WQCS00002_NOV-2021-DV-0464 RSP_20211210

1410
00
Raleigh Water
December 9th, 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-0464
Sanitary Sewer Overflows — October 2021
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept of Environmental Quality
DEC 101U1 i
Raleigh Regional Office
NC Dept of Environmental Quality
Raleigh Regional Office
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2021-DV-0464) received on November 23rd, 2021. This document contains the narrative
regarding a pending violation actions of (3) Sanitary Sewer Overflow (SSO) events, which occurred during the
month of October 2021 within the City of Raleigh Collections System [1]. This document also provides exhibits as
proof of our efforts to mitigate each of the sewer events. The noticed event 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 event, listed with the intended NOV-NOI
action. Please find below, the additional information requested for the SSO event.
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 includes SSOs that were
caused by severe natural conditions or exceptional events unless the Permittee demonstrates through properly signed, contemporaneous operating logs, or other relevant
evidence that:
[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, retention of untreated
wastewater, reduction of inflow and infiltration, use of adequate back-up equipment, or an increase in the capacity of the system. This provision is not satisfied if, in the
exercise of reasonable engineering judgment, the Permittee should have installed auxiliary or additional collections system components, wastewater retention or treatment
facilities, adequate back-up equipment or should have reduced inflow and infiltration; or
[b.] 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
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 facilities to accommodate growth or adequately controlling and preventing infiltration and inflow); preventative maintenance; or
installation of adequate back-up equipment;"
1

Incident Number # 202102084 — 10/25/2021 — 1902 Glenwood Ave., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a partially collapsed 6-inch vitrified clay
sewer gravity main. Although no active SSO was witnessed during the discovery of the failed pipe, the presence
of paper debris was indicative of a previous sewer spill. Based on open channel estimation, hydraulic modeling,
and the amount of flow recovered from a downstream containment and collection site, it was determined that
the approximate volume of the spill was 5,000 gallons. The wastewater reached approximately 3,720 ft
downstream on Oxford Branch Tributary to Crabtree Creek.
On 10/25/2021, at approximately 6:48 am, Utility Operators identified sewer debris on the ground near the base
of sewer manhole SMH153636. A close television inspection identified that a portion of the vitrified clay pipe
had collapsed (see exhibit,1 - Partial collapse) leading to a subsequent sewer overflow reaching the stormwater
channel below..The responding staff took all reasonable steps to stop and mitigate the impact of the damage as
soon as they arrived, restoring the sewer gravity main at approximately 03:45 PM on the same day. Repair crews
were able to replace approximately 9 ft of vitrified clay sewer gravity main with PVC pipe restoring the sewer
flow within the system (see exhibit 2 — Repaired main).
Containment and collection of this spill event consisted of employing a temporary spill containment at
approximately 3,720 ft downstream of the affected area. This approach was intended to contain wastewater
flow and minimize the environmental impact on the surrounding surface waters of the state. Responding crews
employed a pump at the temporary containment site to recover wastewater and any evidence of wastewater
completing the operation by re -introducing the wastewater to the collection system. During the restoration
phase of the operation, crews utilized ample potable water to flush and remove wastewater debris from the
affected area, including the manhole and the creek. 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 $8,225.23. The approximate cost to the
Utility to have treated 5,000 gallons of wastewater would have been approximately $7.50. 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 portion of the sanitary sewer collection system serves a residential area east of Glenwood Avenue. It has
been identified as a hot spot for recurrent assessment. Portions of this sewer collection system have been
assessed as follows:
Flushing activities
Clean 5/28/2020
Clean 9/28/2020
Clean 10/7/2020
CCTV Activities
CCTV 2/22/2018
CCTV 2/26/2018
CCTV 5/10/2019
CCTV 10/25/2019
CCTV 5/28/2020
CCTV 9/15/2020
CCTV 10/25/2021
CCTV 10/26/2021
CCTV 11/2/2021
Repair Activities
Invert Repair 12/3/2018
Point Repair 8/25/2020
Point Repair 10/26/2021
Ring and/or Cover Replacement 11/15/2021
2

A press release notification associated with this event was published in the Raleigh News & Observer on
10/26/2021 (Exhibit 3 — Press release). Since the event no other issues have occurred with this portion of the
collection system.
Exhibit 1— Partial Collapse
3

Exhibit 2 — Repaired Sewer Main
4

Exhibit 3 - Press Release
Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
October 26, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Monday, October 25 at approximately 6:50 AM, Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 1902
Glenwood Avenue, Raleigh, NC The cause of the spill was related to asset failure
disrupting the collection system- 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
spill.
Raleigh Water staff contained the spill at approximately 3.45 PM on the same
day. It is estimated that the spill discharged a volume of approximately 5,000 gallons of
untreated wastewaterreaching the Oxford Branch Tributary of Crabtree Creek.
Restoration for this event is on -going No vegetative damage or fish kill has been
observed related to this 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 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.govfwater.
This news release is required by NCGS Article 21, Chapter 143 215-1C
5

Incident Number # 202102059 —10/18/2021-120 Forest Rd., Raleigh, NC
This spill was neither willful nor intentional; this incident was the result of an AT&T utility pole being
buried directly through an 8-in vitrified clay sewer gravity main. The bore -through resulted in the sewer spill of
approximately 3,600 gallons of untreated wastewater of which approximately 1,000 reached an unnamed
tributary within Pigeon House Basin.
On 10/18/2021, at approximately 1:30 PM, Raleigh Water staff was notified of a sewer odor near a
service road located behind 120 Forest Rd., Raleigh, NC. The responding staff took all reasonable steps to
identify the source of the odor, stop and mitigate the impact of the discharge as soon as they arrived, gaining
control of the spill event by 4:30 PM on the same day. Crews utilized CCTV to identify the source of the odor
determining that the damaged sewer pipe was the direct result of a utility pole being buried directly through an
8-in vitrified clay sewer gravity main (see exhibit 1- Ruptured sewer main and excavated utility pole). Utility
responders immediately established a sewer bypass to re-route sewer flow downstream of the damaged pipe.
The utility pole owner (AT&T) was immediately contacted to remove and relocate the pole. Crews also utilized
hydraulic jetting to dislodge and remove debris that has entered the sewer main as a result of the buried utility
pole.
Exhibit 1—Ruptured sewer main and excavated utility pole
USMH: SMH109743
DSMH: SMH150396
Miscellaneous Survey Abandoned
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.
Cleanup consisted of removing and disposing of sewer debris from the excavation. The area around the affected
sewer gravity main was washed with potable water and the surrounding area was decontaminated with the
application of lime, grass seed, and straw. 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 occurred.
6

Raleigh Water completed the repair of the damaged sewer main, by replacing the damaged section of the main
with PVC pipe and the utility poled was re -positioned accordingly (see exhibit 2- Repair efforts). A Code
Enforcement action was issued to assess the damage and to assign the associated cost of the incident against
the contractor.
Exhibit 2- Repair efforts
The cost associated with the mitigation of this event amounted to $14,734.32. The approximate cost to the
Utility to have treated 3,600 gallons of wastewater would have been approximately $5.40. The City saved no
money from this spill. The costs for cleanup and repair 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 volume of sewage
created by the spill as well as the cost of potable water used to mitigate the event. A press release notification
associated with this event was requested to be published in the Raleigh News & Observer on 10/19/2021
(Exhibit 3 — Press release). There have been no additional issues associated with this section of the collection
system since the last sewer event.
7

Exhibit 3 — Press release
i
*‘Ieol Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
October 19, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
e
Raleigh Water Responds to a Sanitary Sewer Spill
On Monday, October 18, 2021, at approximately 1 30 PM, Raleigh Water- Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 120 Forest
Road, Raleigh, NC. The cause of the spill was related to a telephone pole installation
disrupting the collection system. 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
spill.
Raleigh Water staff contained the spill immediately upon arrival on the same day.
It is estimated that the spill discharged a volume of approximately 3 600 gallons of
untreated wastewater 1000 gallons of which reached an unnamed tributary within
Pigeon House Basin. Restoration for this event will be completed within the next 24
hours. No vegetative damage or fish kill has been observed related to this 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 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.govlwater.
This news release is required by NCGS Article 21, Chapter 143.215.1C.
8

Incident Number # 202102063 — 0/19/2021— 0 Wendel Blvd., Wendell, NC
This spill was neither willful nor intentional; this incident was the result of an excavation been
performed by a private utility contractor. The excavation caused damage to a 6-inch ductile iron sewer force
main (see Exhibit 1— Damaged pipe). The damage resulted in the sewer spill of approximately 8,000 gallons of
untreated wastewater which remained on the natural topography not reaching any surface water of Little S.
Basin.
On 10/19/2021, at approximately 10:27 AM, Raleigh Water staff was notified of a damaged force main near
Wendel Blvd., Wendell, NC. The responding staff took all reasonable steps to mitigate the impact of the
discharge as soon as they arrived, gaining control of the spill event by 4:48 PM on the same day. The Utility
contractor contained the sewer within a temporary excavation preventing it from continuing to spread
downstream. See exhibit 2 — Spill Containment.
Containment and collection of this spill event consisted of throttling down wastewater flow and volume at the
upstream pump station to minimize sewer flow at the affected site. Wastewater flow was rerouted and
simultaneously collected into vacuum trucks to minimize the environmental impact on the surrounding land.
Cleanup consisted of removing and disposing of sewer debris from the excavation. The area around the
damaged pipe was cleared, decontaminated with the application of lime, grass seed, and straw. This spill was
contained without a significant environmental impact on the adjacent area and its natural resources. There was
no observed fish kill associated with this SSO nor unnecessary damage to area vegetation.
Raleigh Water Repair Crews were able to repair and replace the damaged section of force main restoring normal
operations at the lift station. A Code Enforcement action was issued to assess the damage and to assign the
associated cost of the incident against the contractor.
The total cost of the City's response and remediation effort for this spill event was $1,866.91. The approximate
cost to the Utility to have treated 8,000 gallons of untreated wastewater would have been approximately
$12.00. The City saved no money from this spill. The costs for cleanup and repair 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 volume of sewage created by the spill as well as the cost of potable water used to mitigate the event. A
press release notification was requested to be published in the Raleigh News & Observer as required by NCGS
Article 21, Chapter 143.215.1C. (Exhibit 3 — Press release). There have been no additional issues associated with
this section of the collection system since the last sewer event.
C,Dept of Environmental Quality
N
DEC 101
Raleigh Regional Office
9

Exhibit 1 - Damaged pipe
Exhibit 2 — Spill Containment
10

Exhibit 3 — Press release
hi", Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
Weber 20, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Tuesday, October 19. at approximately 10:27 AM, Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 0 Wendell
Blvd, Wendell, NC. The cause of the spill was related to contractor damage disrupting
the collection system 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 spill
Raleigh Water staff contained the spill at approximately 4:48 PM on the same
day. It is estimated that the spill discharged a volume of approximately 8,000 gallons of
untreated wastewater. none of which reached surface waters. Restoration for this event
was completed on the same day. No vegetative damage or fish kill has been observed
related to this 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 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.govlwater.
This news release is required by NCGS Article 21, Chapter 143.215.1C.
�nvicoa�enta, Quality
NC Dept of
/C 0
"Raleigh Regional
Office
11

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 2,566 miles of sanitary sewer pipe and minimize the accidental release of untreated
wastewater.
Since July 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 16,000 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $24,826.46. to mitigate. The City's cost of
sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $24.90 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 LINEAR FEET Linear 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 Total cost of Business to Date
428.40 MILES 3,581,811.42
[3] $.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.
12

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-0464 issued for the month of October
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 Carlos M. Perez, ORC
Assistance Superintendent 919-996-5929.
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]
13

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 4115 6471
Return Receipt Requested
Robert Massengill, Dir Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
November 15, 2021
111 NOV 2 3 tti I
Qya�i't'�i
n��tonmeA`a�
NCB®'Ptof S
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0464
Sanitary Sewer Overflows - October 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 Report/s submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition T
(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 violations that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202102059 10/18/2021 180 120 Forest Rd, Raleigh Other
3,600 1,000 Notice of Violation
202102063 10/19/2021 381 0 Wendell Blvd Other 8,000 0 Notice of Violation
202102084 10/25/2021 537 1902 Glenwood Ave Pipe Failure (Break) 5,000 5,000 Notice of Violation —
Notice of Intent
ar.
North Carolina Department of Environmental Quality I Division of Water Resources
RalelghReglonalOff ce 1 3800 Barrett Drive 1 Raleigh North Carolina2/609
919.791.4200

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, , ' paets 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 anyAuestions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Offirp at 919-791-4200 or via email at [e-mail].
Cc: Raleigh Regional Office - WQS File
Laserfiche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality 1 Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive 1 Raleigh North Carolina 27609
919.791.4200