WQCS00005_NOV-2024-DV-0369_Response-to-Noptice_20241017.docx

WATER MANAGEMENT
CITY OF
DURHAM
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
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City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4344
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October 17, 2024
Subject: Response to NOV-2024-DV-0369
Dated: September 25, 2024; Received: October 1, 2024
Permit No. WQCS00005
Receipt of Delivery
Subject: Response to NOV-2024-DV-0369
Dated: September 25, 2024; Received: October 1, 2024
Permit No. WQCS00005
Receipt of Delivery

WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4344
October 14, 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-0369
Dated: September 25, 2024; Received: October 1, 2024
Permit No. WQCS00005
Dear Ms. Manuel,
Please permit this letter to respond to the above referenced Notice of Violation & Intent to
Issue Civil Penalty received on October 1, 2024. As graciously requested in the letter, the
following evidence anti justification demonstrates that this event was 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 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 SSO that occurred in
the City's wastewater collection system between August 1, 2024 and August 31, 2024.
Incident# 202401491- 303 West Alton Street - August 8, 2024 4:43 PM
On August 8, 2024 at approximately 4:43 PM, an overflow occurred near 303 West Alton Street
releasing an estimated 1,545 gallons of wastewater into an unnamed tributary of Third Fork
Creek. After initial attempts to clear the line were unsuccessful, crews used a JetVac truck to
clear the blockage at approximately 10:01 pm.

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).
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 hazards to persons or property, including no fish kill or
unnecessary vegetative damage.
Crews determined that the cause of the spill was a combination of factors, the first being the
increased flow from the Tropical Storm Debbie which dropped between 4-6 inches of rain on
the Durham area between Friday and Sunday when this spill occurred. The Department takes
great care with severe weather preparedness, planning days before to ensure adequate
equipment, materials, and staffing are available to address concerns in a timely manner. The
Department has focused resources on identifying areas with high inflow and infiltration in order
to identify assets that could potential surcharge during heavy rain and building a map layer to
help facilitate pre and post -storm inspections in high risk areas.
The secondary factor identified by staff was non -woven materials in the line. After immediate
remediation and cleaning of the affected assets, the Industrial Waste team was notified.
Industrial Waste staff blanketed the immediate community around the spill site with 104
mailers regarding appropriate disposal of waste, specifically non -woven materials.
The Department's cost to remediate this spill was $1,773.94 for equipment, labor, and material
costs.
The incident leading to this spill is unintentional, temporary, and caused by factors beyond
reasonable control. 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.
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 FY24, DWM spent approximately $16.1 million on Sewer Rehabilitation projects for linear
sewer assets as a part of its Capital Improvement Program. 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
FY25 (YTD)
23.58
2.05%
FY24
134.97
11.72%
FY23
119.86
10.40%
FY22
116.16
10.14%
Table 1. Unique mileage of gravity mains cleaned by DWM Staff for the three most recent fiscal year and current.
Sewer Rehabilitation Program:
DWM has an active Sewer Rehabilitation Program. The program includes flow monitoring (15
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 Line Maintenance (CLM) 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 CLM 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 64
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 past-SSO follow-up education and enforcement as necessary. DWM invests over
$30,000 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 and should have no Civil Penalty. 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 meat [phone] or via email at Don. Greeley@ durhamnc.pov.
Sincerely,
Donald F. Greeley,
Director
Attachments
C: Kevin Fowler, D_ FQ-- Water Quality Regional Operations Section, Raleigh Regional Office
Kenny Willard, Superintendent, Sewer Maintenance, Water Management
Scott Smart, Assistant Director, Water Management

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SSO at 303 W. Alton Street
Lunne, Joe <[e-mail]>
Fri 8/9/2024 1.45 PM Q
News Media Contact
Joe Lunne, SR Public Information & Communication
COMMUNICATIONS Analyst
Water Management Dept.
CITY OF DURHAM 919.560.4381 ext. 35255 1919.397.6131 (mob'le)
Joe [e-mail]
News Release
For Immediate Release. August 9. 2024
City of Durham contains sewer spill at 303 W. Alton Street
DURHAM, N.C. —The City of Durham Department of Water Management reports that on August 8, 2024, staff
responded to a manhole overflowing at 303 W. Alton Street. Approximately 1,545 gallons of untreated
wastewater flowed into an unnamed tributary of Third Fork Creek. The cause of the overflow was debris
blocking the sewer line.
Staff were notified of the overflow at 4:53 p.m. on August 8, 2024, and the overflow was stopped at 10:02
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 Environmental Quality Division of Water Resources was notified of the event on
August 8, 2024 as required by state regulations/law. For more information, contact Kenny Willard,
Superintendent, Collection System Maintenance.
N
101 City Hall Plaza. $"and Roof, Durham, NC 27701 919.560.4123 I DurhaniNC goy Foqaw Us @CityofDurhamNC
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1601 State of North Carolina
DWk
Department of Environment and Natural Resources
�C Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Dlvlsion of water Resources 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: WOCS00005 (WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System Incident #: 202401491
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): 303 WEST ALTON STREET, DURHAM
Manhole #: 15796
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 08/08/2024 Time: 4:53 pm Incident End Dt: 08/08/2024 Time: 10:02 pm
(mm-dd-yyyy) (hh: mm AMIPM) (mm-dd-yyyy) (hh:mm AMIPM)
Estimated Volume of the $SO: 1,545 gallons Estimated Duration (Round to nearest hour): 5:9 hours
Describe how the volume was determined: 309 minutes X 5gpm = 1,545 gal.ons
Weather conditions during the SSO event: Wet/Raining
Did SSO reach surface waters? [a Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 1545
Surface water name: Third Fork Creek
Did the SSO result in a fish kill? ❑ Yes 10 No ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
[Jf Severe Natural Con( RT Debris in line
24 hour verbal notification (name of person contacted ): Jamie Johnson
❑ DWR [Z Emergency Mgmt Date (mm-dd-yyy): 08/08/2024 Time (hh:mm AMIPM): 11:35:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director Division of Water Resources may take enforcement action for SSOs that are required to be re orted 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 SE.CTONS 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
Severe Natural Condition
Describe the "severe natural condition" in detail?
Hurrican Debbie came ashore in Florida and moved north along the east coastline weakening to a tropical storm as it
moved into the Durham area.
How much advance warning did you have and what actions were taken in preparatio
for the event?
News reports of the Hurricane started aporoximately a week prior to the event. Crews prepared for the event by being on
standby for any emergency conditions that arose in the collections system, as well as the lift stations.
Comments:
The SSO was not caused in any part by Hurrican Debbie or the tropical storm it turned into but rather by debris in the ma
that had built uP over time.
Debris in line
What type of debris has been found in the line?
Rags. Steel Wool, Hair, Floss.
Suspected cause or source of debris.
Residential usage.
Are manholes in the area secure and intact? ,❑/ Yes ❑ No ❑ NA ❑ NE
When was the area last checked/cleaned?
08/10/2023 & 9/1 1/23
Have cleaning and inspections ever been increased at this location due to previous ❑ Yes [Z No ❑ NA ❑ NE
problems with debris?
Explain:
Are appropriate educational materials being developed and distributed to prevent futi [0 Yes ❑ No ❑ NA ❑ NE
similar occurrences?
Comments:
We have forwarded this matter to our Indugtrial Waste Control Division. They will inform the residents on what and what
cannot be Flushed.
System Visitation
O RC
Backup
❑ Yes
[Tj Yes
CS-SSO Form Page: 2

Name -
Todd Ferry
Cert#
1007498
Date visited:
08/08/2024
Time visited-
11:00 PM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews received a call for sewerspilling out of manhole 15796 at 4:53 Pm. Crews responded with the quick response trucl
and attempted to clear the -blockage, however, were unsuccessful. Crews went back and retrieved a vac truck and return(
to the site. Crews jetted and cleared the blockage at 10:02 pm Crews cleaned the sewer debris off the street by washing -
back into the spill manhole_ Crews then set up a pump on Weaver St and oumped the untreated wastewater back into the
system at manhole 10912. The overflows ill rate was at 59pm for 309 minutes resulting 1,545 gallons of untreated sewe-
water reaching an unnamed tributary of third fork creek. Crews set uR a diffuser at 2201 Dallas St to push the wastewater
down to the pump.
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: Todd A Fer
Signature:
Telephone Number: I rl -, 2 / -76 G3 (-
Date: 08/13/24 12:00 am
Title: M A ;
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of i
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 3