WQCS00005_NOV-2021-DV-0263_20210630

WATER MANAGEMENT
CITY OF DURHAM
June 30,2021
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-2021-DV-0263, Permit No. WQC500005
City of Durham Collection System, Durham County
Dear Mr. Vinson,
NC Dept of Environmental Quality
Raleigh Regional Office
This letter is in response toyour notice dated May 20, 2021 which was received bythe City of Durham on June 29,
2021. The May 20, 2021 letterstates that the City of Durham is provided an opportunityto presentevidence and
justification to demonstrate that the proposed civil penaltiesfor the Notice of Violation (NOV) should not be
assessed forthe sanitarysewer overflows (SSOs) which occurred in the City's sewercollection system between
April 1, 2021 and April 30, 2021.
As requested, the City of Durham, Department of Water Management (DWM) is providing information about the
two incidents which occurred during this timeframe which will supportthe 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, temporaryand beyond the City's exercise of reasonable control.
Incident# 202102195 — 9 Yarmouth Place — April 17 2021
On April 17, 2021 manhole #04057 at 9 Yarmouth Place overflowed, with an estimated 1,000 gallons of
wastewater discharging into New Hope Creek. This overflow occurred due to a blockage in the sewer main caused
by roots. Water and Sewer Maintenance staff used a high-pressure jet and a root cutter to remove the blockage
from the main, cleaning the lines with a VAC-ALLcombo truck. The creekwas dammed and then flushed using a
nearby hydrant (dechlorinated) and the untreated wastewaterwas pumped back into the sanitary sewersystem
(4" pump used).
The City's StormwaterServices 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 will continueto monitorthis portion of
the collection system forroot intrusion and if the roots become an ongoing issue, the area will be included in the
City's root control contract.
City of Durham crews have followed up bycleaning the lines above and below the incident location and using CCTV
trucks. As required, a news release was issued within the 24-hour window. The cost to remediate thisspill was
$5,71953.
Incident# 202101217 —1010 Grant Street— April 22, 2021
On April 22, 2021, Water and Sewer Maintenance crews were called to an incident at 1010 Grant Street by a City
contractor who discovered a blockage on a main caused by grease. Asstaff investigated further, they found a pipe

Page 2 of 3
failure allowing wastewaterto leak into the stream. The pipe failure had occurred due to a large tree branch falling
on the pipe, damaging the topside of the exposed pipe. Temporary repairs were made at the location by replacing
the existingductile iron pipe with 9 linear feet of 12-inch ductile iron pipe. The department's Utility Engineering
will be working with a contractor to make permanent repairs. The creekwas dammed and then flushed using a
nearby hydrant (dechlorinated) and the untreated wastewaterwas pumped back into the sanitary sewer system
(4" pump used).
The City's StormwaterServices Division responded and conducted ammonia testingto 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. Departmental public information staff
provided information regardingthe properdisposal of grease via social media and IWC/FOG staff distributed
educational materials in the neighborhood.
City of Durham crews have followed up by cleaning the lines above and below the incident location and using CCTV
trucks. As required, a news release was issued within the 24-hour window. The cost to remediate this spill was
$7,300.80.
Oneoi ne 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
crewsto 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 yearbasis. For the FY 2021 year to date, the
City has cleaned 12.08% 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'ssystem rehabilitation
programs in the Utility Engineering Division of DWM. This workgroup handles flow monitoring and system
data managementand 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-
memberwork group conducts the required daily/weekly inspect ions 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 G rease 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

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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
num be r 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-
SSOsfollow-up education and enforcement as necessary. The City also invests more than $35,000 per yearin
advertising (TV commercials, social media, etc.) regardingthe properdisposal of FOG.
Summary:
Based upon the documented information provided above regarding these incidents, the City believesthat
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 manneras to meetall
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
regardingwhat should and should not be discharged into the City'ssewercollection system.
Department staff welcomes the opportunityto meet with you and yourstaff to review ourprogram and discuss
constructive ways to improve whatwe are already doing in the City of Durham. If you have any questions orneed
any additional information please do not hesitate to contact me at [phone] or via email at
[e-mail].
Sincerely,
Donald F. Greeley, Director, PE, PLS
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.

State of North Carolina
Department of Environment and Natural Resources
DWR Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
ART 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: WOCS00005 (WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System Incident #: 202101195
Owner: City of Durham
City: Durham County: Durham Region: Raleigh
Source of SSO (check applicable): 2 Sanitary Sewer ❑ Pump Station I 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): #9 Yarmounth Place
Manhole #: 04057
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 04/17/2021 Time: 3:20 pm Incident End Dt: 04.17/2021 Time: 06 40 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 1,000 gallons Estimated Duration (Round to nearest hour): 3:20 hours
Describe how the volume was determined: 200mins X 5gpm
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? Yes []No [] Unknown Volume reaching surface waters (gals): 1000
Surface water name: New Hope Creek
Did the SSO result in a fish kill? ❑ Yes [JNo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
0 Roots
24 hour verbal notification (name of person contacted ): Merry Belcher
[] DWR [J Emergency Mgmt Date (mm-dd-yyy): 04/1712021 Time (hh:mm AM/PM): 09:3Q00 pm
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 H:
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 1 area in question? ❑ Yes W No NA NE
Describe
Have cleaning and inspections ever been increased at this location because of roots' ❑ Yes JZ No NA NE
Explain:
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
What corrective actions are planned at the SSO location to reduce root intrusion?
Clean and CCTV the area for root intrusion and structural damage.
Has the line been smoke tested or videoed within the past year? Yes [Z No [] NA [] NE
If Yes, when?
Comments:
System Visitation
ORC
Backup
Name:
Kerry Sanford
Cert#
992773
Date visited:
04/19/2021
Time visited:
09:00 AM
Yes
R Yes
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews accessed the sewer main with an easement fetter and jetted the main to relieve the blockage. The creek was flush
with a hydrant and a pump was
placed downstream to pump the untreated wastewater back in to the sanitary sewer system.
s a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
,jest of my knowledge.
Person submitting claim: Kerry Evan Sanford Date: 04/21/21 02:25 pm
Signature: �•-� Title:
Telephone Dumber:
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).
NC'DePt of �n viron
At� mental Qu$li#y
1141e1gh Rcgrona
!Office
CS-SSO Form Page: 3

Walker, Daniel
From: Lunne, Joe
Sent: Sunday, April 18, 2021 11:05 AM
Subject: SSO at 4217 Trotter Ridge Road
PUBLIC AFFAIRS
City Manager
News Media Contac
Joe F_unne, Sr. Public Information & Communication
Analys
CITY OF DURHAM Water Management Dep,
919.560.4381 ext. 35255 1 919.397.6131(mobile
[e-mail]
News Release
For Immediate Release: April 18, 2021
City of Durham contains sewer spill at 4217 Trotter Ridge Road
DURHAM, N.C. —The City of Durham Department of Water Management reports that on April 17, 2021 staff
responded to a sewer overflow at 4217 Trotter Ridge Road. Approximately 1,000 gallons of wastewater flowed into an
unnamed tributary of New Hope Creek. At this time, the cause of the blockage is unknown.
Aff were notified of the overflow at 3:20 p.m. and the blockage was cleared at 6:40 p.m. Crews jetted the main,
remediated the spill site, dammed the creek downstream, flushed the creek, and pumped the untreated wastewater
back into the sanitary sewer system. There were no observed hazards to persons or property.
The N.C. Department of Environmental Quality Division of Water Resources was notified of the event on April 17,
2021, as required by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water &
Sewer Maintenance.
101 Cety Hall Plata, Second Floor, Durham, NC 27701 919-560.4123 OurhamNC.gov Follow Us @Cityof0urhamNC
C Dept of Fnvir nmentai Qua* © a
Raleigh Rev Office

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: WQCS00005 (WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System Incident #: 202101217
Owner: City of Durham
City: Durham County: Durham Region: Raleigh
Source of SSO (check applicable): [J Sanitary Sewer ❑ Pump Station 1 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): 1010 Grant St
Manhole #: NA
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 04/21/2021 Time: 4:21 pm Incident End Dt: 04/22/2021 Time: 12:42 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 5,010 gallons Estimated Duration (Round to nearest hour): 8:21 hours
Describe how the volume was determined: 501 min x 10 gpm = 5010 gallons
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? 0 Yes []No ❑ Unknown Volume reaching surface waters (gals): 5010
Surface water name: Third Fork Creek
Did the SSO result in a fish kill? ❑ Yes ONo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
0 Pipe Failure (Break)
24 hour verbal notification (name of person contacted ): George Jones
❑ DWR R1 Emergency Mgmt Date (mm-dd-yyy): 04/22/2021 Time (hh:mm AM/PM): 12:42:00 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 _a_ re 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 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
Pipe Failure (Break)
Pipe size (inches)
12
What is the pipe material?
Ductile Iron
What is the approximate age of line/pipe? (years old)
121
Is this a gravity line?
Is this a force main line?
Is the line a "High Priority" line?
Last inspection date and findings
6/15/2009
If a force main then,
Was the break on the force main veritical?
Was the break on the force main horizantal?
Was the leak at the joint due to gasket failure?
Was the leak at the joint due to split bell?
When was the last inspection or test of the nearest air -release valve to determine of
operable?
When was the last maintenace of the air release performed?
If gravity sewer then,
Yes ❑ No ❑ NA ❑ NE
Yes 0 No ❑ NA ❑ NE
R Yes []No DNA ❑ NE
Yes ❑ No W NA ❑ NE
❑Yes [:]No 0NA ❑NE
Yes [:]No WNA [:]NE
[] Yes ❑ No W NA [] NE
Does the line receive flow from a force main immediately upstream of the failed secti. [- Yes 0 No ❑ NA ❑ NE
of pipe?
CS-SSO Form Page: 2

If yes, what measures are taken to control the hydrogen sulfide production?
When was the line last inspected or videoed?
6/15/2009
If line collapsed, what is the condition of the line up and down stream of the failure?
What type of repair was made?
Removed damaged pipe. Installed 6 ft of ductile iron pipe.
Is the repair temporary or permanent?
Temporary
If temporary, when is the permanent repair planned?
Have there been other failures of this line in the past five years? ❑ Yes R] No [] NA NE
If so, then describe
System Visitation
ORC Yes
Backup [71 Yes
Name:
Kerry Sanford
Cert#
992773
Date visited:
4/22/2021
Time visited:
7:55 AM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Removed tree limb from pige. Repaired damaged section of pipe. Dammed creek downstream and set up a pump.
Flushed the creek with a hydrant to return untreated wastewater back into the sanitary sewer system.
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: Kerry Evan Sanford
Signature:
Telephone Number:
Date: 04/23/21 09:00 am
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of t
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

Walker, Daniel
From: Lunne, Joe
Sent: Thursday, April 22, 2021 120 PM
Subject: SSO at 1010 Grant Street
PUBLIC AFFAIRS
City Manager
News Media Contac
Joe Lunne, Sr. Public Information & Communication
Analys
CITY OF DU RHAM Water Management Dep-
919.560.4381 ext. 35255 1 919.397.6131(mobilE
[e-mail]
News Release
For Immediate Release: April 22, 2021
City of Durham contains sewer spill at 1010 Grant Street
DURHAM, N.C. — The City of Durham Department of Water Management reports that on April 21, 2021 staff
responded to a sewer overflow at 1010 Grant Street. Approximately 5,010 gallons of wastewater flowed into an
unnamed tributary of Third Ford Creek. The cause of the overflow is due to pipe failure.
.ity contractor performing sewer line inspections with a video camera discovered a sewer line blockage caused by
grease, and as they investigated further, found the pipe failure which was leaking into the stream. The contractor
alerted City staff who responded to the area.
Staff were notified of the overflow at 4:21 p.m. on April 21, 2021 and the blockage was cleared at 12:40 a.m. on April
22, 2021. Crews jetted the main, remediated the spill site, dammed the creek downstream, flushed the creek, and
pumped the untreated wastewater back into the sanitary sewer system. There were no observed hazards to persons
or property.
As a reminder, only water, human waste, and toilet paper are permitted to be discharged into the sewer system. All
other materials —including fats, oils, and greases (FOG) that should not be disposed of down the sink —contribute to
sanitary sewer overflows. To learn more about the way FOG clogs pipes and to properly dispose of them, visit our
Industrial Waste Control, Pretreatment, and Grease Reduction Program at www.durhamnc.govZ1077.
The N.C. Department of Environmental Quality Division of Water Resources was notified of the event on April 22,
2021, as required by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water &
Sewer Maintenance.
NO
NC Dept of Fnvironmental Quality
r
P*""gh Regional Office