WQCS00065_NOI_NOV2022DV0183_Response_20220727

C ITY OF
G R A H A M
?1 '�(_1-0,
NC Department of
Environmental Quality
Received
July 27, 2022
Certified Mail No. 7019 2970 0001 1081 4550
Lon T. Snider
NCDEQ\DWR
450 West Hanes Mill Rd., Suite #300
Winston-Salem, NC 27105
Subject: Tracking No.: NOV-2022-DV-0183
Sanitary Sewer Overflows — May 2022
City of Graham
Collection System Permit # WQCS00065
Alamance County
Dear Mr. Snider:
AUG 0 2 2022
Winston-Salem
Regional Office
The City of Graham received a notice of violation on July 18, 2022, with an intent to
issue a civil penalty for Sanitary Sewer Overflow incident 202200785 at the end of Ingold Dr.
The City of Graham requests that you consider the following response in your decision before
taking enforcement action.
The Sanitary Sewer Overflow event on May 23, 2022, at a sanitary sewer manhole
at the end of Ingold Dr., was not due to any blockages or station malfunction but occurred due
to an afternoon flash flood that produced between 4 to 5 inches of rainfall throughout the
watershed. The rainfall event lasted less than 2 hours but produced heavy downpours and
flooding. This excessive rainfall event overflowed area creeks, sanitary sewer easements, and
roadways causing property loss and damage. WFMY News 2 reported on this flooding event.
Spectrum News 1 reported that in our neighboring municipality that all nine EMS trucks, along
with police and fire crews, were called out for water rescues. During the Sanitary Sewer Overflow
event, both pumps operated properly at the receiving lift station, at a rate of 1300 GPM, but the
system became overwhelmed by the extremely large volume of water. Once the water level in
the wet well reached high water, our emergency by-pass pump takes over and produces the same
pumping rate per minute. The Collection Crew responded to the 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 the pumps continued to operate properly at the station.
The City of Graham continues to be vigilant in our efforts to combat Inflow and
Infiltration. In addition to our yearly budget allocation, for manhole rehab, pipe lining, and root
control we contracted a company for $125,000 to inspect areas of concern in the preparation of
the upcoming point repair project in the Boyd Creek sewer basin. During these inspections, City
crews Identified and promptly repaired an Inflow source within the sewer shed and anticipate a
measurable improvement. We continued to fund $35,000 in root control, $50,000 in manhole
rehab, and $200,000 CCIP, in our current budget along with an additional $500,000 for Boyd
Creek Sewer Basin Point Repair. The City also recently replaced the Boyd Creek Lift Station in the
spring of 2021 at a cost of over 3 million dollars.
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 S5Os. The current
exception is 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, recent and continual funding of manhole
rehab, pipe lining, root control, replacement of Boyd Creek Lift Station, and the upcoming Boyd
Creek Basin Point Repair Project, it is evident that the City of Graham is committed to using 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 Tonya Mann at
[e-mail] or Ladd Nall, ORC at [e-mail]. Both may be reached
at 336-570-6721.
Sincerely,
Tonya Mann
Utilities Director
Cc: Aaron Holland, Assistant City Manager
Ladd Nall, Field Operations Manager