WQCS00002_NOV-2020-DV-0040 Response_20200218

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Raleigh Water
February At"', 2019
Mr. Scott Vinson
Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources NCDFQ
1628 Mail Service Center
Raleigh, NC 27699-1628
�nv�Tontr,entat Qualt�
14C-Dept of
Re: Response to NOV-2020-DV-0040
Sanitary Sewer Overflows: October, November and December 2019
Permit No. WQCS00002
Dear Mr. Vinson:
i hRegtona1 Office
etc g
Please allow this letter to serve as a response to the Notice of Violation that was received on
February 6th, 2020, regarding pending violation actions of (8) Sanitary Sewer Overflow (SSO) events
which occurred during the fourth quarter of the 2019 calendar year within the City of Raleigh Collections
System M. The noticed events occurred while the City operated its collection system, according to
WQCS00002, dated June 6th, 2017. The permit includes the language outlined in footnote 1 and applies
to the SSOs upon which NOVs with the notice of intent (NOV-NOI) were based. This document will
establish a reasonable explanation of the action taken to mitigate and restore the possible
environmental impacts brought by the release of these SSOs events, listed with intended NOV-NO[
action. Please find below, the additional information requested for each of the SSO events.
1. "The Director may take enforcement act an ago Inst thr Permittee for SSDS that must be reported to the Divisior as stipulated In Condit an IV92). This Includes
SSOs that were caused by severe natural conditions c r ex;eptional events unless the Permittee demonstrates thro,jgh properly signed, contemporaneous operating
logs, or other relevant evidence that:
[a.) The SSO was caused by severe natural conditions; there were no feasible alternatives to the SSO, such as the use of auxiliary treatment facilities, retention
Of untreated wastewater, reduction of Inflow and Infiltration, use of adequate back-up equipment, or an Increase In the capacity of the system. This provision Is
not satisfied If, In the exercise of reasonable engineering judgment, the Permittee should have Installed auxiliary or additional collections system components,
wastewater retention or treatment facilities, adequate backup equipment or should have redu:ed Inf'ow and infiltration; or
[b.) The SSO was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the Permittee; the SSO could not have been
prevented by the exercise of reasonable control, such as proper management, operation, and maintenance; adequate treatment or collection facilities or
components (e.g , adequately enlarging treatment of collection facilities to accommodate growth or adequately controlling and preventing infiltration and
i-rrlow); preventative maintenance; or Installation of adequate back-up equipment;"
One Exchange plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Spill event # 201901618—10/04/2019 — MH # 817 McMakin St. Raleigh
This sewer spill event was the result of a build-up of grease and debris, blocking a portion of an
8" Vitrified Clay Pipe (VCP). This build-up led to a sewer spill of approximately 3000 gallons of untreated
waste water reaching surface waters through Watson Branch (U5G5 blueline streams) within the Walnut
basin.
On 10/04/2019, at approximately 1:40 PM, Sewer Maintenance staff was notified of a sewer
back-up at 817 McMakin St. Raleigh. Upon arrival, it was discovered that untreated sewer was
emanating from an adjacent manhole within the apartment complex. The responding staff took all
reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived, gaining
control of the spill event by 3:40 PM on the same day. Containment, collection, cleanup, and restoration
of this spill event consisted of employing a temporary sewer containment site (dam) downstream from
the SSO location with the intent to stop the flow of sewer into the stream (Watson Branch). Crews
employed pumps at the temporary containment site, to recover the remaining sewer back into a
downstream sewer manhole. During the restoration phase of the operation, crews utilized water from
adjacent hydrants to defuse and flush the affected area. The areas around the manhole were cleared of
debris, treated with an application of lime, and restored with grass seed and straw. There was no
observed fish kill or unnecessary vegetative damage associated with this SSO. The cost associated with
the mitigation of this event amounted to $1,861.12. The approximate cost to the Utility to have treated
3,000 gallons of wastewater would have been approximately $4.15.
This section of the collection system serves a residential area south of Martin Luther King Blvd.,
Raleigh. The last sewer spill near this address was recorded on 11/26/2002. Maintenance records show
that sections of the collection system were last assessed on 08/05/2019. A follow-up CCTV inspection
conducted on 10/24/2019 showed an angular defection on a pipe that may have contributed to the spill.
This pipe issue was transferred to CIP for repair.
Outreach information was delivered on 10/08/2019 to approximately 56 residents upstream of
the SSO and within the affected area. This outreach literature explains the need for customers to use the
sanitary sewer collection system properly. It also serves as an opportunity for citizens to partner with
Public Utilities to protect the City's water quality and the sewer collection infrastructure.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Regcled Paper

'Spill event # 201901743--11/05/2019 — 6701 Fox Rd., Raleigh, NC
This spill event was the direct result of approximately 700 lbs. of construction debris found to be
obstructing a segment of 8-inch Ductile Iron Pipe (DIP). The manhole where this debris was found is
located on an active private construction site. This obstruction led to a sewer spill of approximately
4,000 gallons of untreated waste water, in which approximately 500 gallons reached an open
stormwater channel.
On 11/5/2019, at approximately 9:S5 AM, the Sewer Maintenance staff were notified of a sewer
overflow emanating from a manhole. The responding staff took all reasonable steps to stop and mitigate
the impact of the discharge as soon as they arrived, gaining control of the spill event by 11:00 AM on the
same day.
Containment, collection, cleanup, and restoration of this spill event consisted of employing a
temporary sewer containment site (dam) near the manhole that spilled to contain approximately 3,500
gallons of untreated sewer. Sewer from the containment site was collected and re -introduced into an
adjacent manhole. Crews conducted a confined space entry into the manhole (SMH194326)
immediately downstream of the affected manhole (SMH163949) to manually remove pieces of bricks
and concrete at the bottom invert structure. The sections of debris recovered, ranged in size larger than
the diameter of the pipe, which leads the Utility to believe that the debris may have been dumped
during construction activity by a contractor. Furthermore, approximately 1,500 ft of downstream sewer
pipe and manholes were cleared of smaller construction debris, thus re-establishing normal flow. Follow
CCTV inspection conducted on 12/4/2019 confirmed that the construction debris was removed for the
sanitary sewer gravity main.
During the restoration phase of the operation, crews utilized ample water from an adjacent
hydrant to flush and defuse the affected area. The surface around the affected manhole was cleared of
debris, treated with an application of lime, and restored with grass seed and straw. Crews also flushed
approximately 600 ft of the stormwater channel, ensuring no traces of sewer debris was present. The
area was then decontaminated with the application of lime and restored with grass seed and straw.
There was no observed fish kill or unnecessary vegetative damage associated with this SSO. The cost
associated with the mitigation of this event amounted to $16,714.00. The approximate cost to the Utility
to have treated 4,000 gallons of wastewater would have been approximately $6.00.
Public Utilities Code Enforcement was not able to issue an NOV to the contractor due to
insufficient proof that the debris came for the active worksite. Before this event, these assets were last
CCTV on 03/28/2018. CCTV footage showed no issues with the pipe.
According to our Sanitary Sewer Collection System Permit, the cause of this SSO was
exceptional, unintentional, temporary, and caused by factors beyond our reasonable control.
Furthermore, the SSO could not have been prevented by the exercise of reasonable control, such as
routine operations and maintenance, adequate treatment facilities, or collection system facilities or
components.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 - Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Spill event # 201901779—11/16/2019 — 7305 Cape Charles Rd., Raleigh
This spill event was the result of a grease build-up, restricting flow within a section of 8-inch
Polyvinyl Chloride Pipe (PCP). This build-up led to a sewer spill of approximately 8,350 gallons of
untreated waste water in which approximately 7,000 gallons reached surface waters through an
unnamed tributary within the Sycamore Basin.
On 11/16/2019, at approximately 09:07 AM, Sewer Maintenance staff was notified of a sewer
spill emanating from an adjacent manhole at 7305 Cape Charles Rd., Raleigh. The responding staff took
all reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived, gaining
control of the spill event by 11:32 AM on the same day. Containment, collection, cleanup, and
restoration of this spill event consisted of employing a temporary sewer containment site (dam)
downstream from the SSO location with the intent to stop the flow of sewer into the stream. Crews
employed pumps at the temporary containment site, to recover the remaining sewer back into a
downstream sewer manhole. During the restoration phase of the operation, crews utilized
approximately 7,500 gallons of water to defuse and flush the affected area. The areas around the
manhole were cleared of debris, treated with an application of lime, and restored with grass seed and
straw. There was no observed fish kill or unnecessary vegetative damage associated with this SSO. The
cost associated with the mitigation of this event amounted to $2,773.61. The approximate cost to the
Utility to have treated 8350 gallons of wastewater would have been approximately $12.52.
This section of the collection system serves a residential area north of 1-540, providing sewer
collection to over 1000 properties. The last recorded sewer spill associated with this section of the
sanitary sewer collection systems was on 08/30/2010 (incident # 201002443). No other sewer spills
have occurred since. Prior to this event, maintenance records show that sections of this collection
system were flushed and CCTV on 05/18/2018. The most current maintenance activity was conducted
on 12/31/2019.
Outreach information was delivered on 11/19/2019 to approximately 1074 residents upstream
of the SSO and within the affected area. This outreach literature explains the need for customers to use
the sanitary sewer collection system properly. It also serves as an opportunity for citizens to partner
with Public Utilities to protect the City's water quality and the sewer collection infrastructure.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed an Recycled Paper

Spill event # 201901818—11/26/2019 — 3112 Comstock Rd., Raleigh
This spill event was the result of a grease build-up, restricting flow within a segment of 8-inch
Vitrified Clay Pipe (VCP). This buildup led to a sewer spill of approximately 16,200 gallons of untreated
waste water in which approximately 15,000 gallons reached surface waters of Northshore Lake within
Marsh Basin [1].
On 11/26/2019, at approximately 11:54 AM, Sewer Maintenance staff was notified of a sewer
spill, emanating from a sewer manhole on the north-east bank of the lake, located at 3112 Comstock
Rd., Raleigh. The responding staff took all reasonable steps to stop and mitigate the impact of the
discharge as soon as they arrived, gaining control of the spill event by 1:00 PM on the same day [2].
Containment, collection, cleanup, and restoration of this spill event consisted of employing a
temporary sewer containment site (dam) on the north end of the lake with the intent to minimize the
flow downstream. Crews employed pumps at the temporary containment site, to recover remaining
sewer back into a downstream sewer manhole. Crews utilized ample potable water to defuse and flush
the affected area during the restoration phase of the operation. The areas around the manhole were
cleared of debris, treated with an application of lime, and restored with grass seed and straw. There
were minor fish kill adjacent to the affected area only. The spill mitigation caused no unnecessary
vegetative damage. The cost associated with the mitigation of this event amounted to $8,230.32. The
approximate cost to the Utility to have treated 16,200 gallons of wastewater would have been
approximately $25.95.
Water samples were taken at the request of the Department of Environmental Quality — Division of
Water Resources [3]. The water analysis comprised of the following parameters:
• Ammonia
• Chloride
• COD
• Conductivity
• Fecal Coliform (MPN)
• Nitrate
• TKN
• Total phosphorous
The collection report, along with the analysis results, was sent to the office of Mr. Gary Kreiser, LSS
Soil Scientist, on 12/12/2019 via email and US Postal Service. Copies of the analysis report will be
included in this letter.
This portion of the sewer collection system services a 1.61 Kilometers area, with approximately 588
residential and commercial establishments. The last recorded sewer spill associated with this section of
the sanitary sewer collection systems was recorded on 05/10/2016 (Incident # 201600968). No other
sewer spills have occurred since. Prior to this event, maintenance records show that sections of this
collection system were flushed on 01/25/2017. The most current maintenance activity was conducted
on 01/16/2020.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Outreach information was delivered on 12/3/2019 to approximately 799 residents within the
affected area. A newspaper add and a press release were requested and posted as required (copy of
these requests is included in this letter). This outreach literature explains the need for customers to use
the sanitary sewer collection system properly. It also serves as an opportunity for citizens to partner
with Public Utilities to protect the City's water quality and the sewer collection infrastructure.
[li Norlhshore lake Is part of stormwater collection and containment systems that discharge south Into Beaman lake and is not a source of drinking water
[21 The Collection System Sanitary Sewer Overflow Report found within the Basin incident Management System {BIMs) denotes the incorrect date when the incident
ended. The correct date should be 11/26/20191:00 PM, 18 hrs elapsed t me
131 Water samples were requested and collected on 11/27/2019,
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh. North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Spill event # 201901838—12/03/2019 — 7001 Paint Rock Ln., Raleigh
This spill event was the result of grease build-up and foreign debris (tree branches and large
rocks) resulting from possible vandalism. These obstructions restricted flow within a section of 8-inch
Ductile Iron Pipe (DIP). This build-up led to a sewer spill of approximately 5,040 gallons of untreated
waste water, of which approximately 300 gallons reached surface waters through an unnamed tributary
within the Neuse River Basin.
On 12/03/2019, at approximately 7:26 AM, Sewer Maintenance staff was notified of a sewer
back-up at 7001 Paint Rock Ln. Upon arrival, it was discovered that untreated sewer was emanating
from an adjacent manhole. The responding staff took all reasonable steps to stop and mitigate the
impact of the discharge as soon as they arrived, gaining control of the spill event by 9:50 AM on the
same day. Containment, collection, cleanup, and restoration of this spill event consisted of employing a
temporary sewer containment site (dam) downstream from the SSO location with the intent to stop the
flow of sewer into the stream. Crews employed pumps at the temporary containment site, to recover
the remaining sewer back into a downstream sewer manhole. During a site assessment, it was
discovered that manholes SMH120664, SMH156124, SMF1128098, and SMH181667 were found open
with the manhole cover removed. Each manhole had several branches that may have contributed to the
sewer spill downstream. The branches, along with any remaining debris, were removed accordingly. A
police report was filed for vandalism (a copy of the police report will be included in this letter).
During the restoration phase of the operation, crews utilized ample water to defuse and flush
the affected area. The areas around the manhole were cleared of debris, treated with an application of
lime, and restored with grass seed and straw. There was no observed fish kill or unnecessary vegetative
damage associated with this SSO. The cost associated with the mitigation of this event amounted to
$2,465.70. The approximate cost to the Utility to have treated 5,040 gallons of wastewater would have
been approximately $7.56.
This section of the collection system serves a residential area west of the Neuse River, providing
sewer collection to approximately 148 properties. There have been no other sewer spills associated with
this section of the sanitary sewer collection system. Prior to this event, maintenance records show that
sections of this collection system were assessed on 5/22/2011, 12\31\2012, 9\3\2013, and 9\19\2013.
The most current maintenance activity was conducted on 12/16/2019.
Outreach information was delivered to residents within the affected area of the S50. This
outreach literature explains the need for customers to use the sanitary sewer collection system
properly. It also serves as an opportunity for citizens to partner with Public Utilities to protect the City's
water quality and the sewer collection infrastructure. A copy of the letter will be provided with this
document.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Spill event # 201901926—12/16/2019 — 3311 Grove Crabtree Crest, Raleigh
This spill event was the result of debris build-up (rags and flushed wipe material) blocking a portion of 8-
inch sewer gravity main. This build-up led to a sewer spill of approximately 5,250 gallons of untreated
waste water reaching surface waters through an unnamed tributary within the Hare Snipe Basin.
On 12/16/2019, at approximately 4:37 PM, Sewer Maintenance staff was notified of a sewer
back-up at 3311 Grove Crabtree Crest, Raleigh. Upon arrival, it was discovered that untreated sewer was
emanating from a private cleanout as the result of a standing sewer gravity main. The responding staff
took all reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived,
gaining control of the spill event by 6:22 PM on the same day. Containment, collection, cleanup, and
restoration of this spill event consisted of employing a temporary sewer containment dam downstream
from the 550 location with the intent to stop the flow of sewer into an adjacent pond. Crews employed
pumps at the temporary containment site, to recover remaining sewer back into a downstream sewer
manhole.
During the restoration phase of the operation, crews utilized ample water to defuse and flush
the affected area. The areas around the manhole were cleared of debris, treated with an application of
lime, and restored with grass seed and straw. There were only two fish kill observed as a result of this
event. There was no unnecessary vegetative damage associated with this 550. The cost associated with
the mitigation of this event amounted to $5,576.51. The approximate cost to the Utility to have treated
5,040 gallons of wastewater would have been approximately $8.36.
This section of the collection system provides sewer collection to a large apartment complex
south of West M illbrook Rd. There have been no other sewer spills associated with this section of the
sanitary sewer collection system. Prior to this event, maintenance records show that sections of this
collection system were assessed on 03/22/2018. The most current maintenance activity was conducted
on 12/16/2019.
Outreach information was delivered on 12/17/2019 to approximately 210 residents within the
affected area. This outreach literature explains the need for customers to use the sanitary sewer
collection system properly. It also serves as an opportunity for citizens to partner with Public Utilities to
protect the City's water quality and the sewer collection infrastructure. Copies of the delivered
documents will be included in this letter.
one Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 - Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Spill event q 201901926—12/28/2019 — 5021 Bivens Dr. Raleigh
This spill event was the result of a grease build-up, restricting flow within a section of 8. inch
sewer gravity main. This build-up led to a sewer spill of approximately 7,100 gallons of untreated waste
water reaching surface waters through an unnamed tributary within Perry Creek.
On 12/18/2019, at approximately 4:02 PM, Sewer Maintenance staff was notified of a sewer
spill emanating from an adjacent manhole behind 5021 Bivens Dr., Raleigh. The responding staff took all
reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived, gaining
control of the spill event by 5:13 PM on the same day. Containment, collection, cleanup, and restoration
of this spill event consisted of employing a temporary sewer containment site (dam) downstream from
the SSO location with the intent to stop the flow of sewer into the stream. Crews employed pumps at
the temporary containment site, to recover the remaining sewer back into a downstream sewer
manhole. During the restoration phase of the operation, crews utilized ample water to defuse and flush
the affected area. The areas around the manhole were cleared of debris, treated with an application of
lime, and restored with grass seed and straw. There was no observed fish kill or unnecessary vegetative
damage associated with this SSO. The cost associated with the mitigation of this event amounted to
$2,313.77. The approximate cost to the Utility to have treated 7,100 gallons of wastewater would have
been approximately $3.47.
This section of the collection system serves a residential area east of Capitol Blvd, providing
sewer collection to over 900 properties. The last recorded sewer spill associated with this section of the
sanitary sewer collection systems was on 03/05/2006. No other sewer spills have occurred since. Prior
to this event, maintenance records show that sections of this collection system were assessed on
04/23/2018. The most current maintenance activity was conducted on 12/19/2019.
Outreach information was delivered on 11/19/2019 to approximately 960 residents upstream of
the SSO and within the affected area. This outreach literature explains the need for customers to use the
sanitary sewer collection system properly. It also serves as an opportunity for citizens to partner with
Public Utilities to protect the City's water quality and the sewer collection infrastructure.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Spill event # 201901952—12/21/2019 —1019 Rose of Shearon Dr., Knightdale
This spill event was the result of structural pipe failure of a 4-inch sewer force main. This pipe
failure led to a sewer spill of approximately 12,760 gallons of untreated waste water, of which
approximately 500 gallons reached surface waters through an unnamed tributary within Marks Upper
Basin.
On 12/21/2019, at approximately 10:32 AM, Sewer Maintenance staff was notified of a sewer
spill emanating from the ground alongside the street on Knightdale Blvd HW-64. Upon arrival, it was
determined that a section of forced main had failed, causing the pipe to spill a volume of 35 gallons per
minute. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge
as soon as they arrived, gaining control of the spill event by 4:30 PM on the same day. Containment,
collection, cleanup, restoration, and repair of this spill event consisted of employing a temporary sewer
containment site (dam) downstream from the SSO location with the intent to stop the flow of sewer into
the stream. Crews then employed vacuum trucks to recover the sewer into the containment tank of the
flusher trucks. Crews were able to successfully contain and collect over 12,240 gallons of sewer, only
letting approximately 510 gallons of waste water to spill into the adjacent creek. A total of 8 truck tanks
[1] were filled during the containment and collection phase of the mitigation- Sewer repair crews in
coordination with pump station mechanics were able to replace a section of pipe, thus restoring normal
flow. During the restoration phase of the operation, crews utilized ample water to defuse and flush the
affected area, which was only limited to the immediate location of the dam and a short stretch of
stormwater conveyance. The site of the sewer run-off was then treated with an application of lime and
restored with grass seed and straw. There was no observed fish kill or unnecessary vegetative damage
associated with this 550. The cost associated with the mitigation of this event amounted to $3,490.41.
The approximate cost to the Utility to have treated 12,760 gallons of wastewater would have been
approximately $19.12.
This force main transfers sewer from pump station 124-St Marks PS located at 8109 US Hwy 64
East. During the incident, the pump station continued to operate as designed with no interruptions in
operating cycles or failures. There are no records of mechanical issues in this part of the system before
this event.
I1] a flusher truck collection's tank can store a tot:I volume of 1,500 gallons.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Ralegh, North Carolina 27601
(Mailing Address)
Printed an Recycled Paper

Summary
The City of Raleigh has a very aggressive preventative maintenance program to maintain its
2600 miles of sanitary sewer. Since January 2019 (Fiscal Year 2020), the Utility has maintained
approximately 407 miles 11) of the sanitary sewer by flushing sewer mains with high-pressure nozzles,
CCTV, repair operations, and SSO mitigation. The year to date cost of these operations amount to
$4,114,411.11, approximately 31 of the Division's annual operating budget. The total volume of sewer
spills identified in this letter add up to 61,700 gallons at a total mitigating cost of $43,425.44. The City's
cost of sewer treatment per gallon is $.0015 ill, At this rate, it would have cost the City $92.55 to treat
every gallon of sewer spilled. This fiscal comparison shows the City's commitment to environmental
protection sparing no cost regardless of the severity and complexity of the spill event. The City continues
to demonstrate due diligence in environmental performance by allocating the necessary resources to a
spill event regardless of the associated cost. This effort is noted in the City's low SSO performance rate
of 2.23 spills per 100 miles of pipe, compared to the Southeastern Region of the US, of 7.0 spills per 100
miles of pipe.
(11407 miles represents 16%of the sanitary sewer collection system
[215.0015 is based on the annual water treatment operating cost compounded by the tota treated effluent.
The City of Raleigh maintains approximately 1009 miles of sanitary sewer easements within our
jurisdiction_ The manholes within every easement in our service area are inspected at least once per
year and in most cases, more frequently. Trees and brush must be cut away from these areas to
maintain access to the sewer line for maintenance work such as inspection and cleaning, and it removes
root materials from the proximity of the sewer mains. We currently employ five easement maintenance
crews that continually cut and maintain easements for access and inspections. Approximately 110 miles
of our sanitary sewer easements have experienced substantial tree growth and require more extensive
clearing operations. The City of Raleigh Public Utilities Department contracts with a private tree service
to assist with those removal operations, and we have spent over five hundred thousand dollars
($500,000) throughout the past four years on this contract.
Additionally, City of Raleigh Assistant Public Utility Directors and Collections System staff has
become involved in challenging the standards of the nonwoven fabrics industry to bring about a better
understanding by consumers of these products and their detrimental effects on the collections systems.
PUD staff has personally met with officers of INDA, the leading association of the non -woven fabrics
industry based in Cary, NC, to communicate our concerns about these fabrics, the current industry
standards, and better education for the consumer. PUD has also joined forces with other utilities
nationwide through the National Association of Clean Waters Agencies (NACWA), the Water
Environment Foundation (WEF), and the American Public Works Association (APWA) to challenge INDA
and current industry standards, recognizing that they do not support compatibility in sanitary sewer
collections systems nationally. These agencies are working collectively to challenge the testing
protocols, assessment guidelines, and consumer education and labeling of these non -dispersible.
One Exchange plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

It is essential to mention that the City has seen an increase in the trend of grease related SSOs.
As of today, 65% of 2019 reportable spills have been related to grease accumulation. Public Utilities has
increased its educational outreach to reduce this trend. The Department's Fats, Oil, & Grease Program
has developed new educational material (included in this letter) as well as an informational video
designed to reach not only food service establishments but residential customers as well. The City is also
developing initiatives to increase partnerships with residential customers to address grease
accumulation and proper disposal. The educational FOG video can be accessed by accessing the
following link httns://vimeo.com/362624139 Password: RW2019
In 2018 the Public Utilities Department increased the efforts of community outreach to further
inform the community throughout direct participation in the City's Citizens Advisory Committees.
Through this initiative, the Public Utilities Department has been able to reach numerous Council Districts
with a consistent message of collaboration and environmental partnership. The Department is currently
developing year three of this effort. Furthermore, this message has been made available not only to the
community but to City Council officials as well. A sample of this message is attached to this letter for
reference.
Raleigh continues to implement a seasonal collection of residential cooking oils from curbside
pickup along with customer garbage, recycling, and yard waste. The goal of this program is to prevent
these oils from being deposited within the sanitary sewers and to help prevent grease buildup and
blockages leading to SSO's. Since its implementation in 2010, the program has successfully collected
over 1,000 gallons of residential cooking oils.
The City continues its monetary reward program or bounty program, which pays out fifty ($50)
dollars to any citizen that observes and reports an SSO or conditions that may cause a spill event. This
program has been advertised via printed material, a television advertisement campaign, and graphic
design "wraps" on Sewer Maintenance vehicles. These graphics on our vehicles function as mobile
billboards spreading our message of prevention and offering contact information, throughout the
service area each day. This program was developed with the hope that citizens and customers would
become more aware of the signs of an emerging system problem causing the 550 occurrence and
become proactive in helping the City to prevent these occurrences. Additionally, all customers are
notified via their water and sewer utility bills not to discharge improper materials into the sanitary
sewer mains. The City also circulates information regarding discharging of grease into the sewer system
and the effects of such deposits. Whenever possible, and upon the investigation of the root cause of a
spill event, PUD Code Enforcement officers develop and send registered informational letters about the
spill event to the customer base serviced by the line where the SSO has occurred. This is done to
educate our customers in the proper use of the sanitary sewers in an attempt to prevent disposal of
non-flushable items and items harmful to the continuous operation of the collections system.
On behalf of the City of Raleigh, I am requesting the NOV-NOI issued for the third quarter of
2019 be rescinded as allowed in the Collections System Permit, if additional information is required,
please contact Matthew Vessie, Sewer Maintenance Superintendent [phone] or T.J. Lynch,
Assistant Public Utilities Director, at [phone].
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

ncer`ely,
1
Carlos M Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh Public Utilities Department
P.O. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
Carlos.perezcamachoPraleishnc.Gov
CC: Robert Massengill, Public Utilities Director
T.1. Lynch, Assistant Public Utilities Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance Division
Attachments:
1. NCDE NOV Letter, Received February 6, 2020
2. Police reportfor vandalism
3. Outreach Information for Spill event # 201901838—1210312019 — 7001 Paint Rock Ln., Raleigh
4. Outreach Information for Spill event # 201901926—1211612019 — 3311 Grove Crabtree Crest
5. Laboratory Analysis for Spill event # 201901818—1112612019 — 3112 Comstock Rd., Raleigh
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Sox 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

�.n�Sr,A71. y
Roy COOPER '
MICI MIL S. REGAN �'z, •.+ir» - „�
LINDA CULPEPPER NORTH CAfiouNA
Ix'r.Xh. F.nvlranmenrnf Qua!!ry
r,jRT1FIEjMAIL: 7017 2680 0000 2236 7177
P2ETURN RECEIPT REQUESTED
January 31, 2020
Robert Massengill, PE
City of Raleigh
PO Box 590
Raleigh, NC 27602
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2020-DV-0040
Sanitary Sewer Overflows — October, November, December 2019
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
T M R 0 W T
FEB 0 6 2019
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Reports submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 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 Raleigh an opportunity to provide evidence and justification as
to why the City of Raleigh 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
201901618 10/4/2019 120 MH 817, McMakin St. Grease 3,000 3,000 Notice of Violation
201901743 11/5/2019 65 6701 Fox Road Debris in line 4,000 500 Notice of Violation
201901779 11/16/2019 167 7305 Kate Charles Road Grease 8,350 8,350 Notice of Violation
201901818 11/26/2019 1,695 3112 Comstock Rd, Grease 16,200 16,200 Notice of Violation
Raleigh Notice of Intent
rl_rs�Can raDar an,rartcfir 4r:r"vt*' fat ry I r,Va:•afWatuAtI'6r;tz
�tl FtapFat:rt4HL►Ia_533ErmnDe,#IK6at..ru,rr.^tr:raVe.C?

Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mans) Location Cause (Gals) (Gals) DWR Action
201901838
12/3/2019
141
7001 Paint Rock Ln. Grease
5,040
300
Notice of Violation
201901926
12/16/2019
105
3311 Grove Crabtree Crest Debris In line
5,250
5,250
Notice of Violation
Raleigh
201901937
12/18/2019
71
5021 Blvens Dr. Grease
7,100
7,000
Notice of Violation
201901952
12/21/2019
367
1019 Rose of Shearon Dr, PS equipment failure
12,760
510
Notice of Violation
Knightdale
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 Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
Central Files, Water Quality Section
Laserfiche
Emall copy to Carlos Perez [e-mail]
Wi,',
riro:aro riDeNftmeri&ErtirPmvu ,we z;' I DV1-.F:fWit+lF.a:.r:lf
WrKr�i^FfY.rrCn:�jge:=E�rEcL,s�Yfr�Y�H:t^.�_r��7E.'
v M-7 El-M

RALEIGH POLICE DEPT. OFFENSE/INCIDENT REPORT Pagel 1
CRIMES) - CLASSIFICATION: UCR: DATE/TIME RPTD: SHIFT: BEAT: COMPLAINT NO:
-
All Other/All Other offenses 80A 12/03/19 13:33 01 433 p19068532
LOCATION OF CRIME. TYPE OF PREMIS:
7000 PAINT ROCK LN
OFFENSE DAY(S): DATE OF OFFENSE: HRS OF OFFENSE: OFFICER'S NAME: CODE NO:
TUE TO TUE 12/03/19 TO 12/03/19 07:00 To 08:00 POSTHUMUS 3635
REPORTED BY: RACE: SEX: AGE; COMPLETE ADDRESS: PHONE:
THOMPSON, TIMOTHY ANTIONE B M 36 5012 PARKERW00D DR 919-796-7158
"CODES" --> S-STOLEN R-RECOVERED L-LOST D-DAMAGED PROPERTY F-FOUND PROPERTY
CODE: QTY. DESCRIPTION OF PROPERTY:
VALUE:
VALUE DAMAGED: VALUE RECOVERED: TOTAL VALUE STOLEN;
VICTIMS) {LAST, FIRST, MI): RACE: SEX: AGE: COMPLETE ADDRESS: PHONE:
EMPLOYER -SCHOOL: BUSINESS PHONE: CITY/STATE:
V-CITY OF RALEIGH 222 W HARGETT ST 919-996-3245
RALEIGH, NC
PERSON(S) ARRESTED: RACE: SEX: AGE: HOME ADDRESS: CHARGE:
CO 17 UFORD coo U
Mdnd m*6
��p
U04'�MO®W P iW CE ®IGrWp 1)p EW
(m) 2s

RALEIGH POLICE DEPT. OFFENSE/INCIDENT REPORT Page: 2
CRIMES) - CLA55IFICATION: UCR: BATE/TIME RPTD: SHIFT: BEAT: COMPLAINT NO:
All Other/All Other Offenses BOA 12/03/19 13:33 01 433 p19068532
LOCATION OF CRIME: TYPE OF PREMIS:
7000 PAINT ROCK LN
OFFENSE DAY(S): DATE OF OFFENSE: HRS OF OFFENSE: OFFICER'S NAME: CODE NO:
TUE TO WE 12/03/19 TO 12/03/19 07:00 TO 08:00 POSTHUMUS 3635
REPORTED BY: RACE: SEX: AGE: COMPLETE ADDRESS: PHONE:
THOMPSON, TIMOTHY ANTIONE B M 36 5012 PARKERWOOD DR 919-796-7150
'CODES" -^> S-STOLEN R-RECOVERED L-LOST D-DAMAGED PROPERTY F-FOUND PROPERTY
CODE: ¢TY: DESCRIPTION OF PROPERTY:
VALUE:
VALUE DAMAGED: VALUE RECOVERED: TOTAL VALUE STOLEN:
VICTIM S) (LAST, FIRST, MI). RACE: SEX: AGE: COMPLETE ADDRESS: PHONE:
EMPLOYER -SCHOOL: BUSINESS PHONE: CITY/STATE:
R-THOMPSON, TIMOTHY ANTIONE B M 36 5012 PARKERWOOD DR 919-796-7158
City of raleigh street Maintena KNIGHTDALE, NC
PERSONS) ARRESTED; RACE: SE: AGE: HOME ADDRESS: CHARGE:
Uu H Ill UED c0y�I1_U
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Raleigh
Sanitary Sewer Overflow in your Area
Dear Raleigh Utility Customer:
The City of Raleigh recently had a sanitary sewer overflow in your area. The overflow was caused by
materials such as grease and debris improperly disposed of into the Raleigh sanitary sewer system.
It was found that the lids to some of the manholes within your neighborhood had been removed and
debris placed within the system. Additionally, large amounts of grease were found within the pipes of
the sanitary sewer system as well.
City of Raleigh Municipal code section 8-2013 states: "It shall be unlawful for any person to alter,
remove, damage, or interfere with any part of the utility system etc...". This section of the code is
enforced by City Code section 8-2014 (b) (7) of the Raleigh Municipal Code and if found in violation, a
civil penalty in the amount of $500.00 dollars may be assessed.
You can do some simple things that will help the City protect water quality and maintain Raleigh's
sanitary sewer system.
Do Not interfere with the utility system
Do Not pour grease, fats and oils from cooking down the drain
Do Not use the toilet as a wastebasket -no disposable/flushable wipes, paper towels, baby wipes
or diapers, condoms, tampons or personal hygiene products
Do Not use the sewer (kitchen sink) to dispose of food scraps
Please collect cooking oils and grease in a container and dispose of in the garbage
Please place food scraps in a waste containers or garbage bags for disposal with solid waste or
Most sewer back-ups occur between the house and the City's sanitary sewer main where the property
owner is responsible for maintenance of their sewer service within the street right-of-way or sewer
easement. To report a sewer back-up or overflow, please call the Public Utilities Maintenance Division at
919-996-3245.

For more information on the proper use of your sanitary sewer system, find us on the web at
www.raleighnc.gov.
You may also contact [e-mail] or call 919-996-2465. These suggestions can
help save you money and protect the environment.
Thank you for your help!
Code Enforcement Program
City of Raleigh Public Utilities Department
[e-mail]
Office: 919-996-2465
Public Utilities Department - Administrative Office - 1 Exchange Plaza, suite 620 - Raleigh, NC 27601
Mailing - Post Office Box 590 - Raleigh, NC 27602

1
Thy City of Ralingh recently had a sanitary sewer ov+-rffow
In your air Thr, ovnrfiowyetis-,,ku�ed by mater2als such as-
greise and debris improperly disposed of into the Ralcigh
sanitary sewer system. You can do some simpie things
that will hnip th• City protect wa trr quality and maintain
Raleigh's sanitary ;nwrK ;y;trim
DO NOT pour greasy, fats and oils from cooking down
the drain.
DO NOT use the toilet as a wastebasket. (no disposable
/flushable wipes, paper towels, diapers or baby wipes,
condoms, tampons or other personal hygiene products)
DO NOT use the sewer (kitchen sink) as a means to dispose
of food scraps.
PLEASE collect cooking oils and grease In a container and
dispose of in the garbage.
PLEASE place food scraps in waste containers or garbage
bags for disposal with solid waste, or start a compost pile.
Most sc•,vor br.ck up,., occur b, °t,r:cc-n th.- house and thi?
City's-imit-ary ewer mwn whmv the property a wnvi-
15 respons blo fo- mainto nance of their sewer-ervin,
4 1hin the 5trret right of -%ay or sew•�rLmsrmPnt. To
rr;pOr, a sewer b,,ck up or ov€lrfl sw pir.,se tall the Publ•c
Unlit e�, Mrilrtttnance. Divic on at 919 996 3245. For morn
,information or the proper usK� of your unitary sewer
.ystr-m, please find us on the web n w-,vw.raleighnc go-
ihr!sr above suggpsti.on!, can help'soye wou mont�y and
protect the vnvironmpnt.
Thank you for your help'

,&//04( (9 / ( -6 /
NORTH CAROLINA
Date: X-/ /-'I- / �D19
This document is to serve that I, — _ 4-h ) #l,n received the Sanitary
(Print Naine)
Sewer Overflow door hangers on IYK_/_ I I / 2Wr9 at I :_D (AM PM
(Date) (Tillie)
and I will distribute them to the residents / tenants of: 06 6 (_ 44M
(Apartment Complex)
on the same day of receipt.
ml N
4 = =rr�jlfl
PUBLIC UTILITIES DEPARTMENT • AoMINiSTRATIVE OFFICE • 1 EXCHANGE PLAZA, sURE 620 • RALEIGH. NC 27601
MAILING • POST OFFICE Box 590 • RALEIGH. NC 27602

oll
00
Raleigh Water
Carlos M Perez
Sr. Utilities Analyst
Raleigh Water
Sewer Maintenance Division
December 9t', 2019
Gary Kreiser, LSS
Soil Scientist
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
Ref: Request for water sample analysis related to SSO event # 201901818
Mr. Kreiser,
Thank you for assisting in the efforts to evaluate potential environmental impacts arising from
the sanitary sewer spill recorded at 3112 Comstock Rd., Raleigh, on November 27'h, 2019 (incident
# 201901818). As you requested, we collected water samples in selected locations of the affected
body of water (Beaman Lake). The samples you requested were collected on 11/27/2019 at
approximately 1:00 PM that afternoon. The samples were immediately delivered for analysis at our
laboratory facilities located at Neuse River Resource Recovery Facility on the same day. The
requested analysis included fecal coliform, total nitrogen, total phosphorus, chloride, pH,
conductivity, temperature, and dissolved oxygen. Copies of these reports are included in the
addendum to this letter.
These water samples were collected along the east bank of lake and adjacent to the
manhole that spilled (SMH128739). Three consecutive samples were taken north of the
aforementioned manhole as indicated in picture # 1 below. Additional samples were also collected
downstream and upstream of the spilled manhole. No samples were collected in any surface water
entering the lake.
During the spill event on November 271h, crews placed a 4-inch diesel water pump (as part of
the spill containment efforts) on the north edge of the lake, transferring any remaining sewer, from
the lake, into an adjacent sewer manhole. This pump operation ran for approximately 21-hours;
discharging approximately 1,134,000 gallons of water (1) back in the collection systems.
Municipal Building 1 222 West Hargett Street I Raleigh, North Carolina 27601
One Exchange Plaza 11 Exchange Plaza I Raleigh, North Carolina 27601
Mailing address: City of Raleigh I Post Office Box 590 1 Raleigh, North Carolina 27602-0590

Picture # 1 — 5 to of collected samples
(1) The estimated volume of 1,134,000 gallons, was determined based on duration of pump run time (21-hrs), pump rate capacity (1,600 RPM
Oa 900 gallons per minute)
Municipal Building 1 222 West Hargett Street I Raleigh, North Carolina 27601
One Exchange Plaza I 1 Exchange Plaza I Raleigh, North Carolina 27601
Mailing address: City of Raleigh I Post Office Box 590 1 Raleigh, North Carolina 27602-0590

54'� •
Observed Fish Kill
4
AkL j • y.
`.�jt �T ? •� ' �1�

�'yLL'4
The analysis report for this event is included in this letter for your review and records. Please do not
hesitate to contact my office if there are additional concerns regarding the information provided and
the analysis of the collected samples.
Sincerely,
Carlos M Perez
Sr. Utilities Analyst
Raleigh Water
Sewer Maintenance Division.
[e-mail]
Office [phone]
Cell [phone]
Municipal Building 1222 West Hargett Street I Raleigh, North Carolina 27601
One Exchange Plaza 1 1 Exchange Plaza I Raleigh, North Carolina 27601
Mailing address: City of Raleigh I Post Office Box 590 1 Raleigh, North Carolina 27602-0590

gebtech Invoice
Geotech Environmental EqulpmenL Inc.
2650 East 40th Avenue
Denver, CO 80205
Phone 303,320.4764 FAX [phone]
[e-mail] www.geolechenv.com
Federal ID* 84-0753199
Bill To CITY OF RALEIGH Ship To
ATTK A.P.
P O. BOX 590
RALEIGH, NC 27602
UNITED STATES OF AMERICA
Invoice No;
604881
Invoice Date
12/05/2019
Order No.
00566747
Customer No
00D000340126
Salesperson No.
016 JONATHAN HUEHME F
Account Terms.
1 %-10/NET30
Payment Method
CC
Purchase Ord No:
Placed By:
Carlos Perez
HOLD FOR PICK UP:
GEOTECH ENVIRONMENTAL EQUIPMENT, INC
2517 NOBLIN RD. STE w3
RALEIGH, NC 27MM
UNITED STATES OF AMERICA
Phone No: (919) 6624700 Ext No:
Shipping Date Ship Via Bill Frt Carrier* Location
1112712019 PICK UP NC
Quantity
Line No. Item No. Description Required I Shipped 1 8.0 Unit Price Amount
FOR 1 DAY 11/27119 THRU 1212110
1 R8300037 RENTAL.COND,DO,ORP,PH,OUATRO 1 1 $110_00 S110 03
JIM CABLE,WIFLOWCELL.PROSERIES
RENTAL UNIT#6814 RETURNED
iryou hove questions, please contact JOVATIIAN III; EIIIIIER at the obme number.
MID
Sale Amount
SI10.00
Shippiog4lsodling:
S 0.00
SalesTa: 0.00
S0,00
IntioteeAmount
S110.110
Payment Applied
S0.00
Amount Due
SI10.00
Pagc 1 of

Neuse River Resource Recovery Laboratory
.� Phone [phone]
EPA Laboratory Code NCO 1029
DWR Certification #51
ANAB Certificate #AT-2593
Customer: Sewer Maintenance
Results Report
09-Dec-19
Order ID: 19112721
Sam le
Date
SamaleType
Parameter
Method
Result Ouslifter
Comtock Area I
I Imf2019
Garb
Amomotoa
SM 4500 N113 H (2011)
2s4 mg/L.
Comstock Arm I
t 1272019
Grab
Chkdde
EPA 300.0 2.1 (1993)
<10 maiL.
Comstock Arm 1
11/2712019
Gmb
COD
Hach Method 8000
32.0 mg/L.
Cotmtock Area I
111=2019
Grab
Conductivity
SM 2310 B (2011)
100.6 mm hothmz
Comstock Atsa 1
1127/2019
Grab
Fecal Colifarm (MPN)
X Cohlert®IB (MPN)(Acy
>4839 MMI tNhrd
I
1 Comstock Area 1
I IM12019
Grab
Nimate
EPA 300.0 2.1 (1993)
0.41 uWL.
Comstock Area I
11/27/2019
Grab
NWite
EPA 300.021(1993)
<0.0tMOIL
Comstock Arcs 1
t 1/27/2019
Grab
Nitrite +Nitrate
EPA 300.0 2.1 (1993)
0 41 mg/L
Commtock Arm 1
11127/2019
Grab
TKN
EPA 3512 (1993)
5.07 mg/L
Comstock A= 1
I l27/2019
Grab
TOLL Pbagb mn
SM 4500 P E (2011)
0.46 ms&
Co skw* Atm 2
111=2019
Grab
Ammonia
SM 45W NW H (2011)
2.75 me/1.
Comstock Azsa 2
1127/2019
Grab
Chloride
EPA 300.0 2.1 (I M)
<10 mg/1.
Comstock Am 2
11272019
Grab
COD
Haab Method 9000
33.0 mg/1.
Comstock Arm 2
1 V2712019
Grab
Cadh-fivay
SM 2510 D (2011)
104.6 umhadem
Ilf
Com mock Arca 2
11/27/2019
Grab
Fecal Colifmm (1AM
X CoMedVI9 (MPN)(Acp
>4239 MPW100m1
Carmtock Arm 2
1127/2019
Orab
Nitrate
EPA 300.0 7.1 (1993)
038 mg/L
Comstock Ara 2
11/27/2019
Grab
Nitrite
EPA 300.0 2.1 (1993)
<.01 mg/L
Comstock Ara 2
1 IJ2712019
Grab
Nitrite 4 Nitrate
EPA 300.0 2.1 (1993)
0.33 mg/L
Comstock Area 2
11/27/2019
Grab
TXN
EPA 351.2 (1993)
5.47 mg/L
Comstock Arm 2
11/27/2019
Grab
Total lnmomora
SM 4500 P E (2011)
0.47 mg/L
Comstock Arm 3
1 W712019
Grab
Ammomia
SM4500 NH3 H (2011)
2 77 mg/L
Caslock Arm 3
1 tf2712019
Grab
Chloride
EPA 300.0 2.1 (1993)
<10 mgll.
Comstock Area 3
11/27/2019
Grab
COD
Hark Medmmd 9000
42.0 awl
Comstock Ara 3
1127/2019
Grab
Conductivity
SM 2510 B (2011)
1052 smmhWcw
Comstock Arm 3
1127/2019
Omab
Foal Couform (MPN)
X Cdkr *l B 0"N)(Acp
>4839 MPHI100m1
Comstock Area 3
112712019
Grab
Nitratc
EPA 300.0 2.1 (1993)
037 s41L
Comstock Area 3
1127/20 t9
Grab
Nitrate
EPA 300 0 7.1 (1993)
<101 we&
Comstock Arm 3
1127/2019
Gmab
Nitrite+ Nitnre
EPA 300.011 (1993)
037 mg/L
Comstock Arm 3
H/27/2019
Grab
TM
EPA 351.2 (1993)
527 mg1L
G5 - The glucosdglutamic acid standard exceeded the range of 198 + or - 30.5mg/L Reviewed by: Tamika Black [aborstory scientist A-.£' iiJ' I
Approved by: Darrell Crews Labc-huy 5,4-1- S a-d fur,,
The f4itowing parameters are not included in the ISO 17025 Scope ofAccreditation:
pH. conductivity, temperature, dissolved oxygen and turbidity.
Results apply to tine sample as received unless otherwise noted. Revised 11 /27/2018, SM-001
Page 7 of 3

Comstock Area 3
Neuse River Resource Recovery Laboratory Results Report
Phone [phone]-Dec-19
EPA Laboratory Code NCO 1029
DWR Cerdficadon #51
ANAB Certificate #AT-2593
11127/2019 Grab Tidal PIa»Pboroas SM 4500 P E (2011) 0.56 mglL
Comstock Area 4
11/27/2019
Grab
Ammorda
SM 4500 NH3II (2011)
0.42 mg/L
Comstock Ate& 4
11/27/2019
Grab
DOD
SM 5210 B (2011)
31 mglL. G5
Comstock Area 4
11127/2019
Grab
Chloride
EPA 3D0.0 2,1 (1993)
<10 nVI
Comstock Area 4
11/27/2019
¢rah
COD
Hach Method MM
66.0 MJUL
Comstock Area 4
11/27/2019
Grab
Conductivity
SM 2510 B (2011)
<100.0 u nhollem
Comstock Ara 4
11WI2019
Grab
Fed CoUfams (MPN)
x CoWcrt®I8 (MWAgq
:4839 MPWl00ml
Comstock Area4
11127/2019
Grab
Nitrate
EPA 300.0 2.1 (1993)
0.52 mg/L
Comstock Am 4
1 V2712019
Grab
Nitrite
EPA 300,0 2.1 (1993)
0.06 mg/L
Comstock Ara 4
11/27/2019
Grab
Nitrite+ Nitrate
EPA 3W.0 2.1 (1993)
0.59 mglL
Comstock Arm 4
1 [127/2019
Grab
TKN
EPA 331.2 (1993)
2.04 mg/L
Comstock Arra4
11/27/2019
(Lab
Total Phosoxwous
SM 4500 P E (2011)
0.31 UWL.
G5 — The glucose/glutamie acid standard exceeded the range of 198 + or - 30.5m&'
Reviewed by: Tamika Black Lbonttmry scientist � -,r. rJ�L
Approved by: Dan -di Crews Laborab" Suparvlsor bit'd %y",-
The following parameters are not included in the ISO 17025 Scope of Accreditation:
pH, conductivity, temperature, dissolved oxygen and turbidity.
Results apply to the sample as received unless otherwise noted. Revised 11127/2018, Sivl-001
Page 2 of 3

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Neuse River Resource Recovery Laboratory
Phone [phone]
EPA Laboratory Code NCO 1029
DWR Certification 951
ANAB Certificate #AT-2593
Results Report
09-Dec-19
Customer: Sewer Maintenance
Order ID: 19I 12801
Sample
Date
Sam IeT a
Parameter
Method
Result Ouulifler
Comstock Downstream
11282019
Grab
Amwmia
SM 4500 N11311(2011)
0.69 melt.
Comstock Dowasw=
I IQ82019
Grab
Chloride
EPA 300.0 2,1(1993)
-CIOCOL
Cmmmck Downstream
112812019
Grab
CAD
Hach Method 8000
34.0 rWL
Comtock Downstream
111282019
Grab
Cmulucrivity
sM 2510 B (2011)
<100.0 rmrbm/em
Camtoek Downstream
11282019
Grab
Nitrate
EPA 300.0 2.1 (1993)
053 mgIL
Comtock Downstream
112VI019
Grab
Nitrite
EPA 300.0 2 1 (1993)
0.07 m L
Ceoatock Downstream
11/20019
Grab
Nitrite+ Nitrae
EPA 300.0 2.1(1993)
0.60 atg&
Comstock Dowmtrram
I I282019
Grab
TKN
EPA 351.2 (1993)
1.71 mA
Comtock Downstream
11120019
Grab
TOW Phosplronaa
SM 4500 P E (2011)
0.11 me/L
Cormtork UpwUnt
111=019
Grab
Ammmia
SM 4500 NH3 H (2011)
m. t0 mglL
Comstock Upstream
I MM019
Grab
Chloride
EPA 300.0 2.1(1993)
<10 mWL
Comstock Upstream
11282019
Grab
COD
Had Method 8000
29.0 mglL
Comstock Up Hn=
11=019
Grab
Conductivity
SM 2510 B (7011)
<100,0 mahoalcm
Comstock Upstream
111=019
Grab
Nitrate
EPA 300.011 (1993)
0.38 mg/L
Comonck Upstream
I M/282019
Grab
Nitrite
EPA 300.0 2.1 (1993)
-ADD Wg/L
Comstock Upstmi ar
11/282019
Grab
Nitrite + Nitrak
EPA 300.0 2.1 (19M)
0.38 man.
Carratodr Upstream
11282019
Gab
TXN
EPA 351.2 (1993)
1.97 mWL
r Comstock Upstream
I Irmo 19
Gab
Tool rhoo amus
SM 4500 P E (2011)
0.17 nWL.
Reviewed by: Tamika Black laboratory scicn t . � „"'"l
Approved by: Darnell Crews LtboratmySupervisor bRaid %tz"
The fallowing parameters are not included in the ISO 17025 Scope of Accreditation.
pH, conductivity, temperature, dissolved oxygen and turbidity.
Results apply to the satnplc as received unless otherwise noted. Revised I1127/2018, SM-001
Page 1 of 2

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Neuse River Resource Recovcry Laboratory Results Report -Amended
Phone [phone]-Dec-19
EPA Laboratory Code NCO 1029
DWR Certification #51
ANAB Certificate #AT-2593
Customer: Sewer Maintenance
Order ID: 19120202
Sample
Date
SarnifleType
Parameter
Method
Result Ounfifier
Comstock Area 4
11/27/2019
Grab
Dissolved ChrAcn
H 10360 (2011) Rev. 1.2 (
7.5 uWL
Comstock Aim 4
1 U27/2019
Grab
pH
SM 4500 H+B (2011)
6,8 pH Units
Comstock Area 4
11/2712019
Grab
Tertf=ft a
SM 2550 B (2010)
13'C
Comstock Am 3
11/27/2019
Grab
Dissolved Oxygen
1110360 (2011) Rcv. 1.2 (
4.8 mg1L
Comstock Arco 3
11/27/2019
Grab
pH
SM 45001I4 B (2011)
6 6 PH Umits
ConWack Area 3
11/2712019
drab
Tcmperabue
SM 2550 B (2010)
14'C
Camtock Area 2
11/27/2019
Grab
DmWved Oxygmr
H 10360 (2011) Rev 12 (
4.4 woL
Comstock Arm 2
11127f2019
drab
PH
SM 4500 IRB (2011)
6.6 pH Unb
Comstock Arcs 2
11/27/2019
Grab
Teatperahae
SM 2550 B (2010)
14'C
Comstock Anna 1
11/27/2019
drab
Dissolved Orc Vm
H 10360 (2011) Rev. 1.2 (
21 nVS
Comstock Am 1
11127R019
Grab
pH
SM 4500 H+B (2011)
6.6 pH Units
Comstock Area I
Comstock Upstream
11fI7)4019
11/27/2019
Grab
drab
Tcoperabme
Dissolved Oxygen
SM 235013 (2010)
H 10360 (2011)Rev. 12 (
131C
7.4 mglt.
Comstock Upstream
11/2712019
drab
pH
SM 4500 H+B (2011)
6.7 pH Units
Comstock Upsncom
11/27/2019
Grab
Tcsaperahse
SM 2550 B (2010)
13'C
Comstock Dmwotbram
11/2712019
Grab
Dissolved Oxygen
H 10360 (2011) Rev. 1.2 {
5.S mg/L
CMsrstock DbRMtreav
11127/2019
Grab
pH
SM 4500 Hi B (2011)
6.6 pH Units
4aromo* Dowostrem
11127/2019
Grab
Temperahme
SM 25S0 H (Z010)
12'C
Reviewed by: Tamika Black Labontloy scientist
Approved by: Darrell dews LA —tort' sq-Visor bill G(,[
The following pmwneters are not included in the ISO 17025 Scrape of Accreditation:
pH, conductivity, tttrnperatwz. dissolved oxygen and turbidity.
Results apply to the sample as receivcd unless Otherwise noted
Page 1 of e
Revised 11127/201S.SM-OD 1

,t a ► I 0 j 0I ['?.t -bun--
Chain of Custody
Y
Nov-99 tl rr..LN 14
Bail urging Info:
Date
WL
TD
1" well = 0.122 2"well = 0.49 3"well =1.
TD (fij - WL
❑ Well Closed and Locked
Odor Y N
Cloudy Y N
Total gallons Bailed/ Purged # of Bailers needed
# of Bailers collected
Kimberly Galulia
gal
Sampling Info:.ample Cdll c 7 "� Y
'4 sum S
Date 1\17q-111
Time
Use only if sampling next ay
TD
WL
pH
Temp J!) .Z
Odor N
Cloudy © N
Spc Cond
DO mg/L
❑ 8 oz. unpreserved bottle:
NO3
Sampled by
Kimberly Galutia
Temp
On Ice Y N
VlhLIMAYE43
/11;t:IRl VFD lmk g -i� -
Page 2 of 8

w
`�
Nkvi t
Nov-19
Bai tingeurging Info:
Date
TD
V well = 0.122
Q
Chain of Custo
V" C-0'v
Twell = 0.49 3"well = 1.
3
❑ Well Closed and Locked
Odor Y N
Cloudy Y N
=4A0
To (fti - wl_
Tonal gallons Bailed/ Purged # of Bailers needed
# of Bailers collected
Kimberly Galutla
i liti:�;-`i-, er.: Q� ;,es„Y��wiS[t �r-4.S+r.}:�*r4� ]ihl.«l: ; .,,yyaii..•: � � 'N!N Ck•=L'<
Sampling Info:Sainpt'Collect[?,;_:.�Yta:..:rfi+r;a'q,.
Date XX 1q,:)A `1
Time Wq-
se only it sampling naxt day
TD
Wl_
pH�-- -U`Z
Ternp
Odor l Y� N
Cloudy �1 N
❑ 8 oz. unpreserved bottle:
NO3
Sampled by
Kimberly Galutla
Spc Cond
DO mg1L 4 M,
Temp
On Ice Y N
Page 3 of 8

0
ON
'V
Chain of Custo
Nov-19
ing Info:
Date
TD
Well C t_ igr�2
❑ Well Closed and Locked
Odor Y N
Cloudy Y N
1" well = 0.122 2"well = 0.49 3'Well = 1.1 6" mell =4.40
TD (ft) - WL (ft) X gal
Total gallons Ballet!/ Purged # of Bailers needed
# of Bailers collected
Kimberly Galutla
Sampling Info:
Date \02a'111
1630 ❑ 8oz. unpreserved bottle:
Time NO3
Use only If sampling next ay
TD
Sampled by
WL Kimberly Galuba
pH to iDSpe Cond
Temp - DO mg/L��o
Odor ' N Temp
Cloudy 1� N On Ice Y N
1/-zi.11 ":4sp„,,
By
Page 4 of 8

Nov-19
Bailing/Purging Info:
Date
TD
'efI Chain of Custod
k
❑ Well Closed and Locked
Odor Y N
Cloudy Y N
9" well = 0. W 2"well = 0.49 3"well — B"wel€ =4.90
TD (ft) - WL (ft) X — gal
Total gallons Bailed/ Purged # of Bailers need
# of Bailers collected
Kimberly Galutia
.'- ;1j"sf' +•--a��• x��G� -767 Sampling Info:
- ea. '.r..+..r+'ratit+-x..J'9ui -�• •_-
Date
❑ 8 oz unpreserved bottle:
Time NO3
Use only if sampling next ay
TD
Sampled by
WL IGmberiy Galutla
pH Spc Cond l
Temp L DO mg/L_
Odor N Temp
Cloudy V N On Ice Y N
l
R u€ B Date Time
Relinquished By Date Time
Re ed Date Time
Received By Date Time
I N"r
Page 6 of 8

Chain of Custod
Nov-19 L' b l�S��`n
Bailing/Purging Info: ❑ Well Closed and Locked
Date Odor Y N
WL Cloudy Y N
i
TD
i
1" well = 0.122 2"well 0.49 TWell =1.1 6"well =4.40
TD (ft} - WL {ft} X - gal
Total gallons Bailed/ Purged # of Bailers needed
— # of Ballets collected
Kimberly Galutia
Sampling Info:Sample.Coliected?;' +Yr" Y - Y (N
Date
❑ 8 oz. unpreserved bottle:
Time NO3
Use only Ir sampling next ay
TD
Sampled by
WL r - limberly Galutia
pSpc Cond
Temp DO mg/L_a_,-n
Odor oa, y�-tg Temp
Cloudy Y (0 On Ice Y N
Date Time
Relinquished By Date Time
--IYV4r1-27-lq 545,�,
Date Time
Rv
Received By Date Time
Page 6 of a

I A411.
14
5 11 Chain of C
Nov-19
ing Info:
NMI
%kr4A-Y%-N
❑ Well Closed and Locked
Da Odor Y N
WL Cloudy Y N
TD
i
1" well = 0.122 2"well = 0.49 3"well = 1.1 6"well =4.40
i
TD (ft) - WL (ft) X = gal
Total gallons Bailed/ Purged # of Bailers needed
# of Bailers collected
Kimberly Galutia
Sampling info:
Date �0
� ❑ 8 oz. unpreserved battle:
Time NO3
Use only If sampling next ay
TD
Sampled by
WL Kimberly Galutia
pH Cp- D� Spc Cand
Temp DO mg/L
Odor Y Temp
Cloudy Y On Ice Y N
Is B Date Time
Relinquished By Date Time
lr ,.-7/11 T.4,5p i
Z
IRk"ed Date Time
Received By Date Time
116 X 111 g -7r
Page 7 of 8

Date: ! f — --� 1 C)
Analyst: YNO�
Specific Conductivity
(as needed)
Date:
Specific Conductivity Read Only
PH
Dissolved Oxygen
Date:
Analyst:
Specific Conductivity
(as needed)
Date:
Specific Conductivity Read Only
PH -
Dissolved oxygen
Calibration Log
Standard
Reading Before Cal
Readin After Cal
'temp of Standard
1413
jt S
l
rz�G
Standard
Read Only
Temp of Standard
1000
1052
19. 1
Soo
5-279
_ 112
100
A-AN--c IWb ww-%JA
Standard
Reading Before Cal
Temp of Standard
4
y.03 1
1q. y
7
-1 .O-L
Il.co
10
9.cl$
q
! —5
Wickler
Reading After Cal
Temp of Standard
Calibration Log
Standard
Reading Before Cal
Reading After Cal
Temp of Standard
1413
Standard
Read Only
Temp of Standard
1000
Soo
100
Standard
Reading Before Cal
Temp of Standard
4
7
10
Wickler
Reading After Cal
Temp of standard
Page 8of8

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Invoice Text
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Materials

A&0rder Information
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1 X 53 li
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RAL- News & Observer
Run Schedule Invoice Text
Sewage Discharge (3112 Comstock Dr., Ral
Run Dates
12/07/2019
NOTICE of DISCHARGE
OFUNTREATEDWASTE
Plow I.UtllN Oeparhrent
On November 261h 2019, of 11-53 AM,
Raleigh Water - Sewer Mainlenonce Di-
vision responded to a sewer spill coming
from a manhole located behind 3112
Comstock or, Raleigh. NC. The North
Carotno Department of Environnmial
Quality, Division of Water Quality was
notified of the overflow.
The responding staff took all reason
ble steps to stop and mitigate the import
of the sp:ll as soon as they arrived
ness today. 11
occurred for
based on an
Me wim no observed damage to wild,
life. The cam of the spill was defer•
mined to be grease.
The City of Raleigh has an aggressive
education and enforcement program to
Prevent the discharge of grease, debris,
and other improper materials In the
sewer system and to take enforcement
action where appropriate. Only water,
human waste, and lallet tissue are per.
mitted to be discharged into the sewer
System.
This news release Is required by
NCGS Article 21, Chapter 143113.0 For
more Informallon. contact public UI1111-
ies Director Robert Mossengill or assis-
tant Public Utilities Director T.J. Lynch
at 9194%4540.
North Carolina Department Envlron-
ment and Natural Resources, Division of
Water Quality was notified of the over-
flow.
NLO: December 7, 2319
Production Notes
Placement
0300 - Legals Classified
Position
0301 - Legals & Public Notices
Ad Released
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Times Run Schedule Cost
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P*F 2 of 2 _FRLI 0r1a:Conlrcma!ion rpt

Raleigh Water Responds to a Sanitary Sewer Spill
Prep ared By: Jacob D. Barnhart; Communim Relations Coordinator, Raleigh Water
ForMore Information: Robert Massenoll, Raleigh Water Director. or T.J_ Limch.
AssitantRaietahlVaterDirector, 919-5096-3245
Torember 27. 2019
Raleigh Water Responds to a Sanitary Sewer Spill
On Tuesday,. Norember 26. 21019, at approxirnateh-11:33 am. Raleigh W-ker -
Sewer hUmtenance Dt,,ision staff responded to a sanitary sewer spill located at 3112
Comstock Drive, Raleigh, 'NC, The cause of the spill was related to grease in the line. The
responding staff took all rersonable steps to stop and mitigate the impact of the spill as soon
as they- arrived. The North Carolina Department of Em.4onmental Quality- Ditision of
Water Resomce4 was notified of the spill.
Raleigh [Cater - Sen-er ?Maintenance Dh iston :tiff stopped the spill at approximately
1:00 pm on the same &-. It is estirared that the spill discharged a c-olume of
appro,urnately 16,200 gallons of sewage, with all gallons reaching Beaman Lake in?klarsh
Basm with no obsen-ed damage to ttzidhfe- Restoration associated with this spiU etmni hill
restime onNoc-ember a?, 2019_
?lie City of Raleigh has an aggressive education and enforcement program to
prevent the discharge of grease, debris, and other improper materials in the sewer
system and to take enforcement action where appropriate. Only miter. human waste,
and toilet tissue are permitted to be discharged into the sewer system. If citizens
experience excessive sewer smells or see setter Gveriion ing manholes or pipes, please
call 919-996-3245 and report immediateh:
Tins news release is required by NCG5 Article 21, Chapter 143.215-C. For more
information, contact Raleigh Water Director Robert Massengili or Anistant Raleigh [Cater
Director T.J. U%mch at 919-996-32.13_
rawa�s �en��u