WQCS00110_NOV-2020-DV-0457 Response_20201118

MAYOR
MAYOR PRO TEM
Jody L. McLeod
Jason Thompson
INTERIM TOWN MANAGER
COUNCIL MEMBERS
JD Solomon-
Michael Grannis
TOWN ATTORNEY •�
Art Holder
Parker Poe
Bobby Bunn
Avery Everett
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office, DWR, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
SUBJECT: Notice of Violation NOV-2020-DV-0457
Town of Clayton Collection System Permit Number WQCS00110
Dear Mr. Vinson:
The following information is provided in response to your letter of October 22, 2020, that was received October 10, 2020, related to the
Town of Clayton's actions to correct and prevent future SSO occurrences:
Incident Number 202002550
This SSO was caused by a heavy rain event and subsequent Inflow from a damaged sewer pump tank. The SSO was stopped as quickly
as possible, in less than 1 hour and the standing water in the affected area was returned to the system to minimize any further
environmental impact. The area adjacent to the release was abated and restored. The ToAm located the source of the inflow and contacted
the responsible party, Johnston County Emergency 91 H Center Assistant Director on August 17, 2020 and the broken pump tank lid was
repaired on August 19, 2020. The Town has continually exceeded the State's 10% cleaning requirements as well as the semi-annual
inspection of High Priority sewer lines. The Town has also spent over $16,000 within the last 30 day on a potential I&I issue, has an
annual MH Rehab budget for I&I of over $85,000 as well as a Capital Budget for a system wide I&I Analysis. We have also consistently
complied with the FOG Requirements for distribution of Public Educational Materials related to not only FOG control but also debris
not intended for the Sanitary sewer system, to the entire sanitary sewer customer base as well as exceeding the requirement by providing
can toppers to all customers to use for containerizing cooking grease for disposal into the solid waste stream instead of into the sanitary
sewer system.
Please contact me if any additional information is required at this time. Thank you for the attention provided to our response.
Sincerely,
Rich Cappola, PE
Deputy Town Manager/Public Services Director
Enclosures
Cc: JD Solomon, Interim Town Manager
Collection System File
1UkV O%T
PO Box 879 • Clayton, NC 27528.919-55')-5002 ��"` �° " Fax [phone] • TownofClaytonNC.org

ROY COOPER
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
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Enviro—en tat Q.."ity
CERTIFIED MAIL # 7017 0190 0000 9569 8411
RETURN RECEIPT REQUESTED
October 22, 2020
Adam Lindsay
Town of Clayton
PO Box 879
Clayton, NC 27528-0879
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2020-DV-0457
Sanitary Sewer Overflows - September 2020
Collection System Permit No. WQCS00110
Clayton Collection System
Johnston County
Dear Mr. Lindsay:
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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.
ecific incident_cited_i.n the subject report_il?clude the following;
Total Vol
Total
Surface
Incident Start Duration
Vol
Water
Number Date (Minn) location
Cause
(Gals)
(Gals) DWR Action
202002550 9/1/2020 50 800 NC 42 Hwy East
Inflow and Infiltration,
500
unknown Notice of Violation
(Fire Station 2 lift
Severe Natural
station)
Condition

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,
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 mitch. hayes@ncdenr,gov,
Sincerely,
�2 Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
Laserfiche

State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Incident Started Dt: 09/01/2020 Time
(mm-dd-yyyy)
Estimated Volume of the SSO: 500
Collection System Sanitary Sewer Overflow Reporting Form
Dlvlsion 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 #: 202002550
Owner: Town of Clayton
City: Clayton County: Johnston Region: Raleigh
Source of SSO (check applicable): ❑ 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): 800 NC 42 Hwy East (Fire Station 2 lift station)
Manhole #:
Latitude (Decimal Degrees): 35,6416 Longitude (Decimal Degrees):-78.43175
Incident End Dt: 09/01/2020
lis TM"
Time: 01:50 am
(nn:mm AM/FM) (mm-dd-yyyy)
gallons Estimated Duration (Round to nearest hour):
(nn:mm ANI/F'MI)
0:50 hours
Describe how the volume was determined: Visual 14gpm for 50 minutes
Weather conditions during the SSO event: Heavy Rain
Did SSO reach surface waters? ❑ Yes ❑ No 2 Unknown Volume reaching surface waters (gals):
Surface water name:
Did the SSO result in a fish kill? ❑ Yes 2 No ❑ Unknown If Yes, what is the estimated number of fish killed? 0
SPECIFIC cause(s) of the SSO:
R1 Severe Natural Con( IJ Inflow and Infiltration
24 hour verbal notification (name of person contacted ): Lauren Smith
❑ DWR 0 Emergency Mgmt Date (mm-dd-yyy): 09/01/2020 Time (hh:mm AM/PM):
Or— 1Q-rin —
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 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
Severe Natural Condition
Describe the "severe natural condition" in detail?
Heavy Rain event for a prolonged period of time started raining around 5.30 PM and didn't stop raining until 1 30 AM
How much advance warning did you have and what actions were taken in preparatio
for the event?
Only the weather report stating possible evening thunderstorms So there really was no way of us knowing how much rai
would fall during this event.
Comments:
During this event, there was a road washed out in the county (Galilee Rd) which resulted in swift water rescues from the
amount of rain.
Inflow and Infiltration
Are you under an SOC (Special Order by Consent) or do you have a schedule in any E Yes W No ® NA NE
permit that addresses 1/1?
Explain if Yes:
n/a
What corrective actions have been taken to reduce or eliminate I & I related overflow
at this spill location within the last year?
n/a
Has there been any flow studies to determined/I problems in the collection system at Yes © No E NA P NE
the SSO location?
If Yes, when was the study completed and what actions did it recommend?
n/a
Has the line been smoke tested or videoed within the past year? Yes W No r NA F7 NE
If Yes, when and indicate what actions are necessary and the status of such actions:
n/a
Are there 1/1 related projects in your Capital Improvement Plan? Yes No ❑ NA D NE
If Yes, explain:
$187,500 in FY21/22 for an I & I analysis and an annual budget of $85 000 for manhole rehab in relation to I & 1
Have there been any grant or loan applications for 1/1 reduction projects? Yes W No F NA NE
If Yes, explain:
n/a
CS-SSO Form Page: 2

Do you suspect any major sources of inflow or cross connections with storm sewers, E Yes W No F7 NA ❑ NE
If Yes, explain:
n/a
Have all lines contacting surface waters in the SSO location and upstream been EYes DNo ®NA ❑ NE
inspected recently?
If Yes, explain:
n/a
What other corrective actions are planned to prevent future 1/1 related SSOs at this
location?
On August 16 2020 there was another high rain event in the area which alerted us to the possibility of I & I WO#37396
We found a hole in the Johnston County remote 911 locations septic/pump box I met with Assistant Director of Johnston
County 911, Brett Renfrow on 8-17-20 to show him and they had it repaired on 8-19-20
Comments:
The other site that feeds this lift station is the Town of Cla t�Fire Station # 2 which flows through an oil separator and
into a septic/pump tank then to our lift station We have had a conversation with the fire chief about reworking the sewer
service to eliminate the tanks, due to there location in a low area and slight infiltration as well
System Visitation
ORC (� Yes
Backup 7 Yes
Name:
James E. Blalock
Cert#
1002021
Date visited:
09/01 /2020
Time visited:
01:15 AM
How was the SSO remediated (Le. Stopped and cleaned up)?
We mobilized one of our Vac -trucks and pumped the wet well down to stop the SSO Once we brought the level down w
then retrieved all visible standing water from the area and broadcasted pulverized lime to prevent any other environments
affects.
CS-SSO Form Page: 3

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
Signature:%j..
Telephone Num er: 7�7"�,Cr
Date: 09/03/20 12:41 pm
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of f
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: 4

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