WQCS00002_NOV-2021-DV-0264 Response_20210723

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Raleigh Water
July 1st, 2021
Mr. Scott Vinson
Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources NCDEQ
1628 Mall Service Center
Raleigh, NC 27699-1628
Re: Response to NOV-2021-DV-0264
Sanitary Sewer Overflows — April 2021
Permit No. WQCS00002
Dear Mr. Vinson:
NCB ofEavi runental Quality
JUL-1 ua
Raleigh Regional wane
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2021-DV-0264) received on June 17th, 2021. This document contains the narratives regarding a
pending violation actions of (3) Sanitary Sewer Overflow (SSO) events, which occurred during the month of April
2021 within the City of Raleigh Collections System I31, This document also provides exhibits as proof of our
efforts to mitigate the sewer event. 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 spills; contain the released wastewater;
collect the wastewater and reintroduce 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 the three SSO events.
1. "The Director may take enforcement action against the Permittee for SSOs that must be reported to the Division es stipulated In Condition lV92j. This includes SSOs 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:
la.) The SSO was caused by severe natural conditions; there were no feasible alternatives to the SSO, such as the use of auxliary treatment faciiiti es, retention of untreated
wastewater, reduction of inflow and infiltration, use of adequate beds -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 beck•up equipment or should have reduced inflow and infiltration; or
lb.) The 550 was exceptional, unintentional, temporary and caused by factors beyond the reasonable contral of the Permittee; the 5S0 could not have been prevented by
the exerase 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 Inflow); preventative maintenance; or
installation of adequate back-up equipment;"

Incident Number # 202101179--04/13/2021— 400 Woods of North Bend, Raleigh, NC
This spill was neither willful nor intentional; it resulted from debris partially blocking a portion of an fl-
inch vitrified clay sewer main. The blockage led to a sewer spill of approximately 830 gallons of untreated
wastewater in which 415 gallons reached surface waters In Big Branch Basin.
On 4/13/21, at approximately 4:42 PM, Raleigh Water staff were notified of a sewer overflow located on
the right -of way at 400 Woods of North Bend Dr., Raleigh, NC. Utility Responders were immediately summoned
to the spill site. They took reasonable steps to stop and mitigate the impact of the discharge, gaining control of
the spill event by 6:05 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 a temporary spill containment site
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 $ 3,565.85. The approximate cost to
the Utility to have treated 830 gallons of wastewater would have been approximately $1.24. 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 CCT assessment confirmed that the incident was isolated to only debris accumulation. CCTV
did not find any infrastructure deficiencies within the sewer main. This section of the collection system serves a
residential area north of Spring Forest Rd. it provides sewer collection services to several multi -dwelling
properties. Outreach material was requested to be delivered to the immediate affected area. There have been
no other recorded sewer spills associated with this sewer collection asset. The last maintenance was conducted
in 04/15/2021.

Incident Number # 202101209 — 04/20/2021— 7100 Great Laurel Dr., Raleigh, NC (Brighton Pump Station 40)
This spill was neither willful nor intentional; it resulted from a sewer force main failure at Brighton Pump
Station #40. The dresser coupling and associated bracing in the wet well that connects the suction piping to the
pump had deteriorated to the point that it was unable to hold the force of the head conditions that flowed back
toward the station after the pumping cycle had completed. The failure affected wastewater flow from an 8-inch
Polyvinylchloride (PVC) gravity sewer main. This event resulted in approximately 20,000 gallons of untreated
wastewater spilling into an unnamed tributary of the Neuse River Basin.
On 4/20/2021, at approximately 10:30 pm, Raleigh Water staff were alerted via SCADA alarm
notification that Brighton Pump Station was in a high wet well. Upon arrival, it was noticed that the pumps were
unable to keep up with the flow as most of the wastewater was draining back into the wet well after each pump
run cycle.
Containment and collection of this spill event consisted of placing a temporary containment dam
downstream of the station (see Exhibit-1). This emplacement contained filtering media to stop wastewater
debris from flowing downstream. A water pump was placed in the containment dam to collect and transfer the
wastewater from the stream and reintroduce it into the collection system. Vacuum trucks were used to
removed wastewater from the pump station returning the wastewater elsewhere into the collection system.
Exhibit t—Downstream Containment Site
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 on 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 revealed that the pump began to
unseat from the flange at the end of the force main at the dresser
coupling, and each pump run cycle was spraying wastewater out of the
wet well. A portable bypass pump brought onsite and plumbed prior to
this event was then activated to keep up with the flow of wastewater and
allow personnel to disable the station pumps and cease the flow of
wastewater out of the wet well onto the ground. A utility contractor had
been previously summoned, but they were awaiting parts and finalizing an
engineered solution to correct the issue of surging wastewater flowing back to the station after each pump run
cycle.
The cost associated with the mitigation of this event has amounted to over $1,570.85. The approximate
cost to the Utility to have treated 20,000 gallons of wastewater would have been approximately $30.81. 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 services a vast residential area north and south of Louisburg Rd., providing sewer
services to approximately 580 properties. 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 on 04/04/2021 and inspected on 4/07/2021
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 upgrades have been installed and test for
efficiency. The station continues to be upgraded to ensure no other malfunctions occur. A press release
notification associated with this event was requested to be published in the Raleigh News & Observer on April
23rd, 2021 (see exhibit 2).
Exhibit 2 . Press Release. News and observer.
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Incident Number#202101197 — 04/18/2021— 7703 Oak Marsh Or., Raleigh.
This spill was neither willful nor intentional; it resulted from a failed 6" ductile iron sewer forced main.
This asset failure led to a sewer spill of approximately 31,700 gallons of untreated wastewater.
0n Sunday, April 18th, 2021, at approximately 6:15 PM, Raleigh Water Utility Responders were notified
of wastewater emanating from the ground near 7703 Oak Marsh 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 12:01 AM the following day. Utility response crews were able to contain and collect the
wastewater by utilizing vacuum trucks in tandem and controlling wastewater flow from the nearest pump
station. Although some wastewater entered a stormwater catch basin, crews were able to collect the flow in the
tanks preventing the wastewater from continuing downstream.
Sewer Maintenance Repair crews were dispatched to begin repairing the damaged section of the force
main (see exhibit 1). The repair was made possible by reducing wastewater flow at the nearby pump station.
Once the main was excavated, crews applied a 360° containment band (see exhibit 2) covering the defected
section of pipe (approximately a 1-inch hole). Once the repair was completed, the forced main was turned back
on to verify for effectiveness, no subsequent leaks or repair failures were noted. Crews restored the site by
backfilling the excavation with stable structural aggregates and restoring the surface with seed and straw (see
exhibit 3).
Exhibit 1— Approximate 1-in force main rupture
Exhib t 3— Site restoration
Exhibit 2.360' containment band

This spill was contained without a significant environmental impact on 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 Backup ORC observed no solids and or wastewater within the
stormwater system and the surrounding grounds. The site of the sewer run-off was treated with an application
of lime and restored with grass seed and straw_
The cost associated with the mitigation of this event amounted to $ 4,453.75. The approximate cost to
the Utility to have treated 31,700 gallons of wastewater would have been approximately $47.55. The City saved
no money from this spill. Its costs for cleanup and repair 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.
Before the event on 04/18/2021, this force main was assessed for a point repair on 11/16/2020. No
other maintenance issues have been noted since this incident.
A press release notification related to this event was requested to be published in the Raleigh News & Observer
on April 23rd, 2021 (see exhibit 4)
fi41613 4 Press release, News and Observer
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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 significantly 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 412.09 (1] 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
3,539,719.22 [2], approximately 27% of the Division's annual operating budget. The 52,530 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $9,590.45 to mitigate.
The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $78.00 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 by allocating 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 2.1 total S50 rate [4] per 100 miles of pipe, compared to the Southeastern Region of the
US, of 7.0 spills per 100 miles of line.
[11350 mites represents 13% of the unitary sewer collection system
[2] Associated operet+ionel cost year to date for FY2021
OPERATION LINEARFEET Linear Mlles COST
CCTV 388,577.60 73.60 $ 390,364.31
Flushing 1,779,273.18 336.98 $ 675,890.74
Repair 7,990.00 1.51 $ 2,473,464.17
Total- 2,175,840.78 Ft Total cost of Business to Date
412.09 MILES $ 3,539,719.22
[31$.0015 Is based on the annual water treatment operating cost compounded by the total treated effluent.
[41.24% attributed to dry weather SSOs
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.
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_//raleighnc.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 on
the proper use of sanitary sewers to prevent the 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-2021 NOI-0264 issued for the month of
May 2021 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 [phone] or T.1. Lynch, Assistant Raleigh
Water Director, at [phone].
Sincerely,
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
Carlo].DerezcamachGPraLetahnc.Gov
CC: Robert Massengill, Raleigh Water Director
T. 1. Lynch, Assistant Raleigh Water Director Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance

DwR
Division of Water Resources
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
PART I:
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00002 (WQCS# if active, otherwise use WQCSD#)
Facility: Raleigh Collection System
Owner: City of Raleigh
Incident #: 202101197
City: Raleigh County: Wake
Source of SSO (check applicable): [r!f Sanitary Sewer
Region: Raleigh
❑ Pump Station / Lift Station
SPECIFIC location of the SSO (be consistent in description from past reports or documentation - i.e. Pump Station 6,
Manhole at Westall 8 Bragg Street, etc): 7703 Oak Marsh Drive, Raleigh, NC
Manhole #:
Latitude (Decimal Degrees):
Incident Started Dt: 04/18/2021 Time:
(mm-dd-yyyy)
Estimated Volume of the SSO: 31,700
Describe how the volume was determined:
Weather conditions during the SSO event:
Longitude (Decimal Degrees):
6:15 pm Incident End Dt: 04/19/2021 Time:
(hh:mm AM/PM) (mm-dd-yyyy)
gallons Estimated Duration (Round to nearest hour):
Hydraulic Model based on force main flow and diurnal data
12:01 am
(hh:mm AM/PM)
5:46 hours
clear
Did SSO reach surface waters? Q Yes ❑ No ❑ Unknown
Surface water name: NEUSE RIVER
Volume reaching surface waters (gals): 31700
Did the SSO result in a fish kilt? 0 Yes [r No ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
Q Pipe Failure (Break)
24 hour verbal notification (name of person contacted ): Brion Byers
O DWR ❑ Emergency Mgmt Dale (mm-dd-yyy): 04/19/2021 Time (hh:mm AM/PM): 01:43:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director, Division of Water Resources. may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner. and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED. A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form
Page: 1

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Pipe Failure (BreaI4
Pipe size (inches)
6
What is the pipe material?
ductile iron
What is the approximate age of linelpipe? (years old)
undetermined
Is this a gravity line? Yes 17 No [j NA ❑ NE
Is this a force main line? [,%j Yes 0 No 0 NA ❑ NE
Is the line a "High Priority" line? r Yes 17 No ❑ NA ❑ NE
Last inspection date and findings
previous repair completed on 11/20/2020
If a force main then,
Was the break on the force main veritical?
Was the break on the force main horizantal?
Was the leak at the joint due to gasket failure?
Was the leak at the joint due to split bell?
When was the last inspection or test of the nearest air -release valve to determine of
operable?
When was the last maintenace of the air release performed?
If gravity sewer then,
[j Yes No (] NA [ NE
• Yes [I No ❑ NA G NE
• Yes ❑No [f NA ❑NE
O Yes E No E NA ❑ NE
Does the line receive flow from a force main immediately upstream of the failed secti ❑ Yes ❑ No NA ❑ NE
of pipe?
CS-SSO Form Page: 2

If'yes, what measures are taken to control the hydrogen sulfide production?
NA
Wen was the line last inspected or videoed?
NA
If line collapsed, what is the condition of the line up and down stream of the failure?
NA
What type of repair was made?
Permanent clamp
Is the repair temporary or permanent?
permanent
If temporary, when is the permanent repair planned?
NA
Have there been other failures of this line in the past five years? [7 Yes [ No r NA r NE
If so, then describe
previous repair completed on 11/20/2020
System Visitation
ORC �f Yes
Backup 0 Yes
Name:
Carlos M Perez
Cert#
1.003875
Date visited:
Time visited:
0920 PM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Raleigh Water crews arrived on site at 7:00PM to assess the SSO event. Crews immediately set up a containment site to
keep the wastewater from from running into the nearby storm drain. Repair crew started diaaino around 11:55PM complei
the repair at approximately 12:44 AM. Containment and collection were placed downstream to retum wastewater to the
collection system and prevent further environmental damage.
CS-SSO Form Page: 3

As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Carlos Manuel Perez Date: 04/22/21 10:30 am
Signature: Title:
Telephone Number:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of 1
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 4

I�NR
Nsfon of Water Resources
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
PART I:
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00002 (WQCS# if active, otherwise use WQCSD#)
Facility: Raleigh Collection System
Owner: City of Raleigh
City: Raleigh
Source of SSO (check applicable):
County: Wake
Region: Raleigh
Incident #: 202101209
❑ Sanitary Sewer Er Pump Station / Lift Station
SPECIFIC location of the SSO (be consistent in description from past reports or documentation - i.e. Pump Station 6,
Manhole at Westall & Bragg Street, etc): 7100 Great Laura! Drive
Manhole #:
Latitude (Decimal Degrees):
Incident Started Dt: 04/20/2021 Time:
(mm-dd-yyyy)
Estimated Volume of the SSO: 20,000
Longitude (Decimal Degrees):
10:30 pm Incident End Dt: 04/21/2021
(hh:mm AM/PM) (mm-dd-yyyy)
Describe how the volume was determined:
Weather conditions during the SSO event:
Did SSO reach surface waters?
Surface water name:
Time: 02:00 am
(hh:mm AM/PM)
gallons Estimated Duration (Round to nearest hour): 3:30 hours
Duration and Flow Rate
clear
Q Yes ❑ No ❑ Unknown
Volume reaching surface waters (gals): 20000
Did the SSO result in a fish kill? ❑ Yes
SPECIFIC cause(s) of the SSO:
O Pump Station Equips
24 hour verbal notification (name of person contacted ): Mitchell S Hayes
No ❑ Unknown If Yes, what is the estimated number of fish killed?
▪ DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 04/21/2021
Time (hh:mm AM/PM): 10:07:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director, Division of Water Resources. may take enforcement action for SSOs that are reauired to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED, A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form
Page: 1

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Pump Station Eauipment Failure
What kind of notification/alarm systems are present?
Auto-dialer/telemetry (one-way communication) ❑ Yes
Audible ❑ Yes
Visual ❑ Yes
SCADA (two-way communication) 17 Yes
Emergency Contact Signage W Yes
Other 7 Yes
Describe the equipment that failed?
Force main tie-in coupling
What kind of situations trigger an alarm condition at this station (i.e. pump failure.
power failure, high water, etc.)?
alarm was set by high wet well alarm traced by SCADA at approximately 8:30 PM
Were notification/alarm systems operable? W Yes ❑ No ❑ NA ❑ NE
If no, explain:
NA
If a pump failed, when was the last maintenance and/or inspection performed?
04/04/2021 wet well cleaned
04/07/2021 inspected
What specifically was checked/maintained?
pumps. electrical, alarms
If a valve failed, when was it last exercised?
Were all pumps set to altemate?[%j Yes ❑ No ❑ NA ❑ NE
Did any pump show above normal run times prior to and during the SSO event? ❑ Yes ❑ No W NA ❑ NE
CS-SSO Form Page: 2

Were adequate spare parts on hand to fix the equipment (switch, fuse, valve, seal, r Yes No r] NA r] NE
etc.)?
Was a spare or portable pump immediately available? 17 Yes r] No [ NA r] NE
If a float problem, when were the floats last tested? How?
NA
If an auto -dialer or SCADA, when was the system last tested? How?
SCADA is in constant operation backed by Mometry
Comments:
On site repairs were relinquished to utility contractor. Site is on active bypass with additional pump resources on standby.
System Visitation
ORC [l Yes
Backup [�%j Yes
Name:
Adam Mackay
Cert#
1003041
Date visited:
04/21/2021
Time visited:
07:30AM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews establish a containment / collection site to prevent further spread of wastewater. FlushNacuum trucks were set to
minimize flow outside of the pump station. A sewer by-pass was establish while proper repairs were made. Site is on act
bypass.
As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Carlos Manuel Perez Date: 04/23/21 11:11 am
Signature: Title:
Telephone Number:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of 1
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 3

1

ROY COOPER
Qerwnar
DIONNE DEW-GATTI
Stormy
S. DANIEL SMITH
Director
Certified Mill 7020 3160 0000 2219 2436
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
- Raleigh, NC 27602-0590
NORTH CAROUNA
nEnvironmenfai Qeratify
May 20, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Traddng No.: NOV-2021-DV-0264
Sanitary Sewer Overflows - April 2021
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
Illn—ffreiti, 1 2021
IE
By
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Raleigh. The Division's Raleigh Regional Office condudes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 by falling 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 (Mans) Location Cause (Gals) (Gals) DWR Action
202101179 4/13/2021 33 400 Woods of North Debris In line
Bend
830 415 Notice of Violation
202101197 4/18/2021 346 7703 Oak Marsh Drive, Pipe Failure (Break) 31,700 31,700 Notice of Violation -
Ralelgh, NC Notice of Intent
202101209 4/20/2021 210 7100 Great Laurel Drive Pump station 20,000 20,000 Notice of Violation -
equipment failure Notice of Intent
NaA[arelhwOrprewenedbMnwnendeyeltr I exrearredrVatereenesnee
PaMgeRgeeertoInve t coo Nento eft I Nkli►Neratanew muP
ausuioo

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 dvil 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 dedslons 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 Once
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
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NOV & INTENT TO ISSUE CIVIL PENALTY/NOV--2021-
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Total Balance Due : $10,359.19
Sum Of Total Paid:$46,343.26
Total Enforcement Cost $1,082.45
Total Penalty Amount: $59,650
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Total Penalties After Remissions : $56,702.45
Sum of Total Case Penalties: $60,732.45

•
Water Resources
ENvleotoieN7AL DUALITY
June 6, 2017
Mr. Matthew P. Vessie, Sewer Maintenance Superintendent
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
Subject: Permit No. WQCS00002
City of Raleigh
Raleigh Collection System
Wake County
Dear Mr. Vessie:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
0
r sa
r.
In accordance with your application received May 19, 2015 and Settlement Agreement (16 EHR 00538 and
16EHR 00843), we are forwarding herewith Permit No. WQCS00002, dated June 6, 2017, to the City of Raleigh
for the operation and maintenance of the subject wastewater collection system.
This permit shall be effective from June 6, 2017 until January 31, 2024 and shall be subject to the conditions
and limitations specified herein. It is your responsibility to thoroughly review this permit. Please pay particular
attention to the monitoring and reporting requirements in this permit and any special conditions.
For purposes of permitting, the collection system is considered to be any existing or newly installed system
extension up to the wastewater treatment facility property or point of connection with a separately owned
sewer system. The collection system is considered all gravity lines, pump stations, force mains, low pressure
sewer systems, STEP systems, vacuum systems, etc. and associated piping, valves and appurtenances that
help to collect, manage and transport wastewater to a wastewater treatment plant under the Permittee's
ownership or maintained and operated by the Permittee through a perpetual legal agreement. Satellite
systems are systems tributary to the Permittee's collection system but those collection systems are not owned
or maintained by the Permittee. The system description provided on Page 1 of this permit is meant to provide
a general idea about the size of the system and may not be all inclusive of the collection system at the time of
permit issuance or afterward.
A discharge of wastewater to the environment from the Permittee's wastewater collection system prior to
reaching the wastewater treatment facilities is referred to herein as a Sanitary Sewer Overflow (SSO). The
evaluation of enforcement options after an SSO will be determined considering all relevant information
available or requested of the Permittee. Compliance with all conditions of the permit as well as all statutes
and regulations pertaining to the wastewater collection system must be maintained or appropriate
enforcement actions may be taken as noted in Condition VI(2).
Stalc of North Carolina 1 Environmental Quality
1617 Mail Service Cana j Raleigh. North Carolina 27699.1617
919-707.90OG

Raleigh Collection System
June 6, 2017
A reportable SSO is an SSO greater than 1,000 gallons to the ground or an SSO of any amount that reaches
surface water (including through ditches, storm drains, etc.). Reporting requirements including the required
verbal report and written report to the appropriate regional office are referenced in Condition IV(2). Form
CS-SSO can be downloaded from the SSO Reporting area at: htto://portal.ncdenr.ore/Web/WQ/SWA/OS/CS/SSO
A notice of deficiency (NOD), notice of violation (NOV), civil penalty, and/or a moratorium on the addition of
waste to the system may be issued If adequate justification for an SSO is NOT submitted to the regional office.
In order to submit a claim for justification of an SSO, you must use Part II of form CS-SSO with additional
documentation as necessary. DWR staff will review the justification claim and determine if enforcement
action is appropriate. Please be advised that the information needed to justify a spill is very comprehensive.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to
request an adjudicatory hearing upon written request within thirty days following the receipt of this permit.
This request must be in the form of a written petition, conforming to Chapter 1508 of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC
27699-6714. Unless such demands are made, this permit shall be final and binding.
If you have questions regarding compliance, contact the appropriate regional office. If you need additional
information concerning this permit, please contact Steve Lewis at [phone].
Sincerely,
for S. Jay Zimmerman, P.G.
Director, Division of Water Resources
by Deborah Gore, Supervisor
Pretreatment, Emergency Response, Collection System Unit (PERCS)
enclosure: Permit No. WQCS00002
cc: Raleigh Regional Office, Water Quality Regional Operations
Water Resources Central Files — WQCS00002
Maureen Kinney, NC Operators Certification Program (electronic)
PERCS Files (electronic)