WQCS00002_DV-2021-0186_20211209

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 4115 6617
Return Receipt Requested
Robert Massengiil, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
December 09, 2021
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(6)
and Collection System Permit No. WQCS00002
City of Raleigh
Raleigh Collection System
Case No. DV-2021-0186
Wake County
Dear Mr. Massengill:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $286.57 ($250.00 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).
.g.k,Q3
North Carona Department of Environmental Quality 1 Division of Water Resources
RaidghRegional Office 7800Barren Drive 1 Raleigh North Carolina27609
919.791,1200

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:
$250.00 For 1 of the 5 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.
$250.00 TOTAL CIVIL PENALTY
$36.57 Enforcement Costs
$286.57 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) 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;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether 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; and
(8) 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) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) 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:
(I) 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 request 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 thirty (30) days of receipt of this_
notice. The Division of Water Resources also requests that you comylete 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 etition 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-2021-0186
Assessed Party: City of Raleigh
Permit No.: WQCS00002
JUSTIFICATION FOR REMISSION REQUEST
County: Wake
Amount Assessed: $286.57
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. § 143B-282.1(c), remission of a 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. 143B-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-2021-0186
Having been assessed civil penalties totaling $286.57 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated December 09, 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-2021-0186
INCIDENT VIOLATION
NUMBER DATE VIOLATION TYPE VIOLATION DESCRIPTION
REGION: Raleigh
COUNTY: Wake
202101553 7/8/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit
TOTAL VOLUME PENALTY
(GALLONS) AMOUNT
2,019 $0.00
202101551 7/8/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit
3,300 $0.00
202101552 7/8/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 4,500 $0.00
202101564 7/14/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 1,200 $0.00
202101603 7/20/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 3,500 $250.00

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleigh
Facility Name: Raleigh Collection System
Permit Number: WOCS00002
County: Wake
Case Number: DV-2021-0186
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;
3,500 gallons of sewage overflowed from a manhole due to a blockage in the line. 3,000 gallons reached an UT to
Southgate Basin, an unclassified UT in the Neuse River Basin. Nutrients and pathogens to surface waters.
wtck4 1,4�}- s-f�.,.& ti Irio644S'".r,
2) The duration and gravity of the violation;
The SSO started on 07.20.2021 at 12:19 pm and ended the same day at 2:59 pm.
3) The effect on ground or surface water quantity or quality or on air quality;
Nutrients and pathogens to surface waters. ca ti "ram c l b 1 '-aa.-J'r v
4) The cost of rectifying the damage;
The cost to mitigate the SSO is $4,799.64.
5) The amount of money saved by noncompliance;
The costs to treat 3,500 gallons of wastewater is approximately $5.25.
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;
There have been 9 enforcements within the last 12 months.
8) The cost to the State of the enforcement procedures.
$36.57
Date
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

NO009:
Raleigh Water
August 31ft, 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-0336
Sanitary Sewer Overflows —July 2021
Permit No. WQCS00002
Dear Mr. Vinson:
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2021-DV-0336) received on August 18th, 2021. This document contains the narratives regarding
a pending violation actions of (5) Sanitary Sewer Overflow (SSO) events, which occurred during the month of
May 2021 within the City of Raleigh Collections System (1). 3 of these events were the result of Tropical Storm
Elsa, which produced a 2.52 inches rainfall. This document also provides exhibits as proof of our efforts to
mitigate the sewer events. 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 as stipulated In Condition IV92). This indudes 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:
(a.] The SSO was caused by severe natural conditions; there were no feasible alternatives to the 550, such es the use of auxiliary treatment fadlities, retention of untreated
wastewater, reduction of Inflow and infiltration, use of adequate back-up equipment, or an increase in the capacity of the system. This provision Is not satisfied if, In the
exercise of reasonable engineering Judgment, the Permittee should have Installed auxiliary or additional collections system components, wastewater retention or treatment
fadilties, adequate back-up equipment or should have reduced Inflow and infiltration; or
(b.( The S50 was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the Permittee; the 550 could not have been prevented by
the exercise of reasonable control, such as proper management, operation, and maintenance; adequate treatment or collection facilities or components (e.g., adequately
enlarging treatment of collection fadllties to accommodate growth or adequately controlling and preventing Infiltration and inflow); preventative maintenance; or
installation of adequate back-up equipment"
1

Incident Number # 202101551-- 7/8/2021— 3316 Allegheny Dr., Raleigh, NC
This sewer overflow was neither willful nor intentional; it resulted from Tropical Storm Elsa, which led to
an unexpected sanitary sewage surcharge of approximately 3,300 gallons of untreated sewer from a manhole in
a 24-inch gravity sewer main. The sewer remained within the natural topography with no indication of it
reaching surface waters. The weather event produced an unprecedented rainfall of 2.5 inches for July 8th, 2021
(NOOA, Monthly Climatological Report for Raleigh, NC, see exhibit 4). This weather event was responsible for
other sewer overflow events within the Raleigh service area.
Raleigh Water staff identified signs of a surcharge immediately following the cease of the adverse
weather event. It is estimated that the weather event peak between the hours of 6:05 PM and 7:00 PM on July
8th,2021. The responding staff took all reasonable steps to mitigate the discharge's impact as soon as they
arrived. The staff identified sewer debris surrounding the affected manhole and utilized ample potable water to
flush the affected area removing sewer traces from the area surrounding the manhole. The area around the
manhole was then cleared of debris, treated with an application of lime, and restored with grass seed and straw.
Any collected debris was reintroduced into the collection system. The total cost of the City's response and
remediation effort for this spill event was.
The cost associated with the mitigation of this event amounted to $775.70. The approximate cost to the
Utility to have treated 3,300 gallons of wastewater would have been approximately $4.95. 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.
Crews conducted an area assessment downstream of the surcharge to ensure no other sewer assets
were affected by the storm. As part of a proactive post -storm assessment along the Crabtree Creek corridor,
crews found indications of another surcharge downstream near 2739 Rothgeb Drive. There was no sign of fish
kill related to this SSO.
From 2010 to 2015, the pipe system located at Alleghany Dr. has experienced five sewer overflows
resulting from excessive rain and flooding. This asset is part of an active capital project designed to increase flow
capacity and reduce inflow and infiltration 1. Before the weather event, the most recent routine maintenance
record in this area was conducted on 04/26/2021.
A press release was issued for this spill event, including other simultaneous spills resulting from Tropical
Storm Elsa. (See exhibit 1- Press Release 3316 Alleghany Dr., Raleigh, NC)
Pursuant to our Sanitary Sewer Collection System Permit, the cause of this SSO was exceptional,
unintentional, temporary, and caused by factors beyond our reasonable control. Furthermore, the SSO could not
have been prevented by the exercise of reasonable control, such as routine operations and maintenance,
adequate treatment facilities, or collection system facilities or components.
L Prow WS•2014-45 Crabtree Basin Wastewater System Conveyance Improvements Phase II (Crabtree Pipeline)
2

Exhibit 1- Press Release 3316 Allegheny Dr., Rakish, NC
e'
vgi
itOOkr, Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
July 9, 2021
For rnurc infoirnalion
TJ Lynch, Assistant Director, Raleigh Water, 919-99Ji-3249
144,
Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, July 8, 2021, at approximately 6:05 PM, Raleigh Water- Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 3316
Allegheny Drive, Raleigh, NC. The cause of the spin was related to rainwater
accumulation from Tropical Storm Elsa. The responding staff took ail reasonable steps
to atop and mitigate the impact of the spill as soon as they arrived. The North Carolina
Department of Environmental Duality, Division of Water Resources was notified of the
eptl.
Raleigh Water- Sewer Maintenance Division staff, stopped the spa at
approximately 7:00 PM on the same day. It is estimated that the spin discharged
approximately 3,300 gallons ofwastewaterwhich was recovered and reintroduced back
into the collection system. Restoration associated with tits event Is expected to be
completed on Friday, July 9. There has not been any vegetative damage or fish kdl
associated with tills event.
• Raleigh Water has an 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 end
endanger those who come into contact with the affected areas.
• Water, human waste, and toilet tissue are the only items pennttted 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.gov?water.
This news release is required by NCGS Article 21, Chapter 143.215.1C_
3

Incident Number # 202101552 — 7J8/2021— 2739 Rothgeb Dr., Raleigh, NC
This sewer overflow was neither willful nor intentional; it resulted from Tropical Storm Elsa, which led to
an unexpected sanitary sewage surcharge of approximately 4,500 gallons of untreated sewer from a manhole in
a 36-inch gravity sewer main. The sewer remained within the natural topography with no indication of it
reaching surface waters. The weather event produced an unprecedented rainfall of 2.5 inches forluly 8th, 2021
(NOOA, Monthly Climatological Report for Raleigh, NC, see exhibit 4). This weather event was responsible for
other sewer overflows events within the Raleigh service area.
Raleigh Water staff identified signs of a surcharge immediately following the cease of the adverse
weather event. It is estimated that the weather event peak between the hours of 6:05 PM and 7:00 PM on July
8th,2021. The responding staff took all reasonable steps to mitigate the discharge's impact as soon as they
arrived. The staff identified sewer debris surrounding the affected manhole and utilized ample potable water to
flush the affected area removing sewer traces from the area surrounding the manhole. The area around the
manhole was then cleared of debris, treated with an application of lime, and restored with grass seed and straw.
Any collected debris was reintroduced into the collection system. Crews did not see any further indication of
sewer surcharge nor a sign of fish kill related to this SSO along the Crabtree Creek corridor.
The cost associated with the mitigation of this event amounted to $335.00. The approximate cost to the
Utility to have treated 3,300 gallons of wastewater would have been approximately $6.75. 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.
From 2013 to 2021, the pipe system located at 2739 Rothgeb Dr. has experienced five sewer overflows
resulting from excessive rain and flooding. This asset is part of an active capital project designed to increase flow
capacity and reduce inflow and infiltration 2. Before the weather event, the most recent record of routine
maintenance in this area was conducted on 04/29/2021.
A press release was issued for this spill event, including other simultaneous spills resulting from Tropical
Storm Elsa. (See exhibit 2 - Press Release 2739 Rothgeb Dr., Raleigh, NC)
Pursuant to our Sanitary Sewer Collection System Permit, the cause of this SSO was exceptional,
unintentional, temporary, and caused by factors beyond our reasonable control. Furthermore, the SSO could not
have been prevented by the exercise of reasonable control, such as routine operations and maintenance,
adequate treatment facilities, or collection system facilities or components.
2, Project WS-2014-45 - Crabtree Basin Wastewater System Conveyance Improvements Phase 11(Crabtree Pipeline)
4

Exhibit 2 - Press Release 2739 Rothgeb Dr., Raleigh, NC)
Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
July 9, 2071
For more information.
TJ Lynch, Assistant Director, Paleigh Water, 919-99G-3245
I
Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, July 8, 2021, at approodmately 10.00 AM, Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 2739 Rothgeb
Drive, Raleigh, NC. The cause of the spill was related to rainwater accumulation from
Tropical Storm Elsa. The responding staff took all reasonable steps to stop and mitigate
the Impact of the spill as soon as they arrived. The North Carolina Department of
Environmental Quality, Mon of Wafer Resources was notified of the spill.
The overflow was contained within the natural topography with no visual
indication of debris reaching surface waters. It is estimated that the sewer overflow
event stopped on its own once the storm had passed on July8 , 2021. It is estimated
that the overflow discharged a volume of approximately 4,500 gallons of untreated
wastewater which was recovered and reintroduced into the collection system. The
sewer event occurred within Crabtree Basin. Restoration for this event is expected to
be completed on July 9, 2021. No vegetative damage or ash MO was observed related
to this event.
- Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debris, wipes, raga, diapers and other
improper materials In the sewer system and to take enforcement action
where appropriate. If these items make 1t into the sewer system, they may
cause a spill winch can have an adverse impact on water quality and
endanger those who come into contact with the effected 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.goviweter.
This news release is required by NCOS Article 21, Chapter 143.215.1C.

Incident Number # 202101553 — 7/8/2021— 5532 Neuse View Dr., Raleigh, NC
This sewer overflow was neither willful nor intentional; it resulted from Tropical Storm Elsa, which led to
an unexpected sanitary sewage surcharge of approximately 2,019 gallons of untreated sewer from a manhole in
a 54-inch gravity sewer main. The sewer remained within the natural topography with no indication of it
reaching surface waters. The weather event produced an unprecedented rainfall of 2.5 inches for July 8th, 2021
(NOOA, Monthly Climatological Report for Raleigh, NC, see exhibit 4). This weather event was responsible for
other sewer overflows events within the Raleigh service area.
Raleigh Water staff identified signs of a surcharge immediately following the cease of the adverse
weather event. It is estimated that the weather event peak between the hours of 6:05 PM and 7:00 PM on July
8th,2021. The responding staff took all reasonable steps to mitigate the discharge's impact as soon as they
arrived. The staff identified no sewer debris on the ground, but there were indications of a manhole surcharge
as a result of the storm. The area where the sewer may have settle was washed with potable. Crews conducted
an area assessment downstream of the surcharge to ensure no other sewer assets were affected by the storm.
Crews did not see any further indication of sewer surcharge nor a sign of fish kill related to this SSO.
The cost associated with the mitigation of this event amounted to $1,404.45. The approximate cost to
the Utility to have treated 3,300 gallons of wastewater would have been approximately $3.02. 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 asset experienced an SSO as a result of a pump station failure on 05/20/2021. Records show no
other overflows before the event on 7/08/2021. This asset is part of an active capital project designed to
increase flow capacity and reduce inflow and infiltration 3. Before the weather event, the most recent record of
routine maintenance in this area was conducted on 04/29/2021.
A press release was issued for this spill event, including other simultaneous spills resulting from Tropical
Storm Elsa. (See exhibit 3 - Press Release 5532 Neuse View Dr., Raleigh, NC)
Pursuant to our Sanitary Sewer Collection System Permit, the cause of this 55O was exceptional,
unintentional, temporary, and caused by factors beyond our reasonable control. Furthermore, the SSO could not
have been prevented by the exercise of reasonable control, such as routine operations and maintenance,
adequate treatment facilities, or collection system facilities or components.
3. Project ID- WS-2017-07 West Neuse Interceptor Improvements. Replacement of approximately 26,000 linear feet of existing 48-inch and 54-Inch sewer with 60- end
66dnch plpe along the west side of the Neuse River, upstream of the Neuse River Pump Station.
6

Exhibit 3 - Press Release 5532 Nome View Dr., Raleigh, NC
:°,` Raleigh
NEWS RELEASE
COMM1JrJIC:A1IONts D6PAR1IVI rr1
.duly 9, 2021
For more inform lion
T,l Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, July 8, 2021, al approximately 10:00 AM, Raleigh Water - Sewer
Maintenance Division staff responded 10 a sanitary sewer spill located at 5632 Neuss
View Drive, Raleigh, NC. The cause of the s • '+ was related to rainwater accumulation
from Tropical Storm Elsa. The responding staff took 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 spin.
The overflow was contained within the natural topography with no visual
indication of debris reaching aurface waters. It is estimated that the sewer overflow
event stopped on is own once the storm had passed on July B, 2021_ It is estimated
that the overflow discharged a volume of approximately 2,019 gallons of untreated
wastewater which was recovered and reintroduced into the collection system. The
sewer event occurred within Crabtree Basin. Restoration for this event is expected to
be completed on July 9, 2021. No vegetative damage or fish kW was observed related
to thb event.
• Raleigh Water has an 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 wig cause damage to the
sewer systems and are not permitted.
• 1f you experience excessive sewer smells or see sewer spilling from
manholes or pipes, please call 919-998-3245 to report Immediately.
• For more information about how you can help prevent sanitary sewer
spills, please visit raleighnc.govlwater.
This news release is required by NCOS Article 21, Chapter 143.215.1C.
Al
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7

Exhibit 4 - NOOA, Monthly Climatological Report for Raleigh, NC
These data are preliminary and have not undergone final quality control by the National
Climatic Data Center (NCDC). Therefore, these data are subject to revision. Final and
certified climate data can be accessed at the NCDC - hflp:l/www ncdc.noaa,goy.
Climatological Report (Daily)
888
COUS42 KRAH 999617
CLIRDU
CLIMATE REPORT
NATIONAL, WEATHER SERVICE RALEIGH NC
217 AM EDT FRI ]UL 89 2021
...THE RALEIGH NC CLIMATE SUMMARY FOR 3ULY 8 2821...
CLIMATE NORMAL PERIOD 1991 TO 2920
CLIMATE RECORD PERIOD 1887 TO 2921
WEATHER ITEM OBSERVED TIME RECORD YEAR NORMAL DEPARTURE LAST
VALUE (LST) VALUE VALUE FROM YEAR
NORMAL
TEMPERATURE (F)
YESTERDAY
MAXIMUM 79 1211 AM 1e5 2012 91 -12 89
MINIMUM 71 1159 PM 53 1979 7e 1 74
AVERAGE 7S 88 -5 82
PRECIPITATION (IN)
YESTERDAY 2.52R 1.88 1887 0.15 2.37 T
MONTH TO DATE 3.78 1.11 2.67 e.47
SINCE 3UN 1 11.35 5.88 6.35 3.49
SINCE 3AN 1 27.96 22.22 5.74 24.5E
DEGREE DAYS
HEATING
YESTERDAY e 8 e e
MONTH TO DATE 9 0 e 8
SINCE 3UN 1 e 3 -3 7
SINCE 3UL 1 e e e e
COOLING
YESTERDAY 1e 16 -6 17
MONTH TO DATE 90 121 -31 123
SINCE 3UN 1 430 475 -45 47e
SINCE ]AN 1 648 709 -61 681
WIND (MPH)
HIGHEST WIND SPEED 22 HIGHEST WIND DIRECTION E (110)
HIGHEST GUST SPEED 31 HIGHEST GUST DIRECTION SE (138)
AVERAGE WIND SPEED 8.1
SKY COVER
POSSIBLE SUNSHINE MLM
8

incident Number # 202101564 — 07/14/2021 — 1127 Marshall St., Raleigh, NC
This spill was neither willful nor intentional; it resulted from root intrusion, which caused a pipe failure
on a 6-in" Polyvinyl Chloride gravity sewer main. The pipe failure led to a sewer spill of approximately 1,200
gallons of untreated wastewater in which 1000 gallons reached an unnamed tributary of the Neuse within the
Pigeon House Raleigh Basin.
On 07/14/2021, at approximately 10:07 AM, Sewer Maintenance staff was notified of a sewer overflow
near 1127 Marshall St., Raleigh, NC. Upon arrival, it was discovered that untreated sewer was emanating from
an adjacent manhole SMH195968, (see exhibit 5 - SSO Area of Operation). 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 10:45 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 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 945 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.
A follow-up CCTV assessment conducted immediately following the sewer event found a section of 6-inch
pipe was compromised with root causing the pipe to rupture. A subsequent repair took place to replace
approximately 8 ft of pipe (Exhibit 6 — Pipe Repair), restoring flow.
The cost associated with the mitigation of this event amounted to $5,307.00. The approximate cost to the
Utility to have treated 1,200 gallons of wastewater would have been approximately $1.80. 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 south of Capital Blvd. This section of the
collection system provides sewer collection to at least 33 residential properties. A press release notification
associated with this event was published in the Raleigh News & Observer on 5/29/2021 (Exhibit 7 — Press
release). Before this event, maintenance records show that sections of this collection system were assessed as
follows:
Flushing activities
5/18/10 07/29/2015
1/29/2013 9/13/2017
1/30/2013 10/13/2017
7/24/2014 7/14/2021
7/28/2014 7/16/2021
CCTV Activities
9/6/2017 1/24/2018
9/6/2017 7/14/2021
9/6/2017 7/22/2021
10/18/2017
11/21/2017
Repair Activities Inspection Activities
1/24/2018
1/19/2021
7/15/2021
7/28/2021
6/21/2021 12/2/2019
1/25/2018 3/19/2020
6/5/2018 10/1/2020
1/2/2019 3/2/2021
4/24/2019
9

Note
This site has been identified for future root control.
Exhibit 5 - S5O Area of Operation
Affecting Asset S6MN111698
10

Exhibit 6 — Pipe Repair
11

Exhibit 7--Press Release
Raleigh
NEWS RELEASE
:x
•4111104.
CC)F.i1A11N{Ct I IONS LiEPAR i 1.lEN
Judy 1.1, 2021
For more information
I"J Lynch, A..;sisldnl qucctur, Na;e+yli 4J tier !}1 .9r.F11. .1N
Raleigh Water Responds to a Sanitary Sewer Spill
On Wednesday, July 14, 2021, at approximately 10:07 AM, Raleigh Water -
Sewer Maintenance Envision staff responded to a sanitary sewer spill located et 1127
Marshall Star Raleigh, NC. The cause of the spill was related to a debrs blockage
disrrrpting the collection system. The responding staff took al reasonable steps to stop
and mitigate the Impact of the opal es soon as they arrived. The North Carolina
Department of Environmental Quality, Olvtclan of Water Resources was notMed of the
sPEL
Raleigh Wateraht[contahned the opal at approximately 1110 AM on the same
day. It Is estimated that the spd discharged a volume of approxdmately 1,000 gaeone of
untreated wastewater reaching an unnamed tributary within Neon House Bastn.
Restoration for this event is ongoing. No vegetative damage or flab kOl has been
observed related to fhb 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 sower system and to take enforcement action
where appropriate. tf these items make it into the sewer system, they may
cause a spill which can have an adverse impact on water quality end
ender those who come Into contact with the affected areas.
. Water, human waste, and toilet Onus are the only items permitted to be
discharged MO the sewer system. All other Items will cause damage to the
sewer system and ere not permitted.
. R you experience excessive sewer smalls or see sewer spilling from
manholes or pipes, please call 919-996-3245 to report immedfstey.
• For more Information about how you can help prevent sanitary sewer
spills, please visit raleighnc govlwater.
This news release Is required by NCOS Article 21, Chapter 143.215.1C.
12

Incident Number # 202101603 — 07/14/2021— 2601 Adcox PI., Raleigh, NC
This spill was neither willful nor intentional; it resulted from foreign debris (flushed wipes/ see exhibit —
foreign debris) not consistent with regular wastewater debris such a paper. This debris caused a partial blockage
in a portion of an 8- inch gravity sewer main. The blockage led to a sewer spill of approximately 3,500 gallons, of
which 3,000 gallons reached an unnamed tributary in Southgate Basin.
Exhibit 8— Foreign debris
On 07/20/2021, at approximately 12:19 PM, Raleigh Water staff identified a manhole spilling over.
Utility responders were immediately summoned to respond and mitigate the spill. The responding staff took all
reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived, gaining control of the
spill event by 2:59 PM on the same day. Utility response 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 was intended to contain sewer flow and minimize the
environmental impact on the surrounding land. Responding crews initiated the collection of untreated
wastewaters from the containment site to re -introduced it to the collection system downstream. This spill was
contained without a significant environmental impact on the adjacent area and its natural resources. See exhibit
9 - Containment and collection efforts.
13

Exhibit 9 - Containment and collection efforts
During the restoration phase of the operation, crews utilized ample potable water to remove evidence of
sewer 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. Visual inspection of the affected area and
downstream waters confirmed no fish kill or unnecessary vegetative damage occurred. See exhibit 10 -
Restoration efforts.
Exhibit 10--Restoretion efforts
The cost associated with the mitigation of this event amounted to $4,799.64. The approximate cost to
the Utility to have treated 3,500 gallons of wastewater would have been approximately $5.25. 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 and the cost of potable water used to mitigate the event.
A follow-up close circuit television (CCTV) assessment of approximately 1456.45 ft of sewer gravity
mains upstream and downstream of the affected asset is scheduled for root cause analysis. This assessment will
determine future maintenance requirements. This section of the collection system serves a residential area
south of Rock Quarry Rd and east of Sanderford Rd. It provides sewer collection services to approximately 237
14

properties. Before the sewer event on 07/14/2021, this section of the collection system experienced one sewer
overflow at 2410 Creech Rd on 03/27/2004. This event was isolated and not related to the subsequent event at
5501 Wade Park Blvd. A press release notification was requested to be published in the Raleigh News &
Observer as required by NCGS Article 21, Chapter 143.215.1C (see exhibit 11- Press release 2601 Adcox PI.,
Raleigh, NC). 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. Since the last sewer event, there have been no additional issues
associated with this section of the collection system.
Exhibit 11- Press release 2601 Adcox PI., Raleigh, NC
Dx
gr, Raleigh
NEWS RELEASE
CDMr.lLJ IcATrorl, DFPARIMlE1 T
lily __^ 1, 7021
r m nw, In!oom.1bnn
IJ Lynch, l i 0IJl1I Chfc[lor, P..1160 Vialei. 919-995.9'45
Raleigh Water Responds to a Sanitary Sewer Spill
On Tuesday. July 20. 2021. al approtdmatey 12119 PM Raleigh Wahl • Sews
Maintenance DMsloe slant responded to a sarttary sewer spill located at 21101 Adeett
Place, Raleigh, NC. The cause of ee mg was related b a debris blockage dhrttptinp
the Colecllon system The responding slap tool as reasonable Mee to step and
mlbpals tits mpact Who et+ as soon as May arrived. The Nowt Carolina Deparbrunl
of RnNronmentai Cuafgr. DM61on of Wafer Resources was notified ditto spit
Raleigh Water stag conhbod the spl at apprmdm$My 2.00 PM on tits same
day. t is estimated that the spit discharged a voters of apprmdmahly 4.000 plus of
untreated wastewater, of which. %,S00 salons reached an unnamed tributary waar n
Southgate Bsaln. liestaraton for ids evert is ongcbg No vegolahre damage or fish
Idti has been observed Waled 10 this watt
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge Owasso, debris, wipes, rags, diapers and otter
bnpreps: materials in the sewer system and to take enforcement action
wham appropriate. 0 thaw Rama make It unto tile sewer system, they may
car as a spit which can have an adverse brawl on wain glee ty end
e ndanger those who tone into cornett WMt the affected areas.
• Water, human mate, and toilet Wade are the only tans permitted to be
discharged e1s tm smear system. An other llama will cause derange to the
sower system and are not permitted.
• t you eaperlence sawneiv. sewer smote et see sewer spilling from
menhol.s or pis, plea call 91949E 1246 to report Immediately.
. for mow Information abeul how you can help prevent sanitary sewer
W es, please visit ralelghne govtwater.
This news release le rpubed by NCOS Ankle 21. Chaplin 142 21S IC
15

Before this event, maintenance records show that sections of this collection system were assessed as
follows:
02/05/2009 - 2800 Slippery Elm Dr.
6/11/2009 - 2801 Dancer Ct.
06/11/2009 - 2812 Enka Dr.
06/15/2009 - 3009 Sanderford Rd.
06/23/2009 - 2809 Enka Dr.
06/23/2009 - 2901 Sanderford Rd.
07/07/2009 - 2813 Enka Dr.
10/28/2010 - 2709 Midway Park Ct
5/23/2011- 2820 Sourwood St
7/2/2011- 2701 Big Oak St.
7/6/2011 - 1701 Fox Hollow Dr.
12/30/2011 - 1705 Fox hollow Dr
10/12/2012 - 2709 Owl Tree Ct
11/9/2012 - 2708 ADCOX PL
2/27/2013 - Fox Hollow Dr
Flushing activities
3/4/2013 - 2008 Ferret Ct
3/26/2013 - 2805 Delco Ct
6/17/2013 - 2721 Big Oak St
9/15/2013 - 2701 Big oak St
9/25/2013 -1700 Calypso Ct
10/5/2013 - 2800 Sourwood St
1/9/2014 - 2812 Ferret Ct
8/15/2014 - 2713 Midway Park Ct
1/7/2015 -1800 Fox Hollow Dr
2/10/2015 - 2805 Creech Rd
7/23/2017 - 2514 CREECH RD
10/30/2018 - FOX HOLLOW, SOURWOOD, BIG OAK
4/3/2019 - FOXHILL, FOXTROT, FOXGATE
6/19/2020 - 2609 ADCOX PL
9/21/2020 - 2421 FOXTROT RD
7/20/2021- 2713 MIDWAY PARK CT
Inspection
12/5/11- 2600 Big Oak St
1/4/2014 -1718 Fox hollow Dr
4/30/2014 - 2708 Foxtail Ct
6/23/2020 - Manhole Insp - CREECH RD
Note
28 High priority Inspections from
2/28/2018 - 3/24/2021
16

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 14,519 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $12,621.97 to mitigate.
The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $21.78 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 2.21 total SSO rate [4] per 100 miles of pipe, compared to the Southeastern Region of the
US, of 7.0 spills per 100 miles of line.
[1] 428.40 miles represents 17% of the sanitary sewer collection system
[2( Associated operational cost year to date for FY2021
OPERATION UNEAR FEET Unear Miles COST
CCTV 387,943.05 73.47 $ 393,735.68
Flushing 1,865,983.86 353.41 $ 678,392.25
Repair 8,060.00 1.52 $ 2,509,683.49
Total - 2,261,986.91 Ft
428.40 MILES
Total cost of Business to Date
3,581,811.42
[315.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[4[ .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.
17

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-0336 issued for the month of
July, 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].
Carlos M Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh, Public Utilities Department
P.O. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
Carlos.perezcamacho @ raleiahnc.Gov
CC: Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director • Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance
18

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Permit Enforcement History Details by Owner

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 #: 202101603
City: Raleigh _ County: Wake
Region: Raleigh
Source of SSO (check applicable): El 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): 2601 Adcox Place
Manhole #: SMH160754
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 07/20/2021 lime: 12:19 pm Incident End Dt: 07/20/2021 Time: 02:59 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 3,500
gallons Estimated Duration (Round to nearest hour): 2:40 hours
Describe how the volume was determined: Duration and flow rate
Weather conditions during the SSO event: Clear
Did SSO reach surface waters? Yes ❑ No ❑ Unknown
Surface water name: NEUSE RIVER
Volume reaching surface waters (gals): 3500
Did the SSO result in a fish kill? ❑ Yes ElNo ❑ Unknown if Yes, what is the estimated number of fish killed? 0
SPECIFIC cause(s) of the SSO:
▪ Debris in line
24 hour verbal notification (name of person contacted ): George Jones
❑ DWR [r71 Emergency Mgmt Date (mm-dd-yyy): 07/20/2021 Time (hh:mm AM/PM): 06:52:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 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 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 I1:
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
Debris in line
What type of debris has been found in the line?
Disposable Wipes
Suspected cause or source of debris.
Undetermined. Sewer line Services a Residential Area affecting approximately 230 residences
Are manholes in the area secure and intact? 17 Yes ❑ No ❑ NA ❑ NE
When was the area last checked/cleaned?
10/30/2018
Have cleaning and inspections ever been increased at this location due to previous ❑ Yes ❑ No I71 NA ❑ NE
problems with debris?
Explain:
Routine Maintenance
Are appropriate educational materials being developed and distributed to prevent futi RI Yes ❑ No ❑ NA ❑ NE
similar occurrences?
Comments:
Raleigh Water Code Enforcement scheduled to deliver Educational material to approximately 230 residences
System Visitation
ORC ❑ Yes
Backup p Yes
Name:
Manuel Lopez
Cert#
1001415
Date visited:
07/20/2021
Time visited:
03:10 PM
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews utilized hydraulic jetting to remove the source of the blockage from the affecting asset thus restoring sewer flow. A
temporary spill containment site was emplaced downstream of the affected asset in order to contain the flow of sewer ant
minimize the environmental impact to the surrounding land. Crews utilized ample 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. Approximately 500 Gallons of untreated
waste water remain in low line areas surrounding the manhole and not reaching surface waters. The actual surface Watei
that this spill reached was Southgate Tributary (Not listed in the Bims report)
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: Manuel E Lopez Date: 07/26/21 10:15 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

dent Start Duration
nber Date (Naas) Location
Cause
Total Vol
Total Surface
Vol Water
(Gab) (Gals) DWR Action
D1564 7/14/2021 29 1127 Marshall Street Pipe Failure (Break) 1,200
1,000 Notice of Violation
D1603 7/20/2021 160 2601 Adoox Place Debris in line 3,500 3,500 Notice of Violation
Notice of Intent
Votice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
5. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
st any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
it issued pursuant to G.S. 143-215.1.
office requests that you respond to this Notice, in writing, within 10 business days of its
Ipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
is taken to prevent the recurrence of similar situations. The response to this correspondence will be
dered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
rs, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
dered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
ying the damage, whether the spill was intentional and whether money was saved by non-compliance.
u have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
taleigh Regional Office at 919-791-4200 or via email at [e-mail].
Sincerely,
fieLe.4141---
'et Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Raleigh Regional Office - WQS File
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Water Resources
ENVIRONMENTAL OUALIT
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
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 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).
Stale of North Carolina I Environmental Quality
1617 Mail Service Carter l 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: httu://aortal.ncdenr.ore/web/wo/swo/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 S50 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,
As,
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)