WQCS00002_NOV-2020-DV-0309 Response_20200807

%
�%/00
1iro
11111111
Raleigh Water
August 7th, 2020
Mr. Scott Vinson
Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Response to NOV-2020-DV-0309
Sanitary Sewer Overflows - June 2020
Permit No. WQC500002 Raleigh Collections System, Wake County
Dear Mr. Vinson:
may
Aug —7 �o
NC DENR Raleigh Regional Offs
r:
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil
Penalty document (NOV-2020-DV-0309) received on July 241^, 2020. This document contains narratives
regarding pending violation actions of (3) Sanitary Sewer Overflows (SSO) events, which occurred during
the month of June 2020 within the City of Raleigh Collections System (tj. 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
actions taken to stop the spill; contain the released wastewater; collect the wastewater and
reintroducing it to the collection system; and finally, restoring the possible environmental impacts
brought by the release of the SSO events, listed with the intended NOV-NOI action. Please find below,
the additional information requested for each of the SSO events.
1. "The Director may take enforcement action against the Permlttee for SSos that must be reported to the Division as stipulated In Condition IV92j. This includes
5SOs that were caused by severe natural conditions or exceptional events unless the Permittee demonstrates through properly signed, contemporaneous operating
logs, or other relevant evidence that:
ja.j The 5S0 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 back-up equipment or should have reduced Inflow and Infiltration; or
(b.I The SSO was exceptional, unintentional, temporary and Caused by factors beyond the reasonable control of the Permittee; the S50 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 colrectlon facilitles to accommodate growth or adequately controlling and preventing Infiltration and
Inflow); preventative maintenance; or Installation of adequate back-up equipment;"
Page i of 11

Incident Number # 202002047 — 6/22/2020 — 617 Granite Creek Dr.
This spill was neither willful nor intentional, it was the result of a grease build-up, restricting the
sewer flow within a section of 8-inch gravity sewer main. This build-up led to a sewer spill of
approximately 4,000 gallons of untreated wastewater of which about 1,000 gallons reached the surface
waters of Sanford Creek within the Smith Creek Basin. Approximately 3,000 gallons of wastewater
rested within the natural topography of the land not reaching other major surface waters.
On 06/22/2020, at approximately 11:54 AM, Sewer Maintenance staff was notified of a sewer
spill emanating from a manhole adjacent to 617 Granite Creek Dr. Rolesville NC. 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 2:30 PM on the same day. Crews utilized hydraulic jetting to remove
the source of the blockage within the affecting asset, thus restoring sewer flow.
Containment, collection, cleanup, and restoration of this spill event consisted of employing a
temporary spill containment site downstream of the affected area. This approach was intended to
contain the flow of sewer and minimize the environmental impact on the surrounding land. This spill
was contained without a significant environmental impact to the adjacent area and its natural resources.
Visual inspection of the affected area and downstream waters confirmed that no fish kill or unnecessary
vegetative damage occurred.
During the restoration phase of the operation, crews utilized ample potable water to flush the
affected area and to remove traces of sewer from the area surrounding the manhole and the
downstream stormwater system. Crews employed pumps at the temporary containment site, to recover
flushed wastewater and any evidence of sewer. The area around the manhole was cleared of debris,
treated with an application of lime, and restored with grass seed and straw.
A follow CCTV assessment of the affected asset was completed on 07/31/2020. The assessment
found no infrastructure issues that could have caused the sewer event. Further CCTV assessment is
scheduled to verify the effectiveness of the cleaning, post-SSO mitigation, in order to minimize the
potential of a re -occurrence. No further issues have occurred at this site since this event.
The cost associated with the mitigation of this event amounted to $3,842.83. The approximate
cost to the Utility to have treated 4,000 gallons of wastewater would have been approximately $6.00.
The City saved no money from this spill. The costs for cleanup exceeded the cost of treating the volume
of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater
volume of sewage created by the spill.
This section of the collection system serves a residential area east of Rogers Rd. in Rolesville,
providing sewer collection services to over 200 residents. There have been no previous recorded sewer
spills associated with this section of the sanitary sewer collection system.
A press release notification, associated with this event, was requested to be published in the
Raleigh News & Observer on 06/23/2020.Outreach information was mailed to 214 affected 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. (See enclosure 1 and
2 below)
Page 2 of 11

Prior to this event, maintenance records .show that sections of this collection system were
assessed as follows:
Flushing activities Repair activities CCTV activities
Inspection Easement
activities maintenance
06/24/2020 07/17/2020 01/12/2018
12/16/2015 02/09/2017
07/10/2020
07/20/2018
6/18/2014
There have been no additional issues associated with this section of the collection system since
the last sewer event. This site has been added to the Hot Spot Management Program for grease
management with a recommended maintenance interval of every 90 days.
Page 3 of 11

Incident Number # 202002101— 06/2-9/2020 — 5100 Simmons Branch Trail, Raleigh
This spill was neither willful nor intentional, it was the result of debris blocking a portion of an 8-
inch gravity sewer main. The blockage led to a sewer spill of approximately 570 gallons of untreated
wastewater reaching surface waters of Simmons Branch within Simmons Basin.
On 06/29/2020, at approximately 11:06 AM, Sewer Maintenance staff was conducting a CCTV
assessment in the area near 5100 Simmons Branch Trail, Raleigh when the operator identified a
manhole spilling over. The operator immediately summoned reactive maintenance to the site of the
spill. 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 12:03 PM on the same day. Crews utilized
hydraulic jetting to remove the source of the blockage within the affecting asset thus restoring sewer
flow
Containment, collection, cleanup, and restoration of this spill event consisted of employing a
temporary sewer containment site downstream from the SSO location to stop the flow of sewer into the
stream. Crews used two pumps at the temporary containment site, to recover the remaining sewer and
pump it 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 area around the
manhole was cleared of debris, treated with an application of lime, and restored with grass seed and
straw.
This spill was contained without a significant environmental impact to the adjacent area and its
natural resources. Visual inspection of the affected area and downstream waters confirmed that no fish
kill or unnecessary vegetative damage occurred.
The cost associated with the mitigation of this event amounted to $3,698.08. The approximate
cost to the Utility to have treated 570 gallons of wastewater would have been approximately $0.85. The
City saved no money from this spill. The costs for cleanup exceeded the cost of treating the volume of
sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater volume
of sewage created by the spill.
This section of the collection system serves a residential area east of Jones Franklin Rd., Raleigh.
This system provides sewer collection to over 90 single-family properties.
Before this event, maintenance records show that sections of this collection system were
assessed as follows:
Flushing activities Repair activities CCTV activities
Inspection Easement
activities maintenance
17/15/10 03/26/2020 7/15/2010
02/9/2018 06/29/2020
6/18/2013 6/15/2010
03/26/2018
6/19/2013 07/16/2020
06/4/2018
7/3/2013
11/21/2018
10/3/2014
02/6/2019
7/1/2015
02/19/2019
7/7/2015
06/24/2019
6/25/2018
12/19/2019
09/3/2019
01/7/2020
10/29/2019
04/3/2020
11/7/2019
04/7/2020
Page 4 of 11

The latest maintenance/inspection assessment for this site was conducted on 7/6/2020. CCTV
inspection of the affecting assets identified an offset joint that may have attributed to the accumulation
of debris in the main leading to the consequent spill. A follow-up work order has been scheduled to
correct the pipe joint. There have been no additional issues associated with this section of the collection
system since the last sewer event. This site has been added to the Hot Spot Management Program for
debris management and repair with a recommended maintenance interval of every 60 days.
Page 5 of 11

Incident Number # 202002114 — 6/30/2020 — 4000 Tryon Rd. Raleigh
This spill was neither willful nor intentional, it was the result of substantial pipe tuberculation
restricting sewer flow within an 8-inch Ductile Iron gravity sewer main. This asset failure led to a sewer
spill of approximately 120,223 gallons of untreated wastewater reaching surface waters of Walnut Creek
within Walnut Basin.
On 6/30/2020, at approximately 12:30 AM, during a routine site assessment, Sewer Maintenance
staff discovered sewer emanating from a sewer manhole, which had been utilized as a point of sewer
bypass during the sewer rehabilitation project. Upon arrival, it was determined that debris had
accumulated within the tuberculated pipe resulting in reduced flow capacity and the consequent sewer
spill. 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 2:30 PM on the same day.
Containment, collection, cleanup, and restoration of this spill event consisted of employing
several temporary spill containment sites downstream of the affected area. This approach was intended
to contain the flow of sewer and minimize the environmental impact on surrounding land and surface
waters. This spill was contained without a significant environmental impact to the adjacent area and its
natural resources. Visual inspection of the affected area and downstream waters confirmed that no fish
kill or unnecessary vegetative damage occurred.
This spill was attributed to the rehabilitation project of approximately 1,170 ft. of sewer gravity
main laying under Interstate 40 near Gorman 5t., Raleigh. This Project was the result of a previous spill
that occurred on May 7, 2020 (Incident Number 202001341) caused by pipe corrosion and
tuberculation. The goal of this project was to ensure that the corrosion was not likely to cause an
imminent failure under the Beltline. As part of the corrective action, a by-pass operation was set in
place to allow CCTV work to occur, completing a pipe condition assessment. This assessment
determined that there were no collapsed sections of pipe. Therefore, flow was reintroduced
intermittently, only activating the by-pass during times of active cleaning or camera work. As the
rehabilitation effort of the sewer main progressed, the Utility determined that the bypass operation
could be deactivated during non -working hours (nights and weekends) re-establishing normal flow.
Once sewer flow was fully re-established routine assessments and inspections determined the sewer
main was capable to sustain flow capacity therefore not needing to be bypassed. During the time the
sewer flow was restored, the bypass equipment remained in place to facilitate a proactive replacement
of this line should another sewer spill occurred. The line subsequently backed up due to an unforeseen
blockage under the beltline resulting in a spill event. Crews were able to swiftly reactivate the by-pass
equipment stopping the overflow.
During the restoration phase of the operation, crews utilized ample potable water to flush the
affected area and to remove traces of sewer from the area surrounding the manhole and the
downstream stormwater system. Crews employed pumps at the temporary containment site, to recover
flushed wastewater and any evidence of sewer. The areas around the manhole were cleared of debris
and washed with potable water. The area around the manhole was cleared of debris, treated with an
application of lime, and restored with grass seed and straw. The restoration to this site was completed
on 07/2/2020 cleaning approximately 5,000 ft of surrounding surface waters and adjacent land.
Page 6 of 11

The cost associated with the mitigation of this event has amounted to $ 19,182.27. The
approximate cost to the Utility to have treated 120,223 gallons of wastewater would have been
approximately $180.00. The City saved no money from this spill. Its costs for cleanup exceeded the cost
of treating the volume of sewage had no spill occurred. Furthermore, the City still had to pay the cost to
treat the greater volume of sewage created by the spill. Repairs are currently ongoing which could incur
higher costs for complete mitigation.
This site continues to be an active sewer pipe rehabilitation project. Since June 30th, Utility
Operators have conducted daily inspections, twice a day to ensure no other events are imminent. As of
07/29/2020 the integrity of the pipe has been restored allowing normal sewer flow to continue.
Prior to this event, maintenance records show that sections of this collection system were
assessed as follows:
Repair Easement
Flushing activities activities CCTV activities Inspection activities Maintenance
3/30/2010
6/5/2014
No records of
5/15/2010
8/6/2014
repairs or
3/23/2012
12/28/2014
improvements
9/22/2012
4/18/2015
for the last 10
12/29/2012
9/10/2015
years
3/10/2013
05/01/2018
6/12/2013
02/21/2018
3/20/2014
Activities
06/12/2017 04/6/2020
02/16/2018
09/25/2017
10/11/2018
06/02/2020
12/19/2018
06/03/2020
05/6/2019
O6/10/2020
07/12/2019
06/22/2020
08/6/2019
06/24/2020
This section of the collection system serves a commercial and residential area south of 40 and
West of Gorman St., providing sewer collection services to several multi -dwelling properties and various
commercial establishments. The last recorded sewer spill associated with this section of the sanitary
sewer collection system occurred on 5/07/2020. A press release notification, associated with this event,
was requested to be published in the Raleigh News & Observer on July 2"d, 2020. See picture below.
Page 7 of 11

NOTICE OF DISCHARGE
OF UNTREATED WASTE
City of Raleigh
Public Utilities Department
On Tuesday , June 30th, 2020, at op•
proxlmalely 12.30 PM, Raleigh Water -
Sewer Maintenance Division sluff re-
sponded to a sanitary sewer overflow lo-
cated in the vicinity of 4000 Tryon Rd,r
Raleigh NC. The cause of the overflow
was related to a sewer pipe failure, dis•
rupting the flow of a 8-Inch sewer gravi-
ty main. The responding staff took all
reasonable steps to stop and mlligole
the impact of the overflow as soon as
they arrived. The North Carolina De-
partment of Environmental Qualily, Di-
vision of Water Resources was notified
Responding staff slapped the over-
flow at approximately 2:30 PM on the
some day. It is estimated that the over-
flow discharged a volume of approxi-
mately 120,223 gallons of untreated
wastewater, reaching an unnomed Irlb-
utary at Walnut Basin. Restoration asso-
ciated to this sewer event Is ongoing.
There were no observed fish killed or
vegetative damaged associated with this
event.
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 toilet tissue are Per -
mined to be discharged Into the sewer
system.
This news release Is required by
NCGS Article 21, Chapter 143.215.0 For
more information, contact public Utilit-
ies Director Robert Mossengill or assis-
lanl Public Utilities Director T.J. Lynch
at 919.996.4540.
North Carolina Deportment Environ-
ment and Natural Resources, Division of
Water Quality was notified of the over-
flow.
NCO: July 2, 2020
Page 8 of 11

Summary
The Division of Sewer Maintenance, Public Utilities Department, strives in developing initiatives
that improve operational reliability with the goal to meet customer expectations and to meet or exceed
the requirements of the Water Quality Collection System permit. Our operations are focused on
continual improvement, the prevention of pollution, and increase efficiency in environmental
performance. This is greatly noted as the Division continues to operate an ISO Certified Environmental
Management System governed by the 14001-2015 Standards. As part of these initiatives, the Division
operates a comprehensive reactive and preventative maintenance program whose goal is not only to
maintain over 2600 miles of sanitary sewer pipe but also to minimize the accidental release of untreated
wastewater.
Since July 1, 2019 (Fiscal Year 2020), the Utility has maintained approximately 382 [11 miles of
gravity sewer mains, by flushing with hydraulic jetting, CCTV assessments, repair operations, easement
maintenance, and inspections. The fiscal year 2020 cost of these operations amount to $3,102,022.92,
approximately 23% of the Division's annual operating budget. The total volume of sewer spills identified
in this letter adds up to 124,723 gallons at a total mitigating cost of $26,723.18. The City saved no
money from these spills. Their costs for cleanup exceeded the cost of treating the volume of sewage had
no spill occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage
created by these spills.
The City's cost of sewer treatment per gallon is $.0015 [2]. At this rate, it would have cost the
City $187.08 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 2.25 spills per 100 miles of pipe, compared to the Southeastern Region of
the US, of 7.0 spills per 100 miles of pipe.
(1) 382 miles represents 14%of the sanitary sewer collection system
j21 S-0015 Is based on the annual water treatment operating cost compounded by the total treated effluent
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 sanitarysewer
collections systems nationally. These agencies are working collectively to challenge the testing
protocols, assessment guidelines, and consumer education and labeling of these non -dispersible.
Page 9 of 11

It is important to mention that the reportable sewer events identified in this letter for the
month of June 2020, show that only one event was related to grease. Between January 1st and July 1st,
2020, 40% of reportable spills have been related to grease accumulation. Public Utilities continues to
increase its educational outreach to reduce this trend. The Department has developed new educational
material as well as informational videos 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 material
and videos can access through social media and our Department's website
https://raleighnc.gov/sewer-maintenance
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.
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 SSO 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 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 that the NOV-NOI issued for the month of June
2020 be fairly reviewed taking into consideration the steps the Department has taken to protect the
environment and meet or exceed the requirements of the Collections System Permit. If additional
information is required, please contact Matthew Vessie, Sewer Maintenance Superintendent (919) 996-
2312 orT.1. Lynch, Assistant Public Utilities Director, at [phone].
Page 10 of 11

Sincere
Carlos erez, 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.perezcamachoOraleiehnc.Gov
CC: Robert Massengill, Public Utilities Director
T. I Lynch, Assistant Public Utilities Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance Division
Page 11 of 11

_ _.r�
LBy
E�� L 2 4 2020
ROY COOPER7.
MICHAEL S. REGAN '� �.,,,, ,:%
Srrrrinry �''��;�! m�'
S. DANIEL SMITH NQR7P1�;R' )IJNA
DAva" fnvreanracnfal Quallfy
CERTIFIED AIL: 7 16 3569 0000 4428 7090
RETURN RECEIPIBEQUESTED
July 13, 2020
Robert Massengill, Director Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2020-DV-0309
Sanitary Sewer Overflows - June 2020
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
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 (Mins) Location Cause (Gals) (Gals) DWR Action
202002047 6/22/2020 156 617 Granite Creek Dr Grease
4,000 1,000 Notice of Violation
Notice of Intent
202002101 6/29/2020 R 57 W 5100 SIMMONS Debris in line
500 500 Notice of Violation
BRANCH TRL
202002114 6/30/2020 120 4000 Tryon Road, Pipe Failure (Break)
120,223 120,223 Notice of Violation
Raleigh, NC
Notice of Intent
Jf M10%Cam raDepanaartdErvr:r.rra•ta qua t; I Dva:r,fts{tt28tz;4Ini
,. fiate. 5qlIarea aD•vaIRaIsf rt»t,tee--tIIISC?

This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.5A, 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,
�X'74vx�� z��
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
l.aserfiche
�[?I:rtw.'tr� �►WolR+rlrlcFcfr•:rrrlell ��lsy I D��s:ro}t:n*:F*r.:=a�
`� ;it g•Rig :r* Off :t19f?:Etertr.C-r:*I;itj•.►tauZrrre;M.:?
�rr pL:.I�1+ii�S