WQCS00005_NOV-2022-DV-0231 Rsp_20230109

WATER MANAGEMENT
CITY OF DURHAM
September 22, 2022 NC Y}ept of Lnviconmenta1 Q�`'���,
Mr.Scott Vinson, Regional Supervisor
NCDEQ, Division of Water Resources
Water Quality Regional Operations Section
Raleigh Regional Office Ralcigh Regloi
3800 Barrett Drive
Raleigh, NC 27609
Subject: NOV-2022-DV-0231 Permit No. WQCS00005
Dated:August 17, 2022; Received: September 1, 2022
City of Durham Collection System, Durham County
Dear Mr. Vinson,
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) that occurred in the City's sewer collection system between July 1,
2022 and July 31, 2022.
For the purposes of supporting the City's position that these events were 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#202201179—1321 New Castle Rd—July 25, 2022
On July 25, 2022 at 12:17 PM, an overflow occurred near 1321 New Castle Rd releasing an estimated 290 gallons of
wastewater into Warren Creek,a tributary of the Eno River. Crews discovered that grease was the cause of the
blockage and used a JetVac truck to successfully clear the line. After assessing the extent of the spill,crews
dammed the downstream creek with sandbags, set up a 4-inch pump to pump the untreated wastewater back into
the collection system, and flushed the area using a nearby hydrant(dechlorinated water). Crews then used a
JetVac truck to clean the three upstream and three downstream pipe reaches to ensure the pipes were clear.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the spill's
extent and advise when the site returned to normal conditions.There were no observed hazards to persons,
property,or the environment.
The department's Industrial Waste Control/FOG program staff distributed notices to the neighborhood to inform
and educate the residents on the effects of grease in the collection system and the appropriate disposal options.
WSM crews have scheduled additional follow up cleaning activities for the three upstream and three downstream
pipe reaches at the incident location to ensure the pipes remain clear. The department issued a news release
thin a 24-hour window.The cost to remediate this spill was$5,962.84.

Page 2 of 3
Ongoing Citv-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
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 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 at least 2 to 5%each
year. The City measures the cleaning on a fiscal year basis starting July 1. As of July 31, 2022, 0.66% of the
City's collection system has 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 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 to focus on oversight and
maintenance of the 63 lift stations throughout the service area and the 136 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 to increase awareness of the proper disposal methods for waste and the impact on the wastewater
system. FOG staff also conducts past-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 these incidents, the City believes that these
SSOs were exceptional, unintentional,temporary,and caused by factors beyond the City and Department's
reasonable 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 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(919)560-4381 or via email at
[e-mail].
Sincerely,
Donald F. Greeley, Director, PE,
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.

v[' Dept of Environment-at Quality State of North Carolina
Department of Environment and Natural Resources
DWR CEP 2 2 2 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: WOCS00005 (WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System _ _ Incident#: 202201179
Owner: City of Durham -
City: Durham County: Durham Region: Raleigh
Source of SSO (check applicable): 2 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): 1321 Newcastle Rd, Durham, NC 27704
Manhole#: 2308
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 07/25/2022 Time: 12:17 pm Incident End Dt: 07/25/2022 Time: 01:15 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 290 gallons Estimated Duration (Round to nearest hour): 0:58 hours
Describe how the volume was determined: 5GPM X 58Mins
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 290
surface water name: Eno River
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:
R Grease
24 hour verbal notification (name of person contacted ): Cassidy Kurtz
[� DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 07/25/2022 Time (hh:mm AM/PM): 02:00:00 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 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 1
(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
Grease
When was the last time this specific line (or wet well) was cleaned?
07/25/2022
Do you have an enforceable grease ordinance that requires new or retrofit of grease W Yes ❑ No ❑ NA [] NE
traps/interceptors?
Have there been recent inspections and/or enforcement actions taken on nearby [j Yes WJ No ❑ NA NE
restaurants or other nonresidential grease contributors?
Explain.
Crews will be Perform Cleaning and CCTV work on all assets in area to identify where the grease issue is originating. Or
located we will send information to our F.O.G. Coordinator to pass out literature to residents in area.
Have there been other SSOs or blockages in this area that were also caused by Yes W No ❑ NA [] NE
grease?
When?
N/A
If yes, describe them:
N/A
Have cleaning and inspections ever been increased at this location? W Yes [ No [I NA [ NE
Explain.
They have currently been increased because of overflow. We will out these assets on a hots of monitoring program to
ensure no further issues.
Have educational materials about grease been distributed in the past? Yes W No ❑ NA NE
When?
NA
and to whom?
NA
Explain?
The Director of the F.O.G. program sends Educational material through the mail to various locations. Once we find the
exact location of the issue he will make a in person visit passing out education material. After we will monitor area to mal,
sure issue is being resolved.
If the SSO occurred at a pump station, when was the wet well and pumps last
checked for grease accumulation?
NA
CS-SSO Form Page: 2

Were the floats clean? Yes D No 71 NA [] NE
Comments:
Crews will be cleaning assets in the trouble area and CCTV all tagged assets. Once findings have been recorded we will
send information to Tyrone Battle the director of our grease remediation program. He will then conduct_a investigation an
pass out Educational material to each party associated with issue.
System Visitation
ORC Yes
Backup Yes
Name:
Kerry Sanford
Cert#
992773
Date visited:
07/25/2022
Time visited:
01:30 pm
How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews arrived onsite at 12:17nm and noticed Manhole 23808 overflowing at a rate of 5gpm. Crews proceeded to find the
manhole 23693 and flushed to upstream 23808 and removed blockage of heavy grease. After remediated we had truck V
1 inch hose follow up and clean as well to ensure complete removal of grease. Crews also set up sandbags downstream
a unnamed tributary to ensure no wastewater made it past. Crews set up pump 82946 and pumped all untreated_
wastewater into sewer manhole 23695. Crews used defuser on hydrant to help push all the untreated wastewater to the
pump for removal. Local storm water quality was called to test creek for ammonia on 7/26/22 and came back Zero
ammonia. Crews will clean 3 assets above and 3 assets below spill manhole. We will also set these assets on a hots of
program to be monitored until grease issue is resolved. After CCTV all information will be sent to the Director of our fats
oils and grease program for investigation. Crews washed down small area of spill and removed all tainted soil.
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: 07/26/22 01:12 pm
Signature: Title: _7-
Telephone Number:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of Il
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

From: Lunne, Joe
Sent: Tuesday,July 26, 2022 9:39 AM
Subject:SSO at 1321 New Castle Road A
News Media Conta,
Joe Lunne, SR Public Information &Communicatic
Analy
COMMUNICATIONS
Water Management Dep
919.560.4381 ext. 35255 919.397.6131 mobil,
CITY OF DURHAM ................. �o�_�unne= o rnamivc.&o%
News Release
For Immediate Release- July 26 2022
City of Durham contains sewer spill at 1321 New Castle Road A
DURHAM, N.C. —The City of Durham Department of Water Management reports that on July 25, 2022 staff responded to
a manhole overflowing at 1321 New Castle Road A. Approximately 290 gallons of untreated wastewater flowed into
.rren Creek. The cause of the overflow was due to a grease build-up blocking the sewer main.
itaff were notified of the overflow at 12:17 p.m. on July 25, and the blockage was stopped at 1:15 p.m. Crews dammed
:he creek downstream and pumped the untreated wastewater back into the sewer system. There were no observed
iazards to persons, property, or the environment.
4s a reminder, only water, human waste, and toilet paper are permitted to be discharged into the sewer system.All
ether materials— fats, oils, and greases (FOGS) and nonwoven materials (so called flushable wipes and rags)that should
iot be allowed into the sink—contribute to sanitary sewer overflows. To learn more about the way FOGS and nonwovens
-log pipes and how to properly dispose of them, visit our Industrial Waste Control, Pretreatment, and Grease Reduction
3rogram at www.durhamnc.gov/1077.
the N.C. Department of Environmental Quality Division of Water Resources was notified of the event on July 25, as
•equired by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water&Sewer
Maintenance.
#44

ZLOLDbT�rvO
wbvr
►wM a.
rs..vn
...•D�4•.. ...•M" • 1h —4 f •...
l °
LLZO-A0-ZZOZ•AON:'ON BUP)MAI v e`,,t o''. w���w .€ ��,,,'///��r�JJ, L Y/r• lII T, w�—�
fZOZ Jeap IeJsLA
Alnf-Japenp isL
-oll—I IIIdS j—eS algeyodaa 0.."
D l
WQAV
T f 1f B�Ut UElJI�MI RlUnO'J e ♦ _ — �l
±� +._� o .+•n•..D t fit' f .rr �s✓i --- �' ,�-... � J• y�i � 'r��. 1
5 Afir
�
f 1 e�' ~� � �1 `"� {y� l�-Y1 �� 1 �-�•1�, •l � 11 l I ,1 'ljf/�� ��
r � �� �rl�ya1rY.,'t�� � `�-(!� • •�• - •J -__ °�� __ // .wow
• T C 7� -'1i � -� � 1t� ^ t NS >
t, • L �f
w� Ati � .. _ '•`^' �� wok ap • — ,_: �� —ry.
r- r
� « � ,..._., _ :!� _ _ v — — A.� �r.'�t� •� ° "—mac
I
S � F
r mow;; 1 ; p f ajef •��, C' ... ,� fe4�
«.. <r_4 �" • �..J ,iw •ram .�.1 M1
wrHa no
7 O IUD
� r a
r
EZ,kj �jlo is suoilaoo-I llidS aannaS apeliodag