow occurred from a manhole at 904 Lambeth Circle with an estimated 225 gallons of
wastewater discharging into the unnamed tributary of Sandy Creek. The spill was caused by a contractor installing
a new manhole at the site. They had placed a plug in the line while they worked and failed to properly monitor the
by-pass pump they were using. The pump failed creating a backup in the line, which ultimately over flowed into
the nearby creek. City crews responded to the site where they cleaned up the spill around the manhole and
pumped the untreated wastewater back into the collection system. The creek was dammed downstream and
flushed as well. Robert Young and Mike Monce from Romeo Guest Associates Construction are the points of
contact with this event (919-687-0865). Contractor error

Page 3 of 8
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $740.29.
Incident # 202000305 — Rockwood Park/Stuart Drive - February 6, 2020
On February 61h a sewer overflow occurred from a manhole at Rockwood Park due to heavy rains from a storm that
lasted more than 12 hours resulting in approximately 168,075 gallons of wastewater discharging into an unnamed
tributary of Third Fork Creek. Once the rains subsided, crews were able to inspect the area and determine the
overflow was attributable to the severe natural condition (rain event — approximately3 inches in 12 hours).
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $40.91.
Incident # 202000309 — 3201 Coachman Way — February 6 2020
On February 6th a sewer overflow occurred at 3201 Coachman Way, due to heavy rains from a storm that lasted
more than 12 hours resulting in approximately 24,050 gallons of wastewater discharging into an unnamed
tributary of Sandy Creek. Once the rains subsided, crews were able to inspect the area and determine that the
overflow was attributable to the severe natural condition (rain event —approximately 3 inches in 12 hours).
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $52.53
Incident # 202000313 —1912 Essex Road — February 6 2020
On February 6th a sewer overflow occurred at 1912 Essex Road due to heavy rains from a storm that lasted more
than 12 hours resulting in approximately 67,800 gallons of wastewater discharging into an unnamed tributary of
Goose Creek. Once the rains subsided, crews were able to inspect the area and determine that the overflow was
attributable to the severe natural condition (rain event — approximotely 3 inches in 12 hours).
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $43.77.
Incident # 202000635 — 3014 Soareer Road (Lift Station) — February 11, 2020
On February filth an overflow occurred at the City's Sparger Road Lift Station with an estimated 3,000 gallons of
wastewater flowing into the Eno River. Crew members discovered the event during the routine daily route check.
The GFCI had tripped due to a power blip. Because of this, the SCADA system did not indicate a high wet well
alarm. The crew immediately reset the GFCI receptacle and the pumps were reactivated stopping the overflow.
This event occurred during an intense rain event leading to heavy flows at the Lift Station (approximately 1 inch of
rain).

Page 4 of 8
The City's 5tormwater 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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $50.00
Incident # 202000699 — 707 West Murray Avenue — February 15, 2020
On February 151h a manhole at 707 West Murray Avenue overflowed due to a blockage caused by grease and rags
in the line. This resulted in an estimated 18,370 gallons of wastewater discharging into an unnamed tributary of
Ellerbe Creek. City crews responded to the site, used a high pressure jet to remove the blockage and then cleaned
the line. Staff dammed the creek, and pumped the liquids back into the collection system. This was followed by
flushing the creek and flushing those fluids into the collection system as well.
The City's 5tormwater 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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
Staff 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. The City's FOG Program
staff distributed notices to the neighborhood regarding proper grease, fats and oils disposal options. This section
of sewer line has been added to the Hot Spot program and will be checked by CCTV truck crews every two weeks.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $3,864.16.
Incident # 202000704 —1201 Hamlin Road - February 17 2020
On February 17th a pipe failure in the 36" force main at 1104 Hamlin Road caused a sewer spill, with an estimated
176,400 gallons of wastewater discharging into an unnamed tributary of Ellerbe Creek. City of Durham crews
arrived and installed large full seal clamps over the corroded portion of the force main. Permanent repair/
replacement of 6,000 feet of this force main is under design (90% complete) was already scheduled to begin in the
next 12 to 18 months; this project has now been accelerated. Crews pumped the untreated water into the
collection system; this was followed by flushing the creek using a nearby hydrant. These liquids were also pumped
back into the collection system.
The City's 5tormwater 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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was
$22,303.26.
Incident # 202000714— 309 West Morgan Street -- February 19 2020
On February 191h a manhole at 309 West Morgan Street overflowed discharging estimated 4,000 gallons of
wastewater into South Ellerbe Creek tributary. The spill was caused by a buildup of tissue/wipes in the line. City
crews responded and cleared the blockage using a high pressure jet, followed by cleaning the lines up and
downstream from the site with the Jet Truck. The creek was flushed and a 4-inch pump was set up to move the
untreated waste water back into the collections system. 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.

Page 5 of 8
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $1,212.71.
Incident # 202000771— 2917 Salvone Court — February 21, 2020
On February 2V a sewer backup occurred at 2917 Salvone Court with an estimated 12,500 gallons of wastewater
discharging into an unnamed tributary of Little Lick Creek. This was caused vandalism; crews discovered debris,
trash and home appliances in the manhole. The items were removed from the site and the sewer lines both above
and below this manhole was cleaned by Jet Truck high pressure system. The creek was flushed and the untreated
water was pumped back into the collections system. City staff installed a locking manhole lid at the location to
prevent any recurrences. Staff also plan to install locking lids on up to twelve additional manholes in the
immediate area.
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.
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $3,856.94.
Incident # 202000772 — 24 Phauff Court — February 21 2020
On February 2111 a sewer overflow was reported at 24 Phauff Court, with an estimated 11,400 gallons of
wastewater discharging into an unnamed tributary of Little Lick Creek. This overflow was related to the Incident
#202000771 which occurred one hour earlier. These events were both caused by vandalism; as noted, when crews
arrived, they discovered a large collection of rock, stone, and debris in the manhole causing the blockage. The
items were removed from the site and the sewer line both above and below this manhole was cleaned by Jet Truck
high pressure system. The creek was flushed and the untreated water was pumped back into the collections
system. City staff installed a locking manhole lid at the location to prevent any recurrences. Staff also plan to
install locking lids on up to twelve additional manholes in the immediate area.
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.
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $479.87.
Incident # 202000841— 5210 Peppercorn Street — March 2.2020
On March 2"d a sewer overflow occurred at 5210 Peppercorn Street, with an estimated 3,250 gallons of
wastewater discharging into an unnamed tributary of Eno River. The spill was caused by a blockage of rags in the
line. City crews used a high pressure jet to remove the blockage and then cleaned the line. Staff dammed the
creek, and pumped the liquids back into the collection system. This was followed by flushing the creek and
flushing those fluids into the collection system as well.

Page 6 of 8
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. No immediately visible adverse
environmental impacts or hazards to persons or property occurred.
As required, a news release was issued within the 24-hour window. The cost to remediate this spill was $2,319.79.
Incident # 202000991— Hillandale Golf Course — March 12, 2020
On March 12th a sewer overflow occurred at Hillandale Golf Course with an estimated 4,900 gallons of wastewater
discharging into Ellerbe Creek. The blockage was caused by an accumulation of grease in the line. City crews used a
high pressure jet to remove the blockage and then cleaned the line. Staff dammed the creek, and pumped the
liquids back into the collection system. This was followed by flushing the creek and flushing those fluids into the
collection system as well.
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. Approximately 200 dead fish were noted in
puddles of the creek; flow had been very low for several days prior to the spill. No immediately visible hazards to
persons or 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 was no remaining debris inside the main that would cause additional issues. The City's
FOG Program staff distributed notices to the neighborhood regarding proper grease, fats and oils disposal options.
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 $2,363.90
Incident # 20200111S —1600 Hillandale Road — March 29 2020
On March 29th a sewer overflow occurred at 1600 Hillandale Road resulting in an estimated 4,800 gallons of
wastewater discharging into Ellerbe Creek. City of Durham crews responded by clearing a blockage caused by a
buildup of grease in the line. Crews used a high pressure jet at the site, then cleaned the line upstream and
downstream of the location with a Jet Truck. City crews used a high pressure jet to remove the blockage and then
cleaned the line. Staff dammed the creek, and pumped the liquids back into the collection system. This was
followed by flushing the creek and flushing those fluids into the collection system as well.
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 were 15 dead fish in puddles of the
creek; flow had been very low for several days prior to the spill. No immediately visible hazards to persons or
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. The City's
FOG Program staff distributed notices to the neighborhood regarding proper grease, fats and oils 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 $6,876.82.

Page 7 of 8
Onizoing Ci -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.
■ item 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 CY 2020 year to date, the
City has cleaned 2.76% of the system. As operations normalize post-Covid-19, staff will dedicate more time to
this program.
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 DWM. This workgroup handles flow monitoring and system
data management and contract preparation, administration and inspections. There are 21 employee positions
in our Collections Systems Maintenance 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 department established the Lift Station Maintenance Division in 2018 to focus oversight and
maintenance of the 65 lift stations throughout the service area and the 136 ARVs in the system. This 14-
member work group conducts the required daily/weekly inspections and associated preventive maintenance
activities. 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.

Page 8 of 8
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
Don.Greele durhamnc. ov.
Sincerely,
Donald F. Greeley, Director,; R
Attachments
c: Jason Robinson, DEQ-- Water Quality Regional Operations Section, Raleigh Regional Office
Junior Mobley, Superintendent, Water & Sewer Maintenance
Vicki Westbrook, Assistant Director
Jerry Morrone, Utility Engineering Manager, Sr.