D8 - Investigation Field Audit March 2022

CITY OF
DURHAM
Date: April 27, 2022
To: Melissa Harrison, EP&C Specialist
Signature:
Cc: Michelle Woolfolk, Water Quality Manager
From: Jim Azarelo, IDDE Supervisor
Subject: IDDE Field Investigation Audit
Introduction
Date:
Memo
This writing presents the results of an audit of the City of Durham's Illicit Discharge
Detection and Elimination (IDDE) investigation program for the 2021-2022 fiscal year.
This audit was conducted to evaluate investigation methods and practices used by staff
members in the Stormwater & GIS Services Water Quality Group. The staff member
subject to the field audit must read and sign this document to affirm his or her
understanding of its contents.
At 3:00 p.m. on March 24, 2022 Water Quality received notice from City Water and
Sewer Maintenance that there was a sewage discharge from a residence located at
2408 Chapin St. A W&S crew had already visited the site after receiving a complaint
from an adjacent resident, conducted an investigation, and determined that it was due
to an issue on the private utility side.
At approximately 11:00 a.m. on March 25, 1 accompanied lead investigator Melissa
Harrison while she conducted an investigation into this complaint. Database record
number 22WQ070 was created for this investigation.
Investigation Preparation
Before departing from his home office, Melissa reviewed CityWorks service request
#1330526, which was W&S Maintenance's record of investigation of this matter. She
queried the investigations database for prior history at this location. There was no
relevant site history. She also inspected the GIS webmap for parcel data and other
nearby related investigations.
As this investigation involved a liquid discharge, Melissa brought a Chemetrics kit to test
for pollutant indicators.
She appropriately donned a high -visibility vest and safety shoes for this investigation.
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Investigation Details
Melissa and I arrived separately to 2408 Chapin St. and parked our vehicles along the
side of the street, which appeared to be safe and low -traffic.
Melissa initially made observations and took photographs of the 2408 parcel from the
street. Trails of liquid could be seen leading from the residential property, across the
adjacent driveway, and into the street. Melissa also noted the odor of wastewater in the
area.
Melissa approached the residence and made contact with the tenant. The tenant called
the homeowner to give notice of our visit. Melissa recorded the names of each of these
individuals. The homeowner granted consent for Melissa to investigate and test the
liquid seeping from the house foundation.
I observed Melissa properly use a Chemetrics kit to collect and test a sample of the
discharge for ammonia. The sample immediately turned a deep orange upon testing,
indicating an ammonia concentration in excess of 10 ppm. Melissa reasonably
concluded that this flow was a residential sewage discharge.
Melissa shared her findings with the tenant and inquired into whether corrective actions
were being taken. The tenant revealed that a plumbing contractor had not yet been
secured to perform work. Melissa asked the tenant to let the homeowner know that
Water Quality would be issuing a formal requirement for repair and remediation.
Investigation Result -
Melissa entered her initial investigation findings into the database at approximately 3:50
p.m. on March 28.
After confirming the identity and contact information for the property owner, Melissa
spoke with them via phone to discuss expectations for diagnosis and repair of the
plumbing issue, in addition to remediation of impacted soils.
On March 30, Melissa hand -delivered a Notice of Requirement to the property owner.
She properly noted the issue as an illicit discharge of sewage from the property. Her
corrective actions specified diagnosis and repair of the issue by a licensed plumber and
remediation as appropriate. She set a reasonable deadline of April 8, 2022.
On April 1, the property owner submitted some meagre evidence of plumbing work
conducted on the premises that Melissa appropriately deemed insufficient as evidence
that the issue was resolved. Melissa replied, requesting evidence in the form of a dye
test or written statement from a licensed plumber. As of April 12, Melissa granted a
reasonable extension of the deadline due to additional hazards identified in the repair
area, causing work delays. Furthermore, City NIS is also enforcing housing code
violations at this residence. NIS officers are coordinating their efforts with Melissa.
This case has not yet been resolved as of the writing of this memo.
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e

Audit Recommendations
I have no recommendations for Melissa at this time. This investigation was conducted
efficiently and according to all established IDDE guidelines and safety procedures. The
database records for this investigation are complete and sufficiently chronicle all
evidence and actions taken.
I recommend that we discuss and research a convenient and effective means of
cleaning and/or sanitizing our Chemetrics kits in the field (and laboratory, if necessary).
These kits and their contents usually contact unclean liquids, the most common of
which are sewage -laden flows. These exteriors of the kit containers are almost certainly
contaminated and are usually handled ungloved and stored in clean areas of our
laboratory and vehicles.
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