WQCS00005_NOV-2023-DV-0267_20230804 (2)

NC Dept of Environmental Quality
WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4344
August 3, 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-0267 Permit No. WQCS00005
Dated: July 5, 2023; Received: July 14, 2023
City of Durham Collection System, Durham County
Dear Mr, Vinson,
AUG 4 2023
.Raleigh Regional Office
On July 14, 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 this event was exceptional, unintentional, temporary, and beyond reasonable
control of the utility, and that DWM undertook significant costs to mitigate its 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 SSO that occurred in the City's sewer
collection system between June 1, 2023, and June 30, 2023.
Incident #202300886 -1819 Milan Street —June 1, 2023 6:18 AM
On June 1, 2023, at 6:18 PM, an overflow occurred near 1819 Milan Street releasing an estimated 710 gallons of
wastewater into a body of water or tributary of Ellerbe Creek. The overflow was initiated by a tree falling on a
privately -owned service lateral during severe weather. Upon investigation, our crews determined a contractor had
bored through a downstream gravity main and that that obstruction caused the sewer backup into the private
lateral. After assessing the extent of the spill, crews dammed the downstream creek with sandbags, set up a 4-inch
pump to pump the untreated wastewater back into the collection system, and flushed the area using a nearby
hydrant (dechlorinated water). Crews used a JetVac truck to successfully clear the line and allow WM staff to make
repairs to the gravity main and replace the broken lateral. 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.

We issued required Notice of Discharge within the 24-hour window. The cost to remediate this spill was
$10,051.27.
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. In FY 2023, City staff and contractor cleaned 10.4% of the City's collection system.
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.
Our Lift Station Maintenance Division (LSM) focuses on oversight and maintenance of the 61 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 million 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 this SSO
was 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
Attachments
C: Jason Robinson, DEQ— Water Quality Regional Operations Section, Raleigh Regional Office
Junior Mobley, Superintendent, Water & Sewer Maintenance
Mary Tiger, Assistant Director
Jerry Morrone, Utility Engineering Manager, Sr.

NC Dept of i:nvironmental (duality
DWRState of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
•Division ofWater Resources Raleigh RetxianalOffice 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 #: 202300886
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): 1805 Milan St, Durham, NC, 27704
Manhole #: 21259
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 06/01/2023 Time: 6:18 pm Incident End Dt: 06/01/2023 Time: 08:40 pm
(mm-dd-yyyy) (hh:mmAM/PM) (mm-dd-yyyy) (hh:mmAM/PM)
Estimated Volume of the SSO: 710 gallons Estimated Duration (Round to nearest hour): 2:22 hours
Describe how the volume was determined: 5gpmx142min
Weather conditions during the SSO event:
*id SSO reach surface waters? 0 Yes
Surface water name: Ellerbe Creek
Clear
❑ No ❑ Unknown Volume reaching surface waters (gals): 710
Did the SSO result in a fish kill? ❑ Yes 0 No ❑ Unknown If Yes, what is the estimated number of fish killed? _
SPECIFIC cause(s) of the SSO:
0 Other (Please explai
24 hour verbal notification (name of person contacted ): Jamie Johnson
❑ DWR 0 Emergency Mgmt Date (mm-dd-yyy): 06/02/2023 Time (hh:mmAM/PM): 05:30:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(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 reouired to be reoorted 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 III
Describe:
Were adequate equipment and resources available to fix the problem?
If Yes, explain:
quick response to help flow.
If the problem could not be immediately repaired, what actions were taken to lessen
the impact of the SSO?
NA
Comments:
[ZYes []No DNA F]NE
System Visitation
ORC Yes
Backup 0 Yes
Name:
Nickolas Evans
Cert#
1013120
Date visited:
06/02/2023
Time visited:
05:OOAM
•
•
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
•
fiber bored through the 10inch PVC line from 10am to 3pm inside of Pipe 39ft from upstream manhole. Crew will make
repair and fix issue with broken pipe.
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: Nickolas R Evans Date: 06/05/23 08:34 am
Signature:
Telephone Number:
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 Environmental (duality
r-1 U f] 4 ' 1!'' 3
Raleigh Regional Officv
• 0

NC Dept of Environmental Quality
utu
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
PART I: Raleigh Regional ice
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 #: 202300901
Owner: City of Durham
City: Durham County: Durham Region: Raleigh
Source of SSO (check applicable): RI 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): 419 Monticello Ave, Durham, NC, 27707
Manhole #:
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 06/09/2023 Time: 8:35 am Incident End Dt: 06/09/2023 Time: 09:30 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 130 gallons Estimated Duration (Round to nearest hour): 0:55 hours
Describe how the volume was determined: 2gpm x 65 minutes = 130gallons
Weather conditions during the SSO event:
Did SSO reach surface waters? [Z Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 130
Surface water name: Third Fork Creek
Did the SSO result in a fish kill? ❑ Yes ONo ❑ Unknown If Yes, what is the estimated number offish killed? _
SPECIFIC cause(s) of the SSO:
O Roots O Pipe Failure (Break)
24 hour verbal notification (name of person contacted ): Tyler Clark
O DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 06/09/2023 Time (hh:mm AM/PM): 03:57:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(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 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 1 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? ❑ Yes 2 No Fj NA [ NE
Describe
Have cleaning and inspections ever been increased at this location because of rootsYes 2 No ❑ NA ❑ NE
Explain:
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
The Pipeline was root cut and cleared using a combination truck followed by monitoring with CCTV.
What corrective actions are planned at the SSO location to reduce root intrusion?
The recorded video will be handed over to the Utility Engineering Department for further inspection. An contractor is
replacing the sewer pipe
Has the line been smoke tested or videced within the past year? Yes Rj No NA [ NE
If Yes, when?
Comments:
Pipe Failure (Break)
Pipe size (inches)
8"
What is the pipe material?
Clay and /or VCP
What is the approximate age of line/pipe? (years old)
1966
Is this a gravity line?
Is this a force main line?
Is the line a "High Priority" line?
fF Yes No ❑ NA [] NE
Yes 0 No ❑ NA ❑ NE
Yes R No DNA ❑ NE
CS-SSO Form Page: 2

Last inspection date and findings
01/23/2023 .Slight sag at ioint
If a force main then,
Was the break on the force main veritical?
Was the break on the force main horizantal?
Was the leak at the joint due to gasket failure?
Was the leak at the joint due to split bell?
When was the last inspection or test of the nearest air -release valve to determine of
operable?
n/a
When was the last maintenace of the air release performed?
n/a
If gravity sewer then,
[Yes 2 No DNA ❑NE
[i Yes R No NA NE
❑ Yes [Z No ❑ NA NE
2 Yes No ❑ NA NE
Does the line receive flow from a force main immediately upstream of the failed sect! ❑ Yes 0 No ❑ NA [ NE
of pipe?
If yes, what measures are taken to control the hydrogen sulfide production?
When was the line last inspected or videoed?
6/15/2015
If line collapsed, what is the condition of the line up and down stream of the failure?
What type of repair was made?
replacement of sewer pipe
Is the repair temporary or permanent?
Permanent
If temporary, when is the permanent repair planned?
Have there been other failures of this line in the past five years?
If so, then describe
System Visitation
ORC
Yes [0 No ❑ NA ❑ NE
Yes
CS-SSO Form Page: 3

Backup
Name:
Terrance Vasquez
Cart#
1003853
Date visited:
06/09/2023
Time visited:
11:00 A.m
How was the SSO remediated (i.e. Stopped and cleaned up)?
[f Yes
Good afternoon. At 8:35 a.m. on 6-9-2023, the water management dispatch team received a call for assistance at 419
6-9-23. Fortunately, no fish kills
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: Terrance Vasquez Date: 06/09/23 03:57 pm
Signature:
Telephone Number: M — L175 - l( '7 G 5
Title: Me'i'k erf Said/
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

VC Dept of Environmental Qualitv
. CAROLINA
CIVILWORKS
li# INC.
CHANGE ORDER REQUEST
Project: 2021 Water & Sewer Point Repairs DATE:
Contract: CO#:
Customer: City of Durham
Description of change:
Cost to repair sewer at Brookwood Dr.
Rileigh Regional ()1yice
07.13.23
Materials
SUBTOTALS
1 Total Direct Cost of Materials
$
2,838.39
2 Sales Tax
3 Overhead & Profit
$425.76
4 Shipping & Transportation
$ 3,264.15
Labor
5 Total Manhoum:
$
6 Payroll Taxes & Insurance 45.0%
$
7 Overhead & Profit
$
$
Equipment
8 Equipment
$
• 9 Overhead & Profit
$
$
Subcontractor
10 Subcontractor
$
Overhead & Profit
$
$
Unit Prices
10 Unit Prices
$
49,336.80
Overhead & Profit
$ 49.335.80
$ 62,599.95
12 Bonds ( % of subtotal of proposal)
$0.00
$52,599.95
Time Extension Requests: _ day(s) Schedule Activity # Affected:
The Contractor agrees to perform the work outlined in this change proposal for the amount specified above and in accordance with
the Contract documents if the work is authorized by the Owner.
Contractor's Signature:
Date:
Approval Recommended by Design Consultant:
Date:
Owner's Representative Approval:
Date:

NC Depl ()[Environmental Quality
CCAROLII'���
®� CIVILWORKS
7 ^, 1NC.
CHANGE ORDER BREAKDOWN
JOB NAME: 2021 Water & Sewer Point Repair
Job #:
Material
n
Raleigh Re,iaual Office
Description
Qty
JUNIT
I Amount
I Subtotal
Concrete Collar
2
CY
$ 162.38
$ 324.75
Ductile Price Increase
86
LF
Casing Price Increase
60
LF
Is 28.65
1 $ 1,719.00
Total Material $ 2,838.39
Labor
IDescription IQty (UNIT I Amount I Subtotal
Total Labor $
Subcontractor
Total Sub Price $ -
Unit Price
Description
UNIT
Amount
Subtotal
4a) 8" PVC Pt Repair
1
EA
$ 3,736.00
$ 3,736.00
14a) 8" PVC PT Repair >10'Ion
76
LF
$ 82.00
$ 6,232.00
24a Additional Cost for DIP
86
LF
$ 22.00
$ 1,892.00
25a) New 4' Manhole
1
EA
$ 3,366.00
$ 3,366.00
34 New MH Frame & Cover
1
EA
$ 907.00
$ 907.00
45a 4" Bypass Pump
2
DY
$ 464.00
$ 928.00
47) New Concrete Pier, up to 6 VF
2
EA
$ 8,821.00
$ 17,642.00
60f) Rip -rap bank stabilization
15.8
CY
$ 66.00
$ 1,042.80
61) Tree Removal - 8" DBH up to 12" DBH
10
EA
$ 435.00
$ 4,350.00
67) 16" Casing
60
LF
$ 154.00
$ 9,240.00
Total Unit Price $ 49,335.80
•