WQCS00005_NOV-2021-DV-0419 Response_20211206

WATER MANAGEMENT
CITY OF DURHAM
Date: December 6, 2021
To: Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
NCDEQ, Division of Water Resources
3800 Barrett Drive
Raleigh, N.C. 27609
From: Don Greeley, P.E., P.L.S., Director
Subject: NOV-2020-DV-0419, Permit No. WCS00005
City of Durham Collection System, Durham County
received the document addressed to
(please print NAME)
Raleigh Regional Office on Tuesday, December 6, 2021.
Signature Date
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WATER MANAGEMENT
CITY OF DURHAM
December 3, 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-0419 Permit No. WQCS00005
City of Durham Collection System, Durham County
Dear Mr. Vinson,
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This letter is in response toyournotice dated October5, 2021 which was received by the City of Durham on
November 18, 2021. The October 5, 2021 letter states that the City of Durham is provided an opportunity to
present evidence andjustification to demonstrate thatthe proposed civil penalties forthe Notice of Violation
(NOV) should not be assessed forthe sanitary seweroverflows (SSOs) which occurred in the City's sewercollection
system between August 1, 2021 and August 31, 2021.
As requested, the Cityof 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, temporary and beyond the City's exercise of reasonable control.
Incident# 202101692- 3311 Shannon Road—August3, 2021
On August 3, 2021 manhole #09023 near3311 Shannon Road overflowed with an estimated 2,400 gallons of
wastewaterdischarging into New Hope Creek. This overflow occurred due to a blockage in the sewer main caused
by debris. While Water and Sewer Maintenance worked to remove the blockage, they diverted flow by pumping
wastewaterout of manhole #09023 around to manhole #09035. This reduced the level of wastewater in manhole
#09023 and enabled staff to determine that the root cause of the blockage was due to the manhole invert
becoming detached from the lid and falling into the manhole. While some staff worked to remove the manhole
insert using a pickup stick, otherstaff dammed the creek downstream, flushed using a nearby hydrant
(dechlorinated water) and then pumped untreated wastewater back into the collection system. The area was
remediated bywashing/cleaning the area, reseeding and covering the area with straw. Crews also cleaned reaches
(at least 3 manholes) above and below manhole #09023. Asper practice, staff removed the inserts of this same
type in these 6 manholes and replaced them with newerand more substantial inserts.
The City's Stormwate rServices Division responded and conducted ammoniatestingto 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
$3,906.17.

Page 2 of 3
Incident# 202101722 —4428 Sun Valley Drive— Auigust 9 2021
On August 9, 2021, a sewer ove rf low occu rred near4428 Sun Valley Drive with approxim ate ly 500 gallons of
untreated waste water flowing into Third Fork Creek. Water & Sewer Maintenance's Quick Response crew
responded to the site but were unable to clear the blockage in the mainline. Additional crews responded to the
site and using two VacAll Trucks were able to clear the buildup of debris (rocks and rags) in the line. Crews
remediated the area around the spill, damming the creek, flushed using a nearby hydrant (dechlorinated water)
and pumped the untreated wastewater back into the collection system. Crews also flushed/cleaned the collection
system upstream and downstream of the event location and used CCTV to check for any other issues associated
with the event.
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.
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
$10,078.40
Ongoing City -Wide Measuresto Reduce the Occurrence ofSSOs
The city has several programs in place to reduce and/or prevent the occurrence ofSSOs. 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 sewercollection 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 exceedingthe requirement by at
least 2 to 5% each year. The City measures the flushing on a fiscal year basis. For the FY 2022 year to date, the
City has cleaned 4.62% 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 the Collections Systems Maintenance workgroup in the Water& Sewer Maintenance (WSM) Division of
DWM. This group performs CCTV inspections, hydraulic cleaning activities, mowingand manhole inspection
and repair. They respond to blockages and overflows. WSM does contract inspections as well. In addition,
crewsfrom 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-
memberworkgroup 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.

Page 3 of 3
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 workingclosely with the
Durham County Health Department, staff routinely inspectover 800 food service establishments (FSEs)
annually to ensure appropriate cleaning and maintenance of grease interceptors. Staff participates in a
numberof community events (Earth Day, CenterFest, and Landlord Workshops) as well as n eighborhood
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 and wipes.
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 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
regarding what should and should not be discharged into the City's sewercollection system.
Department staff welcomes the opportunity to meet with you and yourstaff to review our program and discuss
constructive ways to improve whatwe 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,
Donald F. Greeley, Direcfor,
Attachments
c: Jason Robinson, DEQ— Water Quality Regional Operations Section, Raleigh Regional Office
Junior Mobley, Superintendent, Water & Sewer Maintenance
Vicki Westbrook, Assistant Director, Administration, Regulatory Compliance & Communications
Scott Smart, Assistant Director, Systems & Maintenance
Jerry Morrone, Utility Engineering Manager, Sr.

State of North Carolina
DWR t1
Department of Environment and Natural Resources
DEC - 6 2021 Division of Water Resources
D[vision of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Raleigh Regional Office 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 #: 202101692
Owner: City of Durham
City: Durham
County: Durham
Region: Raleigh
Source of SSO (check applicable): [l 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): 3311 Shannon Road
Manhole #: 09023
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 08/03/2021 Time: 5:02 pm Incident End Dt: 08/04/2021 Time: 01:02 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AMIPM)
Estimated Volume of the SSO: 2,400 gallons Estimated Duration (Round to nearest hour): 8:0 hours
Describe how the volume was determined: 480mins x 5gpm
Weather conditions during the SSO event: WET
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 2400
Surface water name: New Hope Creek
Did the SSO result in a fish kill? ❑ Yes ONo ❑ Unknown If Yes, what is the estimated number of fish killed? 0
SPECIFIC cause(s) of the SSO:
0 Debris in line
24 hour verbal notification (name of person contacted ): Lauren Smith
❑ DWR Z Emergency Mgmt
Date (mm-dd-yyy): 08/04/2021 Time (hh:mm AMIPM): 05:03:00 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 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 li 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
Debris in line
What type of debris has been found in the line?
Debri was a dust cover that we use to keen debris from coming in from the Manhole entry point. The dust cover fell in
causing blockage.
Suspected cause or source of debris.
Under Manhole lid dust cover
Are manholes in the area secure and intact? W Yes ❑ No [] NA [] NE
When was the area last checked/cleaned?
08/04/2021
Have cleaning and inspections ever been increased at this location due to previous Yes [0 No ❑ NA NE
problems with debris?
Explain
Are appropriate educational materials being developed and distributed to prevent futi [Z Yes ❑ No [] NA [] NE
similar occurrences?
Comments:
The dust cover used in this location were a old faulty cover that have been known to fail. We replaced all dust covers in
area to avoid future incident.
System Visitation
ORC Yes
Backup fv7 Yes
Name:
Kerry Sanford
Cert#
992773
Date visited:
08/03/2021
Time visited:
5:02om
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews flushed for several hours to find issue with blockage. They were unable to remove blockage with flush truck. Aftei
several hours of flushing crews decided to do a pump around to another Manhole in order to better view blocka a cause.
They pumped the sewer into Mh09035 after Manhole was completely dry they noticed dust cover wedged in line
downstream. They were able to remove dust cover with a pick up removal stick. While trying to remove dust cover we al
had a crew setting up a_pump to bypass all the untreated wastewater from the creek into Mh08290. After removal we ha(
crew clean up spill area with vacuum truck and 5 gallon buckets. We washed down area and reseeded and put straw do%
on area around Manhole. After cleanup crew used extended „fetter to flush 3 assets up and 3 assets down to insure spill
area is clear. We also removed all old dust covers in area.
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: 08/09/21 08:05 am
Title: VL 6�
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).
CS-SSO Form Page: 3

PUBLIC AFFAIRS
City Manager
CITY OF DURHAM
News Media Contact
Jtit Lunne, Sr. Public Information & Comms Analyst
Water Management Dept.
919.560.4381 ext. 35255 1 919.397.6131 (mobile)
[e-mail]
News Release
For Immediate Release, August 4, 2021
City of Durham contains sewer spill near 3311 Shannon Road
DURHAM, N.C. — The City of Durham Department of Water Management reports that on August 3, 2021 staff
responded to a sewer overflow near 3311 Shannon Road. Approximately 2,400 gallons of untreated wastewater
flowed into the New Hope Creek Watershed. The spill was caused by the manhole insert falling into the sewer and
blocking flow.
Staff were notified of the overflow at 5:02 p.m. on August 3, 2021 and the blockage was cleared at 1:00 am on August
4. Crews removed the object, dammed the creek downstream, flushed the creek, pumped the untreated wastewater
back into the sanitary sewer system, and remediated the spill site. 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 August 4,
1021, as required by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water &
:wer Maintenance.
101 City Hall Plaza, Second Floor, Durham, NC 27701 919.560.4123 DurhamNC.gov Follow Us @CityofDurhamNC
O©1-�0

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
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 #: 202101692
Owner: City of Durham
City: Durham County: Durham Region: Raleigh
Source of SSO (check applicable): Z 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): 3311 Shannon Road
Manhole #: 09023
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 08/03/2021 Time: 5:02 pm Incident End Dt: 08/04/2021 Time: 01:02 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 2,400 gallons Estimated Duration (Round to nearest hour): 8:0 hours
Describe how the volume was determined: 480mins x 5gpm
Weather conditions during the SSO event: WET
Did SSO reach surface waters? 21 Yes ❑ No []Unknown Volume reaching surface waters (gals): 2400
Surface water name: New Hope 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 Debris in line
24 hour verbal notification (name of person contacted ): Lauren Smith
❑ DWR Z Emergency Mgmt Date (mm-dd-yyy): 08/04/2021 Time (hh:mm AM/PM): 05:03:00 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 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 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?
Debri was a dust cover that we use to keen debris from coming in from the Manhole entry point. The dust cover fell in
causing blockage.
Suspected cause or source of debris.
Under Manhole lid dust cover
Are manholes in the area secure and intact? Yes [] No ❑ NA ❑ NE
When was the area last checked/cleaned?
08/04/2021
Have cleaning and inspections ever been increased at this location due to previous ❑ Yes [Z No ❑ NA ❑ NE
problems with debris?
Explain:
Are appropriate educational materials being developed and distributed to prevent futi [Z Yes ❑ No ❑ NA ❑ NE
similar occurrences?
Comments:
The dust cover used in this location were a old faulty cover that have been known to fail. We replaced all dust covers in
area to avoid future incident.
System Visitation
ORC ❑ Yes
Backup W Yes
Name:
Kerry Sanford
Cert#
992773
Date visited:
08/03/2021
Time visited:
5:02pm
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews flushed for several hours to find issue with blockacie. They were unable to remove blockage with flush truck. After
several hours of Flushing crews decided to do a pump around to another Manhole in order to better view blockade cause.
They pumped the sewer into Mh09035 after Manhole was compietely dry they noticed dust cover wedged in line
downstream. They were able to remove dust cover with a pick up removal stick. While trying to remove dust cover we al
had a crew setting up a oumo to bypass all the untreated wastewater from the creek into Mh08290. After removal we hac
crew clean up spill area with vacuum truck and 5gallon buckets. We washed down area and reseeded and put straw dog
on area around Manhole. After cleanup crew used extended 'etter to flush 3 assets up and 3 assets down to insures ill
area is clear. We also removed all old dust covers in area.
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: Kern Evan Sanford
Signature:
Telephone Number:
Date: 08/09/21 08:05 am
Title: tJC 6�y
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).
CS-SSO Form Page: 3

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 1 919.397.6131 (mobile)
[e-mail]
News Release
For Immediate Release: August 4, 2021
City of Durham contains sewer spill near 3311 Shannon Road
DURHAM, N.C. —The City of Durham Department of Water Management reports that on August 3, 2021 staff
responded to a sewer overflow near 3311 Shannon Road. Approximately 2,400 gallons of untreated wastewater
flowed into the New Hope Creek Watershed. The spill was caused by the manhole insert falling into the sewer and
blocking flow.
Staff were notified of the overflow at 5:02 p.m. on August 3, 2021 and the blockage was cleared at 1:00 am on August
4. Crews removed the object, dammed the creek downstream, flushed the creek, pumped the untreated wastewater
back into the sanitary sewer system, and remediated the spill site. 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 August 4,
-7021, as required by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water &
:wer Maintenance.
101 City Hall Plaza, Second Floor, Durham, NC 27701 I it 919.560 4123 DurhamNC.gov follow Us @tityo© rhamNC
Ik i NC