WQCS00110_NOV-2020-DV-0543 Response_20210211

MAYOR
Jody L. McLeod
MAYOR PRO TEM
Jason Thompson
TOWN MANAGER
JD Solomon
TOWN ATTORNEY
Cauley Pridgen, P.A.
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-0543
Town of Clayton Collection System Permit Number WQCS00110
Dear Mr. Vinson:
COUNCIL MEMBERS
Michael Grannis
Art Holder
Bobby Bunn
Avery Everett
NC Dept of Environmental Quality
FEB 11 2021
Raleigh Regional Office
The following information is provided in response to your letter of December 15, 2020, that was received January
19, 2021, related to the Town of Clayton's actions to correct and prevent future SSO occurrences:
Incident Number 202003080
This SSO was caused by a heavy rain event and subsequent Inflow caused by Category 4 Hurricane Eta. The SSO
stopped within 1 hour as the flood waters receded. The area adjacent to the release was abated and restored.
The Town has been aware of the deficiency which is related to line size and condition due to age and material, as
well as finished ground elevation along the outfall line, and we have worked diligently to prepare a sufficient
repair strategy for this particular line segment. Since this overflow we have received bids for the replacement and
increase in line size for approximately 2,043LF of sewer line, 18 manholes and associated storm water protection.
The bids were received ranging from $848,896 to $1,573,330 for the project. The approved bid tab will be
available once the consultant has verified the bids. Once that is complete we can provide that if requested.
The Town has continually exceeded the State's 10% cleaning requirements and has cleaned a total of 28.5% of
the entire system, this does not include the additional CCTV work and acoustical investigation that has been
done. We have also exceeded the semi-annual inspection requirement of High Priority sewer lines by inspecting
those line segments three times within 12 months. The Town also 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.
Please contact me if any additional information is required at this time. Thank you for the attention provided to
our response.
SinVCappo(la,
ich P
Deputy Town Manager/Public Services Director
Enclosures
Cc: JD Solomon, Interim Town Manager
Collection System File
.Mnk
eem jy.rV1V
PO Box 879 • Clayton, NC 27528 -919-553-5002"'�"" ""` Fax [phone] • TownofCla onNC.or
Yl 8

DWL�-"
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
lahrlslon of Weer Resources Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
PART I:
This form shall be submitted to the appropriate DWO Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WOCS00110 (WQCS# if active, otherwise use WQCSD#)
Facility: C!a on Collection System Incident #: 202003080
Owner: Town of Clayton
City: Clayton County: Johnston Region: Raleigh
Source of SSO (check applicable): El 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): 1000 Durham Street
Manhole #: 3760
Latitude (Decimal Degrees): 35.6414
Longitude (Decimal Degrees):-78.46341
Incident Started Dt: 11/12/2020 Time: 1:00 pm
(mm-dd-yyyy) (hh:mm AM/PM)
Incident End Dt: 11/12/2020 Time: 02:00 pm
(mm-d -yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 7,000 gallons Estimated Duration (Round to nearest hour): 1:0 hours
Describe how the volume was determined: Visual 30 gym multiplied by duration
Weather conditions during the SSO event: Heavy rain, flooding in the area, remnants of ETA
Did SSO reach surface waters? Q Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 7000
Surface water name: Little 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:
0 Severe Natural Con(
24 hour verbal notification (name of person contacted ): George Bernard
❑ DWR Q Emergency Mgmt Date (mm-dd-yyy): 11/13/2020 Time (hh:mm AM/PM): 07:15:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(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 actin 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 1 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?
Severe storm passing through area which released 2.15 inches on 11/11/20 and an additional 1.35 inchs on 11/12120.
Remnants of ETA.
How much advance warning did you have and what actions were taken in preparatio
for the event?
Local weather forecast for the area. All a ui ment was o erational for an emergency response.
Comments:
System Visitation
ORC Yes
Backup 10 Yes
Name:
Travis iessup
Cert#
998675
Date visited:
11/12/20
Time visited:
1:15 PM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Yes. Cleaned up and applied lime to affected area.
CS-SSO Form Page. 2

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: Travis Milton Jessup Date: 11/13/20 02:00 pm
Signature: Title:
Telephone Number:
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. 3