WQCS00005_NOV-2021-DV-0315 Response_20210823

WATER MANAGEMENT
CITY OF DURHAM
August 23, 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-0315, Permit No. WQCS00005
City of Durham Collection System, Durham County
Dear Mr. Vinson,
Are Dept of Environmental Quality
AUG 24 LUL t
Raleigh Regional Office
This letter is in response to your notice dated July 9, 2021 which was received by the City of Durham on August 3,
2021. The July 9, 2021 letter states that the City of Durham is provided an opportunity to present evidence and
justification to demonstrate that the proposed civil penalties for the Notice of Violation (NOV) should not be
assessed for the sanitary sewer overflows (SSOs) which occurred in the City's sewer collection system between
June 1, 2021 and June 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 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 # 202101371-1609 Hollywood Street — June 2, 2021
On June 2, 2021, a section of the City's sewer main (identified as reach #09149) near 1609 Hollywood Street
overflowed, with an estimated 340 gallons of wastewater discharging into Ellerbe Creek. This overflow occurred
due to a blockage in the sewer main caused by debris. Water and Sewer Maintenance staff used a high-pressure
jet to remove the blockage from the main, cleaning the lines with a VAC -ALL combo truck. The creek was dammed
and then flushed using dechlorinated water from a nearby hydrant. The untreated wastewater was pumped back
into the sanitary sewer system (4" pump used). When the CCTV footage was reviewed, staff identified a hole in the
top of the mainline pipe just upstream of the spill. The department's Utility Engineering team will add this repair to
the slip lining project planned for Spring 2022. The section of line is currently checked monthly and if necessary,
the repair will be expedited.
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. As required, a news release was issued within the 24-hour window. The cost to remediate this spill was
$4,900.39.

Page 2 of 3
Incident # 202101430— 242 Ruby Ridge Road —June 18, 2021
On June 18, 2021 manhole #17251 at 242 Ruby Ridge Road overflowed, with an estimated 525 gallons of
wastewater discharging into Little Lick Creek. This overflow occurred due to a blockage in the sewer main caused
by debris in the line. Water and Sewer Maintenance staff used a high-pressure jet to remove the blockage from the
main, cleaning the lines with a VAC -ALL combo truck. The creek was dammed and then flushed using dechlorinated
water from a nearby hydrant. The untreated wastewater was pumped back into the sanitary sewer system (4"
pump used).
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 usingtTV
trucks. As required, a news release was issued within the 24-hour window. The cost to remediatthis spill was
$5,500.90. b
ti.
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 Cit`ias r-J g
implemented a CMOM plan that expands and enhances its existing programs. VD N s„
0 �'
• System Flushing and Inspection: The City routinely contracts flushing, CCTV inspection, smokesting and t
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. During FY 2021, the City cleaned
13.55% 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 20 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 and respond to blockages and overflows. WSM conducts 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 18-
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)

Page 3 of 3
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 dispose of via 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 and nonwovens.
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].
Sincerely,
-CA.- LuitiathADV, yjit 4)
. net, lacati
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.

DWR
Division of Water Resources
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
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: WQCS00005 (WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System Incident #: 202101371
Owner: City of Durham
City:
County: Durham Region: Raleigh
Source of SSO (check applicable): [l 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): 1609 hollyw000d street
Manhole #: SEWER MAIN
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 06/02/2021 Time: 11:42 am Incident End Dt: 06/02/2021 Time: 12:50 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 340
gallons Estimated Duration (Round to nearest hour): 1:8 hours
Describe how the volume was determined: 1 hour 8mins X 5gpm
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? [r Yes ❑ No ❑ Unknown
Surface water name: Ellerbe Creek
Volume reaching surface waters (gals): 340
Did the SSO result in a fish kill? ❑ Yes El No ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
E Pipe Failure (Break)
24 hour verbal notification (name of person contacted ): Eric S Rice
[✓1 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 06/02/2021 Time (hh:mm AM/PM): 02:34:00 pm
1
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stoppe .
Per G.S. 143-215.1 C(b), the responsible party of a discharge of 1,000 or more of untreated wastewer to surface eaters
shall issue a press release within 24-hours of first knowledge to all print and electronic news meila providing eneral
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wasater meters grface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to tib Division within 30
days. Refer to the reference statute for further detail. oci, -0-
The Director, Division of Water Resources, may take enforcement action for SSOs that are rettuiretio b oorti to
Division unless it is demonstrated that: 0 rp
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the *barge; or
v.di'
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)
8
What is the pipe material?
Clay
What is the approximate age of line/pipe? (years old)
96 Years
Is this a gravity line?
Is this a force main line?
Is the line a "High Priority" line?
Last inspection date and findings
NA
If a force main then,
WYes EiNo f NA ENE
El Yes pNo ID NA []NE
Yes 171No ENA DNE
Was the break on the force main veritical? D Yes [] No D NA D NE
Was the break on the force main horizantal? D Yes D No El NA D NE
Was the leak at the joint due to gasket failure? ID Yes No ID NA [J NE
Was the leak at the joint due to split bell? D Yes ❑ No ❑ NA ❑ NE
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,
Does the line receive flow from a force main immediately upstream of the failed secti l Yes 17 No ❑ NA D 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?
10/23/2014
f line collapsed, what is the condition of the line up and down stream of the failure?
What type of repair was made?
The pipe will be Tined by contractors.
Is the repair temporary or permanent?
Permanent
If temporary, when is the permanent repair planned?
Have there been other failures of this line in the past five years? 11 Yes RI No ❑ NA ❑ NE
If so, then describe
System Visitation
ORC
El Yes
Backup Yes
Name:
Kerry Sanford
Cert#
992773
Date visited:
06/02/2021
Time visited:
12:OOPM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews arrived on site and observed wastewater flowing from sewer main into the creek at 5gom. Crews checked the
manholes and discovered a blockage in the main. Crews jetted the main to relieve the blockage and stopped the flow of
wastewater into the creek, dammed the creek downstream, set up a four inch pump, flushed the creek using a hydrant an
defusser and returned the untreated wastewater back into the sanitary sewer system. During CCTV of the main it was
discovered that there was a hole in the top of the pipe. The hole will be fixed by lining the pipe.
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 Date: 06/04/21 01:25 pm
Title: � c
Telephone Number: [phone] Ext.
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

Walker, Daniel
From: Lunne, Joe
Sent: Thursday, June 3, 2021 10:02 AM
Subject: SSO at 1609 Hollywood Street
PUBLIC AFFAIRS
City Manager
CITY OF DURHAM
News Media Conta
Joe Lunne, Sr. Public Information & Comms Analy
Department of Water Manageme
919.560.4381 ext. 35255 1919.397.6131(mobil
[e-mail]
News Release
For Immediate Release: June 3, 2021
City of Durham contains sewer spill at 1609 Hollywood Street
DURHAM, N.C. —The City of Durham Department of Water Management reports that on June 2, 2021 staff responded
to a sewer spill at 1609 Hollywood Street. Approximately 340 gallons of wastewater flowed into an unnamed tributary
of Ellerbe Creek. The cause of the overflow was a damaged sewer line.
staff were notified of the overflow at 11:42 a.m. and the issue was cleared at 12:50 p.m. Crews jetted the sewer main.
4mediated 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. Water and Sewer
Maintenance personnel are working with the department's Utility Engineering staff to permanently repair the section
of sewer line.
The N.C. Department of Environmental Quality Division of Water Resources was notified of the event on June 2, 2021,
as required by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water & Sewer
Maintenance.
###
101 City Hall Plaza, Second Floor, Durham, NC 27701 919.560.4123 j DurhamNC.gov
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00

DWR
Division of Water Resources
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
ART 1:
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 #: 202101430
Owner: City of Durham
City: City Of Durham
County: Durham Region: Raleigh
Source of SSO (check applicable): 10 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): 242 Ruby Ridge Rd. Durham, NC
Manhole #: 17251
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 0618/2021 Time: 8.14 am Incident End Dt: 06/18/2021 Time: 10:01 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 525
gallons Estimated Duration (Round to nearest hour): _ 1:47
Describe how the volume was determined: (1 hour and 45mins) Gallons per Min x 5 gals min
hours
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown
Surface water name: Little Lick Creek
Volume reaching surface waters (gals): 525
Did the SSO result in a fish kill? ❑ Yes Q No ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
▪ Debris in line
24 hour verbal notification (name of person contacted ): Jerry Belcher
❑ DWR rI Emergency Mgmt Date (mm-dd-yyy): 06/18/2021 Time (hh:mm AM/PM): 07:08:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(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 end electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons ern more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and goof of publicggon shall be provided to the Division within 30
days. Refer to the reference statute for further detail. SI)'°
ua
The Director, Division of Water Resources, may take enforcffnent Oion f SSOs that are required to be reported to
Division unless it is demonstrated that:
aQ
1) the discharge was cause by sever natural conditions and tyre we ern' o fusible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary arM.causittd by *tors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have L n preventedAy the exercise of reasonable control.
Part II must be completed to provide a justification claim for eithea of the above guations. 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
Debris in line
What type of debris has been found in the line?
Nonwovens
Suspected cause or source of debris.
Nonwovens
Are manholes in the area secure and intact?
When was the area last checked/cleaned?
171Yes DNo DNA DNE
Have cleaning and inspections ever been increased at this location due to previous El Yes 2 No ❑ NA D NE
problems with debris?
Explain:
Are appropriate educational materials being developed and distributed to prevent futi ❑ Yes 1=1 No [71 NA NE
similar occurrences?
Comments:
System Visitation
ORC Yes
Backup 17 Yes
I -
Name: 4
Kerry Sanford °+,
Cert# P
922773 ,;:siso*:74 t - °��
o
Date visited: r";j Corr
06/18/2021 o0�r �1
s.
Time visited: .1.
7:00prn oco
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews jetted the sewer main. remediated the spill site, flushed the creek. and pumped the untreated wastewater back ink
the sanitary sewer system.
As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
ast of my knowledge.
Person submitting claim: Date:
Signature:
Telephone Number:
Title: (f .c s
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: 3

Walker, Daniel
From:
Sent:
Subject:
Lunne, Joe
Saturday, June 19, 2021 7:25 AM
SSO at 242 Ruby Ridge Road
PUBLIC AFFAIRS
City Manager
CITY OF DURHAM
News Media Contact
Joe Lunne, Sr. Public Information & Comms Analyst
Water Management Dept.
919.560.4381 ext. 35255 1919.397.6131 (mobile)
[e-mail]
News Release
For Immediate Release: June 19, 2021
City of Durham contains sewer spill at 242 Ruby Ridge Road
DURHAM, N.C. — The City of Durham Department of Water Management reports that on June 18, 2021
staff responded to sanitary sewer overflow near 242 Ruby Ridge Road. Approximately 525 gallons of
untreated wastewater flowed into Lick Creek. The cause of the overflow was unknown debris in the
sewer main.
Staff were notified of the spill at 8:14 a.m. and the clean up was completed at 7:57 p.m. Crews jetted the
sewer main, remediated the spill site, flushed the creek, and pumped the untreated wastewater back into the
sanitary sewer system.
As a reminder, only water, human waste, and toilet paper are permitted to be discharged into the sewer
system. All other materials —including nonwoven wipes and fats, oils, and greases (FOG) that should not be
disposed of down the sink or toilet —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.gov/1077.
The N.C. Department of Environmental Quality Division of Water Resources was notified of the event on June
18, 2021, as required by state regulations/law. For more information, contact Junior Mobley, Superintendent
of Water & Sewer Maintenance.
###
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