WQCS00110_NOV-2023-DV-0068_Response Rvcd_20230228

MAYOR
Jody L. McLeod
MAYOR PRO TEM
Jason Thompson
TOWN MANAGER
Richard D. Cappola, Jr.
TOWN ATTORNEY
Cauley Pridgen, P.A.
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
3800 Barrett Drive
Raleigh, NC 27609
SUBJECT: Notice of Violation NOV-2023-DV-0068
Town of Clayton Collection System Permit Number
Dear Mr. Vinson:
The following information is provided in response to your letter of February 10,
2023, related to the Town of Clayton's actions to correct, and prevent future SS
Incident Number 202300059
Upon investigation, it was determined this SSO was caused by roots a
spill occurred 11 minutes after it was reported. Town staff was able to mobilize
lane of traffic and stop the spill in a total time of 28 minutes. Once the spill
efforts, captured the released untreated wastewater and returned it back to the cc
Town staff proceeded to flush 2000 gallons of fresh potable water into the
downstream to remove any potential contamination in the storm drainage sys
video inspection of the line was completed and revealed no major root intrusion
line has since been added to our weekly inspections of trouble spots. The Tc
easements at the same time as the high priority line inspections, every 3 moi
requirement by our permit. The line segment has also since been added to th
monthly and cleaned every 6 months. This line was previously treated for roots
6, 2022, and is scheduled to be retreated in the first quarter of 2025.
Town staff are committed to improving its aging infrastructure and pre
more regular inspections, consistently cleaning more than the required 100
completing multi -million -dollar CIP projects on major trunk lines, and by
maintenance approach with our CCTV program, which has consistently videoed
in the last few years.
The Town understands and accepts all permit conditions associated t
system and strives to maintain open, cooperative communications with the
occurrence of any overflow is unfortunate, and our goal is to eliminate them. T]
capital improvement plans, combined with our personnel and equipment resoun
us to minimize environmental impacts through a timely response on the occasic
if any additional information is required at this time. Thank you for the attentic
Sincerely,/
l `"
es Blalock
Water Resources Maintenance Superintendent
Enclosures
think
PO Box 879 • Clayton, NC 27528 •919-553-5002 Ctw «m ^ Fax
COUNCIL MEMBERS
Andria Archer
Porter Casey
Avery Everett
Michael Sims
NC Dept of Environmental Quality
FEB 2 S 2023
Raleigh Regional Office
10
was received February 21,
I debris in the line. Response to the
install raffic control to shut down a
is stop ed, staff continued cleaning
ection system for proper treatment.
Ffected storm drain and captured it
in. Fo Howing the spill response, a
i the 19 0's era terra cotta line. This
rn c tly inspects all its lines in
hs, wh ch exceeds the twice a year
trouble spots list, which is checked
y Duk 's Root Control, Inc. on June
sting I
iarm to the environment with
t year
of its gravity sewer lines,
ing de
preventive and predictive
least
0% of existing infrastructure
h our
perations of a public sewer
vision
of Water Resources. The
Town
believes that operational and
supptv
this goal. They also allow
of anerflow.
Please contact me
to our response.
19 • ClaytonNC.org • Page 1 of 2

Cc: Rich Cappola, PE, MPA, CFM, Town Manager
Collection System File
Think
PO Box 879 • Clayton, NC 27528 •919-553-5002 vYT ' Fax [phone] • ClaytonNC.org • Page 2 of 2

ROY COOPER
G"emor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Dlre or
Certified Mail # 7020 3160 0000 4115 5887
Return Receipt Requested
Rich Cappola, Town Manager
Town of Clayton
PO Box 879
Clayton, NC 27528-0879
NORTH CAROLINA
Environmental Quality
February 10, 2023
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2023-DV-0068
Sanitary Sewer Overflows - January 2023
Collection System Permit No. WQCS00110
Clayton Collection System
Johnston County
Dear Mr. Cappola:
NC Dept of Environmental Quality
FEB 2 8
Raleigh Regional Office
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by Town of Clayton indicates violations
of permit conditions stipulated in the subject permit and North Carolina G.S. 143-215.1. Violations include failing to
effectively manage, maintain, and operate the subject collection system so that there is no SSO to the land or
surface waters and making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a
permit is required.
Specific incident(s) cited in the subject report include the following:
Incident Start Duration
Number Date (Mins) Location Cause
Total Vol
Total
Surface
Vol
Water
(Gals)
(Gals) DWR Action
202300059 1/11/2023 29 Township of Clayton, Debris in line, Roots 600 600 Notice of Violation
NC,
Remedial actions, if not already implemented, should be taken to correct the above noncompliance. Please submit
a written response to this Notice of Violation. Your response is to be received by the regional office within 15
business days following receipt of this violation. Please include any additional documentation about this incident(s)
in the response. The submittal will be considered in determining whether the Division will assess a civil penalty for
the cited violations.
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If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Laserfiche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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NC Dept of Environmental Quality
DWR
Division of Water Resources
PART I:
FEN28/
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Raleigh Regional Offi0cCollection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
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: WQCS00110
Facility: Clayton Collection
Owner: Town of Clayton
City: Clayton
Source of SSO (check applicable):
(WQCS# if active, otherwise use WQCSD#)
County: Johnston Region:
0 Sanitary Sewer ❑ Pump Station / Lift Station
Incident #: 202300059
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): , Township of Clayton, NC,
Manhole #: 1016
Latitude (Decimal Degrees):
35.6538
Incident StartedDt: 01/11/2023 Time:
(mm-dd-yyyy)
Estimated Volume of the SSO: 600
Longitude (Decimal Degrees):-78.46497
6:49 am Incident End Dt: 01/11/7023 Time: 07:18 am
(hh:mmAM/PM) (mm-dd-yyyy) (hh:mmAM/PM)
_ gallons Estimated Duration (Round to nearest hour): 0:29 hours
Describe how the volume was determined: Est. flow out of MH multi
Weather conditions during the SSO event: Chilly and clear
Did SSO reach surface waters?
Surface water name:
time
0 Yes ❑ No ❑ Unknown Volume reaching iurface waters (gals): 600
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 Roots 0 Debris in line
24 hour verbal notification (name of person contacted ): Jane Bernard
0 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 01/11/2023 Time (hh:mm AM/PM): 08:29:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis ntil SSO can be stopped.
Per G.S. 143-215.1 C(b), the responsible party of a discharge of 1,000 or more of untreateJ 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 reauired 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 1 PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED O DESIRED
(In the check boxes below, NA = Not Applicable and NE = Not Ei aluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRUtT DWR 1EGIONAL OFFICE UNLESS IS
Roots
Do you have an active root control program on the line I area in question? 0 s ❑ No ❑ NA ❑ NE
Describe
Have cleaning and inspections ever been increased at this location because of root' ❑ Vies 2 No ❑ NA ❑ NE
Explain:
We check this line segment three times a year during high Priority line inspections.
What corrective actions have been accomplished at the $SO location (and
surrounding system if associated with the SSO)?
What corrective actions are planned at the SSO location to reduce root intrusion?
and cleaned every three months until a solution can be imolented.
Has the line been smoke tested or videoed within the past year? s 2 No ❑ NA ❑ NE
If Yes, when?
n/a
Comments:
n/a
Debris in line
What type of debris has been found in the line?
While cleaning the line to unstop it, we found small rocks and rags.
Suspected cause or source of debris.
Potential broken clay pipe to be determined by CCTV which did not reveal that.
Are manholes in the area secure and intact? 0 es ❑ No ❑ NA ❑ NE
When was the area last checked/cleaned?
Around Dec. 8 2022 during high Priority inspections. WO #49103
Have cleaning and inspections ever been increased at this location due to previous ❑ as 0 No ❑ NA NE
problems with debris?
cs-sso Form Page: 2

Explain:
Are appropriate educational materials being developed and distributed to prevent
similar occurrences?
Comments:
System Visitation
ORC
Backup
Name:
James E. Blalock
Cert#
1002021
Date visited:
01/11/2023
Time visited:
07:00 A.M.
How was the SSO remediated (i.e. Stopped and cleaned up)?
® Y+s ❑ No NA 171 NE
WA
n
As a representative for the responsible party, I certify that the information contained in this
best of my knowledge.
Person submitting claim: James Ernest Blalock
Signature:
Telephone Number:
Any addition information desired to be submitted should be sent to the appropriate DI%
knowledge of the SSO with reference to the incident number (the Incident number is c
form is completed, if used).
is true and accurate to the
Date: 1 01/11/23 08:29 am
k27ie 2ESev1Rc6S
Title:
I Office within five days of I
when electronic entry of th
CS-SSO Form
Page: 3

00
NA •!F

0
L-N
zi
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i

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Town of C/
Cityworks Work Order
Work to be Performed:
Overflow Event -
..:..t. .
Date Initiated: 1/11/2023 6:45:59 AM
Initiated By: Blalock, Jame
Projected Start Date: 1/11/2023 6:45:59 AM
Submit To: Blalock, lame
Projected Finish Date: 1/12/2023 6:45:59 AM
Date
ubmit To: 1/11/2023 6:45:59 AM
Actual Start Date: 1/11/2023 6:45:00 AM
Priority: Emergent
Actual Finish Date: 1/11/2023 9:30:27 AM
Asset-
lEntity Type
ILocation
SMANHOLE
IFIRE RESCUE DR
Instructions:
Complete Custom Field.
Comments:
By Blalock, James : 1/11/2023 12:25:48 PM
Fire Chief called and said manhole behind Fire Station 1 on Fire Rescue Dr.
the stormdrain.
By Blalock, James : 1/11/2023 12:33:48 PM
Notified at 0649
Arrived at0700
Stopped at 0718
Jetted line found roots and debris.
Flushed storm drain twice for a total of 2000 gallons of fresh water flushed
storm drain basin. No sewer actually made it to a creek, stayed in storm drt
Notified DEQ at 0829, spoke with Jane Bernard, reported 600 gallons
By Blalock, James : 2/20/2023 2:43:58 PM
Waiting on NOV/NOI if any from the State.
Labor:
and running into
in the down stream
Em to ee
Hours
Start Date
E
d Date
Blalock, James
.750000
1/11/2023 6:45:00 A
4
1/11/2023
9:30:00 AM
Norris, Stephen
.750000
1/11/2023 6:45:00 A
A
1/
1/2023 9:30:00 AM
Ilihan,Tim
2.750000
1/11/2023 6:45:00 AM
1/11/2023
9:30:00 AM
Troll, Dylan
2.750000
1/11/2023 6:45:00 AM
1/
1/2023 9:30:00 AM
Kyer, Jake
2.750000
1/11/2023 6:45:00 A
1/
1/2023 9:30:00 AM

E ui ment:
D
IDescription
Ho
rs
704
04-2020 Western Star Vactor 2100i
2.750000
79
9-2021 Ram 2500 4x4 Pickup
.7
0000
3
73 - 2019 Ford F250 4WD
.7
0000
75
75 - 2015 Ford F-250 PU Trk
2.7
0000
Cost:
Labor
Imawrials
E uilment
393.66
1$0.00
1$522.50
Custom Fields:
Custom Field Name
ustom Field Value
Location
re Rescue Dr.
Incident #
02300059
NOV #
OV-2023-DV-0068
100
Case #
MH #
016
Volume Estimated allons
Did It reach the surface?
ES
Volume Estimated Surface
00
Cause
roots/debris
Source
ollections system
Repairs
LEANED

Town of Clayton ept
f Env
ronmentaI Quality
�qi •
Cityworks Work Order
WORK ORDER ID:
I
EB8
5243
Work to be Performed:
Camera - Sewer GravityLin i
h Re
Status:
Tonal Office
nose
Date Initiated: 1/3/2023 6:00:00 AM
Initiated By: Blalock, Jame
Projected Start Date: 1/3/2023 6:00:00 AM
Submit To: Blalock, Jame
Projected Finish Date: 1/31/2023 9:00:00 AM
Date 5
ubmitTo: 2/6/2023 11:56:21 AM
Actual Start Date: 1/11/2023 1:00:55 PM
Priority: Medium
Actual Finish Date: 1 31 2023 12:00:00 PM

Use this work order as monthly camera work order. Also utilize the inspectic ns on e ich asset to score using
NASSCO system.
Labor:
Employee
Hours
Start Date
End Date
Carroll, Dylan
1.750000
1/11/2023 1:00:00 PM
1/11/2023 2:50:00 PM
Kyer, Jake
1.750000
1/11/2023 1:00:00 PM
1/11/2023 2:50:00 PM
rroll, Dylan
4.000000
1/17/2023 8:00:00 A14
1/
7/2023 12:00:00 PM
Kyer,Jake
4.000000
1/17/2023 8:00:00 A14
1/17/2023
12:00:00 PM
Carroll, Dylan
6.500000
1/19/2023 8:00:00 A14
1/19/2023
2:30:00 PM
Kyer, Jake
6.500000
1/19/2023 8:00:00 AM
1/19/2023
2:30:00 PM
Carroll, Dylan
3.000000
1/25/2023 7:15:00 A14
1/25/2023
10:15:00 AM
Satterwhite, James
3.000000
1/25/2023 7:15:00 AM
1/
5/2023 10:15:00 AM
Norris, Stephen
2.000000
1/24/2023 12:45:00 PM
1/
4/2023 2:45:00 PM
Carroll, Dylan
2.000000
1/24/2023 12:45:00
qM
1/
4/2023 2:45:00 PM
ttenahite,James
12.000000
1/24/2023 12:45:00
IM
1/
4/2023 2:45:00 PM
ID
Description
Hc
urs
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
1.
50000
721
721, 2020 Leopald Trailer with Proteus Camera
1.
0000
07
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
00000
21
721, 2020 Leopald Trailer with Proteus Camera
0000
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
00000
721
721, 2020 Leopald Trailer with Proteus Camera
00000
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
3.(00000
721
721, 2020 Leopald Trailer with Proteus Camera
3.000000
707
707 - 2021 Dodge Ram 4x4 Utility Body Service Truck
2.1
00000
21
721, 2020 Leopald Trailer with Proteus Camera
2.
00000
3
73 - 2019 Ford F250 4WD
2.
00000

Project Name: 22-0640
Treated Date$: 06/06/22 - 06/06/22
Job# 22-0640
Report Date:06/10/22
Up
Up
Up
Down
Down Down
Treated
Street
Type
Loc MH
Twe
Lon
M
Size
Feet
Guar End
06/06/22
OAKDALE AVENUE
M
F
1912
M
8
1306
8
397
06/06/25
O6/06/22
PINELAND AVENUE
M
F
1304
M
D
1305
8
353
06/06/25
O6/06/22
LAKE DRIVE
M
B
1714
M
B
2138
8
225
06/06/25
O6/06/22
DAMON STREET
M
S
1889
M
S
1888
8
137
06/06/25
O6/06/22
DAMON STREET
M
S
1888
M
S
1603
8
343
06/06/25
06/06/22
DAMON STREET
M
S
221
M
S
3443
8
158
06/06/25
06/06/22
DAMON STREET
M
S
3443
M
S
1603
8
144
06/06/25
06/06/22
POND STREET
M
E
1600
M
S
212
8
272
06/06/25
O6/06/22
POND STREET
M
S
211
M
S
212
8
301
06/06/25
O6/06/22
CARTER STREET
M
S
76
M
S
12
8
43
06/06/24
O6/06/22
CARTER STREET
M
F
12
M
B
3006
8
243
06/06/24
O6/06/22
CARTER STREET
M
B
3006
M
F
1098
10
128
06/06/24
O6/06/22
WILLOW DRIVE
M
E
1747
M
E
4232
8
42
06/06/24
O6/06/22
WILLOW DRIVE
M
E
4232
M
S
1745
8
200
06/06/24
O6/06/22
FIRE RESCUE DRI
M
S
1016
M
S
1745
8
271
06/06/25
Manhole Type Codes:
C Clean Out
H House Number
L Line Number
M Manhole Number
Manhole Location Codes:
A Alley
8 Backyard
E Easement (woods or no building)
F Front Yard
L Left Side Yard(when facing front)
R Right Side Yard(when facing front)
S Street
U Unknown
Down:
10 128
8 3,129
Total: 3,257