WQCS00013_NOV-2023-DV-0130_Resp Rvcd_20230330

Manuel, Vanessa
From:
Donald Smith <[e-mail]>
Sent:
Thursday, March 30, 2023 5:42 PM
To:
Vinson, Scott; Manuel, Vanessa
Cc:
Jamie Revels; Paul Campbell; Matthew Flynn; Jimmy Simpson
Subject:
[External] Town of Cary SSO (NOV-2023-DV-0130) Response Letter
Attachments:
NCDEQ NOV-2023-DV-0130 Response Letter 3-30-23.pdf
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Mr. Vinson,
Please find attached an electronic submittal/copy of Cary's response to a NCDEQ notice of violation (NOV)
letter that was dated March 13, 2023 and received on March 23, 2023. The NOV letter was for a sanitary
sewer overflows (SSO) that occurred in February, 2023. A written hard copy of our response for the NOV was
sent by certified mail today to your attention. We very much appreciate the opportunity to respond and
provide additional information on the SSO.
Please feel free to contact me if there are any questions.
Thank you,
Donald
Donald Smith
Wastewater Collection System Manager
Cary
Utilities Department
PO Box 8005 1 Cary, NC 27512-8005
40OJamesJockson Avenue I Cary, NC27513-8005
phone: [phone] fax: [phone]
Email: [e-mail]

C A RY
I %
LIVE INSPIRED"
March 30, 2023
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Subject: Notice of Violation (NOV-2023-DV-01 30)
Dear Mr. Vinson:
00C-s oo 0 /-3
CERTIFIED MAIL
On March 23, 2023 the Town of Cary Utilities Department received a Notice of Violation
(NOV) letter dated March 13, 2023 from the North Carolina Department of Environmental
Quality, Division of Water Resources — Raleigh Regional Office for two sanitary sewer
overflows (SSO) that occurred on February 1 and February 11, 2023. The NOV letter
identifies the February 11 SSO as an NOV and requests written response from Cary to
provide additional information within 15 business days from receipt of the letter. The written
submittal will be considered by NCDEQ and used to determine if a civil penalty will be
assessed.
Incident# Start Date Duration
(min)
202300263 2/11/2023 94 82
Av
202300197 2/01/2 37 10
Location
Cause
Total
Total Volume
DWR
Volume
Surface
Action
(Gal)
Water
9 Madison
Grease/Roots
280
280
Notice of
enue, Ca
,Tue �L;
Violation
50
Notice of
2 Chamnes
Roots
200
Dr, Gary I
Dekiency__
Cary takes pride in the operation and management of our 1,000 miles of wastewater collection
system. We are an award winning and progressive wastewater utility that has very few
reportable or large volume SSO. We place emphasis on responding quickly to sewer
emergencies to prevent and minimize any spills that impact our citizens, community, and
environment. We appreciate the opportunity to provide information on the recent sewer
overflows, our efforts, and justification for why additional enforcement action or civil penalty
should not be assessed to the Town of Cary.
INCIDENT # 20230026 — 829 Madison Avenue
Sewer Overflow Cause - On February 11, 2023, town staff received a phone call from a
citizen reporting water coming from a manhole at approximately 9:45 AM. Cary wastewater
collection system staff immediately responded to investigate the call. Staff observed an
919.469.4000 1 carync.gov
PO Box 8005 Cary, NC 27512

overflowing manhole (SP75416044). Sewer was slowly exiting the manhole from a single
three-quarter inch vent hole and the wastewater accumulated and ponded around the
manhole with flow from the area entering into Coles Branch. The Sewer Spill Estimation
Guide provided on the NCDEQ website along with site conditions was used to estimate the
total sewer spilled and volume that was ponded and reached the stream. Cary staff used a
hydraulic sewer jetting machine to clear the blockage and stop the sewer overflow at 11:19
AM. While clearing the blockage, roots were noted entering where the 8-inch sewer line
connects with the manhole. Grease was adhered to the root within the manhole. Staff
removed the root and grease blocking the sewer line which stopped the sewer spill. The
manhole and sewer lines downstream of where the spill occurred are included in a chemical
root treatment program. The manhole that had the root and grease blockage is the starting
manhole for the root treatment program in that area. An inaccurate entry is noted on the 5-
day Collection System Sanitary Sewer Overflow Reporting Form (Form CS-SSO) and in the
BIMS Portal Report, the entirety of the sewer spill (280 gallons) did not reach Coles Branch.
An estimated 50 gallons reached surface waters based on the volume of wastewater that
accumulated in a low-lying area around the sewer manhole. We apologize for the original
inaccurate data entry in the 5-day report.
Sewer Spill Cleanup — After stopping the sewer spill, Cary staff immediately began the sewer
spill cleanup. Standing or ponded water around the manhole was pumped back into the
sewer system for disposal and treatment. Powdered lime was applied to the ground where
the spill occurred to help treat the soil. The creek was flushed with 15,000 gallons of
dechlorinated potable water. Little evidence of sewer was noted in the creek, conductivity
readings upstream of the spill were very close to conductivity downstream of the spill (Table
1.) and did not warrant constructing a dam and pumping the creek and flush water out.
Sewer Spill Assessment - The Town performed conductivity readings following the overflow
and during the spill cleanup to assess the spill. The following table provides a summary of
the data collected at the time of the SSO and with sewer spill cleanup. No fish kill or visible
impacts were identified following the spill cleanup.
C
Date/Time =>
Location
SSO entry point to creek
50' Upstream in creek
50' Downstream in creek
100' Downstream in creek
200'Downstream in creek
Table 1
260
:i6O
Corrective Actions — After clearing the blockage, the area sewer lines were hydraulicly
cleaned, video inspected and acoustically assessed to ensure there were no additional
accumulations or partial sewer line blockages. Roots were removed by staff and monitored
to ensure the root intrusion is permanently fixed and will not create another blockage
condition.
cAny

INCIDENT # 202300197 — 102 Chamness Drive
Sewer Overflow Cause - On February 1, 2023 Cary staff received a call of an overflowing
manhole (SP76518071) and responded immediately to the site at 11:03 AM. The Sewer spill
was stopped at 11:40 AM with Cary staff using a hydraulic sewerjetting machine to clear the
blockage that was found in the sewer main caused by roots inside the manhole.
Sewer Spill Cleanup — After stopping the sewer spill, Cary staff immediately began cleaning
up the spill. Debris was collected from around the manhole and powdered lime was applied
to the ground to treat the soil. A small trickle of wastewater did enter the creek that was
already flowing at elevated levels from the previous day's rainfall event. Beyond what was
observed flowing into the creek, there was little to no evidence of sewer in the creek due to
high creek stormwater flow condition.
Corrective Actions — After clearing the blockage the area sewer lines were hydraulicly
cleaned and video inspected to ensure there were no additional accumulations or partial
sewer line blockages. The roots were removed, and a contractor was hired to repair and apply
a cementitious coating inside the manhole to repair and prevent future water and root
intrusion.
We appreciate the opportunity in being able to provide information on both unfortunate sewer
spills. These two instances are the only sewer spills that have occurred from those manholes.
We appreciate NC DEQ's consideration in evaluating these sewer spills, the cause, and
Cary's record and response to remediate and help ensure that a SSO reoccurrence does not
reoccur at these locations. If we can answer any questions or provide any additional
information, please feel free to contact Mr. Donald Smith, Wastewater Collection System
Manager at [phone].
Sincerely,
4a ie Revels , :?rQ=
��eN
Utilities Director
Cc: Donald Smith, Wastewater Collection System Manager
Paul Campbell, Wastewater Collection System Operator
Attachments:
• NCDEQ Notice of Violation to issue Civil Penalty — NOV-2023-DV-01 30
• Collection System Sanitary Sewer Overflow Reporting Form — Incident #
202300263
• Collection System Sanitary Sewer Overflow Reporting Form — Incident #
202300197
CAPY

*Cc'ILre,L zt oPsA
3 - 2 3 -202-S
ROY COOPER
G�or
ELIZABETH S. BISEP
seattary
RICHARD E. ROGERS, JR.
birater
Certified Mail # 7Q20 31fig 0000 4115 6334
Return Receipt Reguested
Jamie Revels, Director Utilities
Town of Cary
PO Box 8005
Cary, NC 27512-8005
SiMt "l,
NORTH CAROLINA
March 13, 2023
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2023-DV-0130
Sanitary Sewer Overflows - February 2023
Collection System Permit No. WQCS00013
Cary Collection System
Wake County
Dear Mr. Revels:
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by Town of Cary 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 fbr 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:
Total Vol
Total
Surface
Incident
Start
Duration
Vol
Water
Number
Date
(Mins)
Location Cause
(Gals)
(Gals) DWRAction
202300263
2/11/2023
94
829 Madison Ave, Grease, Roots
2BO
280 Notice of Violation
Cary, NC, 27513
202300197
2/01/2023
37
102 Chamness or, Roots
200
50 Notice of Deficiency
Cary, 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 vvithin-15-
business-dqys following receipt of this violation. Please include any additional documentation about this Incident(s)
N9191,4200

in the response. The submittal will be considered in determining whether the Division will assess a civil penalty for
the cited violations,
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 Sect -ion
Raleigh Regional Office
Division of Water Resources, NCDEQ
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State of North Carolina
Department of Environment and Natural Resources
DWR Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
PART 1:
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: WQCS00013 (WQCS# if active, otherwise use WQCSD#)
Facility: Cary Collection System Incident #: 202300263
owner: Town of Cary
City: Cary County: Wake 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): 829 Madison Ave, Cary, NC, 27513
Manhole #: MANHOLE #SP75416044
Latitude (Decimal Degrees)
Incident Started Dt: 02111/2023
(mm-dd-yyyy)
Estimated Volume of the SSO: 280
17,19
Describe how the volume was determined:
Weather conditions during the SSO event:
-- Longitude (Decimal Degrees);
9:45 am Incident End Ot: 02/1112023 Time: 11:19 am
(hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AMIPM)
— gallons Estimated Duration (Round to nearest hour): 1 34 hours
Area of spill at site and creek conductivity testing
Clear
Did SSO reach surface waters? R1 Yes [] No Unknown Volume reaching surface waters (gals): 280
Surface water name: Coles Branch
Did the SSO result in a fish kill? E] Yes R[No E] Unknown If Yes, what Is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
0 Grease 0 Roots
24 hour verbal notification (name of person contacted ): Todd Green
E] DWR R1 Emergency Mgmt Date (mm-dd-yyy): 0211112023 Time (hh:mm AM10M) 04:46:00 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. 1 C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a oress releas 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 _Qivis�Qq_qfWaIci Rem! s ..may take enforcement action for SSOs that are required to be reported to
Lqe�
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 11 must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART IIIIS-C THE END OF THIS FORM
CS-SSO Form Page: I

PART fl:
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 THECAUSE OF THE SSO AS CHECKED IN PART 1,,
-- (in the check boxes below, NA = Not-A-pplicable 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?
11/2812011
Do you have an enforceable grease ordinance that requires new or retrofit of grease JZ Yes [] No [:] NA [] NE
trapslinterceptors?
Have there been recent inspections and/or enforcement actions taken on nearby
restaurants or other nonresidential grease contributors?
Explain.
Residential noighborhood, o restaurant contributions
Have there been other SSOs or blockages in this area that were also caused by
grease?
When?
If yes, describe them:
Have cleaning and inspections ever been increased at this location?
Explain.
Have educational materials about grease been distributed in the past?
When?
and to whom?
Ej Yes [Z No El NA D NE
E] Yes [0 No 0 NA [] NE
El Yes W No [] NA C NE
El Yes F No [7] NA E] NE
Explain?
No qtea�t 1��s U Cjlry'S JtW4k)h 0o gICHSC disf�g.—ell
Ag �n �iist no educattonai materfals distj tio led 1) o s
jj�J�h� ft(_
If the SSO occurred at a pump station, when was the wet well and pumps last
checked for grease accumulation?
Were the floats clean?
E] Yes [:] No [0 NA E] NE
GS-SSO Form Page: 2

Comments:
Blockage occurred in a manhole, due y) rotAts m I No Jump atjq11% wepe Involved.
as(
Roots
Do you have an active root control program on the line / area in question? 10 Yes E] No [-] NA [:] NE
Describe
We have rocit-pontrol avolication and treatment on the scwct line negrient itist downstream of the block,19P Roots
guntered it jLar�le-
Have cleaning and inspections ever been increased at this location because at roots' [Z Yes [71 No D NA F] NE
Explain:
Inckided area fur root contiol "i tim paw due to viirww� day �lw and po(ontial for nuot intrusion.
What corrective actions have been accomplished at the SSO location (and
surrounding system if assoclated with the SSC)?
R ved roots wid blocks
_gc, from manhole Lines v o i .f?pg1%jLo.q!)§u aqOL:fw�i: Nonka u,nownlial I;(:wcr 1111(
Lis; rylL
ir.
What corrective actions are planned at the SSO location to reduce root intrusion?
Gonlintie with' area root control treatinent and re�dcvelo[jrnent
Has the line been smoke tested or videoed within the past year? 10 Yes E] No 0 NA [] NE
If Yes, when?
8/1612022
Comments:
Manhole was visually inspected willi no inimediate issues Lim, and manholes were also �iLc=suc tested on Mai-ch 3, 202
with no immediate issues identified.
Systern Visitation
ORC
Backup
Name:
JLJ in
� At- -1z '1111el
Cert#
1007085
Date visited:
2/11/2023
Time visited:
10:45 AM
CS-SSO Form
[3 Yes
W Yes
Page: 3

How was the SSO remediated (i.e. Stopped and cleaned up)?
Bluckagv,noots, grease were removed frorn the inanhole and the syqIern Up urnpal-tonorrnalop atign. leanup c urfq(
gL_ tl cu_ _
aninedialely,deqns was collected and ­powdered lime applied to treat affected soil. 15.000 gallons of decillprinaled water
was used to lightly flush the creek, Conductivity readinas at soill stle before creek 11LIShinil wqre low with little or no viiibit
ajg��an obseived smalf the Unnamed tobutary. Conductivay eLia --
yfitiqs up r�nj By
AL rj1-Q[-sjm!Iw
Mid after fi,'Ji kill observed.
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: Donald Bradley Smith Date: 02115/23 02:30 pm
Signature.
Telephone Number: 9 V) - 4LA - 4LA
Title: L�U U t;,, '),10 " '4(�-'k
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of I
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: 4

State of North Carolina
Department of Environment and Natural Resources
DWR Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
ii-ART 1:
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).
PermitNumber: WQCS00013 (WQCS# if active, otherwise use WQCSD#)
Facility: Cary Collection System Incident #: 202300197
Owner: Town of Cary
City: Cary County: Wake Region: Raleigh
Source of SSO (check applicable): 0 SanitarySewer 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): 102 Chamness Drive
Manhole #: SP76518071
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 02/01/2023 Time: 11:03 am Incident End Dt: 02/01/2023 Time: 11:40 am
(mm-dd-yyyy) (hh:mmAM/PM) —(F­m—dd­-y­yy­yT (hh:mm AM/PM)
Estimated Volume of the SSO: .200 gallons Estimated Duration (Round to nearest hour): 0:37 hours
Describe how the volume was determined: Area of spill at site and creek conductivity testing
Weather conditions during the SSO event: Clear
- " SSO reach surface waters? 0 Yes E] No E] Unknown Volume reaching surface waters (gals): CIO
,�urface water name: Black Creek
Did the SSO result in a fish kill? E] Yes PJNo M Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
0 Roots
24 hour verbal notification (name of person contacted ): James Westcott
V DWR E] Emergency Mgmt Date (mm-dd-yyy): 02/01/2023 _ Time (hh:mm AM/PM) 02:56:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO Gan be stopped.
Per G.S. 143-215.1 C(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 11 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 I
(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
Roots
Do you have an active root control program on the line / area in question? E]Yes RNo DNA E]NE
Describe
Roots entered where the ductile iron pipe penetrates the manhole.
Have cleaning and inspections ever been increased at this location because of roots' D Yes [0 No D NA E] NE
Explain:
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
The roots and blockaoe was removed from the manhole
What corrective actions are planned at the SSO location to reduce root intrusion?
Monitor manhole for future root intrusion.
Has the line been smoke tested or videoed within the past year?
If Yes, when?
8/3/2022
Comments:
Interior of manhole was visually inspected No blockage or backup identified.
System Visitation
ORC
Backup
Name:
Chad Lemke
Carl#
1000563
Date visited:
2/1/2023
Time visited:
11:43 AM
[0 Yes D No [71 NA E] NE
R Yes
W Yes
CS-SSO Form page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Roots and blockage was removed. Debris was collected from the (Iround surrounding the manhole and powdered lime wE
applied and raked in to treat the soil, Creek was flowing steady (Joe to previous rainfall. No evidence of $pill in rreek that
required remediation and no fish kill was observed,
r.- 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: Donald Bradley Smith Date: 02/06/23 02:30
Signature:
Telephone Number: q (9 - q(,A
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of I
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