WQCS00065_NOI_NOV2021DV0495_Response_20220104

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P. O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
January 4, 2022
NC Department of
Environmental Quality
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Wir - 'em
Certified Mail No. 7019 2970 0001 10814727 F"
Lon T. Snider
NCDEQ\DWR
450 West Hanes Mill Rd., Suite #300
Winston-Salem, NC 27105
Subject: Tracking No.: NOV-2021-DV-0495
Sanitary Sewer Overflows — October 2021
City of Graham
Collection System Permit # WQCS00065
Alamance County
Dear Mr. Snider:
The City of Graham received a notice of violation on December 29, 2021, with an intent to
issue a civil penalty for Sanitary Sewer Overflow incident 202102095 at Porter Ave. 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 October 27, 2021, at Porter Ave. Outfall, was due to
vandarrsrr,. Apparerrtly,il `e1b'ii y uliit icime:;rw had remjv2d man'3!c lid #OD353 bera.:sE rifi3 J iype
rock was found in the sewer main. Debris collected around the riprap, created a blockage and caused
the SSO. City personnel responded with a jet machine to help relieve the sewer blockage and used a
ccty to investigate the!: ,,Ver main to ensure no further blockages or issues existed downstream. Lime
was applied to the surface area affected as part of remedial action. Upstream and downstream process
control water samples were taken from Back Creek and analyzed for temperature, pH, DO and fecal
counts. The results are as follows:
Upstream Downstream
Temp 20 c 16 c
PH 6.2 6.2
DO 8.5 mg/I 8.0 mg/I
Fecal 365.4/100mL 272.3/100mL
As the results show there is Pttle to no impact to the creek. The industrial user that is discharging to MH
00353 is in the city s pretreatment program and has DMP Unit including Chemical Precipitation,

Filtration, Flocculation, Ion Exchange, pH adjustment, sand filters, and polishing tank to treat process
water before discharge in the city collection system. Following cleanup of the SSO City personnel
replaced the manhole lids with bolt down type frames and covers to help prevent this from happening
again. Vandalism is an incident that is beyond the City's control and the City of Graham does not believe
should be considered for enforcement action.
The City of Graham continues to be vigilant in our efforts to combat Inflow and Infiltration,
as well as, permit compliance. The City continues to budget a minimum of $285,000 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. 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 or individuals vandalizing our system. Based on our immediate
response, remedial action, and ongoing committed budget expenditures, 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,
Tonya Mann
Utilities Director
Cc: Megan Garner, City Manager
Ladd Nall, Field Operations Manager