WQCS00005_DV-2024-0100 Civil Penalty Assessment Folder_20241008

ROY COOPER
Cowmar
MARY PENNY KELLEY
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7017 0190 0000 2485 9166
Return Receipt Requested
Don Greeley
City of Durham
101 City Hall Piz
Durham, NC 27701-3229
NORTH CAROLINA
Environmental Quality
October 8, 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-2024-0100
Durham County
Dear Permittee:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $1,601.00 ($1,500.00 civil penalty
+ $101.00 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)(]) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
D_EQ� NnrlhC.irnhnaDepanwnio(FnviranmenialQuality Divl%lonnfWater Reamirre%
Raleigh Regloml Offke 3800 barretl Drive Raklyh North laroliru 17b04
M� _0 919.791.4200

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 Vanessa
Manuel, Assistant Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against
City of Durham:
$1,500.00 For 2 of the 2 violations of Collection System Permit No. WQCS00005 and G.S. 143-215,1(a)(]) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
$1,500.00 TOTAL CIVIL PENALTY
$101.00 Enforcement Costs
$1,601,00 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.I (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

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) days of receipt of this
notice. The Division of Water Resources also reguests 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
AND
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

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
filingprocess.
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
dateltime 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,
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Laserfiche

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2024-0100
Assessed Party: City of Durham
Permit No.: WQCS00005
County: Durham
Amount Assessed: $1,601.00
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 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. 14313-282.1(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 unavoidahle 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:

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-2024-0100
Having been assessed civil penalties totaling $1,601.00 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated October 8, 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
ADDRESS
TELEPHONE
- — — ] 20
SIGNATURE

PERMIT NO: WQCS00005
FACILITY: Durham Collection System
Other Violations
INCIDENT VIOLATION
NUMBER DATE VIOLATION TYPE
ATTACHMENT A
City of Durham
CASE NUMBER: DV-2024-0100
REGION: Raleigh
COUNTY: Durham
TOTAL VOLUME PENALTY
VIOLATION DESCRIPTION (GALLONS) AMOUNT
202400778
4/12/2024
CSOISSO(Sewer Overflow)
Discharge without valid permit
5,670
$750.00
202400821
4/23/2024
CSOISSO(Sewer Overflow)
Discharge without valid permit
3,260
$750.00

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Durham
Facility Name: Durham_ Collection System
Permit Number: Wo CS00005
County: Durham
Case Number: DV-2024-0100 (Incident # 202400778)
ASSESSMENT FACTORS
l) 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 5,670 gallons of wastewater overflowed from the Durham Collection System due to debris in line. 5,670 gallons
of wastewater flowed to Northeast Creek, a class WS-V;NSW in the Cape Fear Basin. Nutrients and pathogens to surface
waters.
2) The duration and gravity of the violation;
The SSO started on 04.12.2024 at 09:06 AM and ended the same day at 12:05 PM.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on surface water quality include nutrients and pathogens to surface waters.
4) The cost of rectifying the damage;
The cost of rectifying the damage was given as $16,892.24.
5) The amount of money saved by noncompliance;
It is believed that no money was saved by nomcompliance.
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 5 enforcement cases within the past 12 months.
8) The cost to the State of the enforcement procedures.
$101.00
Date Vanessa Manuel, Assistant Regional'supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Durham
Facility Name: Durham Collection System
Permit Number: WOCS00005
County: Durham
Case Number: DV-2024-0100 (Incident # 202400821)
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 3,260 gallons of wastewater overflowed from the Durham Collection System due to grease. 3,260 gallons of
wastewater flowed to Crooked Creek, a class WS-V;NSW in the Cape Fear Basin. Nutrients and pathogens to surface
waters.
2) The duration and gravity of the violation;
The SSO started on 04.23.2024 at 09:37 AM and ended the same day at 12:20 PM.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on surface water quality include nutrients and pathogens to surface waters.
4) The cost of rectifying the damage;
The cost of rectifying the damage was given as $ l 6,844,69.
5) The amount of money saved by noncompliance;
It is believed that no money was saved by nomcompliance.
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 5 enforcement cases within the past 12 months.
8) The cost to the State of the enforcement procedures.
$101.00
Date Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

I M WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4344
July 1, 2024
Ms. Vanessa Manuel, Assistant 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-0237
Dated: May 23, 2024; Received: June 17, 2024
Permit No. WQCS00005
Dear Ms. Manuel,
SCANNED
JUL - 2 �0 4
Please permit this letter to respond to the above referenced Notice of Violation & Intent to
Issue Civil Penalty received on June 17, 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 any unquantifiable or 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 (SSO). 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 April 1, 2024 and April 30, 2024.
Incident#202400778 — April 12, 2024 — 448 Martin Luther King Jr Parkway
On April 12, 2024 at approximately 9:06 AM, an overflow was reported near 448 Martin Luther
King Jr Parkway releasing an estimated 5,670 gallons of wastewater into a tributary of
Northeast Creek. Crews responded promptly and discovered that non -woven rags were the
cause of the blockage and used a JetVac truck to clear the line. Crews dammed the downstream
creek 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 upstream and downstream pipe reaches to ensure the pipes
were clear.
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Image 1. Spill location and cleaning efforts for Incident#202400778 448 Martin Luther King Jr. Pkwy
The incident leading to this spill is exceptional, unintentional, temporary, and caused by factors
beyond reasonable control. 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.
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.
In addition, 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
distributed 152 mailings regarding the appropriate disposal of nonwovens and grease to
educate the community.

The Department's cost to remediate this spill was $16,892.24.
Incident#202400821— April 23, 2024 — 6100 Pine Glen Trail
On April 23, 2024 at approximately 9:37 AM, an overflow occurred near 6100 Pine Glen Trail
releasing an estimated 3,260 gallons of wastewater into a tributary of the Crooked Creek basin.
Crews discovered that debris and grease in the line was the cause of the blockage and used a
JetVac truck to successfully clear the line. Crews carefully dammed the downstream creek 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 City -owned upstream and downstream pipe reaches to ensure the pipes
were clear.
Gravity Main Clean ng Update - Pine Glen & NC 54 SSO Area '
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Image 2. Spill location and cleaning efforts for lncidentli202400821 6100 Pine Glen Trail
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 for areas
identified, 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.

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.
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. Staff distributed 132 mailings regarding
rags and grease. They also delivered 168 Newsletters for circulation to tenants and 200 cards
for future tenants. Industrial Waste staff educate the community about the appropriate
disposal options, as well as providing interactive giveaways like grease trappers through the
website.
The Department's cost to remediate this spill was $16,884.69.
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, to date
115.24
10.09%
FY23
119.86
10.40%
FY22
116.16
10.14%
Table 1. Unique mileage of gravity mains cleaned by DWM Staff far 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 8imbd 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 at Don.Greeleyl2durhamnc.gov.
Sincerely,
Donald F. Greeley,
Director
Attachments
C: Kevin Fowler, DEQ—Water Quality Regional Operations, Raleigh Regional Office
Kenny Willard, Superintendent, Sewer Maintenance, Water Management
Scott Smart, Assistant Director, Water Management

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Certified Mail # 7017 0190 0000 2486 0704
Return Receipt Requested
May 23, 2024
C Dept `J4 Quali,Y
Donald F Greeley JUL 2 2024
City of Durham
101 Durhamty , IPiz alGi
m, NC27701-3329;' Pcg:a.�.a
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No,: NOV-2024-DV-0237
Sanitary Sewer Overflows - April 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
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 malting 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
202400778 4/1212024
202400821 4/23/2024
179 448 Martin Luther King Debris in line
Jr Parkway, Durham,
NC, 27713
163 6100 Plne Glen Trail,
Durham, NC, 27713
� D_E
Grease
5,670 5,670 Notice of Violation -
Intent to Assess
3,260
3,260
Notice of Violation -
Intent to Assess

DocuSign Envelope ID (}3' 89687-11A4-452E-B3DD-F3E9C9F6456D
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
QEQ��
Sincerely,
OocuSigned by:
V&1A,t,SSa'E. h& LU
- 02914EGA032144F
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

DocuSign Envelope ID: 03FB9687-11A4-452E-B3DD-F3E9C9F6456D
ROY COOPER
Gnvp,ry0r �i _ �j
ELIZABETH S. BISER w
Srcretury w•�'
RICHARD E. ROGERS, JR. NORTH CAaauNA
Dirrrror Environmental Quality
Certified Mail # 7017 0190 0000 2486 0704
Return Receipt Requested
May 23, 2024
Donald F Greeley
City of Durham
101 City Hall Piz
Durham, NC 27701-3329
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0237
Sanitary Sewer Overflows - April 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 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.
143-215.1.
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
202400778 4/12/2024 179 448 Martin Luther King Debris in line 5,670 5,670 Notice of Violation -
Jr Parkway, Durham, Intent to Assess
NC, 27713
202400821 4/23/2024 163 6100 Pine Glen Trail, Grease 3,260 3,260 Notice of Violation -
Durham, NC, 27713 Intent to Assess
�� N ih [xd... Mp.mm�+dEn.xw.e.natQ.ulry o.ALridwne. a.,a..n
o,irpnc.gdiar r vnasrnuom. 9,+rgl.n..ihGrd`e.i7e0Q
vQT4u700

DocuSign Envelope ID- 03FB9687-11A4-452E-B3DD-F3E9C9F6456D
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,
DocuSlyned by:
Voun�.SSa f. 111.aun.la
B2916E6AB32144F
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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State of North Carolina
DWR
Dlvlslon of Water Resources
PART I:
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00005
(WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System Incident #: 202400821
Owner: City of Durham
City: Durham
County: Durham
Region: Raleigh
Source of SSO (check applicable): 0 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): 6100 Pine Glen Trail, Durham, NC, 27713
Manhole #: 02557
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 04i2312024 Time: 9:37 am Incident End Dt: 04/23/2024 Time: 12:20 pm
(mm-dd-yyyy) (hh:mm AMIPM) (mm-dd-yyyy) (hh:mm AMIPM)
Estimated Volume of the SSO: 3.260 gallons Estimated Duration (Round to nearest hour): 2:43 hours
Describe how the volume was determined: 163 minutes X 20gpm
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? [l Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 3260
Surface water name: Crooked Creek
Did the SSO result in a fish kill? Q Yes ❑ No ❑ Unknown If Yes, what is the estimated number of fish killed? 2
SPECIFIC cause(s) of the SSO:
0 Grease
24 hour verbal notification (name of person contacted ): Tyler Clark
.7 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 04123/2024 Time (hh:mm AMIPM): �02:27:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director Division of Water Resources may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form Page: 1

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Grease
When was the last time this specific line (or wet well) was cleaned?
05/14/2018
Do you have an enforceable grease ordinance that requires new or retrofit of grease W Yes ❑ No ❑ NA [] NE
traps/interceptors?
Have there been recent inspections and/or enforcement actions taken on nearby [j Yes [0 No ❑ NA ❑ NE
restaurants or other nonresidential grease contributors?
Explain.
We have not have a issue in the area but will enforce documentation to the nearbV area apartments that are the root of th
issue.
Have there been other SSOs or blockages in this area that were also caused by
grease?
When?
NA
If yes, describe them:
NA
Have cleaning and inspections ever been increased at this location?
Explain.
na
Have educational materials about grease been distributed in the past?
When?
NA
and to whom?
NA
Explain?
Yes 0 No ❑ NA ❑ NE
Yes RjNo [7)NA []NE
r' Yes [ No F- NA ❑ NE
We currently have our F.O.G. team l2assing out verbiage to local residents and also put out a l2ress release on grease an
non -woven issues.
If the SSO occurred at a pump station, when was the wet well and pumps last
checked for grease accumulation?
NA
CS-SSO Form Page: 2

Were the floats clean?
E] Yes 2 No [ NA ❑ NE
Comments:
I forwarded all information to the F.O.G. admin team to make sure we pass out verbiage to all nearby residents and we w
also monitor the area for issues moving forward. We will keep area on hots of monitoring Program until we see area is fit
for removal.
System Visitation
ORC
Backup
Name:
Larry Edward Hughes
Cert#
1005483
Date visited:
04/23/2024
Time visited:
1:00gm
How was the SSO remediated (i.e. Stopped and cleaned up)?
[I Yes
W,I Yes
Crew arrived on scene at 12:00 m to find manhole 02557 overflowing at 20qpm. Crew remediated spill by Oet truck water
pressure. They flushed line pulling back severe grease. We set up a bypass Pump upstream with sandbags to block the
creek and used the purng to remove all untreated wastewater and Pump it back into the collections system. Crew used
hydrant meter with defuser to helo vush the untreated wastewater to the bypass Dump. Crew cleaned up around removir
soil with the vac/'et combo and replaced area and put down seed and straw. Crew will also flush 3 assets above and 3
assets below to ensure no further issues arise in the area. Storm water gualfty will be called once creek is 100% clear of
any wastewater and residual.
As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Larry Edward Hughes Date: 04/24/24 01A9 pm
Signature:
Telephone Number:
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of f
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 3

Dkislon of Water Resources
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
PART f:
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00005
(WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System Incident #: 202400778
Owner: City of Durham
City: Durham
Source of SSO (check applicable):
County: Durham
Region: Raleigh
2 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): 448 Martin Luther King Jr Parkway, Durham, NC, 27713
Manhole #: 11772
Latitude (Decimal Degrees):
Incident Started Dt: 04/12/2024 Time
(mm-dd-yyyy)
Estimated Volume of the SSO: 5,670
Longitude (Decimal Degrees):
9:06 am
(hh:mm AM/PM)
Incident End Dt: 04/12/2024 Time: 12:05 pm
(mm-dd-yyyy) (hh:mm AMIPM)
gallons Estimated Duration (Round to nearest hour): 2:59 hours
Describe how the volume was determined: 30gpm x 189minutes = 5,670gallons
Weather conditions during the SSO event: clear and Dry
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 5670
Surface water name: Northeast Creek
Did the SSO result in a fish kill? ❑ Yes [INo ❑ Unknown if Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
0 Debris in line
24 hour verbal notification (name of person contacted ): Chris Smith
0 DWR [] Emergency Mgmt Date (mm-dd-yyy): 04/12/2024 Time (hh:mm AM/PM): 02:46:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director Division of Water Resources may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part 11 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?
nonwovens Ra s was on the round and on the cleaninq nozzle as well
Suspected cause or source of debris.
The Businesses and homes in the area.
Are manholes in the area secure and intact?
When was the area last checked/cleaned?
being added to upcoming CCTV contract
Yes W No ❑ NA ❑ NE
Have cleaning and inspections ever been increased at this location due to previous ❑ Yes W No ❑ NA [] NE
problems with debris?
Explain:
This line is currently being added to the upcoming CCTV and cleaning contract
Are appropriate educational materials being developed and distributed to prevent futi W Yes ❑ No ❑ NA ❑ NE
similar occurrences?
Comments:
We will have the team distribute educational material about nonwovens in the area.
System Visitation
ORC Yes
Backup 1;7 Yes
Name:
Terrance Vasquez
Cert#
1003853
Date visited:
04/12/2024
Time visited:
11:00 a.m
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
The staff responded to a sewer overflow at 448 MARTIN LUTHER KING JR PKWY that got called in at 9:06 am. When th
crew arrived, they found
Manhole11772 overflowing at a rate of 30qpm. Crew was able to stop the overflow at 12.15 gm for a totalspillage of 5,67(
gallons in Northeast Creek.
Crew set ug a hydrant meter box and a defuser at 717 Belgreen Rd. to heir) push untreated wastewater to the bypass
pump. The crew tested the creek downstream and used sandbags to block it off. They then set up a 4-inch Dump to puM
all untreated wastewater back into sewer manhole 06770. There was no sign of fish kill and DWQ was notified of the
overflow at 2:46 p.m.
The cause of the overflow was nonwovens Rags. The spill site was remediated with equipment excavator, skid steer,
durng truck. The crew cleaned three lines above and below s ill manhole 11772
As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Terrance Vasquez Date: 04/12/24 02:46 pm
Signature:
Telephone Number:
Title:
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

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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 t 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)j
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. [15A NCAC 02T .0108 (b)]
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. 143-215.913; 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. 143-215.961
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 fails, 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. [15A 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)]
IL OPERATION AND MAINTENANCE REQUIREMENTS
Upon classification of the collection system by the Water Pollution Control System Operators
Certification Commission (WPC50CC), 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.]
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)]
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 SSOs 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)]
Durham Collection System Permit No. WQCS00005 Page 4 of 8