WQCS00002_DV-2021-0155_20211005

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 2219 3044
Return Receipt Requested
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
October 5, 2021
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(1)
and Collection System Permit No. WQCS00002
City of Raleigh
Raleigh Collection System
Case No. DV-2021-0155
Wake County
Dear Mr. Massengill:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $786.57 ($750.00 civil penalty +
$36.57 enforcement costs) against City of Raleigh.
This assessment is based upon the following facts: a review has been conducted of the Sanitary Sewer Overflow (SSO)
5-Day Report submitted by City of Raleigh. This review has shown the subject facility to be in violation of the requirements
found in Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1). The violation(s) that occurred are
summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that City of Raleigh violated the terms, conditions or
requirements of Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
North Carolina Department of Environmental Qudhy I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Rakigh, North Carolna 27609
919.7914200

Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, I, Scott
Vinson, Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against City of
Raleigh:
$750.00 For 2 of the 4 violations of Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
$750.00 TOTAL CIVIL PENALTY
$36.57 Enforcement Costs
$786.57 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(I)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
The duration and gravity of the violation;
The effect on ground or surface water quantity or quality or on air quality;
The cost of rectifying the damage;
The amount of money saved by noncompliance;
Whether the violation was committed willfully or intentionally;
The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1)
(2)
(3)
Submit payment of the penalty, OR
Submit a written request for remission, OR
Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to rec uest remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties
Waiver of Right to an Administrative Hearing. and Stipulation of Facts" form within thirty1301, days of receipt of this_
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
AND
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center, Raleigh
Raleigh, NC 27699-1628

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document, you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS § 150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
6714 Mail Service Center
Raleigh, NC 27699 6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact Mitchell Hayes with the Division of Water Resources staff of the Raleigh
Regional Office at [phone] or via email at [e-mail].
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Raleigh Regional Office - Enforcement File
Laserfiche

Case Number: DV-2021-0155
Assessed Party: City of Raleigh
Permit No.: WQCS00002
JUSTIFICATION FOR REMISSION REOUEST
County: Wake
Amount Assessed: $786.57
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § I43B-282.1(c), remission ofa civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. I43B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF WAKE
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
City of Raleigh
Raleigh Collection System
PERMIT NO. WQCS00002
) WAIVER OF RIGHT TO AN
) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
)
)
)
) CASE NO. DV-2021-0155
Having been assessed civil penalties totaling $786.57 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated October 5, 2021, the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the day of , 20
ADDRESS
TELEPHONE
SIGNATURE

PERMIT NO: WQCS00002
FACILITY: Raleigh Collection System
Other Violations
ATTACHMENT A
City of Raleigh
CASE NUMBER: DV-2021-0155
INCIDENT VIOLATION
NUMBER DATE VIOLATION TYPE
REGION: Raleigh
COUNTY: Wake
VIOLATION DESCRIPTION
202101344 5/20/2021 CSOISSO(Sewer Overflow)
Discharge without valid permit
TOTAL VOLUME
(GALLONS)
1,400
202101350 5/24/2021 CSO/SSO(Sewer Overflow)
Discharge without valid permit
202101351 5/24/2021 CSO/SSO(Sewer Overflow)
1,500
Discharge without valid permit
202101366 5/29/2021 CSO/SSO(Sewer Overflow)
14,000
Discharge without valid permit
4,230
PENALTY
AMOUNT
$0.00
$0.00
$500.00
$250.00

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleigh
Facility Name: Raleigh Collection System
Permit Number: WOCS00002 Incident Number: 202101351
County: Wake
Case Number: DV-2021-0155
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
14,000 gallons SSO overflowed from a manhole due to grease build up in the line. All 14,000 flowed to Marsh Creek class
C; NSW in the Neuse River Basin. -4- C.n h C 4,,,� �� „ cb,,"c,1,;,�t, 5 �� �� vt` �� p.,.i
2) The duration and gravity of the violation; J
The SSO started at 9:13 am on 05.24.2021 and ended the same day at 12:31 pm.
3) The effect on ground or surface water quantity or quality or on air quality; 1
Nutrients and pathogens to surface waters, C Cam � t-a w" �+' -- -\.i S r
4) The cost of rectifying the damage;
The cost of mitigating this event amounted to $16,109.11
5) The amount of money saved by noncompliance;
The cost to treat 14,000 gallons of wastewater would have been approximately $21.00.
6) Whether the violation was committed willfully or intentionally;
It does not appear that the violation was committed willfully or intentionally.
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority;
DV-2020-0029, DV-2020-0083, DV-2020-0087, DV-2020-0101, DV-2020-0114, DV-2021-0034, DV-2021-0040,
DV-202 1 -0077, DV-2021-0094, DV-2021-0122.
8) The cost to the State of the enforcement procedures.
$36.57
/0-s— 2091
Date
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1/I�

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleigh
Facility Name: Raleigh Collection System
Permit Number: WOCS00002 Incident Number: 202101366
County: Wake
Case Number: DV-2021-0155
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
4,230 gallons SSO overflowed from a manhole due to root intrusion in the line. All 4,230 flowed to an UT to Mine Creek
class C; NSW in the Neuse River BasinrCC¢., Cc,A1'kss- t 4Q - cbtiait.. S s d
2) The duration and gravity of the violation;
The SSO started at 2:01 pm on 05.29.2021 and ended the same day at 4:24 pm.
3) The effect on ground or surface water quantity or quality or on air quality;
Nutrients and pathogens to surface waters Coro Cc.,., u. S ka"'-.k S
4) The cost of rectifying the damage;
The cost of mitigating this event amounted to $3,850.65.
5) The amount of money saved by noncompliance;
The cost to treat 4,230 gallons of wastewater would have been approximately $6.34.
6) Whether the violation was committed willfully or intentionally;
It does not appear that the violation was committed willfully or intentionally.
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority;
DV-2020-0029, DV-2020-0083, DV-2020-0087, DV-2020-0101, DV-2020-0114, DV-2021-0034, DV-2021-0040,
DV-2021-0077, DV-2021-0094, DV-2021-0122.
8) The cost to the State of the enforcement procedures.
$36.57
°-s
Date
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

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2/26/19 $6,000.00
DV-2019-0031
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7/8/19 $3,400.00
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8/22/20 $250.00
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3/22/21 $3,500.00
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DV-2021-0040
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5/11/21 $500.00
DV-2021-0077
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6/14/21 $1,000.00
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7/23/21 $1,500.00
DV-2021-012a.
Total Balance Due : $10,859.19
Sum Of Total Paid:$47,379.83
Total Enforcement Cost: $1,119.02
Total Penalty Amount: $61,150
f0
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Total Cases:
Total Penalties After Remissions : $58,239.02
Sum of Total Case Penalties: $62,269.02

Water Resources
ENVIR0Nr7ENTAL OUALUUT
June 6, 2017
Mr. Matthew P. Vessie, Sewer Maintenance Superintendent
City of Raleigh
PO Box S90
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
Secretory
S. JAY ZIMMERMAN
Director
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 wets 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).
State of North Carolina I Environmental Quality
1617 Mail Service Ceuta i Raleigh, North Carolina 27699.1617
919-707.9000

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). Fonn
CS SSO can be downloaded from the SSO Reporting area at: htto://aortal.ncdenr.ore/web/wo/swo/og(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 550, 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 fotiowing 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 flied with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC
27699-6714. Unless such demands are made, this permit shalt 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,
Lva, Ar,
for S. Jay Zimmerman, P.G.
Director, Division of Water Resources
by Deborah Gore, Supervisor
Pretreatment, Emergency Response, Collection System Unit (PERCS)
endosure: Permit No. WQCS00002
cc: Raleigh Regional Office, Water Quality Regional Operations
Water Resources Central Files — WQC500002
Maureen Kinney, NC Operators Certification Program (electronic)
PERCS Files (electronic)

ROY COOPER.
Governor
JOHN NICHOLSON
!interim Secretary
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 2219 5017
Return Receipt Requested
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
June 14, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0279
Sanitary Sewer Overflows - May 2021
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
202101344 5/20/2021 112 5536 Neuse View Drive Pump station 1,400 Notice of Violation
equipment failure
202101350 5/24/2021 107 3800 Hillsborough Roots 1,500 Notice of Violation
Street
202101351 5/24/2021 198 5000 Windy Hills Drive Grease
>'DE
14,000 14,000 Notice of Violation —
Notice of Intent
Non CaroUna Ceparllot ni at [mironmcutal Quallly I Ut.h:on at Walt.. Itrooff41
Raleigh Regiona.011lec ; 711OO Barren UrNe 1 Raleigh North Carolina 27601
919.741.4700

Incident Start Duration
Number Date (Mins) Location
Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
202101366 5/29/2021 143 1837 Snow Wind Drive Pipe Failure (Break), 4,230 4,230 Notice of Violation -
Roots Notice of Intent
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance withthe 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].
Cc: Raleigh Regional Office - WQS File
Laserfche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
North Carolina Dorarl..trnt al Cm loichnenial Quality I Dietsionol W..,.Resources
Raleigh Regional Dlflr.., 1800 Ra-rc11 Orlue I Raklph North rarogna 21601,
&N/.i II.4Z00

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 Incident #: 202101351
Owner: City of Raleigh
City: Raleigh
County: Wake Region: Raleigh
Source of SSO (check applicable): Sanitary Sewer ❑ 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): 5000 Windy Hills Drive
Manhole #: SMH169075
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 05/24/2021 Time: 9:13 am Incident End Dt: 05/24/2021 Time: 12:31 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 14,000 gallons Estimated Duration (Round to nearest hour): 3:18 hours
Describe how the volume was determined: Estimating Volume Based on Spill Dimensions/ Open channel
Weather conditions during the SSO event: clear
Did SSO reach surface waters? Yes ❑ No ❑ Unknown
Surface water name: Marsh Creek
Volume reaching surface waters (gals): 14000
Did the SSO result in a fish kill? ❑ Yes IZINo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
Grease
24 hour verbal notification (name of person contacted ): Mitchell S Hayes
DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 05/25/2021 Time (hh:mm AM/PM): 09:00:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(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
Grease
When was the last time this specific line (or wet well) was cleaned?
05/25/2021
Do you have an enforceable grease ordinance that requires new or retrofit of grease 17 Yes D No D NA 12 NE
traps/interceptors?
Have there been recent inspections and/or enforcement actions taken on nearby ❑ Yes ❑ No 171 NA ❑ NE
restaurants or other nonresidential grease contributors?
Explain.
This is a residential area with no restaurants or fat producing establishments
Have there been other SSOs or blockages in this area that were also caused by [ Yes D No D NA ❑ NE
grease?
When?
12/26/2013
If yes, describe them:
5128-A Windy Hill Drive
72000 gallons as a result of grease accumulation
Have cleaning and inspections ever been increased at this location? ❑ Yes ❑ No WI NA ❑ NE
Explain.
Routine maintenance
Have educational materials about grease been distributed in the past? ❑ Yes ❑ No ❑ NA WI NE
When?
and to whom?
Explain?
No past outreach information available. Outreach material to be delivered for the May 24th event
If the SSO occurred at a pump station, when was the wet well and pumps last
checked for grease accumulation?
NA
Were the floats clean? ❑ Yes D No g NA D NE
CS-SSO Form Page: 2

Comments:
NA
System Visitation
ORC RI Yes
Backup ❑ Yes
Name:
Carlos M Perez
Cert#
1003875
Date visited:
5/24/2120
Time visited:
11:10 AM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews utilized hydraulic letting to remove the source of the blockage from the affecting asset thus restoring sewer flow. A
temporary spill containment site was emplaced downstream o the affected asset in order to contain the flow of sewer and
minimize the environmental impact to the surrounding land. Crews utilized potable water to flush the area and to remove
traces of sewer from the affected area. Flushed water was then collected at the temporary containment point and
reintroduced to the collection system. CCTV inspection assessment will follow.
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: 05/28/21 12:30 pm
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

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Raleigh Water
August 11th, 2021
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 0279
Sanitary Sewer Overflows — May 2021
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept of Environmental Quality
AUG 12 Aid
Raleigh Regional Ofiice
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2021-DV-0279) received on July 28tt', 2021. This document contains the narratives regarding a
pending violation actions of (4) Sanitary Sewer Overflow (550) events, which occurred during the month of May
2021 within the City of Raleigh Collections System (1:. 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 Direct.): may ta.e enforceme it act:on against the Permittee for S50s that must be reported to the Division as stipulated in Condition IV92F. This includes 550s that wee
t aused by sever natural conditions or except onal events unless the Pem ttee deni:rnxtrates thrnugh properly signed, contemporaneous operating logs, or other relevant
rvidence that:
(a.) The SSO was caused by severe natural conditions; there were no feasible alternatives to the SSO, such as the use of auxiliary treatment facilities. retent:on 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 sat.sfied if, in the
exercise cif reasonable engineering judgment, the Permittee should have installed auxiliary or additional collections system components, wastewater retention or treatment
Fa:ilit'es, adequate back-up equipment or should have reduced inflow and infiltration; or
lb.] The SSO was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the Permittee, the SSO could not have been prevented by
th# exercise of reasonable control, such as proper management. oprratioc., and maintenance; adegi. ate treatment or collection facilities or components (e.g., adequately
enlarging treatment of collection facilities to accommodate growth or adequately controlling and pieve:.ting infiltration and inflowj; preventative maintenance: or
Installation of adequate back-up equipment;"

Incident Number # 202101344 — 05/20/2021— 5536 Neuse View Dr., Raleigh, NC (Neuse River Pump Station
52)
This spill was neither willful nor intentional; it resulted from a loss of utility power and pump #2 tripping
the main breaker to the station. When the generator activated, the automatic transfer switch (ATS) could not
send power back to the pumps without a mechanic to reset the correct breakers. Signage is present at the
station with the proper steps for transferring power. At the time, SCADA alarms were present for Loss of Utility
Power, RTU Status: Inactive, and generator Running. The responsible plant operator on duty responds to these
alarms and makes a phone call to the on -call mechanic in time to save an overflow. The failure affected flow and
surcharged a 54-inch Reinforced Concrete Pipe (RCP) gravity sewer main upstream of the station and resulted in
approximately 1,400 gallons of untreated wastewater spilling directly to the ground and did not reach surface
waters.
On 5/20/2021, at approximately 3:53 am, Raleigh Water staff were alerted via flow meter alarm
notification that manhole SMH108009, directly upstream of Neuse River Pump Station, was surcharged above
the elevation of the manhole. Neuse River Operations was contacted immediately, and an on call mechanic was
sent to the site. Upon arrival, the mechanic reset the correct breakers, activated the pumps, and returned the
station to normal operation.
Restoration of this spill event consisted of washing the land surrounding a manhole that surcharged.
Although no utility operator or bystander witnessed this incident, the only evidence was a 20 ft by 35 ft puddle
of clear sewer surrounding a manhole. The flow remained within the natural topography with no indication of
sewer reaching surface waters. No traces of solids were present. Crews utilized ample potable water to flush,
clear, and collect any evidence of sewer for proper disposal. Crews completed the restoration by applying lime
seed and straw. This spill was mitigated without a significant environmental impact on the adjacent area and its
natural resources.
There is no history of previous 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
5/13/21. Since the sewer event, there have been no other issues associated with this section of the collection
system. This site remains an active maintenance spot as specified by the collections system permit.
2

Incident Number # 202101350 — 5/24/2021— 3800 Hillsborough St., Raleigh
This spill was neither willful nor intentional; it was the result of root intrusion, which blocked a portion of
an 8-in" gravity sewer main. The root intrusion led to a sewer spill of approximately 1,500 gallons of untreated
wastewater not reaching surface waters of the state.
On 5/24/2021, at approximately 7:25 AM, Sewer Maintenance staff was notified of a sewer overflow
located at 3800 Hillsborough St., Raleigh. Upon arrival, it was discovered that untreated sewer was emanating
from an adjacent manhole (SMH142431). The responding staff took all reasonable steps to stop and mitigate the
impact of the discharge as soon as they arrived, gaining control of the spill event by 9:12 AM 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 (see
Exhibit 1- SSO Area of Operation, p4). Crews used pumps at the temporary containment site to recover the
remaining sewer into a downstream sewer manhole. The area around the manhole was cleared of debris,
treated with an application of lime, and restored with grass seed and straw. During the restoration phase of the
operation, crews utilized water from adjacent hydrants to defuse and flush the affected area.
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 no fish kill or unnecessary
vegetative damage.
The cost associated with the mitigation of this event amounted to $1,426.00. The approximate cost to
the Utility to have treated 1,500 gallons of wastewater would have been approximately $2.25. 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 serves a residential area near Meredith College. This system
provides sewer collection to several multi -dwelling properties. A press release notification associated with this
event was published in the Raleigh News & Observer on 5/27/2021 (Exhibit 2 — Press release, p5)
Before this event, maintenance records show that sections of this collection system were assessed as
follows:
Flushing activities CCTV Activities Inspection activities
1/27/2004 7/7/2021 2/13/2018 3/16/2020
7/28/2009 7/12/2021 4/27/2018 8/5/2020
2/10/2020 1/18/2019 8/27/2020
6/14/2021 1/22/2019 8/28/2020
5/1/2019 9/2/2020
5/2/2019 9/22/2020
5/9/2019 9/29/2020
11/6/2019 2/17/2021
3/5/2020 2/18/2021
3/11/2020 2/22/2021
3/13/2020
3

The latest maintenance/inspection assessment for this site was conducted on 6/14/2021 in which several
segments of main were flushed. 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
root management with a recommended maintenance interval of every 6 months.
Exhibit 1- S5O Area of Operation
t ft0.51111. 04442
4

Exhibit 2 • Press Release
Raleigh
NEWS RELEAS
COMMUNICATIONS DEPARTMENT
May 27, 2021
For more information
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Monday, May 24. 2021. at approximately 7.34 AM, Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spa' located at 3800
Hillsborough Street, Raleigh, NC 27616. The cause of the spill was related to riot
intrusion into the sewer gravity main The responding staff took an reasonable steps to
stop and mitigate the impact of the spill as soon as they arrived The North Carolina
Department of Environmental Quality. Division of Water Resources was notified of the
spill.
Raleigh Water - Sewer Maintenance Division staff, stopped the spill at
approximately 9 12 AM on the same day It is estimated that the spin discharged
approximately 1,500 gallons of untreated wastewater with none reaching surface
waters Restoration associated with Ihis event was completed on the same day There
has not been any vegetative damage or fish kilt associated with this event
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debris, wipes, rags, diapers and other
improper materiels in the sewer system and to take enforcement action
where appropriate. 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
discharged into the sewer system. Alt other items will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or see sewer spilling from
manholes or pipes, please call 919-996-3245 to report immediately.
For more information about how you can help prevent sanitary sewer
spills, please visit: rafeighnc.govlwater.
This news release is required by NCGS Article 21, Chapter 143 215 1C
###
5

Incident Number # 202101351— 05/24/2021— 5000 Windy Dr, Raleigh, NC
This spill was neither willful nor intentional. It resulted from grease accumulation, restricting the sewer
flow within an 8" gravity sewer main. This accumulation led to a sewer spill of approximately 14,000 gallons of
untreated wastewater, reaching an unnamed tributary within the Marsh Basin (see exhibit 1 — SSO Area of
Operation, p7)
On 05/24/2021, at approximately 10:24 AM, Sewer Maintenance staff was notified of a sewer spill
emanating from a manhole near 5000 Windy Hill Dr., Raleigh, NC. The responding staff arrived shortly after and
commenced taking all reasonable steps to stop and mitigate the impact of the discharge, gaining control of the
spill event by 12:31 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 was intended to contain wastewater flow and minimize
the environmental impact on the surrounding land. Responding crews employed pumps at the temporary
containment sites to recover flushed wastewater and any evidence of sewer completing the operation by re-
introducing the wastewater to the collection system. 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 no fish kill or unnecessary vegetative damage.
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 approximately 4,031 ft of the
downstream conveyance. The area around the manhole was cleared of debris and washed with potable water.
The site was treated with an application of lime and restored with grass seed and straw. The restoration was
completed on 5/28.
A follow-up CCTV assessment was conducted immediately following the sewer event and did not find any
evidence of infrastructure deficiency leading to grease accumulation. Further sewer cleaning has been
scheduled.
The cost associated with the mitigation of this event amounted to $ $16,109.11. The approximate cost to the
Utility to have treated 14,000 gallons of wastewater would have been approximately $21.00. 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.
This section of the collection system provides sewer collection services over 100 properties near the spill
event (see exhibit 2- Zone of Influence, p8). Before the event on May 24th, this portion of the collection system
experienced the following SSOs: 10/2/2000 5128-A Windy Hill Dr.; 3/20/2006 5155 Windy Hill Dr.; 2/2/2008
5031 Windy Hill Dr.; and 12/26/2013 5128-A Windy Hill Dr. Due to these events, this area has been identified as
an area for repeated maintenance.
A press release notification associated with this event was requested on 05/28/2021 (see exhibit 3 —
Press Release, p---9). Outreach information literature was also requested to be sent to the immediate -affected
area. The requested outreach literature would explain 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 4 — Code Enforcement Letter, p10)
6

Before this event, maintenance records show that sections within the zone of influence (see exhibit 2 —
Zone of Influence, p of this collection system were assessed as follows:
Flushing activities CCTV activities Inspections (manholes and High Priority assets)
10/2/2000 3/21/2014 6/27/2018 12/8/2017 10/4/2019 7/29/2020
3/20/2006 4/29/2014 5/16/2017 2/6/2018 10/8/2019 7/30/2020
2/2/2008 6/4/2014 1/13/2021 2/8/2018 10/10/2019 8/13/2020
12/26/2013 6/10/2014 10/8/2020 2/9/2018 10/11/2019 8/24/2020
2/9/2012 7/24/2014 5/27/2021 3/22/2018 10/14/2019 9/3/2020
2/14/2012 4/17/2015 5/25/2021 5/10/2018 10/15/2019 11/13/2020
2/15/2012 10/5/2020 5/28/2021 5/14/2018 10/17/2019 11/24/2020
2/15/2012 1/25/2021 5/16/2018 10/31/2019 12/7/2020
3/29/2012 1/28/2021 Repairs Activities 8/9/2018 11/1/2019 12/9/2020
3/30/2012 2/15/2021 5/9/2017 8/13/2018 1/10/2020 12/15/2020
4/4/2012 5/25/2021 7/20/2017 8/20/2018 1/21/2020 1/27/2021
7/29/2021 7/25/2017 8/21/2018 2/24/2020 1/28/2021
6/28/2018 10/19/2018 2/25/2020 2/11/2021
11/23/2020 3/15/2019 4/27/2020 3/15/2021
12/14/2020 3/18/2019 6/1/2020 8/2/2021
3/19/2019 7/27/2020 8/3/2021
10/3/2019
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 further sewer
main cleaning and CCTV assessment.
Exhibit 1 550 Area of Operation
Exhibit 2 - Zone of Influence
7

8

Exhibit 3 • Press Release
Raleigh
NEWS REL. k-AF
COMMUNICATIONS DEPARTME11T
May 25, 2021
For more rnSormation:
TJ Lynch, Assistant Director, Raleigh Water, 919-956-3245
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep Grease Out of the Shared Sanitary
Sewer System
On Monday, May 24. 2021, at approximately 10 09 AM. Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spat located at 5000 Windy
Hill Drive, Raleigh, NC 27616. The cause of the spill was related to grease found in
the sewer gravity main The responding stall look all reasonable steps to stop and
mitigate the impact of the spill as soon as they arrived The North Carolina Department
of Environmental Quality. Division of Water Resources was notified of the spill
Raleigh Water - Sewer Maintenance Division staff stopped the spill at
approximately 12 31 PM on the same day It is estimated that the spill discharged
approxtmatety 12 500 gallons of untreated wastewater. reaching surface waters of
Marsh Creek Basin Restoration associated with this event is on -going There has not
been any vegetative damage or fish kill associated with this event
• Raleigh Water has en aggressive education and enforcement program to
prevent the discharge of grease, debris, wipes, rags, diapers and other
improper materials in the sewer system and to take enforcement action
where appropriate. 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
discharged 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
manholes or pipes, please call 919-996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer
spills, please visit raleighnc.goviwater.
This news release is required by NCGS Article 21, Chapter 143 215.1C
9

Exhibit 4 Code Enforcement Letter
r
is
Raleigh
Re Sanitary Sewer Overflew in your neighborhood
Deer Raleigh Milky customer
The city of Raleigh recently experienced a sanitary sever v-redohw in your area. The overflow was
caused by improperty disposing of materials into the city of Raleigh sanitary sewer systeta such as
plasma, paper. grease or rags You can help prevent these evenly from occurring by tollowtitg simple
practices listed below This will help the City protect water quality. maintain our sanitary sewer system
and keep the sewage bt the pipe.
DO NOT
DO NOT
DO NOT
PLEASE
PLEASE
pow pease, fate and ails from cooldog down the drain.
use the toilet as a wastebasket. (m disposable/'floshable' wipes. paper
towels. dabala diaper er baby wipes, condoms. tampons or alb ;seismal
twtdm• yeedoRs).
ow the sower system or the kitchen sink se a arm to depose of food euaps.
collect caakhos oils and gear in a contain and dispose of in the =hut
place food wage ha wite tsaket in a garbage bag akug .with disposal of
adage solid waste oar start a comyort pW
Pre%cntlmt can save you moteyl Property owmrs are respondble far keeping their sewer serve line
dean, sanitary. and continually fmctloniug from their home to the sewer main. This also includes
service line connecaorn bt easements Moat back-ups are due to blockages that occur in the senate lire
and tie hasoeownha or costa= would typically have to call a plumber You can avoid these
preventable plumber bills by properly dispostltg of waste
To report a sewer backup dulls overflowing from a City manhole, please call the Public Utilities
Operations Division at 911A963245 at any time, 24 }ours a day, 7 days a week
For more tnfomuuon on the proper use of your sanitary sewer system, please contact the Public
llttttlee Department at the number above or find us on the web at wwwsalriytimc ytov With your help
and with the Pubbc Uliblin Department preventive maintenance and fats, clan and grease programs
most sewer overflows can be avoided
Please help its prevent needless damage to property and the environment
Thank vot
so- raa
10

Incident Number # 202101366 — 05/29/2021 — 1837 Snow Wind, Raleigh, NC
This spill was neither willful nor intentional; it was the result of root intrusion, which caused a pipe failure
on an 8-in" Ductile Iron gravity sewer main. The pipe failure led to a sewer spill of approximately 4,230 gallons
of untreated wastewater reached an unnamed tributary of the Neuse within the Mine Basin.
On 5/29/2021, at approximately 2:01 PM, Sewer Maintenance staff was notified of a sewer overflow
located near 1837 Snow Wind, Raleigh, NC. Upon arrival, it was discovered that untreated sewer was emanating
from an adjacent manhole (SMH117290). 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 04:24 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 (see
Exhibit 1- SSO Area of Operation, p12). Crews used pumps at the temporary containment site to recover the
remaining sewer into a downstream sewer manhole. The area around the manhole was cleared of debris,
treated with an application of lime, and restored with grass seed and straw. During the restoration phase of the
operation, crews utilized water from adjacent hydrants to defuse and flush the affected area.
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 no fish kill or unnecessary
vegetative damage.
The cost associated with the mitigation of this event amounted to $3,850.65. The approximate cost to
the Utility to have treated 4,230 gallons of wastewater would have been approximately $6.34. 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 serves a residential area west of Creedmoor Rd. This system
provides sewer collection to several properties. A press release notification associated with this event was
published in the Raleigh News & Observer on 5/29/2021 (Exhibit 2 — Press release, p13)
Before this event, maintenance records show that sections of this collection system were assessed as
follows:
Flushing activities CCTV Activities Easement Activities Inspection Activities
7/25/2011 9/5/2014 5/30/2021 6/2/2021 6/2/2021
7/26/11 4/15/2015 7/9/2021 7/9/2021
7/27/2011 4/6/2015 10/9/2017
7/28/2011 12/8/2015 7/16/2019
9/30/2012 4/18/2017 6/29/2021
4/17/2014 5/3/2019
7/22/2014 5/6/2019
7/23/2014 5/29/2021
9/4/2014
11

This site has been scheduled for easement clearing in order to improve access and minimize future root
intrusion as well as a point repair to address sewer main issues.
Exhibit 1 - SSO Area of Operation
12

Exhibit 2 - Press Release
Raleigh
C.L?t.11,.i 1CINS F:iISTA'Ftr7
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F r mcsr4Intarn:gfTran_
7-1Lyral''t Anal:urdLt c-1:Y.7ta g
Raleigh Water Responds to a Sanitary Sewer Spill
On bsal.nday May 29. 2021, at apprcxtsmdy701FM, RaloillWalarslart
resspcoded to a santarf senior avaMira located on a watery rmwor aosomen1 De ind
1837 Snow Wait 0.r, Flalalgfk NG 77815 Tho aorr flaw was o resiAl at reel hints on
Into an B' pdrairrpl chloarla sewer main RasponaIng stall tack al rcasonsnc slops to
slop and m119alo Iho overIbw . mead as soon as t ay err rod Tha !loin Carr4fa
Uepxlmanl of Eirriranmantal Matti. DiAsian al W21Dr Resources has Devon nalflod of
tna overflow
Raleigh Wader suit stopped a•xl contained tnc ararteve ar apprcalmaiele
4.21FM tha same day 11 a esIhme d due the avcrikra dtuma*god a vcluma ai
apprarbmalalr 4,320 gallons al unlmalod rnstewarler Thal reached an unrwmod
Irby ay clam N t o wann Iha Mix Bases Tho oantaiomen' ells oil remain
operab:nod through Ma night wtlti restoraton ahem farecaseod m to completed by
4 tCP1M01 on May 33. 2021 lop tirsgatatr v damage cr t1s+t 'di has b en cedar/ad raIatod
to tads :notion;
• gataltrn Water has an agar' salve education and errfarastnent program to
prevent i1m dlsaharge of grease, debris. segos, rags, diapers and other
Improper materials in he sewer system and la tare andhroenaent aebon
W here appraprlala, n these Karns make it bdha the smear systam, they may
Dante a spill rtdoh Dan haw an adverse impact on waist quiiity and
endanger thane who Dime mho annlaot with the retested areas-
• Misr, unman waste. and toilet lassos are the only Items permitted In bat
d isoberped Into the GOWN' system. Alf attar Items ewes MUG. damage 1D the
sewer system and are not permlhled_
• 1r you experience Imees4are smear braille or see sewer spilling from
manholes or pleas. pleas, atatl US.898 8246 to resort hnmadlrlely.
• For more In(armatlon about hair you Den help prevent sanitary saner
spans. please mat nilelglano-gavlwalsr.
Tax news release a rcq.crod by NCt3S Mice& 24. Clap*, f 43 21 G . L
13

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 428.40 [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
3,581,811.42 [2], approximately 28% of the Division's annual operating budget. The 21,130 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $21,385.76 to mitigate.
The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $31.70 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 spilt event irrespective of the associated cost. This effort is noted in the City's low SSO
performance rate of 2.21 total SSO rate 14] per 100 miles of pipe, compared to the Southeastern Region of the
US, of 7.0 spills per 100 miles of line.
(11428.40 mi'rti repr#sent5 17% of the sanitary s1wer collection syste'1
121 Asso' iated Dperatiooal cost year to date For PY2021
OPERATION LINEAR FEET Linear Miles COST
CCP1 387,943.04 73.47 $ 393,735.68
F11.0ing 1,865,983.86 353.41 $ 678,392.25
RepalF 8,060.00 1.12 $ 2,509,683.49
Total - 2,261,986.4 I. Ft Total cost of Business to Date
428.40 MILES 3,581,811.42
1315.0015 Is based o9 tFe annual water treat^}e11 operating cost compounded by the total treated effluent
[4) .24%attributed to 3ry weather 55:7s
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.
14

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 5S0 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-0279 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.J. Lynch, Assistant Raleigh
Water Director, at [phone].
'ncerely,
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
[e-mail]
CC: Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance
t5

ROY COOPER
Governor
JOHN NICHOLSON
Int (rim Scn'rtm )
S. DANIEL SMITI I
Zlirectn+'
Certified Mai! # 7020 3160 0000 2219 5017
Return Receipt Requested
Robert Massengiil, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORrH [_AROLINA
Environmental Quality
June 14, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0279
Sanitary Sewer Overflows - May 2021
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengiil:
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 concludes that the City of Raleigh v4olated 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
202101344 5/20/2021 112 5536 Neuse View Drive Pump station 1,400 Notice of Violation
equipment failure
202101350 5/24/2021 107 3800 Hillsborough Roots 1,500 Nonce of Violation
Street
202101351 5/24/2021 198 5000 Windy Hills Drive Grease 14,000 14,000 Notice of Violation •
Notice of Intent
E
North Caro!maOcpartmcnt of Gnlronafental Quality I Division of Water Rrso.nccs
Raleigh tleglnn.I tiff Ice 180011a relt Drive 1 Ralclgh. Not h Car&1na2760.1
II) P11,d200

Incident Start Duration
Number Date (Mins) Location
Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
202101366 5/29/2021 143 1837 Snow Wind Drive Pipe Failure (Break), 4,230 4,230 Notice of Violation -
Roots Notice of Intent
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
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