WQCS00005_CPA Folder_DV 2024 0073_20240731

Docusign Envelope ID: B1B6E54F-1E02-47E5-B44E-3A20F2D37147
DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Durham
Facility Name: Durham Collection System
Permit Number: WOCS00005
County: Durham
Case Number: DV-2024-0073
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
A total of 4,200 gallons of wastewater overflowed from the Durham Collection System due to a broken pipe. 4,200 gallons
of wastewater flowed to the Ellerbe Creek, a class WS-IV; NSW in the Neuse River Basin. Nutrients and pathogens to
surface waters.
2) The duration and gravity of the violation;
The SSO started on February 1, 2024, at 05:08 pm and ended the same day at 09:10 pm.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on surface water quality includes nutrients and pathogens to surface waters.
4) The cost of rectifying the damage;
The cost of rectifying the damage was given as $697,914.66.
5) The amount of money saved by noncompliance;
It is believed that no money was saved by the noncompliance.
6) Whether the violation was committed willfully or intentionally;
It does not appear that the violation was committed willfully or intentionally.
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority;
There have been four (4) penalty assessments issued within the past 12 months to the permittee for violations of the
Durham Collection system permit.
8) The cost to the State of the enforcement procedures.
$95.36
7/31/2024
Date
DocuSigned by
C� FF
RRddR
John Hennessy, Section Chief
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

Docusign Envelope ID: B1B6E54F-1E02-47E5-B44E-3A20F2D37147
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS,IR.
Director
Certified Mail # 7017 0190 0000 24861060
Return Receipt Requested
Don Greeley
City of Durham
101 City Hall Plz
Durham, NC 27701-3229
NORTH CAROLINA
Environmental Quality
7/31/2024
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(6)
and Collection System Permit No. WQCS00005
City of Durham
Durham Collection System
Case No. DV-2024-0073
Durham County
Dear Mr. Greeley:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $595.36 ($500.00 civil penalty +
$95.36 enforcement costs) against City of Durham.
This assessment is based upon the following facts: a review has been conducted of the Sanitary Sewer Overflow (SSO)
5-Day Report submitted by City of Durham. This review has shown the subject facility to be in violation of the
requirements found in Collection System Permit No. WQCS00005 and G.S. 143-215.1(a)(1). The violation(s) that occurred
are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that City of Durham violated the terms, conditions or
requirements of Collection System Permit No. WQCS00005 and G.S. 143-215.1(a)(1) in the manner and extent shown in
Attachment A. hi accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty maybe assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
-D. � North Carolina Departmentof Envtronmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett brive I Raleigh. North Carolina 2704
919,791.4Z00

Docusign Envelope ID: 61 B6E54F-1 E02-47E5-B44E-3A20F2D37147
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, I, John
Hennessy, Section Chief, Water Quality Regional Operations hereby make the following civil penalty assessment against
City of Durham:
$500.00 For 1 of the 1 violations of Collection System Permit No. WQCS00005 and G.S. 143-215.1(a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
$500.00 TOTAL CIVIL PENALTY
95.36 Enforcement Costs
595.36 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of-
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Docusign Envelope ID: B1 B6E54F-1 E02-47E5-B44E-3A20F2D37147
Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282. I (b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty (30) dgys of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center, Raleigh
Raleigh, NC 27699-1628

Docusign Envelope ID: B1B6E54F-1E02-47E5-B44E-3A20F2D37147
Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document, you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS §15013-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
6714 Mail Service Center
Raleigh, NC 27699 6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact Kevin Fowler with the Division of Water Resources staff of the Raleigh Regional
Office at [phone] or via email at [e-mail].
Sincerely,
DocuSigned by:
C�
8328B44CE9EB4A1...
John Hennessy, Section Chief
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Laserfiche

Docusign Envelope ID: B1B6E54F-1E02-47E5-B44E-3A20F2D37147
Case Number: DV-2024-0073
JUSTIFICATION FOR REMISSION REQUEST
County: Durham
Assessed Party: City of Durham
Permit No.: WQCS00005 Amount Assessed: $595.36
Please use this form when requesting remission of this civil penalty. You must also complete the 'Request for Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:

Docusign Envelope ID: B1B6E54F-1E02-47E5-B44E-3A20F2D37147
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF DURHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
City of Durham )
Durham Collection System )
PERMIT NO. WQCS00005 ) CASE NO. DV-2024-0073
Having been assessed civil penalties totaling $595.36 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated/31/2024 , the undersigned, desiring to seek remission of the civil penalty, does hereby waive
the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the day of 520
SIGNATURE
ADDRESS
TELEPHONE

Docusign Envelope ID: B1 B6E54F-1 E02-47E5-B44E-3A20F2D37147
ATTACHMENT A
City of Durham
CASE NUMBER: DV-2024-0073
PERMIT NO: WQCS00005 REGION: Raleigh
FACILITY: Durham Collection System COUNTY: Durham
Other Violations
INCIDENT VIOLATION TOTAL VOLUME PENALTY
NUMBER DATE VIOLATION TYPE VIOLATION DESCRIPTION (GALLONS) AMOUNT
202400418 2/5/2024 CSO/SSO(Sewer Overflow) Discharge without valid permit 4,200 $500.00

DocuSign Envelope ID: OCAF9C57-12OA-4E53-9BF4-2244CE231432
ROY COOPER
Garin Flar
ELIZABETH S. BISER
serrelary
RICHARD E. ROGERS. JR.
Drrertw
Certified Mail # 7017 0190 0000 2486 0377
Return Receipt Reauested
Donald F Greeley
City of Durham
101 City Hall Piz
Durham, NC 27701-3329
NORTH CAROLINA
Environmental Quality
March 13, 2024
SUBJECT: NOTICE Of VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0156
Sanitary Sewer Overflows - February 2024
Collection System Permit No. WQCS00005
Durham Collection System
Durham County
Dear Mr. Greeley:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Reports submitted by
City of Durham. The Division's Raleigh Regional Office concludes that the City of Durham violated Permit Condition
1 (2) of Permit No. WQCS00005 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Durham an opportunity to provide evidence and justification as
to why the City of Durham should not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mina) Location Cause (Gals) (Gals) DWR Action
202400407 2/1/2024 242 905 PARKRIDGE ROAD, Debris in line, Grease 12,100 0 Notice of Violation
DURHAM, 27713
202400418 2/5/2024 210 2006 AIKEN AVENUE, Pipe Failure (Break)
DURHAM, 27704
4,200
4,200 Notice of Violation -
Notice of Intent
�^�,�!..rrrhGr�is[kp,nimen[�!Cn.�ewun�nralijr;;r3dy.ir.r�F�r. rl l5aser Rr•wrcr,
D_EQr� Galrylrkrgrna!Cl11Kr 3fNra&errn[)mr HaklgR\nr!hCvntina2:..0+

DocuSgn Envelope ID: OCAF9C57-12DA-4E53-9BF4-2244CE231432
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Kevin Fowler with the Water Quality Section in the
Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Cc: Laserfiche
Sincerely,
Oocuftned by:
i/aunt-SSa �. Nl.a�n�,ct,L� �Di'`
—H2916EBAH32144F
Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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I M WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4344
April 8, 2024
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: Response to NOV-2024-DV-0156
Dated: March 13, 2024; Received: March 26, 2024
Permit No. WQC500005
On Monday, April 8, 2024, 1 received the document and attachments addressed to:
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Signature
Date

I M WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4344
April 8, 2024
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: Response to NOV-2024-DV-0156
Dated: March 13, 2024; Received: March 26, 2024
Permit No. WQCS00005
Dear Mr. Vinson,
Please permit this letter to respond to the above referenced Notice of Violation & Intent to
Issue Civil Penalty received on March 26, 2024. 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. This evidence will also
establish the significant costs and actions taken to stop the discharge; contain the release of
untreated wastewater; collect the wastewater, and restore the possible environmental
impacts. Further, it demonstrates the City of Durham Department of Water Management's
(DWM) strong commitment to and investment in preventing and mitigating sanitary sewer
overflows (55O). 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 wastewater collection system between February 1, 2024 and February 29, 2024.
Incident#202400407 — February 1, 2024 — 905 Parkridge Road
On February 1, 2024 at 5:08 PM, an overflow occurred near 905 Parkridge Road releasing an
estimated 12,100 gallons of wastewater into a storm water ditch in the Third Fork Creek basin.
Crews discovered that debris in the line was the cause of the blockage and used a JetVac truck
to successfully clear the line. After assessing the extent of the spill, crews determined that no
waste water entered the waters of the State or any unnamed tributary of the Third Fork Creek.

Crews carefully dammed the storm water ditch with sandbags, used a JetVac truck to vacuum
the untreated wastewater, and flushed the area using a nearby hydrant (dechlorinated water).
This approach contained the sewer and minimized the environmental impact on the
surrounding land and downstream waters. Crews used a JetVac truck to clean the three
upstream and three downstream pipe reaches to ensure the pipes were clear.
The incident was reported to the Department's Industrial Waste staff so they could canvas the
neighborhood and nearby homeowner's associations with information about the effects of non-
woven materials and grease in the collection system. industrial Waste staff educate the
community about the appropriate disposal options, as well as providing interactive giveaways
life grease trappers through the website.
During the follow up investigation, crews cctv'd the three upstream and three downstream pipe
reaches and found areas containing root growth. These gravity mains have been added to the
annual lining contract that the Department is funding and the manholes have been sent to the
Department's excavation workgroup for sealing.
The Department's cost to remediate this spill was $3,319.71.
The incident leading to this spill is exceptional, unintentional, temporary, and caused by factors
beyond reasonable control. The Department has made consistent efforts to prevent such an
incident by regular cleaning of the sewer system, a cyclical hot spot program, and constant
engagement with the community about proper waste disposal. The staff immediately
responded to the incident to mitigate the impact of the spill and used every effort to ensure the
infrastructure and environment was restored.
Incident#202400418 -- February 5, 2024 — 2006 Aiken Avenue
On February 5, 2024 at approximately 11:00 AM, an overflow was reported near 2006 Aiken
Avenue releasing an estimated 4,200 gallons of wastewater into a tributary of Ellerbe Creek.
Crews responded and promptly discovered that separation of the pipe was the cause of the
spill_ Crews used a by-pass pump to divert flow and called in an excavation crew to make the
repair. 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). This approach
contained the sewer flow and minimized the environmental impact on the surrounding land
and downstream waters. Crews used a JetVac truck to clean the three upstream and three
downstream pipe reaches to ensure the pipes were clear.
The pipe separation occurred in a pipe segment that was scheduled to be replaced as part of
our Aiken Avenue Sewer Rehabilitation Project. The contractor had recently started
construction on the project.
The City's Stormwater Services Division responded and conducted ammonia testing to
determine the spill's extent and advise the Department when the site returned to normal

conditions. Visual inspection of the affected area and downstream waters confirmed there
were no immediately visible adverse environmental impacts or hazards to persons or property,
including no fish kill or unnecessary vegetative damage.
DWM takes substantial and consistent actions to protect and monitor high priority lines (HPLs).
Staff perform comprehensive bi-annual inspections of all sewer lines categorized as an HPL
including looking for obstructions, changes in the creek bank and bed, and trees in proximity to
the easement. This section of easement had been identified as a high -risk area previously and
the location was put on a replacement contract. Following this spill, the Department escalated
the replacement of the pipe at 2006 Aiken Avenue to fully remediate the site.
The Department's initial cost to respond to this spill was $17,141.94. The contractor project
costs totaled to $680,772.72. Together, the Department's costs to remediate this spill was
approximately $697,914,66
Category Cost
Initial Response $17,141.94
Contractor Repair $680,772.72
Total $697,914.66 }
Table 1. Responsive costs accrued by the Department to remediote 2006 Aiken Avenue and area.
The incident leading to this spill is exceptional, unintentional, temporary, and caused by factors
beyond reasonable control. The Department has made consistent efforts to prevent such an
incident by regular HPL inspections and a proactive pipe replacement plan. Department staff
immediately responded to the incident to mitigate the impact of the spill and used
extraordinary efforts to ensure the infrastructure and environment were restored.
Ongoing City -Wide Measures to Reduce the Occurrence of SSO Incidents
DWM has several programs in place to prevent and reduce the occurrence of SSO incidents.
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.
In FY23, DWM spent approximately $22 million on Sewer Rehabilitation projects as a part of its
Capital Improvements Programs. 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.
DWM measures the cleaning on a fiscal year basis starting July 1.

Reporting Period Miles Percent of System
-- -
FY24 74.63 6.74%
FY23 119.86 _10.40%
FY22 — — ,-116.16 10.14%
Table 2. Unique mileage of gravity mains cleaned by DWM Staff for the three most recent fiscal years.
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 seven 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 20 FTEs in the City's Collections Systems Maintenance (CSM) workgroup in the Sewer
Maintenance Division of DWM. This group performs CCTV inspections, hydraulic cleaning
activities, 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 who perform identified point repairs, line replacements, and cured -in -place
lining.
The Lift Station Maintenance workgroup (LSM) focuses on oversight and maintenance of the 63
lift stations throughout the service area. This workgroup of 17 FTEs conducts required daily,
weekly, monthly, and annual inspections and associated preventive maintenance activities.
The 11 FTEs in the Outfall Maintenance (OFM) workgroup perform routine inspection and
mowing of easements and inspection of the designated high priority lines. in addition, they
facilitate the inspections and repair of the 136 air relief valves (ARVs) in the City's sewer
system.
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 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 this incident, 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 [e-mail].
Sincerely,
Donald F. Greeley,
Director
Attachments
C. Jason Robinson, DEQ— Water Quality Regional Operations, Raleigh Regional Office
Kenny Willard, Superintendent, Sewer Maintenance, Water Management
Scott Smart, Assistant Director, Water Management

lReportable Sewer Spill Locations - FY24 3rd QTR FEBtit
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DURHAM
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Incident #202400418
Gravity Main 0 8977
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4400Z7 Incident #2024
Manhole 06063
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DorirSrgn Envelope 10 OCAFUG,57.120A. 4E53-EBF4•274dCE23l432
Certified Mail # 7017 0190 0000 2486 0377
Return Receipt ReQuested
March 13, 2024
Donald F Greeley
City of Durham
101 City Hall Plz
Durham, NC 27701-3329
RECEIVED
City of Durham
Office of rho Dlrecfor
Dept. tirf Water Management
SU83ECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0156
Sanitary Sewer Overflows - February 2024
Collection System Permit No. WQCS00005
Durham Collection Systipm
Durham County
Dear Mr. Greeley:
A review has been conducted of the self -repotted Sanitary Sewer Overflows (SSO's) S-Day Reports submitted by
City of Durham. The Division's Raleigh Regional Office concludes that the City of Durham violated Permit Condition
1 (2) of Permit No. WQCS00005 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the C;ty of Durham an opportunity to provide evidence and justification as
to why the City of Durham should nut be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202400407 2/1/2024 242 905 PARKRIDGE ROADr Debris in line, Grease 12.100 0 Notice of Violation
DURHAM,2770
202400,118 215/202,1 210 2006 AIKEN AVENUE, Pipe Failure (Break) 4,200 4,200 Notice of Violation -
DURHAM, 27704 Notice of Intent

UaCUSrgiz Fnvr. -1r.e 11'1 1-v E2314:?l
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being Issued for the noted violation. Pursuant
to G,S, 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the te!'ms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-corpliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Kevin Foviler with the Water Quality Section in the
Raleigh Regional, Office at 919-791-4200 or via email at [e-mail].
Sincerely,
DGac ';u,,r.1 �.,.
Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Laserfiche

State of I\i►rtil Carolina
Dt'p irrioicnt of I" l ironnuni and Natriral Rew►frrcei
Di%isiun of WaIer RevIui'ces
Cnlleclinn System Si}nita,y Sew+�r Overf.nv. R.�,prirting Form
Division of Water llesouftes Form CS-SSO
PART I:
This form shall be submitted to the appropriate DWO Reg onal Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WOCS00005
(WOOS# if active, otherwise use WOCSD#)
Facility. Durham Collection System Incident h': 202-100407
Owner- City of Durham
City: Din,hani County_ Dur~?am Region: Raleigh
Source of SSO (check applicable): © Sanitary Sewer ❑ Pump Station / Lift Station
SPECIFIC location of the SSO (be consistent in description from past reports or documenlation - i.e. P.imp Station 8,
Manhole at Westall & Bragg Street. etc): 905 PARKRIDGE ROAD, DURHAM , 27, ;
Manhole #: 060133
Latitude (Decinial Degrees): Longitude (Decimal Degrees):
Incident Started Dr 02/0 1/202 t Time: 5 Q8 l;m Incidenl End Dt. 02101/2024 Time: 09 10 p n
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PiA)
EsliiTlrited VOILlr11P- of the SSO: 12.100 gallons Estimated Duration L.Rourid to nearest hour): 4.2 hours
Describe how the volume was determined 509pinx242min
Weather conditions during the SSO ovent: sl c►sai::_il
Did SSO reach suffacix waters?
Surface waver name:
❑ Yes [ No ❑ Unknown V011ime reaching surface waters (gals):
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:
Q Grease Q Debris in line
24 hour verbal notificat-on (name of person contarled ): Mike Bennett
❑ DINR [Z Emergency Mgmt Date (mm-dd-yyy): 02?0 U2024 Time (hh:mm AM/PM): _-I t A2.0o 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 gress 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 pub:ished 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 SS_Os 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
Parmittee 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 oasis
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 Iasi time this specific line (or wet well) was cleaned?
1011--Ii21
Do you have an enforceable grease ordinance Thal requires new or retrofit of grease [ Yes [ No DNA ❑ NE
trapslinierceptors?
Have there been recent inspections andlor enforcement actions taken on nearby Yes W No n NA F] NE
restaurants or other nonresidential grease contributors?
Explain.
After inves;i ation with CCTV we will oet the rooer documentation out to an one we find issues with in area.
Havv there been other SSOs or blockages in this area that were also caused by [ I Yes 7 No r-1 NA FI NE
grease?
When?
NA
If yes, describe them:
NA
Have cleaning and inspections ever been rncrPised at this location? Yes Z No ❑ NA [] NE
Explain.
We will Put assets nearby on the hots of munitoring program and clean and investigate evea 6 months to make sure no
full•re SSO in area.
Have educational materials about grease been d'stributed in the past? n Yes [7 No n NA r' NE
When?
NA
and to whom?
NA
Explain?
In the past none has been passed out but we will send information to our director of our F.O.G. program to have verbia e
passed out to businesses and residents.
If the SSO occurred at a pump station, when was the wet well and pumps la9t
checked for grease accurnulation?
PEA
CS-SSO Form Page 2

Were the floats ilea::? r- Yes r No [,7,1 NA [—I NE
Conomems:
Crevis are currenliv cluing thn CCTV rind rleanincl totk„rr tic) Arid %01 put the connacte_ci_assats on a 6_months nionilorinu s
we can keep from having reneal issue-s in area.
Debris in line
What type of (Inbris has htten fntn,d in the I.nr-.?
rags
SUsaected cause or source of debris,
residential
Are manholes in the area secure and intact? 17, Yes [ No [� NA ❑ NE
When was the area last checked/cleaned?
10rt ar21
Have cleaning and inspections ever been increased at this location We to previous (I Yes j7 No [—jj NA n NE
problems with debris?
Explain
Na
Are appropriate educational materials being developed and distr bated to prevent fur [✓I Yes r No ri NA n NE
similar occurrences?
Co,nments:
We will have the director of the F.O.G. oroarani oass out Drover verbiage to residents in area exo1ainiria the importance o
not flushing non-wovens.
System Visitation
ORC [ Yes
Bac,kup
Name:
Warren Goodwin
Cert4-
1007495
Dale visited:
02101l2024
Time visited.
C Yes
How was the SSO rernediated (i.e. Stopped and cleaned up)?
Crews jetted main to relive blockage. UnlreatPd waste water that was contained to a clitch line was ,�umped back into the
collectian system.
CS-SSO Form Page 3

ids a re.prFisen.mive IfnithF, re: pollslble lln rty, I i:e riify Inat the Information clininwed Ill Illls repori i ; true and accurate to the
nest of lire kn�wrlad9e,
Person submit1mg {:taim: Vlhia n Aldean Goodv:in
Date:: OM6-2) 08,15 am
Sigrattire: �I uu. ,vr/.r%r� Title:
Telephone Number: °) - 56i.
Any addition information desired to be submitted sl ould be sent to the appropriate Dr-rision Regional Office wdhir five days of
knovdedge of the SSO with reference to the incident number (rhe incident number is ophj generated «hen electronic entry of In,
form is completed, if Used).
CS-SSO Form page 4

Rr,llr of North Carulilm
Drpaflmellt of Fmirutinrcnl and'Natural Resource;
Di%isioll of%%wer lzesuurcc"
Collevtion System Sanitary Sewer Overflow Reporting Form
Division of Water Resources
Form CS-SSO
PART 1:
This form shall be submitted to the appropriate DWO Regio-ial Office within five buskness days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: YMCS00005
(U'lQCSh if active. otherwise use lr/QCS0#)
Facility: Durham Collection Svsten-, Incident M 2024V4 1
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 - Le Pump Station 6,
Manhole at Westall & Bragg Street, etc). A -KEN AVENUE. DURHAkl -I'/ j4
P11anhole 9. 0594.4
Latitude (Decimal Degrees):
Incident Started Dt: UM5120211 Time
(rnnl-dd-yyyy)
Estimated Volume of the SSO: 4.200
Longitude (Decimal Degrees):
11.00 ant Incident End Dt 02/051202,1 Time: 02,30 pm
(I*rnm AM/PM) (mm-dd-yyyy) (hh:mm AM1PM)
gallons Estimated Duration (Round to nearest hour):
Describe how the volume was determined. %';`;Ptv1 x 210Nlir-,;;
3 30 hours
Weather conditions during the SSO event: ; ),,
Did SSO reach surface waters? R1 Yes ❑ No [] Unknown Volume reaching surface waters (gals): 4230
Surface water name: Ellerbe Creak
Did the SSO result in a fish kill? ❑ Yes QNo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO.
[a Pipe Failure (Break)
24 hour verbal notificabon (name of person co-rtacted ). Michael Hall
0 DWR ❑ Emergency Mgrnt Date (mm-dd-yyy). 0105/2024 Time (hh:mm AM/PM): 03:20:00 prn
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 Vie 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 deta I.
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 andfor owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justificatio-- claim fof 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
Pipe Failure (Break)
Pipe size (inches)
12
What is the p pe material?
Vitrified Clay, Pi[Le
What is the approximate age or linelpipe? (years old)
1.0/1.8.:1985 =58 years and3 monihs
Is this a gravity line? F Yes n No n NA r- NE
Is this a force main line?
Is the line a "High Priority" line?
Last inspection date and findings
11/3/2021 lines had debris but no leaks or con-ditioning issues.
If a ford main then.
4Vas the break on the force main veritical?
Was the break on the force main horizantal?
Was the leak at the Joint due to gasket failu•e?
Was the leak at the joint due to split bell?
When was the lest inspection or test or the nearest air -release valve to determine of
operable?
NA
When was the last maintenace of the air release performed?
NA
If gravity sewer then,
F— Yes [7 No rl NA r; NE
[7 Yes n No n NA [—NE
r- Yes n hlf) [j NA r- NE
r" Yes r' No [7 NA r" NE
r Yes n N.) W. NA r. NE
r- Yes n No (7 NA n NE
Does the line receive flow from a force main immediately upstream of the fa led sect r- Yes r� No 0 NA ❑ NE
of pipe?
CS-SSO FoF,n Pace; 2

If yes. +vhat measure- sire taken to control the nydrogtin sulfide production?
MA
V-1hen was trse line last inspected or vitlwnev
111312024
If line collapsed, what is the condition of the line up and down stream of the failure?
Line. was not collapsed but separaled from the bell ioint.
What type of repair was made?
20-foot section of piue +eras replaced.
Is the repair temporary or permanent?
Tomoorary
If temporary. when is the permanent repair planned?
PiPe was replaced with 20ft of temporary i e. The complete asset will be removed and replaced with new pipe from
manhole to manhole..
Have there been other fahll-05 of this line in the past free years?
If so, then describe
No failures to descrbe.
System Visitation
ORC:
Backup
Name:
Larry Huches
Certit
1005483
Date visited:
02/0512024
Time visited.
11.30am
How %vas the SSO remediated (i.e. Stopped and cleaned up)?
r— Yes W No F. NA � NF
r Yes
,(7 Yes
arrived onsite at 11:30am after contractor reported sewer in the creek. After finding leak in the creek we proceeded to c
downstream and test area for zero ammonia for pump placement for bypass, After finding zero ammonia on Camden Avr
we placed pump with over.100 sandbags to block creek and use_purnp to remove all untreated wastewater. We then
proceeded to plug off mainline at manhole 21760 and proceed to do a pump„aroundd. We pumped the wastewater from
manhole 21760 to 53892. Afters ill was remediated al 2:30 m we groceeded to have excavation crew make a 20ft repa
for a temporary replacement on pipe until the complete asset is removed and renewed. We also set up a 3rd pump in the
creek and removed all wastewater around break and bvpassed it into manhole 53892. Repair was made on 2/5124 to fix
leak then a separate repair was made to keep „from future Incident for a total of loft replaced. We set up a hydrant meter
after re a}r 0 push all untreated wastewater to the bypass pump. Storm Water quality will be called to test creek before
removal of bypass pumD.
CS-SSO Form P�0o- 3

Asa represents'=ive for the risao,ISi0o. party, I certify that the Informalioi, contaliwt- I iii Ilrr.; resort •S trtlf? and acr:ura:o to ttio
best of my knowlertq�:.
PerS01- subMiRing ClF irti Larry Edward Hiuti7es
Date: 02)07e24 Qg d$ am
1 //
Signature:%��' ' " Z ? Title lac
Telephone Number: o-t+�j�-
Any acid-tion iiiformat-on desired to be submitted shnuld 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 III
form is completed, if used).
CS•SSO Form Page: 4

SSO at 2006 Aiken Avenue
Lunne, Joe <[e-mail]>
Tue 2/6/2024 9:08 AM
COMMUNICATIONS
CITY OF DURHAM
News Media Contact
Joe Lunne, SR Public Information & COMMumcatio,i AnalysL
WatUf M.in,3(wmenl Dept
919.560.4381 rxt 3c,255 ; 919.397 6 L31 (mobile)
loe Lunn0@0urhai1,NC gov
News Release
City of Durham contains sewer spill at 2006 Aiken Avenue
DURHAM, N.C. —The C ty of Durham Department of Water Management reports that on February 5, 2024, staff
responded to a separated sewer main at 2006 Aiken Avenue, Approximately 4,200 gallons of untreated wastewater
flowed into an unnamed tributary of Ellerbe Creek. The cause of the overflow was separation of the sewer line_
Staff were notified of the overflow at 11 a.m. on February 5, 2024, and the overflow was stopped at 2:30 p.m. The crew
cleared the blockage, 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.
The N.C. Department of Environmenta Quality Dlvision of Water Resources was notified of the event on February 5, 2024
as required by state regulations/law. For more Information, contact Kenny Willard, Superintendent, Collection System
Maintenance.
494
101 Cit•� Clad Plata. Secant:: lour. Dwimm, N(. 2 /701 919 560 -t t> 3 Dtarharci Ni".I;riv Follo,. Us �_'C�CiIYOIDurharnNC
©0 0

STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
SYSTEM -WIDE COLLECTION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations, permission is hereby granted to the
City of Durham
WQCS00005
FOR THE
operation and maintenance of a wastewater collection system consisting of, at the time of permit
issuance, 1,124 miles of gravity sewer, approximately 56 miles of force main, 63 duplex pump stations,
and all associated piping, valves, and appurtenances required to mace a complete and operational
wastewater collection system to serve the City of Durham and any deemed permitted satellite
communities, pursuant to the application received August 9, 2018, and in conformity with the documents
referenced therein and other supporting data subsequently filed and approved by the Department of
Environmental Quality and considered a part of this permit.
This permit shall be effective from August 16, 2018 until July 31, 2026, and shall be subject to the
following specified conditions and limitations:
Durham Collection System Permit No. WQCS00005 Page I< of 8

I. PERFORMANCE STANDARDS
1. The sewage and wastewater collected by this system shall be treated in the properly permitted
Wastewater Treatment Facility identified in the permit application and documented in the Division's
database. [15A NCAC 02T.0108 (b)]
The wastewater collection system shall be effectively managed, maintained and operated at all times
to prevent discharge to land or surface waters, and to prevent any contravention of groundwater
standards or surface water standards. In the event that the wastewater collection system fails to
perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take
immediate actions as per the Response Action Plan (Condition II (9)), as well as any actions that may
be required by the Division of Water Resources (Division), such as the construction of additional or
replacement sewer lines and/or equipment. [AA NCAC 02T .0108 (b)]
3. The Permittee shall establish by ordinance, inter -local agreement or contract its legal authority to
require new sewers be properly constructed; to ensure proper inspection and testing of sewer mains
and service laterals; to address flows from satellite systems and to take enforcement action as
required by Condition 1(4). [G.S. 143-215.98; G.S. 143-215.1(f)(1)]
4. The Permittee shall develop and implement an educational fats, oils and grease program that shall
include at least semiannual distribution of educational material targeted at both residential and non-
residential users. The Permittee shall also develop and implement an enforceable fats, oils and grease
program for non-residential users under which the Permittee can take enforcement against users who
have not properly installed, operated and maintained grease traps or grease interceptors as directed
or otherwise violated the terms of the enforcement program pertaining to fats, oils and grease. [15A
NCAC 02T .0108 (b)]
5. The Permittee shall adopt and implement a Capital Improvement Plan (CIP) to designate funding for
reinvestment into the wastewater collection system infrastructure. The CIP should address the short-
term needs and long-term "master plan" concepts. The CIP should typically cover a three to five-year
period and include a goal statement, description of the project area, description of the existing
facilities, known deficiencies (over a reasonable period) and forecasted future needs. Cost analysis is
integral to the CIP. [G.S. 143-215.96]
6. Overflow piping from manholes and pump stations, excluding piping to approved equalization
structures, known or discovered after permit issuance shall be immediately removed or permanently
capped. Plugged or valved emergency pumping connections are allowable for portable pumping or
rerouting without intentionally bypassing the wastewater treatment facility. [15A NCAC 02T .0108
(b)]
7. The Permittee shall maintain a contingency plan for pump failure at each pump station. If one of the
pumps in a pump station containing multiple pumps fails, the process of repairing or replacing the
pump shall be initiated immediately and the new parts or pump shall be installed as soon as possible.
The permittee shall provide justification for delay in initiating the process for repair or replacement
at the Division's request. If the pump in a simplex pump station serving more than a single building
or pump stations not capable of pumping at a rate of 2.5 times the average daily flow rate with the
largest pump out of service falls, it shall be replaced immediately. [15A NCAC 02T .0305 (h) (1)]
8. Each pump station shall be clearly and conspicuously posted with a pump station identifier and an
emergency contact telephone number at which an individual who can initiate or perform emergency
Durham Collection System Permit No. WQCS00005 Page 2 of 8

service for the wastewater collection system 24 hours per day, seven days per week can be contacted.
This emergency contact telephone number shall be coupled with instructions that the emergency
contact should be called if the visual alarm illuminates, if the audible alarm sounds, or if an emergency
is apparent. [15A NCAC 02T .0305 (h) (2)]
9. Pump station sites, equipment and components shall have restricted access. 115A NCAC 02T .0305
(h) (4)]
10. Pump stations that do not employ an automatic polling feature (i.e. routine contact with pump
stations from a central location to check operational status of the communication system) shall have
both audible and visual high water alarms. The alarms shall be weather-proof and placed in a clear
and conspicuous location. Permits issued for the construction of pump stations that included high
water alarms in the description must maintain the alarms even if simple telemetry (i.e. notification of
an alarm condition initiated by the pump station control feature) is installed.
11. [15A NCAC 02T .0305 (h) (1)]
12. For all newly constructed, modified and rehabilitated pump stations, all equipment and components
shall be sealed within a corrosion -resistant coating or encasement to the extent practicable and
equivalent to the minimum design criteria unless the permittee can demonstrate it is not practicable
or another form of corrosion resistance is employed. [15A NCAC 02T .0108 (b)]
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. Upon classification of the collection system by the Water Pollution Control System Operators
Certification Commission (WPCSOCC), the Permittee shall designate and employ a certified operator
to be in responsible charge (ORC) and one or more certified operator(s) to be back-up ORC(s) of the
facilities in accordance with 15A NCAC 8G .0201. The ORC shall visit the system within 24 hours of
knowledge of a bypass, spill, or overflow of wastewater from the system, unless visited by the Back -
Up ORC, and shall comply with all other conditions of 15A NCAC 8G .0204.
115A NCAC 08G .0200 et.seq.]
2. The Permittee shall develop and adhere to a schedule for reviewing all inspection, maintenance,
operational and complaint logs. If the review process results in the identification of any recurring
problem in the wastewater collection system that cannot be resolved in a short time period, the
Permittee shall establish a plan for addressing the problem(s). [15A NCAC 02T .0108 (b)]
3. The Permittee shall develop and adhere to a schedule for testing emergency and standby equipment.
[15A NCAC 02T .0108 (b)]
4. The Permittee shall develop and implement a routine pump station inspection and maintenance
program which shall include the following maintenance activities:
a. Cleaning and removing debris from the pump station structure, outside perimeter, and wet
well;
b. Inspecting and exercising all valves;
c. Inspecting and lubricating pumps and other mechanical equipment; and
d. Verifying the proper operation of the alarms, telemetry system and auxiliary equipment.
[15A NCAC 02T .0108 (b)]
Durham Collection System Permit No. WQCS00005 Page 3 of 8

5. For each pump station without pump reliability (i.e. simplex pump stations serving more than a single
building or pump stations not capable of pumping at a rate of 2.5 times the average daily flow rate
with the largest pump out of service), at least one fully operational spare pump capable of pumping
peak flow shall be maintained on hand. [15A NCAC 02T .0305 (h) (1) (A)]
6. The Permittee shall maintain on hand at least two percent of the number of pumps installed, but no
less than two pumps, that discharge to a pressure sewer and serve a single building, unless the
Permittee has the ability to purchase and install a replacement pump within 24 hours of first
knowledge of the simplex pump failure or within the storage capacity provided in a sewer line
extension permit. [15A NCAC 02T .0108 (b)]
7. Rights -of -way and/or easements shall be properly maintained to allow accessibility to the wastewater
collection system unless the Permittee can demonstrate the ability to gain temporary access in an
emergency situation where existing land -use conditions do not allow the establishment and
maintenance of permanent access. In this case, the Permittee shall continue to observe the lines
visually, utilize remote inspection methods (e.g. CCTV) and use the opportunity of drier conditions to
perform further inspections and necessary maintenance. [15A NCAC 02T .0108 (b)]
8. The Permittee shall assess cleaning needs, and develop and implement a program for appropriately
cleaning, whether by hydraulic or mechanical methods, the wastewater collection system. At least
10 percent of the gravity wastewater collection system, selected at the discretion of the ORC, shall be
cleaned each year. Preventative cleaning is not required for sewer lines less than five years old unless
inspection otherwise reveals the need for cleaning or cleaning is required by a sewer line extension
permit. [15A NCAC 02T .0108 (b)]
9. The Permittee shall maintain a Response Action Plan that addresses the following minimum items:
a. Contact phone numbers for 24-hour response, including weekends and holidays;
b. Response time;
c. Equipment list and spare parts inventory;
d. Access to cleaning equipment;
e. Access to construction crews, contractors and/or engineers;
f. Source(s) of emergency funds;
g. Site restoration and clean up materials;. and
h. Post-SSO assessment.
[15A NCAC 02T .0108 (b)]
10. The Permittee, or their authorized representative, shall conduct an on -site evaluation for all SSQs as
soon as possible, but if feasible no more than two hours after first knowledge of the SSO. The
Permittee shall document in its 5-day report why it was unable to initially respond to any SSO location
within two hours. [15A NCAC 02T .0108 (b)]
11. In the event of an SSO or blockage within the wastewater collection system, the Permittee shall
restore the system operation, remove visible solids and paper, restore any ground area and restore
the surroundings. [15A NCAC 02T .0108 (b)l
Durham Collection System Permit No. WQCS00005 Page 4 of 8

Ill. RECORDS
1. Records shall be maintained to document compliance with Conditions 1 (4), 11 (2) - II (4), II (7) - II (8),
IV (3) and V (1) -V (4). Records shall be kept on file for a minimum of three years. [15A NCAC 02T
.0108 (b)]
2. The Permittee shall maintain adequate records pertaining to SSOs, and SSO or wastewater collection
system complaints for a minimum of three years. These records shall include, but are not limited to,
the following information:
L Date of SSO or complaint;
ii. Volume of wastewater released as a result of the SSO and/or nature of complaint;
iii. Location of the SSO and/or complaint;
iv. Estimated duration of the SSO;
v. Individual from the Division who was informed about the SSO and/or complaint, when
applicable;
vi. Final destination of the SSO;
vii. Corrective actions;
viii. Known environmental/human health impacts resulting from the SSO; and
ix. How the SSO was discovered.
[15A NCAC 02T .0108 (b))
3. The Permittee shall maintain an up-to-date, accurate, comprehensive map of its wastewater
collection system that also notes the locations where other wastewater collection systems become
tributary. If a comprehensive map of the collection system has not been established, a rough sketch
shall be drawn. The Permittee shall map approximately 10 percent of its existing collection system
each year for the next ten years beginning at the original permit issuance date, or until complete,
whichever is sooner. The comprehensive map shall include, but is not limited to: pipe size, pipe
material, pipe location, flow direction, approximate pipe age, and each pump station identification,
location and capacity. [15A NCAC 02T .0108 (b)]
4. The Permittee shall maintain records of all of the modifications and extensions to the collection
system permitted herein. The Permittee shall maintain a copy of the construction record drawings
and specifications for modifications/extensions to the wastewater collection system for the life of the
modification/extension. Information concerning the extension shall be incorporated into the map of
the wastewater collection system within one year of the completion of construction. The system
description contained within this permit shall be updated to include this modification/extension
information upon permit renewal. [15A NCAC 02T .0108 (b)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. In the event of an SSO the Division may require monitoring that is necessary to ensure surface water
and groundwater protection and an acceptable sampling and reporting schedule shall be
implemented. 115A NCAC 02T .0108 (c)]
2. The Permittee shall verbally report to a Division of Water Resources staff member at the Raleigh
Regional Office, at telephone number [phone] as soon as possible, but in no case more than
24 hours following first knowledge of the occurrence of the following circumstances within the
Durham Collection System Permit No. WQCS00005 Page 5 of 8

collection system which is under the Permittee's ownership or maintained and operated by the
Permittee through a perpetual legal agreement:
a. Any SSO and/or spillover 1,000 gallons to the ground; or
b. Any SSO and/or spill, regardless of volume, that reaches surface water.
Voice mail messages or faxed information shall not be considered as the initial verbal report. SSOs (and
other types of spills) occurring outside normal business hours may also be reported to the Division of
Emergency Management at telephone number [phone] or [phone].
Persons reporting any of the above occurrences shall file a spill report by completing Part I of Form
CS-SSO (or the most current Division approved form), within five business days following first
knowledge of the occurrence. This report shall outline the actions taken or proposed to ensure that
the problem does not recur. [G.S. 143-215.1C(a1)]
3. The Permittee shall meet the annual reporting and notification requirements provided in North
Carolina General Statute §143-215.1C.
V. INSPECTIONS
1. The Permittee or the Permittee's designee shall inspect the wastewater collection system regularly to
reduce the risk of malfunctions and deterioration, operator errors, and other issues that may cause
or lead to the release of wastes to the environment, threaten human health or create nuisance
conditions. The Permittee shall keep an inspection log or summary including, at a minimum, the date
and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken
by the Permittee. [15A NCAC 02T .0108 (b)]
2. Pump stations that are not connected to a telemetry system (i.e., remote alarm system) shall be
inspected by the permittee or its representative every day (i.e., 365 days per year). Pump stations
that are connected to telemetry shall be inspected at least once per week. [15A NCAC 02T .0108 (b)]
A general observation by the permittee or its representative of the entire wastewater collection
system shall be conducted at least once per year. [15A NCAC 02T .0108 (b)]
4. inspections of all high priority lines (i.e. aerial line, sub -waterway crossing, line contacting surface
waters, siphon, line positioned parallel to stream banks that are subject to eroding in such a manner
that may threaten the sewer line, or line designated as high -priority in a permit) shall be performed
at least once per every six-month period of time. A list of high -priority lines is presented as
Attachment A and is hereby incorporated into this permit condition. New high priority lines installed
or identified after permit issuance are incorporated by reference and subject to this permit condition
until permit renewal where they shall be referenced in writing in Attachment A. [15A NCAC 02T.0108
(b)]
VI. GENERAL CONDITIONS
1. This permit is not transferable. In the event that the Permittee desires to transfer ownership of the
wastewater collection system or there is a name change of the Permittee, a formal permit
modification request shall be submitted to the Division. The request shall be accompanied by
documentation from the parties involved, and other supporting materials as may be appropriate.
Durham Collection System Permit No. WQCS00005 Page 6 of 8

Such request will be considered on its merits and may or may not be approved. [15A NCAC 02T .0104;
G.S. 143-215.1(d)(3)]
2. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee
to an enforcement action by the Division in accordance with North Carolina General Statute §143-
215.6A through §143-215.6C, and a sewer moratorium may be established. [15A NCAC 02T .0104]
3. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances that maybe imposed by other government agencies (i.e., local, state,
and federal) having jurisdiction. [G.S. 143-215.1(b)]
4. The issuance of this permit does not prohibit the Division from reopening and modifying the permit,
revoking and reissuing the permit or terminating the permit as allowed by the laws, rules, and
regulations or as needed to address changes in federal regulations with respect to the wastewater
collection system, in accordance with required procedures. [G.S. 143-215.1(b)(4)]
S. The Permittee shall pay the annual fee within thirty (30) days after being billed by the Division. Failure
to pay the fee accordingly may cause the Division to initiate action to revoke this permit.
[15A NCAC 02T .0110 (4)]
6. The Permittee shall file an application for renewal of this permit at least six months prior to the
expiration of this permit. Upon receipt of the request, the Director will review the adequacy of the
wastewater collection system described therein, and if warranted, will extend the permit for a period
of time and under such conditions and limitations, as the Director may deem appropriate. [15A NCAC
02T .0109]
7. The Permittee shall notify the Division's Pretreatment, Emergency Response and Collection Systems
Unit in writing at 1617 Mail Service Center, Raleigh, North Carolina 27699 of any changes to the name
and/or address of the responsible party (i.e. mayor, city/town manager) of the wastewater collection
system. [15A NCAC 02T .0106 (c)]
8. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the collection system
at any reasonable time for the purpose of determining compliance with this permit, may inspect or
copy any records that must be maintained under the terms and conditions of this permit, and may
obtain samples of wastewater, groundwater, surface water, soil, or plant tissue.
[15A NCAC 02T .0110 (3)]
9. The Permittee or their authorized representative shall have available a copy of this permit to present
upon request by any duly authorized officer, employee, or representative of the Division.
[15A NCAC 02T .0104]
VII. SPECIAL CONDITIONS
1. The local sewer permitting program that has been delegated to the Permittee by the Environmental
Management Commission (EMC) may be suspended or revoked unless the documentation within the
approved delegation application package and any modifications thereto are valid, the requirements
in 15A NCAC 2T .0306 and General Statute §143-215.1(f) are met, the conditions of this permit are
met, and the wastewater collection system extensions are constructed in accordance with the
conditions and specifications of the delegated program. [G.S. 143-215.1(f)(1)]
Durham Collection System Permit No. WQCS00005 Page 7 of 8

The local sewer permitting program shall require that all wastewater collection system extensions
meet the minimum design requirements in 15A NCAC 2T .0305 as well as any Division adopted
minimum design criteria. 1G.S. 143-215.1(f)]
The local sewer permitting program shall obtain approval from the Raleigh Regional Office, at
telephone number [phone], prior to issuing any permits for wastewater collection system
extensions in accordance with the agreement between the Regional Office Regional Office and the
Delegated Program for block flow allocation. [15A NCAC 02T .0306 (d) (1)]
4. The local sewer permitting program shall submit quarterly reports to the appropriate Division
Regional Office on forms provided or approved by the Division. [15A NCAC 02T .0306 (d) (2)]
The Division shall continue to permit activities not delegated to the Permittee as specified in the
delegation approval letter or in accordance with 15A NCAC 02T .0306(a). [15A NCAC 02T .0306 (a)]
Permit issued this the 16th of August, 2018
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
for Linda Culpepper
Interim Director, Division of Water Resources
By Authority of the Environmental Management Commission
by Deborah Gore, Pretreatment, Emergency Response, Collection System Unit Supervisor
Division of Water Resources, NCDEQ
Durham Collection System Permit No. WQCS00005 Page 8 of 8

DocuSign Lrivelop, ID OCAFlIC57.120A-4E53.911r4.224-CI-231432
I'. ' ,Ik11 ,
Certified Mail # 7017 0190 0000 2486 0377
Return Receipt Re juested
Donald F Greeley
City of Durham
101 City Nall Plz
Durham, NC 27701-3329
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CERTIFIED MAWO RECEIPT
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101 CITY HALL PIL _
OURIIAM,NC 27701
r9 Wq: NOV S INT TO ASSESS CIVIL PNLiY/NOV-2024-OV-0156
C3 WClCS000OS/DURHAM COLLECTION SVS/DIJR11A
f` 70170190000o2486o377 M;03/IS/2024
.{,'icy. S%T
March 13, 2024
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0156
Sanitary Sewer Overflows - February 2024
Collection System Permit No. WQCS00005
Durham Collection System
Durham County
Dear Mr. Greeley:
A review has been conducted of the self-rLtported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Durham. The Division's Raleigh Regional Office concludes that the City of Durham violated Permit Condition
I (2) of Permit No. WQCS00005 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-2.1S.1.
The Raleigh Regional Office is providing the City of Durham an opportunity to provide evidence and justification as
City of D n _;1
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