WQCS00005_RSP NOV-2022-DV-0327_20221215

WATER MANAGEMENT
CITY OF DURHAM
Date: December 15, 2022
To: Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
NCDEQ, Division of Water Resources
3500 Barrett Drive
Raleigh, N.C. 27609
From: Don Greeley, P.E., P.L.S., Director
Subject. NOV-2022-DV-0327, Permit No. WCS00005
City of Durham Collection System, Durham County
I LI t 6 received the document addressed to
(please print N E)
Raleigh Regional Office on Thursday, December 15, 2022.
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Signature .
Date
NC Dept of Environmental Quality
DEC 15 2622
Raleigh Regional Office
1600 Mist Lake Dr. Durham, NC 27704 919.560.4381 DurhamNC.gov 1
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WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1100 Martin Luther King Jr Parkway
Durham, NC 27707
919-560-4344
December 15, 2022
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
NCDEQ, Division of Water Resources
3800 Barrett Drive
Raleigh, NC 27609
Subject: NOV-2022-DV-0327 Permit No. WQCS00005
Dated: November 14, 2022; Received: December 2, 2022
City of Durham Collection System, Durham County
Dear Mr. Vinson,
NC Dept of Environmental Quality
DEC 15 ?02?
Raleigh Regional Office
The above referenced 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 overflow (SSO) which occurred in the City's sewer collection system between
October 1, 2022 and October 31, 2022.
For the purposes of supporting the City's position that this event was exceptional, unintentional, temporary, and
beyond its reasonable control, the Durham Department of Water Management (DWM) is providing information
about the requested incident that occurred during this timeframe. All conditions of the City's Collection System
permit are met by the Department, including system cleaning, site visits, inspections, and easement maintenance.
Incident# 202202599 - 5 Benwick Court- 10/19/2022 11:15 AM
On 10/19/2022 at 11:15 AM, an overflow occurred near 5 Benwick Court releasing an estimated 4,200 gallons of
wastewater into an unnamed tributary of Little Creek. Crews discovered a pipe failure on the force main just
outside the Downing Creek Lift Station as the cause of the overflow. Our Lift Station Maintenance (LSM) staff
make weekly inspections of the lift station and noted no signs of the pipe failure in the inspection 2 days prior.
LSM staff used a bypass pump to stop the flow while City contractors were brought in to make the infrastructure
repairs to the force main. After assessing the extent of the spill, crews dammed the downstream creek with
sandbags, set up pumps to pump the untreated wastewater back into the collection system, and flushed the area
using a nearby hydrant (dechlorinated water).

Page 2 of 3
Department staff conducted ammonia testing along the downstream marshland areas to help determine the spill's
extent. No visible adverse environmental impacts or hazards to persons or property were observed. Crews have
observed no lasting effects to persons, property, or the environment during the following weekly inspections
completed at the lift station.
A news release was issued within the 24-hour window. The cost to remediate this spill was $ 51,604.46.
Ongoing City -Wide Measures to Reduce the Occurrence of SSOs
The City has several programs in place to prevent and reduce the occurrence of SSOs. The City has implemented a
Collection System Management, Operations & Maintenance (CMOM) plan that expands and enhances its existing
programs.
■ System Flushing and Inspection: The City routinely contracts cleaning, CCTV inspection, smoke testing, and
manhole inspections of portions of the sewer collection system. The City completes the inspection of the
collection system systematically based on City defined geographical basins.
The City ensures the requirements of the collection system permit are met by deploying City crews to clean at
least 10% of the collection system annually with a goal of exceeding the requirement by 2% to 5% each year.
The City measures the cleaning on a fiscal year basis starting July 1. As of October 31, 2022, 1.76% of the City's
collection system had been cleaned by City staff and contractors.
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 four full-time equivalents (FTEs) employees 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
21 FTEs in the City's Collections Systems Maintenance (CSM) workgroup in the Water and Sewer Maintenance
(WSM) Division of DWM. This group performs CCTV inspections, hydraulic cleaning activities, mowing,
manhole inspections, and manhole repairs. They respond to all reported concerns including blockages and
overflows. In addition, the CSM crews are supported by the Excavation Services workgroup of WSM who
perform identified point repairs, line replacements, and cured -in -place lining. In 2018, the department
established the Lift Station Maintenance Division (LSM) to focus on oversight and maintenance of the 63 lift
stations throughout the service area and the 136 air relief valves (ARVs) in the system. This workgroup of 21
FTEs conducts required daily, weekly, monthly, and annual 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.
Fats, Oils, and Grease Program (FOG): The department's FOG education and outreach effort is conducted by
three FTEs (staff shared between the Industrial Pretreatment, Septage and FOG Programs). In addition to
working with the Durham County Health Department, staff routinely inspect over 800 food service
establishments (FSEs) annually to ensure appropriate cleaning and maintenance of grease interceptors. Staff
participate in several community events, such as Earth Day, Center Fest and Bimbe, as well as neighborhood
meetings. Department staff deliver residential Fat Trappers to increase awareness of the proper disposal
methods for waste. FOG staff also conducts post-SSO follow-up education and enforcement as necessary. The
City invests over $50,000 per year in advertising the proper disposal of FOG on television. Staff post to the
City's quarterly newsletter, The Durham Digest, along with multiple mentions in the City Manager's Report
known as City Connect, to reach a broad range of Durham residents.

Page 3 of 3
Summary:
Based upon the documented information provided above regarding this incident, the City believes that this SSO
was exceptional, unintentional, temporary, and caused by factors beyond the City and Department's control. The
City actively manages, operates, and maintains its system in such a manner as to meet or exceed all the
requirements of the Collection System permit. As detailed above, the City systematically inspects, flushes, and
rehabilitates its wastewater collection system. The Department also actively works to educate the community
regarding what should and should not be discharged into the City's sewer collection system.
The 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,
Donald F. Greeley
Director
Attachments
c: Jason Robinson, DEQ— Water Quality Regional Operations Section, Raleigh Regional Office
Junior Mobley, Superintendent, Water & Sewer Maintenance
Scott Smart, Assistant Director
Jerry Morrone, Utility Engineering Manager, Sr.

NC Dept of Environmental Quality State of North Carolina
Department of Environment and Natural Resources
DWR Division of Water Resources
Division of Water Resources DEC 15 RCotlection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
PART I: Raleigh Regional Office
This form shall be submitted to the appropriate DW R 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: Downing Creek Force Main Incident #: Owner: City of Durham
Region: Raleigh City: Durham County: Durham
Source of SSO (check applicable): ❑ 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.): Force Main broke at the Downing Creek Lift Station Property,
Fore Main Asset ID #00038, broke at a 90 degree joint
Manhole #:
Latitude (degrees/minute/second): Longitude (degrees/minute/second):
Incident Started Dt: 10-19-2022 Time: 11:15AM Incident End Dt: 10-19-2022 Time: 12:15PM
(mm-dd-yyyy) (hh:mm) AM/PM (mm-dd-yyyy) (hh:mm) AM/PM
Estimated volume of the SSO: 4,200 gallons Estimated Duration (round to nearest hour): 1.0 hour(s)
Describe how the volume was determined: Lift Station ran 7 times at 3 minutes each time, GPM 200 X 21 MIN. _
4,200gal
Weather conditions during the SSO event: Clear
Did the SSO reach surface waters? ® Yes
Volume reaching surface waters: 4,200 gallons
❑ No ❑ unknown
Surface water name: Little Creek Watershed
Did the SSO result in a fish kill? ❑ Yes ® No ❑ unknown
If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
❑Severe Natural Conditions ❑ Grease
[—]Pump Station Equipment Failure ❑ Power Outage
[--]Other (Please explain in Part II)
❑Roots ❑Inflow & Infiltration
[]Vandalism ❑ Debris in line ®Pipe Failure (Break)
24-hour verbal notification (name of person contacted): Curtis Tyree
®DWR []Emergency Management Date (mm-dd-yyy): 10-20-2022Time: (hh:mm AM/PM): 8:25AM
Per G.S. 143-215.1 C(b), the owner or operator of any wastewater collection system shall:
In the event of a discharge of 1,000 gallons or more of untreated wastewater to the surface waters of the State, issue
a press release to all print and electronic news media that provide general coverage in the county where the
discharge occurred setting out the details of the discharge. The press release shall be issued within 24 hours after
the owner or operator has determined that the discharge has reached surface waters of the State.
In the event of a discharge of 15,000 gallons or more of untreated wastewater to the surface waters of the State,
publish a notice of the discharge in a newspaper having general circulation in the county in which the discharge
occurs and in each county downstream from the point of discharge that is significantly affected by the discharge. The
Regional Office shall determine which counties are significantly affected by the discharge and shall approve the form
and content of the notice and the newspapers in which the notice is published.
WHETHER OF NOT PART II IS COMPLETED, A SIGNATURE IS REQUIRED SEE PAGE 13
Form CS-SSO Page 1

Severe Natural Conditions hurricane tornado etc.
Describe the "severe natural condition" in detail:
How much advance warning did you have and what actions were taken in preparation for the event?
Comments:
Form CS-SSO Pagc

Roots
Do you have an active root control program on the line 1 area in question? ❑ Yes ❑ No
Describe:
Have cleaning and inspections ever been increased at this location because
of roots? ❑ Yes ❑ No
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?
Has the line been smoke tested or videoed within the past year? ❑ Yes ❑ No
If Yes, when?
Comments:
®NA ❑ NE
®NA ❑ NE
RR Mm
Form CS-SSO Fags 6

Pump Station Equipment Failure (Documentation of testing records, etc should be provided upon request)
What kind of notification/alarm systems are present?
Auto-dialer/telemetry (one-way communication) ❑ Yes
Audible ® Yes
Visual ® Yes
SCADA (two-way communication) ® Yes
Emergency Contact Signage ® Yes
Other ❑ Yes
If Yes, explain:
Describe the equipment that failed: No Failure at the Lift Station
What kind of situations trigger an alarm condition at this station (i.e. pump failure, power failure, high water, etc.)?
Were notification/alarm systems operable? ® Yes ❑ No ❑NA ❑ NE
In no, explain:
If a pump failed, when was the last maintenance and/or inspection performed?
What specifically was checked/maintained?
If a valve failed, when was it last exercised?
Were all pumps set to alternate?
❑ Yes ❑ No ❑NA ❑ NE
Did any pump show above normal run times prior to and during the SSO event? ❑ Yes ® No ❑NA ❑ NE
Were adequate spare parts on hand to fix the equipment
Was a spare or portable pump immediately available?
If a float problem, when were the floats last tested? How?
If an auto -dialer or SCADA, when was the system last tested? How?
Comments: manually tested every week
® Yes ❑ No ❑NA ❑ NE
® Yes ❑ No ❑NA ❑ NE
Form CS-SSO Pa7c

Vandalism
Provide police report number:
Was the site secured? ❑ Yes ❑ No
If Yes, how?
Have there been previous problems with vandalism at the SSO location?
If Yes, explain:
What security measures have been put in place to prevent similar ❑ Yes ❑ No
occurrences in the future?
Comments:
❑NA
❑NA
❑ NE
❑ NE
Form CS-SSO Page 10

Other pictures and police report, as applicable, must be available upon request.)
Describe:
Were adequate equipment and resources available to fix the problem?
If Yes, explain:
If the problem could not be immediately repaired, what actions
were taken to lessen the impact of the SSO?
Comments:
❑ Yes ❑ No ❑NA
❑ Yes ❑ No ❑NA
❑ NE
❑ NE
Form CS-SSO Page 12

System Visitation
ORC
Backup
Name: George Kepic
Certification Number: 995866
Date visited: 10-19-2022
Time visited: 12:20pm
How was the SSO remediated (i.le. Stopped and cleaned up)?
❑ Yes
® Yes
Lift Station was turned off and we colsed the force main valve. set up a bypass pump, bypassing the broken
section of force main and opened the bypass valve a head of the brake and pumped the lift station wet well
while the contractor made the repair. City Crews traced how far the sanitary sewer went and set out a pump
and pued the sewer back into the Collection system while we flushed the tributary.
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: Kenny Willard Date: 11-8-2022
Signat Title.., —
Telephone Number: 9/4)_ S&
Any additional information desired to be submitted should be sent to the appropriate Division Regional Office within five
business days of first knowledge of the SSO with reference to the incident number (the incident number is only generated
when electronic entry of this form is completed, if used).
Form CS-SSO Page 14

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