WQ0013348_NOV-2023-DV-0199_20230531

WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1100 Martin Luther King Jr Parkway
Durham, NC 27707
919-560-4344
May 31, 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-2023-DV-0199 Permit No. WQCS00005
Dated: May 8, 2023; Received: May 16, 2023
City of Durham Collection System, Durham County
Dear Mr. Vinson,
NC Dept of finvironmental Quality
MAY 31 2023
Raleigh Regional Office
On May 16, 2023, the City of Durham Department of Water Management (DWM) received the above referenced
Notice of Violation and Intent to Issue Civil Penalty. As graciously requested in the letter, the following evidence
and justification demonstrates that these events were exceptional, unintentional, temporary, and beyond
reasonable control of the utility, and that DWM undertook significant costs to mitigate their impact. Further, it
demonstrates DWM's strong commitment to and investment in preventing and mitigating sanitary sewer
overflows (SSOs). All conditions of the City's Collection System permit are met by the Department, including
system cleaning, site visits, inspections, and easement maintenance.
As such, we respectfully request that no civil penalties be assessed for the SSOs that occurred in the City's sewer
collection system between April 1, 2023, and April 30, 2023.
Incident# 202300605 —1024 Andrews Chapel Road —April 5, 202311:40 AM
On April 5, 202311:40 AM, an overflow occurred near 1024 Andrews Chapel Road releasing an estimated 26,000
gallons of wastewater into an unnamed tributary of Brier Creek near the Durham -Raleigh boundary. Crews
discovered that an air release valve (ARV) failure on a force main was the cause of the overflow and used bypass
pump to divert the flow while crews successfully repaired and replaced associated infrastructure. After assessing
the extent of the spill, crews dammed the downstream creek with sandbags, set up two 4-inch pumps to move the
untreated wastewater back into the collection system, and flushed the area using a nearby hydrant (dechlorinated
water). Staff coordinated with Raleigh to pump the water in to Raleigh's collections system based on the
accessibility of their gravity system. Crews inspected the nearest manhole to ensure there were no further issues
to be remediated.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the spill's
extent and advise the Department when the site returned to normal conditions. No immediately visible adverse
environmental impacts or hazards to persons or property were observed.

A news release was issued within a 24-hour window as well as notice to the required Notice of Discharge. The cost
to remediate this spill was $13,584.32.
The City has a proactive ARV replacement and maintenance program. The City employs a dedicated crew that
inspects and maintains all 147 ARVs within the collection system at least once a year. This past year, the City
replaced 27 older ARVs.
Incident#202300645 -1 Williams Way —April 10, 2023 8:05AM
On April 10, 2023 at 8:05 AM, an overflow occurred near 1 Williams Way releasing an estimated 11,500 gallons of
wastewater into an unnamed tributary of the Eno River. Crews discovered that a rain guard insert had fallen into
the invert was the cause of the blockage and used bypass pump to divert the flow while crews successfully cleared
the line. After assessing the extent of the spill, crews dammed the downstream creek with sandbags, set up a fl-
inch pump to pump the untreated wastewater back 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.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the spill's
extent and advise the Department when the site returned to normal conditions. No immediately visible adverse
environmental impacts or hazards to persons or property were observed.
A news release was issued within a 24-hour window. The cost to remediate this spill was $4,974.89.
Ongoing City -Wide Measures to Reduce the Occurrence of SSOs
DWM has several programs in place to prevent and reduce the occurrence of SSOs. DWM has implemented a
Collection System Management, Operations & Maintenance (CMOM) plan that expands and enhances its existing
programs.
• System Flushing and Inspection: DWM routinely contracts cleaning, CCTV inspection, smoke testing, and
manhole inspections of portions of the sewer collection system. DWM completes the inspection of the
collection system systematically based on City defined geographical basins.
DWM 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 an additional two to
five percentage points each year. DWM measures the cleaning on a fiscal year basis starting July 1. In FY 2021,
DWM cleaned 14.8%of the collection system. In Fiscal Year 2022, DWM cleaned 13.4% of the collection
system. As of April 30, 2023, 6.7% of the City's collection system had been cleaned by City staff and contractors
since July 1, 2022. As usual, we plan to increase our rate of sewer cleaning activity in the spring.
Sewer Rehabilitation Program: DWM has an active Sewer Rehabilitation Program. The program includes flow
monitoring (25 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 DWM's system rehabilitation programs in
the Utility Engineering Division of the Department. 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 63 lift 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. DWM 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 are shared between the Industrial Pretreatment, Septage and FOG Programs). In addition to
working with the Durham County Health 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 the Bimbe Festival, as well as
neighborhood meetings. Department staff deliver residential Fat Trappers to increase awareness of the proper
disposal methods for waste. DWM staff also conducts post-SSO follow-up education and enforcement as
necessary. DWM 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.
Summary'
Based upon the documented information provided above regarding these incidents, DWM believes that these
SSO's were exceptional, unintentional, temporary, and caused by factors beyond the City and Department's
control. DWM 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, DWM systematically inspects, flushes, and
rehabilitates its wastewater collection system. The Department also actively works to regulate and 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 [phone] or via email at
[e-mail].
Sincerely,
Donald F. Greeley, Director, PE, PLS
Attachments
C: Vanessa Manuel, DEQ— Water Quality Regional Operations Section, Raleigh Regional Office
Kevin Fowler, DEQ— Water Quality Regional Operations Section, Raleigh Regional Office
Junior Mobley, Superintendent, Water & Sewer Maintenance
Scott Smart, Assistant Director
Mary Tiger, Assistant Director
Jerry Morrone, Utility Engineering Manager, Sr.

State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
RT I: NC Dept of f-Awironmental Quality
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#) MAY 3 1 2023
Facility: Durham Collection System %��I`202 5.
` 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): 1024 Andrews Chapel Rd, Durham, NC, 27703
Manhole #: 263804
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 04/05/2023 Time: 11:40 am Incident End Dt: 04/05/2023 Time: 01:50 pm
(mm-dd-yyyy) (hh:mmAM/PM) (mm-dd-yyyy) (hh:mmAM/PM)
Estimated Volume of the SSO: 26,000 gallons Estimated Duration (Round to nearest hour): 2:10 hours
Describe how the volume was determined: 200gal x 130min = 26,000 gallons
Weather conditions during the SSO event: Clear
6 SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 26000
rface water name: Brier Creek
Did the SSO result in a fish kill? ❑ Yes Z No ❑ Unknown If Yes, what is the estimated number offish killed? 0
SPECIFIC cause(s) of the SSO:
0 Other (Please explai
24 hour verbal notification (name of person contacted ): Timothy Clark
0 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 04/06/2023 Time (hh:mm AM/PM): 08:20:00 am
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 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.
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

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
Other (Please explain in Part II)
Describe:
ARV on the force main failed asset #00381
Were adequate equipment and resources available to fix the problem? Yes ❑ No ❑ NA ❑ NE
If Yes, explain:
We were able to isolate the ARV valve to eliminate the S.S.O and then we replaced the ARV after cleaning up the spill.
If the problem could not be immediately repaired, what actions were taken to lessen
the impact of the SSO?
Comments:
System Visitation
ORC
Backup
Name:
Kenny Willard
Cert#
990222
Date visited:
04/06/2023
Time visited:
09:00am
How was the SSO remediated (i.e. Stopped and cleaned up)?
name is not in the report options.
Yes
•
Yes
Is
CS-SSO Form Page: 2

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: Kenneth Wayne Willard
nature:
Telephone Number:
Date: 04/06/23 08:20 am
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

NC Dept of l .M itonmental Quality
From: Lunne, Joe
• Sent: Thursday, April 6, 2023 9:31 AM
Subject: SSO at 1025 Andrews Chapel Road
COMMUNICATIONS
CITY OF DURHAM
MAY 3 12023
Raleigh Regional Office
News Media Contact
Joe Lunne, SR Public Information &
Communication Analyst
Water Management Dept.
919:560,4381 ext. 35255 919,397,6131
(mobile)
Jae _Lunn(,@DurhamNC.goy
News Release
For Immediate Release: April 6, 2023
City of Durham contains sewer spill at 1025 Andrews Chapel Road
• DURHAM, N.C. —The City of Durham Department of Water Management reports that on April 5,
2023 staff responded to a manhole overflowing at the Del Webb Pump Station-1025 Andrews
Chapel Road. Approximately 26,000 gallons of untreated wastewater flowed into Briar Creek.
The spill was caused by a failed air release valve on the force main.
Staff were notified of the overflow at 11:40 a.m. on April 5, and the spill was stopped at 1:50
p.m. Crews set up sandbags, remediated the site, and pumped the untreated wastewater back
into the sewer system. There were no observed hazards to persons, property, or the
environment.
The N.C. Department of Environmental Quality Division of Water Resources was notified of the
event on April 6, as required by state regulations/law. For more information, contact Kenny
Willard, Lift Station Maintenance Superintendent.
101 CityHall Plata,Seccnd Flcor, Durham, NC 27701 kk 919.5E0.4123 I DurhamNC..gov Follow Uc PCityofDurhamNC
• E 00

DWRState of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
PART I:
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#: 202300645
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): 1 Williams Way, Durham, NC, 27704
Manhole #: 24374
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 04110/2023 Time: 8:05 am Incident End Dt: 04/10/2023 Time: 10:00 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 11,500 gallons Estimated Duration (Round to nearest hour): 1:55 hours
Describe how the volume was determined: 115mins X 10gpm
Weather conditions during the SSO event:
Did SSO reach surface waters? RI Yes
Surface water name: Eno River
❑ No ❑ Unknown Volume reaching surface waters (gals): 11500
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:
Z Other (Please explai
24 hour verbal notification (name of person contacted ): Zachary Thomas
0 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 04/10/2023 Time (hh:mm AM/PM): 01 A8:00 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 Dress 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

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
Other (Please explain in Part II)
Describe:
Call came in at 805am on 4-10-23. Manhole was overflowing at 100gpm upon arrival. We oerformed a pump around and
remediated spill at 10:00am. For a total of 11,500 gallons of wastewater touching the around and getting into state waters
115mins X 100gpm. The issue was a Infiltration dish or dust cover. These are inserted on ring on manhole lid to keep
infiltration and debris from entering the manhole. The insert was filled with debris and dropped down blocking invert of
downstream 8 inch pipe causing the overflow.
Were adequate equipment and resources available to fix the problem? R Yes ❑ No ❑ NA NE
If Yes, explain:
Crew set up bypass pump on Manhole 24392 and diverted flow to manhole 36039. After flow went down we were able to
retrieve infiltration dish (dust cover).
If the problem could not be immediately repaired, what actions were taken to lessen
the impact of the SSO?
Issue was fixed within the hour after arrival.
Comments:
Crew will clean assets in area and remove all infiltration dishes so no further issue with these falling into mainline.
System Visitation
ORC ❑ Yes
Backup 7 Yes
Name:
Larry Hughes
Cert#
1005483
Date visited:
04/10/2023
Time visited:
9:30am
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Call came in at 805am on 4-10-23. Manhole was overflowing at 100gpm upon arrival. We performed a pump around and
remediated spill at 10:00am. For a total of 11,500 gallons of wastewater touching the ground and getting into state waters
115mins X 100gpm. The issue was insert dust cover falling into the manhole blocking invert not allowing wastewater to flc
After removal crew set up pump downstream in creek to remove anv untreated wastewater and pump back into the systei
at manhole 24320. Crew used vacuum truck, rakes and quick response truck to clean up area of anv untreated
wastewater. The spill area was in yard at address 1 Williams Way, we removed mulch from bedding area in yard and will
replace with new mulch. We also removed any soil around area and will replace. Crews are currently working flushing
mainlines 3 above and 3 below to make sure no issues were caused when the inflow dish backed up the main. Storm we
quality will be called today to insure creek test for zero ammonia. Also press release was issued informing the oublic of tf
overflow issue.
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: Larry Edward Hughes Date:
Signature:
Telephone Number: 9p /'� a9- 30tiL
04/11/23 09:10 am
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of 1
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

From: Lunne, Joe
Sent: Monday, April 10, 2023 4:16 PM
Subject: SSO at 1 Williams Way
COMMUNICATIONS
CITY OF DURHAM
NC Dept of Environmental Quality
MAY 3 12023
Raleigh Regional Office
News Media Contact
Joe Lunne, SR Public Information &
Communication Analyst
Water Management Dept.
919.560:4381 ext. 35255 919,397,6131
(mobile)
Joe,Lunne.@DurhamNC,goy
News Release
For Immediate Release. April 10, 2023
City of Durham contains sewer spill at 1. Williams Way.
DURHAM, N.C. —The City of Durham Department of Water Management reports that on April
10, 2023 staff responded to a manhole overflowing at 1 Williams Way. Approximately 11,500
gallons of untreated wastewater flowed into an unnamed tributary of Eno River. The spill was
caused by a manhole dust cover that had detached into the sewer line.
Staff were notified of the overflow at 8:04 a.m. on April 10, and the spill was stopped at 10 a.m.
Crews set up sandbags, remediated the site, and pumped the untreated wastewater back into
the sewer system. There were no observed hazards to persons, property, or the environment.
The N.C. Department of Environmental Quality Division of Water Resources was notified of the
event on April 10, as required by state regulations/law. For more information, contact Junior
Mobley, Superintendent of Water & Sewer Maintenance.
101 City Hall Plaza, Second floor, Durham, NC 27701 919.560,4123 1 DurhamNC.gov Follow Us @CityofDurhamNC
0©(D9