WQCS00005_NOV-2023-DV-0340_20231002

WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4344
October 2, 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-0340 Permit No. WQCS00005
Dated: September 6, 2023; Received: September 18, 2023
City of Durham Collection System, Durham County
Dear Mr. Vinson,
NC Dept of Environmental Quality
OCT 2 2023
Raleigh Regional Office
On September 18, 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 August 1, 2023, and August 30, 2023.
Incident #202301176 - 2415 Camellia Drive - August 15, 2023 8:12 AM
On August 15, 2023, at 8:12 AM, an overflow occurred near 2415 Camellia Drive releasing an estimated 921 gallons
of wastewater into a body of water or tributary of Warren Creek. Crews discovered that grease was the cause of
the blockage and used 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). Staff 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 $4,398.45.

Incident #202301186 - 831 Martin Luther King Jr. PKWY — August 16, 2023 6:45 PM
On August 16, 2023, 6:45 PM, an overflow occurred near 831 Martin Luther King Junior Parkway releasing an
estimated 8,500 gallons of wastewater into a body of water or tributary of Third Fork Creek. Crews discovered that
grease was the cause of the blockage and used 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).
Staff 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 new release was issued within a 24-hour window. Additionally, Durham Water staff mailed information about
proper grease disposal methods to customers upstream of the blockage. The cost to remediate this spill was
$5,695.55.
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 1.3% 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 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.

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 conduct 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

Carol
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DWR State of North Resources
NI. Dept Ot LCi�ii'0!1!lt�ntal �L8111
�bepartment of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources OCT 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 #: 202301176
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 8 Bragg Street, etc): 2415 CAMELLIA DRIVE, DURHAM, , 27705
Manhole #: 24012
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 08/15/2023 Time: 8:12 am Incident End Dt: 08/15/2023 Time: 01:19 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 921 gallons Estimated Duration (Round to nearest hour): 5:7 hours
Describe how the volume was determined: 3GPM X 307 Mins
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 921
Surface water name: Eno River
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:
0 Grease
24 hour verbal notification (name of person contacted ): Curtis R Tyree
0 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 08/15/2023 Time (hh:mm AM/PM): 02:28:00 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 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
Grease
When was the last time this specific line (or wet well) was cleaned?
05/19/2012
Do you have an enforceable grease ordinance that requires new or retrofit of grease Wi Yes El No 0 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.
Our local FOG program administrator was contacted and literature will be distributed to nearby apartment complexes.
Have there been other SSOs or blockages in this area that were also caused by [ Yes 0 No ❑ NA ❑ NE
grease?
When?
NA
If yes, describe them:
NA
Have cleaning and inspections ever been increased at this location? [j Yes [0 No 0 NA NE
Explain.
Never any issues in area it is the beginning that attaches to a private line from apartment complex.
Have educational materials about grease been distributed in the past? [ Yes [0 No ❑ NA ❑ NE
When?
Na
and to whom?
Na
Explain?
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:
Yes ❑ No ro NA D NE
The creek was actually a named tributary Warren Creek Tributary A that dumps into the ENO Also these assets in area
will be monitored and out on a hotspot program where we will keep a close eve on a 3-month basis on any issues in the
collections system.
System Visitation
ORC [ Yes
Backup Z Yes
Name:
Larry Hughes
Cart#
1005483
Date visited:
08/15/2023
Time visited:
01:OOpm
How was the SSO remediated (i.e. Stopped and cleaned up)?
Water crews received the call around 8 12am on 08/15/2023. The call was initially called in as a leaking water meter.
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 subr
Signature:
Telephone Number: qiq �-D q ^ 3 0l,1�
Date: 08/17/23 10:47 am
Title: 66su'k-UP 09t,
I
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

wt ticpt of Enviromnental (hialit state or North Carolina
DWR
Department of Environment and Natural Resources
qq Division of Water Resources
OCT A:iUVotton System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
PART I: Raleigh Regnorial Ott 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 #: 202301186
Owner: City of Durham
City: Durham
Source of SSO (check applicable):
County: Durham
Region: Raleigh
Z 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): 831 Martin Luther King Jr. Pkwy
Manhole #: #10294
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 08/16/2023 Time: 6:45 pm Incident End Dt: 08/16/2023 Time: 08:10 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 8,500 gallons Estimated Duration (Round to nearest hour): 1:25 hours
Describe how the volume was determined: 100gpm X 85mins
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 8500
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:
0 Grease
24 hour verbal notification (name of person contacted ): Jamie Johnson
❑ DWR 0 Emergency Mgmt Date (mm-dd-yyy): 08/17/2023 Time (hh:mm AM/PM): 12:04:00 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.
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
Grease
When was the last time this specific line (or wet well) was cleaned?
08/16/2023
Do you have an enforceable grease ordinance that requires new or retrofit of grease W Yes ❑ No ❑ NA ❑ NE
traps/interceptors?
Have there been recent inspections and/or enforcement actions taken on nearby ❑ Yes [Z No ❑ NA ❑ NE
restaurants or other nonresidential grease contributors?
Explain.
We have not had a visible issue of grease in area since starting the hotspot program We will investigate and have
educational material sent out to problem areas.
Have there been other SSOs or blockages in this area that were also caused by ❑ Yes [Z No ❑ NA ❑ NE
grease?
When?
NA
If yes, describe them:
na
Have cleaning and inspections ever been increased at this location? ❑ Yes [Z No ❑ NA ❑ NE
Explain.
There is an HPL asset close by that has been attended to as such but we had no issues with It. The current asset with
overflow has had no issues in the past.
Have educational materials about grease been distributed in the past? ❑ Yes [0 No ❑ NA ❑ NE
When?
NA
and to whom?
NA
Explain?
We will CCTV and pass out any education materials to residents to when we find the source of the 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:
Yes D No 0 NA [ NE
Gerald Battle with the F.O.G. Program will be involved in the investigation to find where the excessive grease is entering i
sewer main at. Educational material will be Passed out in Person. Assets in the area will be monitored on the hotsoot
program until there is minimal grease issue.
System Visitation
ORC [I Yes
Backup Yes
Name:
Larry Hughes
Carl #
1005483
Date visited:
08/16/2023
Time visited:
9:15pm
How was the SSO remediated (i.e. Stopped and cleaned up)?
Call came in through water dispatch about a water manhole overflowing at 6:45pm. After looking at pictures in call duty
response, team member noticed issue was wastewater. He rerouted this to sewer dispatch. Crews arrived onsite at
7:15Pm and were able to remove blockage of grease at 8:10om by using quick response wart hog on the mini Flusher.
Manhole 10294 was overflowing at a rate of 100 gallons a min for 85 minutes After crew relieved blockage we set up
bypass Pump downstream on Third Fork Creek with sandbags. We blocked flow going to outlet with sandbags and
proceeded to use 4inch pump to remove all untreated wastewater and Pump back into manhole 05238 Crew used vacut
combo truck to vacuum all untreated wastewater soil and waste We used two hydrant meters with defusers to help Push
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: Title:
Telephone Number: 2A% J i)'� " � tl�%/-�7
08/18/23 10:04 am
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

tVC Dept ui'; m irotunental Quality
COMMUNICATIONS
CITY OF DURHAM
Ce News Media Contact
Joe Lunne, SR Public Information & Communication Analyst
Water Management Dept.
919.560.4381 ext.35255 1919.397.6131 (mobile)
[e-mail]
News Release
For Immediate Release: August 17, 2023
City of Durham contains sewer spill at 831 Martin Luther King, Jr. Parkway
DURHAM, N.C. —The City of Durham Department of Water Management reports that on August 16, 2023
staff responded to a manhole overflowing at 831 Martin Luther King, Jr. Parkway. Approximately 8,500
gallons of untreated wastewater flowed into Third Fork Creek. The cause of the overflow was grease
buildup in the sewer main.
Staff were notified of the overflow at 6:45 p.m. on August 16, 2023, and the spill was stopped at 8:10 p.m.
The crew jetted the sewer main, dammed the creek downstream and pumped the untreated wastewater
back into the sewer system. There were no observed hazards to persons, property, or the environment.
As a reminder, only water, human waste, and toilet paper are permitted to be discharged into the sewer
system. All other materials —nonwoven materials (so called flushable wipes and rags) and fats, oils, and
greases (FOGS) that should not be allowed into the sink —contribute to sanitary sewer overflows. To learn
more about the way FOGS and nonwovens clog pipes and how to properly dispose of them, visit our
Industrial Waste Control, Pretreatment, and Grease Reduction Program at www.durhamnc.eov/1077.
The N.C. Department of Environmental Quality Division of Water Resources was notified of the event on
August 17 2023, 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 1
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