WQCS00002_DV-2022-0027_20220303

ROY COOPER
Governor
EUZABETH S. BISER
Secretory
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 4109 5350
Return Receipt Requested
Whit Wheeler, Assistant Public Utilities Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
March 03, 2022
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-2022-0027
Wake County
Dear Mr. Wheeler:
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).
t.sty,")
North Carolina Department of Emtronmensl Quality Division of water Resources
Raleigh Regional Office 3600 Darren DrNe I Raleigh North Carolina 27609
919.79IA200

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 2 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:
(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;
(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:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to 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 Fact" form within thirty (30) days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
AND
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources. NCDEQ
1628 Mail Service Center, Raleigh
Raleigh, NC 27699-1628

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document, you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (ifa 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-2022-0027
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-2022-0027
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 March 03, 2022, 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
SIGNATURE
ADDRESS
TELEPHONE

PERMIT NO: WQCS00002
FACILITY: Raleigh Collection System
Other Violations
ATTACHMENT A
City of Raleigh
CASE NUMBER: DV-2022-0027
INCIDENT VIOLATION
NUMBER DATE VIOLATION TYPE
VIOLATION DESCRIPTION
REGION: Raleigh
COUNTY: Wake
202101925 9/16/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit
TOTAL VOLUME PENALTY
(GALLONS) AMOUNT
2,550 $250.00
202101973 9/23/2021 CSOISSO(Sewer Overflow) Discharge without valid permit 1,000 $0.00

2) The duration and gravity of the violation;
The SSO started 09.16.2021 at 9:40 am and ended the same day at I 1:05 am.
3) The effect on ground or surface water quantity or quality or on air quality;
DIVISIION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleigh
Facility Name: Raleigh Collection System
Permit Number: WOCS00002
County: Wake
Case Number: DV-2022-0027
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;
A total of 2,550 gallons flowed from a manhole to an UT to Bushy Creek, a class C, NSW in the Neuse River Basin due to
debris in the line. All 2,550 gallons flowed to the UT. Increased nutrients and pathogens to surface waters water
quality standard violations. Ga h
Cc. 1/4S�
The effect on surface water quality include Increased nutrients and pathogens to surface waters tie water quality standard
violations and surface water quality standard violations.
4) The cost of rectifying the damage;
The cost of mitigation of this event amounted to $41,873.28.
5) The amount of money saved by noncompliance;
The amount of money to treat 2,550 gallons of wastewater would have been approximately $3.82.
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 enforcement cases against the violator within the past 12 months.
8) The cost to the State of the enforcement procedures.
$36.57
3, 3 Air
Date
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

010 0
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r0
Raleigh Water
November 15th, 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-0454
Sanitary Sewer Overflows — August 2021
Permit No. WQCS00002
Dear Mr. Vinson:
NC D of Environmental Quality
NOV 16 Luc
Raleigh Regional Moe
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2021-DV-0454) received on November 1st, 2021. This document contains the narrative
regarding pending violation actions of (2) Sanitary Sewer Overflow (SSO) events, which occurred during the
month of September 2021 within the City of Raleigh Collections System I1j. This document also provides exhibits
as proof of our efforts to mitigate each sewer event. 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 property signed, contemporaneous operating logs, or other relevant
evidence that:
[a.I The SSO was caused by severe natural conditions; there were no feasible alternatives to the SSO, such es the use of auxiliary treatment facilities, retention of untreated
wastewater, reduction of Inflow and Infiltration, use of adequate back-up equipment or en 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
Willies, adequate back-up equipment or should have reduced Inflow and infiltration; or
lb.] The SSO was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the PermIttee; the SSO could not have been prevented by
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 # 202101925 — 09/16/2021 — 1510 Graduate Ln., Raleigh, NC
This spill was neither willful nor intentional; it resulted from foreign debris (flushed wipes) 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 2,550 gallons, reaching an
unnamed tributary in Bushy Basin.
On 9/16/21, at approximately 9:45 AM, 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 11:10 AM 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.
During the restoration phase of the operation, crews utilized approximately 115,500 gallons of potable
water to assist in washing the creek and remove all 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.
The cost associated with the mitigation of this event amounted to $41,873.28 (this amount includes the
cost to repair the offset gravity main). The approximate cost to the Utility to have treated 2,550 gallons of
wastewater would have been approximately $3.82. 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 conducted on 09/29/2021 determined that the
cause of the debris accumulation was the result of an offset joint within the gravity main. A follow up repair
operation was scheduled and completed on 10/04/2021 (See Exhibit 1— Repair).
Exhibit 1— Repair
2

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 1- Press Release). Since the last sewer event, there have
been no additional issues associated with this section of the collection system.
Exhibit 2 Press Release
Raleigh
NEWS RELEASE
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40
Raleigh water Responds to a Sanitary Sewer Spill
R9 INDER: Keep All Wipes Out of the Shared Sanitary
Sewer System
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and Wlpee510Impact daiospllasscan asMao saved TM Hahn harsh&
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3

Incident Number # 202101973 — 09/23/2021— 917 Willow Run South Dr., Raleigh
This spill was neither willful nor intentional; it was the result of root intrusion, which blocked a portion of
an 8-in" vitrify clay pipe gravity sewer main. The root intrusion led to a sewer spill of approximately 1,000
gallons of untreated wastewater reaching surface waters of the state.
On 9/23/2021, at approximately 12:54 PM, Sewer Maintenance staff was notified of a sewer overflow
located at 917 Willow Run South Dr., Raleigh. Upon arrival, it was discovered that untreated sewer was
emanating from an adjacent manhole (SMH116241, see exhibit 1- 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 1:25 PM on the same day. Crews utilized hydraulic jetting to remove the source of the
blockage within the affecting asset thus restoring sewer flow
Containment, collection, cleanup, and restoration of this spill event consisted of employing a temporary
sewer containment site downstream from the SSO location to stop the flow of sewer into the stream Crews
used pumps at the temporary containment site to recover the remaining sewer into a downstream sewer
manhole. The area around the manhole was cleared of debris, treated with an application of lime, and restored
with grass seed and straw. During the restoration phase of the operation, crews utilized water from adjacent
hydrants to defuse and flush the affected area.
This spill was contained without a significant environmental impact on the adjacent area and its natural
resources. Visual Inspection of the affected area and downstream waters confirmed no fish kill or unnecessary
vegetative damage.
The cost associated with the mitigation of this event amounted to $1,687.62. The approximate cost to
the Utility to have treated 1,000 gallons of wastewater would have been approximately $1.50. 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 section of the collection system serves a residential area west of Falls of the Neuse Rd. This system
provides sewer collection to several residential properties. A press release notification associated with this event
was published in the Raleigh News & Observer on 9/24/2021 (Exhibit 2 — Press release)
Maintenance records show that sections of this collection system were assessed as follows:
Flushing activities CCTV Activities Inspection activities
3/26/2015 9/28/2021 12/7/2017 8/7/2019
4/19/2012 12/21/2017 1/14/2020
3/10/2014 1/16/2018 1/16/2020
3/14/2014 3/22/2018 4/21/2020
1/22/2019 4/30/2018 8/17/2020
10/1/2019 5/2/2018 10/1/2020
10/2/2019 9/27/2018 12/15/2020
10/9/2018 2/25/2021
10/10/2018 4/7/2021
10/25/2018 4/26/2021
3/11/2019 7/19/2021
4/1/2019 8/26/2021
8/30/2021
4

The latest maintenance/inspection assessment for this site was conducted on 9/28/2021 in which several
segments of main were CCTV to identify the event's root cause (see exhibit 3-SSO Investigation Report). There
have been no additional issues associated with this section of the collection system since the last sewer event.
This site has been added to the Hot Spot Management Program for root management with a recommended
maintenance interval of every 6 months.
Exhibit 1- SSO Area of Operation
flrlef two AF.54,I
SCMt1I42882 •
4
1_.
r Containment and Collection Site
5

Exhibit 2 — Press Release
NEWS RELEASE
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Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, September 23, 2021, al approximately 12-54 PM, Raleigh Water -
Sewer Maintenance Division staff responded to a sanitary sewer epm located at 917
Willow Ran South Drive, Retelgh, NC. The cause of the spit was related to root
bthuslon disrupting the collection system. The responding stall took an reasonable
steps to slop and mitigate the impact of the spin as soon es they salved. The North
Carolina Departnmed of Envfmnmentai Quality Division of Water Resauwtes was
notified Mho spit
Raleigh Water ela11 contained the spill at approximately 2-15 PM on the same
day.11 is est m tad that the spill discharged a volume of approxmatey 1,000 gallons of
untreated wastewater reading an unnamed tributary AMIN Mine Creels Basin
Restoration for this event was completed on the same day. No vegetative damage or
1ish Iltil has been observed related to this event
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debds, wipes, rags, diapers and ether
improper materials in the sower system and to take enforcement action
where appropriate. R these items make it into the sewer system, they may
cause a spin which can have an adverse Impact on water quality and
endanger those who come Into contact with the eRected areas.
• Water, human waste, and toilet tissue are the only Items pennNtad to be
discharged into the sewer system. All other items will cause damage to the
sewer system and are not permlttsd.
• if you experience excessive sewer smells or see server spilling from
manholes or pipes, please call 619-995W245 to report Immediately.
lately.
• For mare information about how you can help prevent sanitary sewer
spills, please visit: raielghnc.govlwater.
This news release Is mequhad by NCOS Asede 21, Chapter 143.215.1C
6

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 3,550 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $ 43,560.9 to mitigate. The City's cost of
sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $5.33 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.
11) 428.40 miles represents 17% of the sanitary sewer collection system
(2) Associated operational cost year to date for FY2021
OPERATION LINEAR FEET Linear Mlles 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 3,581,81142
(3) $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
141.24% attributed to dry weather 550s
Additionally, the City of Raleigh Assistant Public Utility Directors and Collections System staff has
become involved in challenging the nonwoven fabrics industry standards to better inform consumers of these
products and their detrimental effects on the collections systems. PUD staff has personally met with officers of
INDA, the leading association of the nonwoven fabrics industry based in Cary, NC, to communicate our concerns
about these fabrics, the current industry standards, and better education for the consumer. PUD has also joined
forces with other utilities nationwide through the National Association of Clean Waters Agencies (NACWA), the
Water Environment Foundation (WEF), and the American Public Works Association (APWA) to challenge INDA
and current industry standards, recognizing that they do not support compatibility in sanitary sewer collections
systems nationally. These agencies work collectively to challenge the testing protocols, assessment guidelines,
and consumer education and labeling of these non -dispersible.
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
7

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-0454 issued for the month of
September 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].
Sincerely,
Carlos M Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh, Public Utilities Department
P.O. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
Carlos.oerezcamacho raleixhn€.Gov
CC: Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance
8

DWR
Division of Water Resources
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
PART I:
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00002 (WQCS# if active, otherwise use WQCSD#)
Facility: Raleigh Collection System Incident #: 202101925
Owner: City of Raleigh
City: Raleigh
County: Wake Region: Raleigh
Source of SSO (check applicable): 2 Sanitary Sewer ❑ Pump Station / Lift Station
SPECIFIC location of the 55O (be consistent in description from past reports or documentation - i.e. Pump Station 6,
Manhole at Westall & Bragg Street, etc): 1510 Gradulate Ln, Raleigh
Manhole #: SMH103042
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 09/16/2021 Time: 9:40 am Incident End Dt: 09/16/2021 lime: 11:05 am
(mm-dd-yyyy) (hh:mm AM/PM) mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 2,550 gallons Estimated Duration (Round to nearest hour): _ 1:25 hours
Describe how the volume was determined: 30 gpm for 85 mins
Weather conditions during the SSO event: clear, dry
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 2550
Surface water name:
Did the SSO result in a fish kill? E] Yes pNo ❑ Unknown If Yes, what is the estimated number offish killed?
SPECIFIC cause(s) of the SSO:
El Debris in line
24 hour verbal notification (name of person contacted ): Joshua S Brigham
[� DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 09/17/2021 Time (hh:mm AM/PM): 10:45:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director, Division of Water Resources, may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED. A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form
Page: 1

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Debris in line
What type of debris has been found in the line?
Rags, flushed wipes
Suspected cause or source of debris.
Apartment complex
Are manholes in the area secure and intact? RI Yes [] No ❑ NA ❑ NE
When was the area last checked/cleaned?
3/16/2021. 10/19/2020
Have cleaning and inspections ever been increased at this location due to previous Yes p No D NA ❑ NE
problems with debris?
Explain:
We have cleaned this area 2 times in the last year because of roots.
Are appropriate educational materials being developed and distributed to prevent futi RI Yes No ❑ NA fl NE
similar occurrences?
Comments:
Apartment complexes are petting material on what do put down drains and what to do with grease with every new tenant
that moves into the building. plus they have things listed with the office.
System Visitation
ORC fl Yes
Backup RI Yes
Name:
David Jackson
Cert#
1001659
Date visited:
09/16/2021
Time visited:
11:18 am
CS-SSO Form Page: 2

How was the SSO remediated (Le. Stopped and cleaned up)?
Blockage was broke using high pressure iet hose. Hay bales were put into the creek to slow flow and prevent solids from
going past. Pumps were put into areas past last discolored area was in creek. Dechlorinated water was entered into the
stormdrain system to facilitate washing. Washing of the creek was started from point of occurrence and washed to the
pumps. Pumped water was put back into the collection system through a close by manhole. Area around the manhole wa
washed, raked up any solids and used seed and straw and lime where we could.
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: David Raymond Jackson Date: 09/21/21 09:25 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

ROY COOPER
Governor
ELIZABETH S. RISER
Secretory
S. DANIEI. SMITH
Director
Certified Mali # 7020 3160 0000 2219 322$
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROUNA
EnvIronmonta Quality
October 22, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0454
Sanitary Sewer Overflows - September 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 I
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there Is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S.143-215.1(a)(1), for which a permit Is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the Clty 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
Inddent Start Duration Vol Water
Number Date (Mine) location Cause (Gale) (Gals) DWR Action
202101925 9/16/2021 85 1510 Graduate Ln, Debris in line 2,550 2,550 Notice of Violation -
Raleigh Notice of Intent
202101973 9/23/2021 31 917 Willow Run South Roots
Drive
1,000 1,000 Notice of Violation
Northeiroltio Depirdsmed EnNrormaisICtsolty I OMs u dWrlaa sswre,
IWeghibigked-Dk. I OOODwrwtOrh. I IWyl.wnhcaalh.tr M
911111.4200

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 -live thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered In this process. Enforcement dedslons will also be based on volume spilled, volume reaching surface
waters, duration and gravity, Impacts to public health, fish kills or recreational area dosures. Other factors
considered in determining the amount of the dvil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was Intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
de-rz
Cc: Raleigh Regional Office - WQS File
Laserflche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
lkraa.i..belrtatndater eee.eiJeyeq<yIbhtasadWaltr&eoerep
tidal' ilegionslOfflor I 310011wen ben I add* tioulh Ceram 77600

R.OY COOPER
Qoom r
ELIZABETH S. BLSER
Secretary
S. DANIEL SMITH
air
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTHCAROUNA
Eindromaintafenaltly
October 22, 2021
SUBJECT: NOTICE OF VIOLATION It INTENT TO ISSUE CIVIL PENALTY
Traddng No.; NOV-2021-DV-0454
Sanitary Sewer Overflows - September 2021
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Reports submitted by
Catty of Raleigh. The Division's Raleigh Regional Office condudes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as
to why the City of Raleigh should not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date Mina) Location Caws (Gab) DWR Action
202101925 9/16/2021 85
1510 Graduate Ln, Debris in line
Raleigh
202101973 9/23/2021 31 917 Willow Run South Roots
Drive
2,550 2,550 Notice of Violation -
Notice of Intent
1,000 1,000 Notice of Violatlan
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Water Resources
ENVIRONMENTAL QUALM
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
-0
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 Eovire:menial Quality
1617 Mail Service Ceuta 1 Raleigh, North Catalina 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). Form
CS-SSO can be downloaded from the SSO Reporting area at: htto:/Joortal,ncdenr.ore/weeb/wo/swo/ns/cs/sso
A notice of deficiency (NOD), notice of violation (NOV), civil penalty, and/or a moratorium on the addition of
waste to the system may be issued if adequate justification for an SSO Is NOT submitted to the regional office.
In order to submit a claim for justification of an SSO, you must use Part 1l 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,
Ase.,
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)