WQCS00005_NOV-2023-DV-0313_20230913

WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4344
September 12, 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-0313 Permit No. WQCS00005
Dated: August 7, 2023; Received: August 22, 2023
City of Durham Collection System, Durham County
Dear Mr. Vinson,
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On August 22, 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 July 1, 2023, and July 31, 2023.
Incident #202301089 - 4023 Wake Forest Highway - July 20, 20231:15 PM
On July 20, 2023 at 1:15 PM, an overflow occurred near 4023 Wake Forest Highway releasing an estimated 45
gallons of wastewater into a tributary of Little Lick Creek. Crews discovered that grease was the cause of the
blockage and used a JetVac truck to successfully clear the line. 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 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.
The cost to remediate this spill was $4,274.63.

Incident #202301123 - 3640 Pine View Circle - July 30, 2023 2:19 PM
On July 30, 2023 at 2:19 PM, an overflow occurred near 3640 Pine View Circle releasing an estimated 292 gallons
of wastewater into a tributary of Mud Creek. Crews discovered that roots were the cause of the blockage and used
a JetVac truck to successfully clear the line. 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 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.
The cost to remediate this spill was $6,888.88.
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 Fiscal
Year 2022, DWM cleaned 10.14%of the collection system. In Fiscal Year 2023, DWM cleaned 10.4%of the
collection system. As of August 30, 2023, approximately 1.5% of the City's collection system had been cleaned
by City staff and contractors for the Fiscal Year 2024.
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 FFEs 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.

The 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. In FY23, DWM spent about $22 million on Sewer Rehabilitation projects 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
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 Environmental Quality State of North Carolina
DWR Department of Environment and Natural Resources
Division of Water Resources
5 N i 3 : I-IZJ Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources
Form CS-SSO
PART l: Raleigh Regional Office
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 #: 202301089
Owner: City of Durham
City: 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): 4023 Wake Forest Highway, Durham, NC, 27703
Manhole #: 18240
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 07/20/2023 Time: 1:15 pm Incident End Dt: 07/20/2023 Time: 01:55 pm
(mm-dd-yyyy) (hh:mmAM/PM) Cmm-dd-yyyy) (hh:mmAM/PM)
Estimated Volume of the SSO: 45 gallons Estimated Duration (Round to nearest hour): 0:40 hours
Describe how the volume was determined: lgpm x 45 mins = 45gals
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 45
Surface water name: Little Lick Creek
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 Grease
24 hour verbal notification (name of person contacted ): Michael Hall
0 DWR ❑ Emergency Mgmt
Date (mm-dd-yyy): 07/2012023 Time (hh:mm AM/PM): 04:51:00 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 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 If 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
Grease
When was the last time this specific line (or wet well) was cleaned?
10/18/2022
Do you have an enforceable grease ordinance that requires new or retrofit of grease R1 Yes ❑ No NA NE
traps/interceptors?
Have there been recent inspections and/or enforcement actions taken on nearby [ Yes [0 No ❑ NA ❑ NE
restaurants or other nonresidential grease contributors?
Explain.
Have there been other SSOs or blockages in this area that were also caused by [Z Yes No [] NA ❑ NE
grease?
When?
01/1612020
If yes, describe them:
This was the first incident where we had a grease issue causing the overnow. We remediated the spill and out on 6 mont
monitoring of hotsoot to ensure no folow up spill.
Have cleaning and inspections ever been increased at this location?
Explain.
Have educational materials about grease been distributed in the past?
When?
NA
and to whom?
NA
WYes []No DNA ENE
Yes O No NA E NE
Explain?
We are currently working to set up CCTV investigation in the area so we can possibly Pinpoint the beginning of the proble
area and pass out necessary paperwork to stop grease issue.
If the SSO occurred at a pump station, when was the wet well and pumps last
checked for grease accumulation?
NA
CS-SSO Form Page: 2

Were the floats clean?
Comments:
System Visitation
ORC
Backup
Name:
Larry Hughes
Cart#
1005483
Date visited:
07/20/2023
Time visited:
01:35om
How was the SSO remediated (i.e. Stopped and cleaned up)?
❑Yes El No WNA ❑NE
Yes
F Yes
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: LarryEdward bluohes Date: 07/21/23 10:55 am
i
Signature: �! ` 9 Title: r L 1t�0r� (_
Telephone Number: q-M U
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of f
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

DWR Stale of North Carolina
NC Dept of Environmental Quality Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
DIvlslon of Water Resources j l ' j Form CS-SSO
PART I: Raieigh Regional Office
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#: 202301123
Owner: City of Durham
City: Durham County: Durham Region: Raleigh
Source of SSO (check applicable): 2 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): 3640 Pineview Cir, Durham, NC, 27705
Manhole #: 13311
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 07/30/2023 Time: 2:19 pm Incident End Dt: 07/30/2023 Time: 07:19 pm
(mm-dd-yyyy) (hh:mmAM/PM) (mm-dd-yyyy) (hh:mmAM/PM)
Estimated Volume of the SSO: 292 gallons Estimated Duration (Round to nearest hour): 5:0 hours
Describe how the volume was determined: Est 1gpm`292min=292gal
Weather conditions during the SSO event: Fair skys Hot
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 292
Surface water name: Mud Creek
Did the SSO result in a fish kill? ❑ Yes EINo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
Q Roots
24 hour verbal notification (name of person contacted ): Jerry Unkown
❑ DWR 0 Emergency Mgmt Date (mm-dd-yyy): 07/30/2023 Time (hh:mm AM/PM): 08:50:00 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 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
Roots
Do you have an active root control program on the line / area in question? ❑ Yes [Z No NA NE
Describe
While we do have a hotspot program in place, we currently have none in place for the area in question. Moving forward v
will have cctv work done to find root issue and fix problem.
Have cleaning and inspections ever been increased at this location because of roots' D Yes R1 No NA NE
Explain:
Area is PVC which has a high success rate for keeping root intrusion to a minimum. The only percent of root issues we
have seen in the past are due to lateral separation issues.
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
Crews came out and flushed to remove all roots in connected assets in area. We also performed CCTV work on all asses
to locate the root problem at its core and will create a repair work order to have resolved. Also, we found a can manhole
the area which will be removed and replaced with manhole for better CCTV inspection. (Update) After investigation we foi
root issue was coming from manhole cone failure. We will put in to get manole rehabbed to fix issue.
What corrective actions are planned at the SSO location to reduce root intrusion?
After CCTV we will write up any repairs needed for root intrusion at location. Since assets are pvc . it is a high chance
issue is due to lateral separation from main. We will let engineering know after CCTV and have all separated laterals
repaired. We will have contractors fix manhole issue that caused the root intrusion.
Has the line been smoke tested or videoed within the past year?
If Yes, when?
NA
Comments:
Yes [Z No ❑ NA ❑ NE
All assets in area will be put on a hotspot monitoring program until repairs are made to root intrusion area.
System Visitation
ORC r7 Yes
Backup W Yes
Name:
Warren Goodwin
m"is:
CS-SSO Form Page: 2

Date visited:
Time visited:
How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews dammed Mudd Creek downstream, flushed the creek and pumped untreated waste water back into the sanitary
serwer system
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
Signature:
Telephone Number:
Warren Aldean Goodwin
Date:
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