WQCS00005_NOV-2022-DV-0345 Rsp_20230109

WATER MANAGEMENT NC Dept of Environmental Quality
CITY OF DURHAM
JA N 112023
City of Durham
Department of Water Management Raleigh Regional Office
1100 Martin Luther King J r Parkway
Durham, NC 27707
919-S60-4344
January 9, 2023
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-0345 Permit No. WQCS0000S
Dated: December 8, 2022; Received: December 21, 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 forth sanitary sewer overflow(SSO)which occurred in the City's sew ercoIlection system between
November 1, 2022 and November 30, 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
permitare met by the Department,includingsystem cleaning,site visits, inspections, and easement maintenance.
Incident#202201738 - 1447 E INC Highway 54— November 25,2022 10:35 AM
On November 2S, 2022 at 10:35 AM, an overflow occurred near 1447 East NC Highway 54 releasing an estimated
610 gallons of wastewater into Northeast Creek.Crews discovered that gravel and rags in the line caused the
blockage.Crews used a Jet Vac truck to clear the line successfully. After assessing the extent of the spill, crews
dammed the downstream creek with sandbags,set up a 4-inch pump to pump the untreated wastewaterback 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.
Staff promptly reported the spill to the City's StormwaterServices Division. However,due to Storm Water Division
staffing shortages,Water Management staff conducted ammonia testing to help determine the spill's initial extent
Water Management staff retested at various points during the flushing process to determine when the site
returned to normal conditions. No immediately visible adverse environmental impacts or hazards to persons or
property were observed.

Page 2 of 3
The department's Industrial Waste Control staff responded to this event with an approximate 173 mailings to
customers in the vicinity.Staff also provided approximately 400 information cards for the nearby apartment
complex to distribute to future tenants.
A news release was issued within a 24-hour window.The cost to remediate this spill was$7,931,97.
Ongoing City-Wide Measures to Reduce the Occurrence of SSOs
The City has several programs in place to preventand 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 November 30, 2022, 2.5%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(2S 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 63lift
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 Wealth 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 forwaste.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 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(919) 560-4381 or via email at
[e-mail].
Sincerely,
Donald F. Greeley, Director, PE, PL5
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
IAN ] ?0?3 Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
ART I:
Raleigh Regional Office
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#: 202201738
Owner: City of Durham
City: Durham County: Durham Region: Raleigh
Source of SSO (check applicable): 0 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): 1447 E NC Highway 54, Durham, NC, 27713
Manhole#: 53222
Latitude (Decimal Degrees): Longitude(Decimal Degrees):
Incident Started Dt: 11/25/2022 Time: 10:35 am Incident End Dt: 11/25/2022 Time: 11:36 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 610 gallons Estimated Duration (Round to nearest hour): 1:1 hours
Describe how the volume was determined: 10gpm x 61 minutes =610gallons
Weather conditions during the SSO event:
Did SSO reach surface waters? 2 Yes ❑ No [] Unknown Volume reaching surface waters (gals): 610
urface water name: Northeast Creek
Did the SSO result in a fish kill? ❑ Yes oNo ❑ Unknown If Yes,what is the estimated number of fish killed?
SPECIFIC cause(s)of the SSO:
[1 Debris in line
24 hour verbal notification (name of person contacted ): Jerry Belcher
❑ DWR 2 Emergency Mgmt Date (mm-dd-yyy): 11/25/2022 Time (hh:mm AM/PM): 08:03:00 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

How was the SSO remediated (i.e. Stopped and cleaned up)?
On November 25, 2022,staff responded to a manhole overflowing at 1447 NC-54 Highway. Approximately 610 gallons of
untreated wastewater flowed into Northeast Creek. The cause of the overflow was debris (gravel and rags) in the sewer li
Staff was notified of the overflow at 10:35 a.m. on November 25 and the spill was stopped at 11:36 a.m. Our quick-res o
truck was used to stop the manhole from spillinq over.The Crew used a combination truck to vacuum up the grayel and
rags. Crews dammed the creek downstream, pumped the untreated wastewater back into the sewer system, and flushed
the creek.
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: Terrance Vasquez Date: 11/30/22 01:06 pm
Signature: Title: Jt AK2Z2f-
Telephone Number:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of t
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

NC Dept of Environmental Quality
From: Lunne,Joe
Sent:Saturday, November 26, 2022 9:04 AM JAN 1 1 2023
Subject: SSO at 1447 NC-54 Highway
Raleigh Regional Office
News Media Contaf
Joe Lunne, SR Public Information &Communicatio
Analy
COMMUNICATIONS
Water Management Dep
919.560,4381 ext. 35255 919.397.6131 mobilt
CITY OF DURHAM Joe.Lunne(@DurhamNC.&q%
ews Release
For Immediate Release: November 26, 2022
City of Durham contains sewer spill at 1447 NC-54 Highway
1URHAM, N.C. —The City of Durham Department of Water Management reports that on November 25, 2022 staff
?--onded to a manhole overflowing at 1447 NC-54 Highway. Approximately 610 gallons of untreated wastewater
A into Northeast Creek. The cause of the overflow was debris and rags in the sewer line.
taff were notified of the overflow at 10:35 a.m. on November 25, and the spill was stopped at 11:36 a.m. Crews
ammed the creek downstream, pumped the untreated wastewater back into the sewer system, and flushed the creek.
here were no observed hazards to persons, property, or the environment.
.s a reminder, only water, human waste, and toilet paper are permitted to be discharged into the sewer system. All
ther materials—nonwoven materials (so called flushable wipes and rags) and fats, oils, and greases (FOGS)that should
of be disposed of in the sink or toilet—contribute to sanitary sewer overflows. To learn more about the way FOGs and
onwovens clog pipes and how to properly dispose of them, visit our Industrial Waste Control, Pretreatment, and Grease
eduction Program at www.durhamnc.gov/1077.
he N.C. Department of Environmental Quality Division of Water Resources was notified of the event on November 25,
s required by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water&Sewer
laintenance.
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