wqcs00005_NOV-2021-DV-0054 Response_20210217

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/ FEB t 6 2021
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` 0 NC DENR Raleigh Regional QMQ9
Raleigh Water
February 161, 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-2021-DV-0054
Sanitary Sewer Overflows — December 2020
Permit No. WQCS00002
Dear Mr. Vinson:
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil
Penalty document (NOV-2020-DV-0054) received on February 2n', 2021. This document contains
narratives regarding pending violation actions of (3) Sanitary Sewer Overflows (SSO) events, which
occurred in month of December 2020 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 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-N01 action. Please find below,
the additional information requested for each of the SSO events.
1. 'The Director may take enforcement action against the Permittee for SSOs that must be reported to the division as stipulated In Condition IV92j. This Includes
550s that were caused by severe natural conditions or exceptional events unless the Permlttee demonstrates through 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 S50, 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
[fa.] The SSO was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the Permittee; the S5o cauld not have been
prevented by the exercise of reasonable control, such as proper management, operation, and maintenance; adequate treatment or collection facilities or
:omponents (e.g., adequately enlarging treatment of collection facilities to accommodate growth or adequately controlling and preventing infiltration and
r,fiow); preventative maintenance; or Installation of adequate back-up equipment;"

Incident Number # 202003448—12/19/2020 — 9299 Glenwood Ave., Raleigh, NC (Sycamore Creek
Pump Station 36)
This spill was neither willful nor intentional; it was the result of a circuit breaker
malfunction causing electrical conflict between the Programmable Logic Control (PLC) system
[1] and the Radio Telemetry Unit (RTU) [2] of Sycamore Creek Pump Station # 36. The
malfunction affected wastewater flow from a 30-inch Polyvinylchloride (PVC) gravity sewer
main. This event resulted in approximately 58,544 gallons of untreated wastewater to spill into
an unnamed tributary of Sycamore Basin.
On 12/09/2020, at approximately 6.28 AM, Raleigh Water staff discovered that the
wastewater flow within the facility's wet -well was above the normal level. Operators
immediately started to actuate the pumps to bring the wastewater levels down manually;
however, the pumps would only work momentarily due to the electrical control system that
actuates the pumps were submerged under wastewater. As an immediate corrective action,
Utility Contractors were summoned to initiate a sewer by-pass. As part of the spill containment
measures, several large -capacity pumps were deployed and strategically placed to control the
facility's wastewater flow. The containment measure ensured that the wastewater remained
within the facility's wet and dry well. This initiative ensured that approximately 140,753 gallons
of wastewater remained in the facility's wells. At approximately 2:04 PM, the containment
measures were unable to keep up with the demand of sewer flow resulting in the subsequent
spill of roughly 58,544 gallons of untreated wastewater. At approximately 7:40 PM, the
temporary by-pass was installed and activated, restoring sewer flow and stopping the spill.
Containment and collection of this spill event consisted of placing a temporary
containment dam downstream of the station. This emplacement contained filtering media to
stop wastewater debris from flowing downstream. A 4-inch pump was placed in the
containment dam to collect and transfer the wastewater from the stream and reintroduce it
into the collection system. With the capacity to store 6,000 gallons of liquid, two tankers trucks
were utilized to removed roughly 48,000 gallons of wastewater from the facility. This combined
containment and collection effort was successful in the transfer of wastewater elsewhere in the
collection system.
Restoration of this spill event consisted of washing the land surrounding the station.
Crews utilized ample potable water to flush the affected area. Sewer debris and solids were
collected and disposed of accordingly. 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.
A subsequent investigation of these events revealed that a circuit breaker had
malfunction causing the Programmable Logic Control system (PLC) to fail to actuate alternate
pumps within the station's dry well. The circuit breaker malfunction also triggered the Radio
Telemetry Unit (RTU) to transition into alternate battery power resulting in a failed telemetry
alarm. The unintentional electronic malfunction caused the primary, secondary and tertiary
wastewater pumps to stop. When these pumps stopped, wastewater levels increased and
r}... ... 7 Ch

flowed from the wet well into the dry well through a conduit aperture on the wall that
separates both wells. The wastewater -flow subsequently submerged the pumps and their
electrical controls, resulting in a systemic malfunction.
The cost associated with the mitigation of this event has amounted to over $230,000.
The approximate cost to the Utility to have treated 58,544 gallons of wastewater would have
been approximately $87.81. 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.
This pump station transfers approximately 1.0 MGD South of Glenwood Avenue,
providing sewer collection services to residential and commercial establishments within Turkey
and the Sycamore Basin. There has been no history of sewer spills associated with this section
of the sanitary sewer collection system. Before this event, maintenance records show that this
station was last serviced and inspected on 12/01/2020
There have been no additional issues associated with this section of the collection
system since the last sewer event. This site remains an active maintenance spot until all electric
upgrades have been installed ad test for efficiency. The sewer by-pass connection used to
temporarily control the wastewater flow remained a permanent backup system of the station.
The station continues to be upgraded to ensure no other malfunctions occur. As the result of
this event, the Utility conducted a systematic assessment of 8 other pump stations identifying
them as possible sites requiring electronic system updates.
A press release notification associated with this event was requested to be published in
the Raleigh News & Observer on December 10th, 2020.
[1] A Programmable Logic Controller or PLC, is a ruggedized computer used for industrial automation. These controllers can automate a specific
process, machine function, or even an entire production line. In wastewater, operations is often used to control alternating pump functions
within a sewer network structure such as a pump station.
(2] A Radio Telemetry Unit, or RTU, is a point-to-point direct communications system used to alert the system's controller of the status of a
remotely located peripheral device such as a pump In a remote pump station. The system Is designed as an early warning device to alert
operators of possible remote system Issues.
paua R of cl

Incident Number # 202003538—12/23/2020 — 3120 Walnut Creek Parkway, Raleigh, NC
This spill was neither willful nor intentional; it resulted from debris (see Exhibit #1 below)
partially blocking a portion of an 8-inch ductile iron gravity sewer main. The blockage led to a sewer spill
of approximately 39,000 gallons of untreated wastewater reaching an unnamed tributary's surface
waters in Walnut Basin.
On 12/26/2020, at approximately 11:55 AM, a Sewer Maintenance staff conducting a site
inspection identified a manhole spilling over. The operator immediately summoned Utility Responders
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 2:05 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 and collection of this spill event consisted of employing two temporary spill
containment sites downstream of the affected area. This approach is intended to contain sewer flow
and minimize the environmental impact on the surrounding land. Responding crews initiated the
collection of untreated wastewater from both containment sites to re -introduced it to the collection
system downstream. 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
no fish kill or unnecessary vegetative damage occurred.
During the restoration phase of the operation, crews utilized ample potable water to remove any
sewer evidence downstream of 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.
The cost associated with the mitigation of this event amounted to $27,138.93. The approximate
cost to the Utility to have treated 39,000 gallons of wastewater would have been approximately $58.50.
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.
A follow-up investigation of this event determined that this spill event may have been attributed
to a previous rehabilitation project upstream of the affected asset. This project resulted from a prior
sewer spill on May 7th, 2020 (Incident Number 202001341). This spill was caused by pipe corrosion and
tuberculation. As a result of this project, approximately 1,170 ft. of sewer gravity main (traversing under
1-40 was assessed for tuberculation and lined with PVC.
As a result of the sewer spill event on December 23rd, Raleigh Water increased the sewer
maintenance effort of approximately 3,261 ft of gravity sewer main. Maintenance of this section of the
collection system consisted of hydraulic flushing, mechanical hydro -cutting, vacuum & removal of
debris, and CCTV verification. Since January 5th, 2021, crews have completed maintenance of
approximately 1,684 ft of sewer main. Maintenance and CCTV verification are still ongoing.
This section of the collection system serves a commercial and residential area south of 40 and
West of Gorman St. It provides sewer collection services to several multi -dwelling properties and various
commercial establishments. The last recorded sewer spill associated with this asset occurred on
5/07/2020. A press release notification of the December 23rd event was requested to be published in
the Raleigh News & Observer on 12/23/2020 (see Exhibit #2 below).
Page 4 of 9

Exhlb"t # 1— Debris found in the ma'n not consistent
with regular wastewater debris such a paper
Exhibit # 2 — Nonce of Discharge and Press release
December 23rd, 2020
Raleigh Water Responds to a
Sanitary Sewer Overflow
On Wednesday, December 23rd, 2020, at
approximately 11:55 AM, Raleigh Water
staff responded to a sanitary sewer
overflow located at 3120 Walnut Creek
Parkway, Raleigh, NC. The cause of the
overflow was related to debris accumu-
lation and heavy sediment, which dis-
rupted the flow of an 8 -inch ductile iron
pipe sewer gravity main. The respond-
ing staff took all reasonable steps to stop
and mitigate the overflow's impact as
soon as they arrived. The North Caroli-
na Department of Environmental Quali-
ty, Division of Water Resources was no-
t If led of the overflow.
Raleigh Water - Sewer Maintenance Di-
vision staff stopped the overflow at ap-
proximately 2:05 PM on the some day. It
is estimated that the overflow dis-
charged a volume of approximately
39,000 gallons of untreated wastewater,
reaching an unnamed tributary of Wal-
nut Basin. Restoration associated with
this sewer event is ongoing.
Raleigh Water has an aggressive edu-
cation and enforcement program to pre-
vent the discharge of grease, debris,
wipes, rags, diapers and other improper
materials in the sewer system and to
take enforcement action where appro-
priate. If these items make it into the
sewer system, they may cause a spill
which can have an adverse impact on
water quality and endanger those who
come into contact with the affected
areas.
• Water, human waste, and toilet tissue
are the only items permitted to be dis-
charged Into the sewer system. All other
Items will cause damage to the sewer
system and are not permitted.
• If you experience excessive sewer
smells or see sewer spilling from man-
holes or pipes, please call 919-995-3245 to
report Immediately.
• For more information about how you
can help prevent sanitary sewer spills,
please visit: ralelohnc.gov/water,
This news release Is required by NCGS
Article 21, Chapter 143.215.1C.
N&O: December 25, 2020
„__„ V _#„

Incident Number # 202003591 — 12/30/2020 —10S Summershade Ct., Knightdale, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the
sewer flow within a section of 8-inch polyvinyl chloride gravity sewer main. This build-up led to a sewer
spill of approximately 780 gallons of untreated wastewater in which approximately 400 gallons reached
an unnamed tributary within the Mingo Basin.
On 12/30/2020, at approximately 10:20 AM, Sewer Maintenance staff was notified of a sewer
spill emanating from a private residential cleanout located at 105 Summershade Ct., Knightdale. The
responding staff arrived at approximately 11:00 AM and commenced taking all reasonable steps to stop
and mitigate the impact of the discharge, gaining control of the spill event by 11:32 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 and collection of this spill event consisted of employing a temporary spill
containment downstream of the affected area. This approach was intended to contain sewer flow and
minimize the environmental impact on the surrounding land. Responding crews initiated the collection
of untreated wastewater from the containment site and re -introduced it to the collection system
downstream. 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 remove sewer traces 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 cleanout was cleared of debris, treated with an
application of lime and restored with grass seed and straw.
A follow CCTV assessment was conducted on 01/05/2021 to identify the root cause of grease
accumulation. The CCTV assessment did not find any infrastructure issues that may have led to the
grease accumulation.
The cost associated with the mitigation of this event amounted to $4,298.46. The approximate
cost to the Utility to have treated 780 gallons of wastewater would have been approximately $1.17. 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.
This section of the collection system is located in a residential area. It provides sewer collection
services to over 200 residents. There has been no history of sewer spills associated with this section of
the sanitary sewer collection system.
A press release notification associated with this event was not required since the event was
below the 1000 gallons threshold. Outreach information literature was sent to approximately 205
residents within the immediate affected area on 01.07/2021. The outreach literature delivered 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 Exhibit # 1 below).
Page 6 of 9

Before this event, maintenance records show that sections of this collection system were
assessed as follows:
Flushing activities
03/27/2017
03/28/2017
12/31/2020
01/1/2021
CCTV activities
11/18/2015
03/10/2017
03/27/2017
03/26/2019
03/28/2019
03/29/2019
There have been no additional issues associated with this section of the collection system since
the last sewer event. This site continues to remain an active maintenance spot pending completion of
investigation.
Exhibit 1 Outreach information sent to residents w thinF
the immediate affected area of the spill event.
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Summary
The Sewer Maintenance Division of Raleigh Water strives to develop initiatives that improve
operational reliability to meet customer expectations and meet or exceed the Water Quality Collection
System permit requirements. Our operations are focused on continual improvement, the prevention of
pollution, and increased environmental performance efficiency. This endeavor is greatly noted as the
Division operates 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 to maintain over 2600 miles of sanitary sewer pipe and minimize
the accidental release of untreated wastewater.
Since July 1, 2020 (Fiscal Year 2021), the Utility has maintained approximately 258111 miles of
gravity sewer mains by flushing with hydraulic jetting, conducting CCTV assessments, and performing
repair operations, easement maintenance, and inspections. The fiscal year to date cost of these
operations amounts to $2,360,241.57121, approximately 13% of the Division's annual operating budget.
The 98,324 gallons of untreated wastewater spills identified in this letter has cost the Utility
approximately $261,437.39 to mitigate. The City's cost of sewer trealmenL per gallon is $.0015 111. At
this rate, it would have cost the City $147.50 to treat the entire volume of sewer spilled. The City saved
no money from these spills. The costs of mitigation well 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 sewage
volume created by these spills. This fiscal comparison shows the City's commitment to environmental
protection, sparing no cost regardless of the spill event's severity and complexity. The City continues to
demonstrate due diligence in environmental performance byallocating the necessary resources to a spill
event irrespective of the associated cost. This effort is noted in the City's low SSO performance rate of
1.14 total SSO rate [4l per 100 miles of pipe, compared to the Southeastern Region of the US, of 7.0 spills
per 100 miles of line.
111 186 miles represents 8%of the sanitary sewer collection system
121 Associated operational cost year to date for FY2021
OPERATION LINEAR FEET
COST
CCTV 220,357.31
$ 249,703,36
Flushing 1,134,893.96
$ 384,789.17
Repair 4,810
$1,451,831.56
Total-1,360,062,27 Ft
Total cost of
258 MILES Business to Date
$z,086,324.09
131$.0015 Is based on the annual water treatment operating cost compounded by the total treated effluent.
[41.24% attributed to dry weather 550S
Additionally, the City of Raleigh Assistant Public Utility Directors and Collections System staff has
become involved in challenging the nonwoven fabrics industry standards to better inform 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 nonwoven 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 work collectively to challenge the testing protocols, assessment guidelines, and
consumer education and labeling of these non -dispersible.
Page 8 of 9

Raleigh Water has an aggressive educational outreach initiative to address illicit discharges such
as wipes, fats, oil, and grease to commercial and residential users. Raleigh Water has developed a
complimentary property managers resource kit that provides best practice resources for establishing a
property -specific awareness program. Each kit contains brochures and complimentary gadgets to help
residents manage grease and fat collection and disposal. The resource kit also features a multimedia
flash drive with videos and reproducible educational material that property managers can use to
educate tenants to reduce the risk of sewer backups caused by the introduction of solids through their
residential piping. Each kit costs Raleigh water approximately $85.00 to produce and is provided free of
charge to the property management. Raleigh Water is continuously developing initiatives to increase
residential and commercial customer partnerships to address grease accumulation and prevent illicit
discharges. The educational material and videos can be accessed through social media and the Raleigh
Water website httPs:Hraleighnc.gov/sewer-maintenance
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 hoping 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 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 the discharge of grease into the sewer system and the effects of such
deposits. Whenever possible, and upon investigating 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-2020 NO1-0054 issued for the
month of December 2020 be fairly reviewed, considering 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 or T.J. Lynch, Assistant Raleigh Water Director, at [phone].
J
a
e�rely,
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. [e-mail]
CC; Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance Division
Pa PP q of q

Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mina) location Cause (Gals) (Gals) DWR Action
202003591 12/30/2020 78 105 Summershade Grease 780 40D Notice of Violation
Court
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 falls 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 splll 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
Laserfiche
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ROY COOPER
aoWmar
MICHAEL S. REGAN
S"Otory
S. DANIEL SMITH
Dhvdor
Robert Massengiil, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
EnWronmental QuaJlty
January 22, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL. PENALTY
Tracking No.: NOV-2021-DV 0054
Sanitary Sewer Overflows - December 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 Surrace
Incident Start Duration Vol Water
Number Date (Minn) Location Cause (Gals) (Gals) DWR Action
202003448 12/9/2020 336 9299 Glenwood Pump station 58,544 58,544 Notice of Violation -
Ave, pump station- Asset equipment failure Notice of Intent
IMNS1085 PS 36
sycamore creek
202003538 12/23/2020 130 3120 Walnut Creek Debris In line 39,000 39,000 Notice of Violation -
Parkway Notice of Intent
4Ar95NorthGrodne DepeArornto ElivironenentsiQun1Ay I DWnnoflYate US09refs
Relei0 Redgnei off or 18800 Berton Aria I ftdef�h, North Ceral nrr 2784E
1
Bi9 7B1-47Do