WQCS00110_NOV-2024-DV-0286 Resposne to Notice_20240719

MAYOR
Jody L. McLeod
MAYOR PRO TEM
Michael Sims
TOWN MANAGER
Richard D. Cappola, Jr.
TOWN ATTORNEY
Cauley Pridgen, P.A.
Ms. Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
SUBJECT: Notice of Violation NOV-2024-DV-0286
Town of Clayton Collection System Permit Number WQCS00110
Dear Ms. Manuel:
COUNCIL MEMBERS
Ruth Anderson
Andria Archer
Porter Casey
Gretchen Williams
The following information is provided in response to your letter of July 2, 2024, that was received July 16, 2024,
related to the Town of Clayton's actions to correct, and prevent future SSO occurrences:
Incident Number 202401062
This SSO was caused by an 8" metal wing nut plug that was left in the gravity main by the contractor who installed
the lines. We suspect that the plug either drifted down the line and became lodged or was in that line segment the
whole time. After repeated attempts, Town crews were able to dislodge the plug and remove it from the downstream
manhole. The untreated sewage that spilled on the ground was caused by a plumber removing multiple clean out caps
and allowing it to discharge into the street. The untreated sewage entered a nearby storm drain system and stopped at
the outlet of the drainage pipe approximately sixty feet from a sedimentation pond. Town crews were able to remove
all standing sewage and flush the storm drainage system with potable water and capture it in Vac Trucks and return it
to the collections system. The affected area was treated with lime and returned to its normal state with no negative
affects to the environment. The Town contacted the developer of the subdivision to inform them of the situation and
to have them ensure that their contractors take care to remove all plugs after the lines are accepted.
Please contact me if any additional information is required. Thank you for the attention provided to our response.
Sincerely,
f
James tEB�Ia�lock
Assistant Water Resources Director
Enclosures
Cc: Rich Cappola, PE, MPA, CFM, Town Manager
Joshua Baird, PE, CFM, Water Resources Director
Collection System File
�TThAi�ON
PO Box 879 • Clayton, NC 27528 •919-553-5002 Fax [phone] • ClaytonNC.org • Page 1 of 1

DocuSign Envelope ID: 207C9616-6E96-4CFB-8E45-B29DE7360980
ROY" COOPER
ELIZABETH 5. BISER
%' . f P6il
RICHARD E. ROGERS JR.
Richard Cappola
Town of Clayton
PO Box 879
Clayton, NC 27528-0879
NOR r4 CAROL,NA
En vironmenraf QuahlY
July 02, 2024
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2024-DV-0286
Sanitary Sewer Overflows - June 2024
Collection System Permit No. WQCS00110
Clayton Collection System
Johnston County
Dear Mr. Cappola:
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by Town of Clayton indicates violations
of permit conditions stipulated in the subject permit and North Carolina G.S. 143-215.1. Violations include failing to
effectively manage, maintain, and operate the subject collection system so that there is no SSO to the land or
surface waters and making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a
permit is required.
Specific incident(s) cited in the subject report include the following:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202401062 6/10/2024 15 269 PANSY PARK, Debris in line, Other 1,800 Unknown Notice of Violation
CLAYTON, 27520
Remedial actions, if not already implemented, should be taken to correct the above noncompliance. Please submit
a written response to this Notice of Violation. Your response is to be received by the regional office within 15
business days following receipt of this violation. Please include any additional documentation about this incident(s)
in the response. The submittal will be considered in determining whether the Division will assess a civil penalty for
the cited violations.

DOGU&gn Envelope ID' 207COG 16-6E96-4CFME45-829DE73609130
If you have any questions, please do not hesitate to contact Kevin Fowler with the Water Quality Section in the
Raleigh Regional Office at 919-791-4261 or via email at [e-mail].
Sincerely,
!—noc�5ignc4 by:
�--_ 32916ECA312134F
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Laserfiche

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:
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: WQCS00110
(WQCS# if active, otherwise use WQCSD#)
Facility: Clayton Collection System Incident #: 202401062
Owner: Town of Clayton
City: Clayton County: Johnston Region: Raleigh
Source of SSO (check applicable): P Sanitary Sewer ❑ Pump Station 1 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): 269 PANSY PARK, CLAYTON, , 27520
Manhole #: NIA
Latitude (Decimal Degrees)
Incident Started Dt: 06/10/2024
(mm-dd-yyyy)
Estimated Volume of the SSO: 1,500
35.6291
Longitude (Decimal Degrees):
-78.4416
Time: 4:00 pm Incident End Dt: 06/10/2024 Time: 04:15 pm
(hh:mm AMIPM) (mm-dd-yyyy) (hh:mm AM/PM)
Describe how the volume was determined
Weather conditions during the SSO event:
Did SSO reach surface waters? ❑ Yes
Surface water name:
gallons Estimated Duration (Round to nearest hour): 0:15 hours
By measuring area and doing the volume formula
sunny & warm
❑ No Z Unknown Volume reaching surface waters (gals):
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:
W Debris in line P Other (Please explai
24 hour verbal notification (name of person contacted }: Jamie Johnson
DWR [1 Emergency Mgmt Date (mm-dd-yyy): 06110I2024 Time (hh:mm AM/PM): 11:44:00 pm
C;
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
Debris in line
What type of debris has been found in the line?
8" Win -nut metal plug
Suspected cause or source of debris.
We suspect a contractor working on additional phases must have not secured it at the phase line.
Are manholes in the area secure and intact? 0 Yes ❑ No ❑ NA ❑ NE
When was the area last checked/cleaned?
Initial acceptance of subdivision, around Oct. 2022somewhere around
Have cleaning and inspections ever been increased at this location due to previous [ Yes W No ❑ NA ❑ NE
problems with debris?
Explain:
There have been no reported issues of debris.
Are appropriate educational materials being developed and distributed to prevent futt [7 Yes ❑ No ❑ NA ❑ NE
similar occurrences?
Comments:
We have notified the developer and this subdivision will be added to our annual FOG program for notifications.
Other (Please explain in Part II
Describe:
We found an 8" metal wingnut plug in the line.
Were adequate equipment and resources available to fix the problem? Yes ❑ No ❑ NA ❑ NE
If Yes, explain:
We mobilized two of our vactor trucks, one was removing liquid from a manhole to prevent further discharge and the othe_
was letting the line to remove blockage.
If the problem could not be immediately repaired, what actions were taken to lessen
the impact of the SSO?
The problem was immediately resolved, and cleanupcompleted.
ompleted.
Comments:
Upon arriva!, evidence of the spill on the ground from where a plumber had removed 4 cleanout caps and allowed sewer
spill onto the ground and then washed it into the street and into storm drain. The spill was not active at the time of our
arrival.
System Visitation
CS-SSO Form Page: 2

ORC PI Yes
Backup 0 Yes
Name. -
Stephen M. Norris
Cert#
995863
Date visited:
06/1012024
Time visited:
05-55 PM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Since the spill was not active, one of the vactors was utilized to remove sewer from the upstream MH 4269, while the oth(
vactor was trying to let through the blockage located 80' upstream of MH4277. After multiple attempts, the blockage
became dislodged and revealed the plug. We then washed all evidence of the spill off of the sidewalks, the road and the
storm drain. Captured all of the liquid at the mouth of an outlet pipe to a storm drainage pond. None of the liquid entered
the standing water of the pond. we then reheated this process the next morning, 6-11-2024, We collected all visible debr
in the yards, spread pulverized lime and returned the area back to it's natural state.
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: Stephen M. Norris Date
Signature:
Telephone Number:
CIIq-%V7- f 73.s
06/11/24 06:45 am
Title: &06N*tjc Q W Lava -
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of t
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

State of forth Carolina
Department of Environment and Natural Resources
DWR Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Fonn
Division of Water Resources Form CS-SSO
PART 1:
This form shall be submitted to the appropriate DWR Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: w(PC,S 00 d I O (WQCS# if active, otherwise use WQCSD#)
Facility: laves i=CGfY%o✓1 Incident #: Owner: _/ac%u p/� �[✓IyT��+1
Region: t�ALEI('14 City: C4417COJ County:-Q/-1AJf7d-J
Source of SSO (check applicable): 5d Sanitary Sewer ❑ Pump Station I 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.): % 10,4Nsy'
Manhole #: A1LA
Latitude (degrees/minute/second): .3!&.6 -21 Longitude (degreeslminutelsecond): -79, 115/11,,b
Incident Started Dt: Time: Incident End Dt: (a -/d • ZZY Time: 51S- ,'"
(mm-dd-yyyy) (hh:mm) AM/PM (mm-dd-yyyy) (hh:mm) AM/PM
Estimated volume of the SSO: tSLOp gallons Estimated Duration (round to nearest hour): hour($)
Describe how the volume was determined: /Yii-1U/h55> XW--A d yl•"X+V 1(7 vi, 7 ye
Weather conditions during the SSO event: W,,7 JlJy<Jf�
Did the SSO reach surface waters? Yes ❑ No ❑ Unknown
Volume reaching surface waters: _ I CVO gallons Surface water name: S/;Aew pM1AJ
Did the SSO result in a fish kill? ❑ Yes gNo ❑ Unknown
If Yes, what is the estimated number of fish killed? f�
SPECIFIC cause(s) of the SSO:
❑Severe Natural Conditions ❑ Grease ❑Roots ❑Inflow & Infiltration
❑Pump Station Equipment Failure ❑ Power Outage ❑Vandalism W Debris in line []Pipe Failure (Break)
Other (Please explain in Part 11)
24-hour verbal notification (name of person contacted): .,i4/,OZe jog t4(r)" J
❑DWR [Emergency Management Date (mm-dd-yyy): IV-2V51 Time: (hh:mm AMIPM):
Per G.S. 143-215.1 C(b), the owner or operator of any wastewater collection system shall:
In the event of a discharge of 1,000 gallons or more of untreated wastewater to the surface waters of the State, issue
a press release to all print and electronic news media that provide general coverage in the county where the
discharge occurred setting out the details of the discharge, The press release shall be issued within 24 hours after
the owner or operator has determined that the discharge has reached surface waters of the State.
In the event of a discharge of 15,000 gallons or more of untreated wastewater to the surface waters of the State,
publish a notice of the discharge in a newspaper having general circulation in the county in which the discharge
occurs and in each county downstream from the point of discharge that is significantly affected by the discharge. The
Regional Office shall determine which counties are significantly affected by the discharge and shall approve the form
and content of the notice and the newspapers in which the notice is published.
WHETHER OF NOT PART II IS COMPLETED, A SIGNATURE IS REQUIRED SEE PAGE 13
Fonn CS-SSO Pave I

In order to submit a claim for justification of an SSO, you must use Part II of form CS-SSO with additional documentation as
necessary. DWR staff will review the justification claim and determine if enforcement action is appropriate.
PART [I:
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 HAS BEEN SUBMITTED ELECTRONICALLY THROUGH THE ONLINE REPORTING SYSTEM
Form CS-SSO Page 2

Debris in fine (Rocks, sticks, rags and other items not allowed in the collection system, etc.)
What type of debris has been found in the line? S A//.vG rtl47 IiV I -
Suspected cause or source of debris: C D TilEL7O;C O z.<I4/G aw Aal-lafil 01i,4SG` s
Are manholes in the area secure and intact?
[5Yes ❑ No ❑NA ❑ NE
When was the area last checked/cleaned? 0,100,V OVIX 4C - p,/- �UQplWfjw
Have cleaning and inspections ever been increased at this location ❑ Yes jo No ❑NA ❑ NE
due to previous problems with debris?
Explain: '410 PREllova" pi w'60J 4a- A ge`�
Are appropriate educational materials being developed and distributed Yes ❑ No ❑NA ❑ NE
to prevent future similar occurrences?
Comments: LfJ/CG di'—", %40 V �1&_ 0%JZd1OY71aJ ' 4 lv Ia,,7,W,0 J
Form CS-SSO Page 10

Other Pictures and police.report, as applicable, must be available upon request.)
Describe:
Were adequate equipment and resources available to fix the problem? PdYes ❑ No ❑NA ❑ NE
If Yes, explain: Wig / ,Q oc;k ;rX e'.!j
If the problem could not be immediately repaired, what actions ❑ Yes ❑ No ONA ❑ NE
were taken to lessen the impact of the 55O?
Comments:
(/F�•+� 9RkIUdG Ei1146vec= avc T/,` Olt oj 0/,/- d 4V FM !.1/ /l
/Cam /1,Uo i5w Sim A.e 14i we- 1-1101 l y iA77 TWd6601 W
</,✓c`- wli/f!f P-'A64ib9 .4 V fY 114kr; w A✓Gvl VO AM/, 7� /'/W
L� CEo JV ! /N WJ,-,e64M 9F Tim Olft, 4"t- ebv7e�z.-� JXU/L0/•1-G
Form CS-SSO Page 1 l

System Visitation
Name
Certification Number
Date visited.
Time visited:
ORC 0yes ❑ No
Backup [yes ❑ No
S r-6P16t '"W/S
How was the SSO remediated (iJe. Stopped and cleaned up)?
J/' ,'z - 7*f - EAU- 4*J 07 U 7wo 0Ceirgov"C-
fozx
%/r ig yW- fjlliGl'W- 1"k'vzo "VAIL0T/r -,Cb ��'+ed�'? /%J�SI `r' 7'y /HIV I>IGtT�PI�
411rd4 dw 04111 t4,e::i l.✓ "'w L/ "/C A .�(AWLY ey C i-7v,�,r Af�-&JOIIJF�7 Tl
IfoAl) An�J 42crIfloo -5c tO 044-1 Ale c ,-A,.[a4 r,wS . 7
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: . 726141 1-y keO 13
Date: /",— /"�FQz7
Signature: -7i] �-t ,� Title- ' yVwml /1%.i 6W'tz'e�- LE/f02/t-
Telephone Number:
Any additional information desired to be submitted should be sent to the appropriate Division Regional Office within five
business days of first knowledge of the SSO with reference to the incident number (the incident number is only generated
when electronic entry of this form is completed, if used).
4 __570e I Ag4/,v aj�F*lq Ao. G t'7,41Me*I A7 ;Wt-' IVOWIa- g
7/ j atif-C2 eg6i�icc Wc�
70- f)-j M 7r Sr9*1-15
Form CS-SSO Pane 13

r«r�yz�rwzc�:��a
Print Preview - Cityworks
Town of Clayton
Cityworks Work Order
Work to be Performed:
Overflow Event - Manhole
WORK ORDER ID:
68641
Statu
8 — Waiting to be Clos
Date Initiated: 6/10/2024 4:00:00 PM
Initiated By: Norris, Stephen
Projected Start Date: 6/10/2024 4:00:00 PM
Submit To: Blalock, Jame
Projected Finish Date: 6/11/2024 4:00:00 PM
Date Submit To: 6/11/2024 2:58:08 PM
Actual Start Date: 6/10/2024 4:00:00 PM
Priority: Emergent
dual Finish Date: 6/11/2024 2:57:37 PM
Address or Intersection: 269 pansy park
Location Details: 269 Pansy Park
Asset:
Entity Type Location
SGRAVITYMAIN
SMANHOLE
SMANHOLE
Instructions:
Complete Custom Field.
Comments:
By Probst, Heather : 6/10/2024 4:04:28 PM
(Copied from Service Request 15687): "Customer is reporting a busted pipe at the road"
By Heiler, Joshua : 6/11/2024 7:08:36 AM
(Copied from Service Request 15687): "Arrived to investigate and found sewer had Been spilled into street. I
asked the home owner at 269 pansy park what happened. And she said that Thornton plumbing came out
and opened the clean out caps and sewer came out then they took water hoses and washed it into the road.
Then we also discovered the main was backed up. Also got information about the plumber who went out
Thornton Plumbing and a contact number for them is 919-550-8755 , home owner for 269 pansy parks name
is Mary contact number is 980-505-3810"
By Blalock, James : 6/11/2024 9:22:18 AM
Handwritten version of 5-day report completed & press release sent to email contacts.
By Norris, Stephen : 6/11/2024 2:49:56 PM
We cleaned up the entire site per standards. Pictures are attached
By Blalock, James : 6/12/2024 7:19:09 AM
Waiting on state to respond to spill, will leave in review
Labor. -
Employee
lHours
tart Date
End Date
Blalock, James
r.000000
/10/2024 6:00:00 PM
/11/2024 1:00:00 AM
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7117124, 7:23 AM
Print Preview - Cityworks
Probst, Heather
2.000000
/10/2024
7:15:00
PM
/10/2024
8:15:00 PM
Macdonald, Michael
6.500000
/10/2024
6:00:00
PM
/11/2024
12:30:00 AM
Johnson, Ethan
6.500000
/10/2024
6:00:00
PM
/11/2024
12:30:00 AM
Kyer, Jake
8.000000
/10/2024
4:30:00
PM
/11/2024
12:30:00 AM
Norris, Stephen
6.500000
/10/2024
5:30:00
PM
/11/2024
12:00:00 AM
Norris, Stephen
8.500000
/11/2024
6:00:00
AM
/11/2024
2:50:00 PM
Carroll, Dylan
8.500000
/11/2024
6:00:00
AM
/11/2024
2:50:00 PM
Kyer, Jake
8.500000
/11/2024
6:00,00
AM
/11/2024
2:50:00 PM
Johnson, Ethan
8.500000
/11/2024
6:00:00
AM
/11/2024
2:50:00 PM
Macdonald, Michael
.500000
/11/2024
6:00:00
AM
/11/2024
2:50:00 PM
Materials:
Part Number Description Units Account
Eauipment:
ID
Description
Hours
79
9-2021 Ram 2500 4x4 Pickup
5.000000
704
04-2020 Western Star Vactor 2100i
8.000000
75
75 - 2015 Ford F-250 PU Trk
6.500000
851851-Vactor
Truck
6.500000
704
04-2020 Western Star Vactor 2100i
8.500000
707
707 - 2021 Dodge Ram 40 Utility Body Service Truck
&500000
73
73 - 2019 Ford F250 4WD
8.500000
75
75 - 2015 Ford F-250 PU Trk
8.500000
851851-Vactor
Truck
8.500000
717
717 - 1996 Pred Eagle Trailer -Confined Space Equip
4.000000
Cost:
Labor
IMaterialls
JEquipment
$1,361.12
$0.00
4,293.50
Custom Fields:
Custom Field Name
Custom Field Value
Location
269 Pansy Park
Incident #
202401062
NOV #
NOV-2024-0286
Case #
M H #
4277
Volume (Estimated) gallons
1800
Did it reach the surface?
YES
olume Estimated (Surface)
1800
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7/17/24, T.23 AM
Print Preview - Cityworks
Cause
Sewer plug in gravity main
Source
Collections
Repairs
CLEANED
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