WQCS00065_NOI_NOV2021DV0440_Response_20211026

Ti#y of Grabam
P. O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
October 26, 2021
Certified Mail No. 7019 2970 0001 1081 4710
Lon T. Snider
NCDEQ\DWR
450 West Hanes Mill Rd., Suite #300
Winston-Salem, NC 27105
Subject: Tracking No.: NOV-2021-DV-0440
Sanitary Sewer Overflows — August 2021
City of Graham
Collection System Permit # WQCS00065
Alamance County
Dear Mr. Snider:
n, I Ou3lty
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Niy e 8 2021
Wiruta-, Salem
ReH7lona! Office
The City of Graham received a notice of violation on October 18, 2021, with an intent to
issue a civil penalty for Sanitary Sewer Overflow incident 202101812 at Boyd Creek Outfall. The City
of Graham requests that you consider the following response in your decision before taking
enforcement action.
The Sanitary Sewer Overflow event on August 22, 2021, at Boyd Creek Outfall, was
not due to any blockages or station malfunction but occurred due to an afternoon thunderstorm that
produced between 4 to 5 inches of rainfall throughout the watershed. The rain event lasted less than
2 hours but produced heavy downpours. This excessive rainfall event overflowed area creeks and
roadways. An example of the flooding was the creek running along the Waste Treatment Plant
entrance which came past the perimeter fence. During the Sanitary Sewer Overflow event, both
pumps ran continuously at the receiving lift station, at a rate of 1300 gpm, but the system became
overwhelmed by the extremely large volume of water. The Collection Crew was already onsite
responding to a high-water alarm at the lift station when the overflow occurred. Once notified, the
ORC remained on site throughout the SSO event to make sure both pumps continued to operate
properly at the station.
The City of Graham continues to be vigilant in our efforts to combat Inflow and Infiltration.
The new Boyd Creek Lift Station finally came online this past spring at a cost of over $3 million dollars.

In the past 3 years this department has purchased a new CCTV, at a cost of $96,000, that gives our
staff better quality equipment to inspect a variety of pipe sizes and a $77,000 jet machine which
replaced a 12-year-old well used machine. In addition to the recently purchased items, the City
budgeted $285,000 this year to continue our efforts for manhole rehab, pipe lining, and root control
to help mitigate I and I issues.
The City of Graham believes our collection staff is doing an outstanding job maintaining our
collection system demonstrated by the limited number of system wide SSOs. The current exception
being Boyd Creek Basin, which seems to occur less frequently and with lower volume flows.
Although our ultimate goal is to have zero Sanitary Sewer Overflows, it is almost impossible to
prevent all SSOs when the city has no control over extreme weather events. Based on our
immediate response, remedial action, equipment purchases and the recent replacement of Boyd
Creek Lift Station, it is evident that the City of Graham is committed to use the resources necessary
to maintain compliance with our permit and maintain our collection system.
Based on the information provided herein, the City of Graham requests that enforcement
action not be taken in this Sanitary Sewer Overflow incident. Thank you for your consideration in
this matter. Should you have any questions please contact myself at [e-mail] or
Ladd Nall, OCR at [e-mail]. Both may be reached at 336-570-6721.
Sincerely,
wle-
paMann
Utilities Director
Cc: Aaron Holland, Interim City Manager
Ladd Nall, Field Operations Manager