WQCS00002_DV-2022-0031_20220413

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7020 3160 0000 4109 5565
Return Receipt Requested
Whit Wheeler, Assistant Public Utilities Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
April 13, 2022
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(1)
and Collection System Permit No. WQCS00002
City of Raleigh
Raleigh Collection System
Case No. DV-2022-0031
Wake County
Dear Mr, Wheeler:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $186.57 ($150.00 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. 143-2I5.1(a)(1). The violation(s) that occurred are
summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that City of Raleigh violated the terms, conditions or
requirements of Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Mee 13t100 Barrett Drive i Raleigh. North Carolina 2T609
919.791.4200

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:
$150.00 For 1 of the 3 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.
$150.00 TOTAL CIVIL PENALTY
$36.57 Enforcement Costs
$186.57 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(I)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
The duration and gravity of the violation;
The effect on ground or surface water quantity or quality or on air quality;
The cost of rectifying the damage;
The amount of money saved by noncompliance;
Whether the violation was committed willfully or intentionally;
The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option I: 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.
PIease 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 i301Alays of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
AND
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center, Raleigh
Raleigh, NC 27699-1628

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

Case Number: DV-2022-0031
Assessed Party: City of Raleigh
Permit No.: WQCS00002
JUSTIFICATION FOR REMISSION REQUEST
County: Wake
Amount Assessed: $186.57
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 (Le., 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 (Le., 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-2022-0031
Having been assessed civil penalties totaling $186.57 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated April 13, 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
ADDRESS
SIGNATURE
TELEPHONE

PERMIT NO: WQCS00002
FACILITY: Raleigh Collection System
Other Violations
ATTACHMENT A
City of Raleigh
CASE NUMBER: DV-2022-0031
INCIDENT VIOLATION
NUMBER DATE VIOLATION TYPE
REGION: Raleigh
COUNTY: Wake
VIOLATION DESCRIPTION
202102069 10/18/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit
202102063 10/19/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit
TOTAL VOLUME PENALTY
(GALLONS) AMOUNT
3,600 $0.00
8,000 $0.00
202102084 10/25/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 5,000 $150.00

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DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleigh
Facility Name: Raleigh Collection System
Permit Number: WOCS00002
County: Wake
Case Number: DV-2022-0031
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;
5,000 gallons spilled into Oxford Branch due to a broken pipe. All 5,000 gallons reached surface waters. Nutrients and
pathogens to surface waterWater quality standard violations.,
Cetl.k. C M,�-
2) The duration and gravity of the violation;
The SSO started 10.25.2021 at 6;48 am and ended the same day at 3:45 pm. Nutrients and pathogens to surface waters
3) The effect on ground or surface water quantity or quality or on air quality; Ir 1'o j4,,.,ys
Nutrients and pathogens to surface waterserater quality standard violations.
Ca+1rc%ASc
4) The cost of rectifying the damage;
The cost of rectifying the damage amounted to $8,225.23.
5) The amount of money saved by noncompliance;
The cost to treat 5,000 gallons of sewage is approximately $7.50.
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 10 enforcements against the violator within the past 12 months.
8) The cost to the State of the enforcement procedures.
$36.57
-13 -,2-2
Date
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

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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 #: 202102084
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 SSO (be consistent in description from past reports or documentation - i.e. Pump Station 6,
Manhole at Westall & Bragg Street, etc): 1902 Glenwood Ave
Manhole #: SGMN154665
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 10/25/2021 Time: 6:48 am Incident End Dt: 10/25/2021 Time: 03:45 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy (hh:mm AM/PM)
Estimated Volume of the SSO: 5,000 gallons Estimated Duration (Round to nearest hour): 8:57 hours
Describe how the volume was determined: Open Channel Spill Estimation
Weather conditions during the SSO event: Clear
Did SSO reach surface waters? El Yes ❑ No ❑ Unknown
Surface water name: Oxford Branch
Volume reaching surface waters (gals): 5000
Did the SSO result in a fish kill? ❑ Yes Er No ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
El Pipe Failure (Break)
24 hour verbal notification (name of person contacted ): Eric S Rice
DWR [] Emergency Mgmt Date (mm-dd-yyy): 10/26/2021 Time (hh:mm AM/PM): 09:25:00 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
Pipe Failure (Break)
Pipe size (inches)
6
What is the pipe material?
Vitrified Clay Pipe
What is the approximate age of line/pipe? (years old)
Unknown
Is this a gravity line? RI Yes [] No D NA El NE
Is this a force main line? ❑ Yes WI No E NA El NE
Is the line a "High Priority" line? ❑ Yes 17 No E NA D NE
Last inspection date and findings
Inspection showed broken vitrified clay pipe near manhole SMH153636.
If a force main then,
Was the break on the force main veritical? D Yes 17i No El NA D NE
Was the break on the force main horizantal? ❑ Yes ❑ No NA ❑ NE
Was the leak at the joint due to gasket failure? ❑ Yes ❑ No 171 NA E NE
Was the leak at the joint due to split bell? ❑ Yes ❑ No 17 NA ❑ NE
When was the last inspection or test of the nearest air -release valve to determine of
operable?
NA
When was the last maintenace of the air release performed?
If gravity sewer then,
Does the line receive flow from a force main immediately upstream of the failed secti Yes ❑ No ❑ NA D NE
of pipe?
CS-SSO Form Page: 2

If yes, what measures are taken to control the hydrogen sulfide production?
NA
When was the line last inspected or videoed?
10/25/2021
If line collapsed, what is the condition of the line up and down stream of the failure?
Stable / operational
What type of repair was made?
Repair crews replaced approximately 20ft of sewer gravity main with PVC
Is the repair temporary or permanent?
permanent
If temporary, when is the permanent repair planned?
NA
Have there been other failures of this line in the past five years? [] Yes 171 No ❑ NA NE
If so, then describe
NA
System Visitation
ORC WI Yes
Backup ❑ Yes
Name:
Carlos M Perez
Cert#
1008375
Date visited:
10/25/2021
Time visited:
09:00 AM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews utilized hydraulic iettinq 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 anc
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 identified a failed assets resulting in a subsequent
repair operation replacing approximately 20 ft. of sewer gravity main.
CS-SSO Form Page: 3

As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Carlos Manuel Perez Date: 10/29/21 07:15 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: 4

A V /
Al o/
Raleigh Water
December 91h, 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 Enviiommental Quality
DEC 10 MI
Raleigh Regional Mee
NC Dept of Environmental Quality
DEC 102021
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'''. 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 550s that ware
caused by severe natural conditions or exceptional events unless the Permitter demonstrates through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(a.l 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
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 # 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 belaw.'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 l'eplace 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
CCTV
CCTV
CCTV
CCTV
CCTV
CCTV
CCTV
CCTV
2/22/2018
2/26/2018
5/10/2019
10/25/2019
5/28/2020
9/15/2020
10/25/2021
10/26/2021
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
GONIPAHNICAA fogs t)I.1'nftl MFN r
Oclo1:. r 2Ei 2071
rw molt: ultorrn.rtion
-1,1 Lynch, Assistant ❑ucctor, f2afeigh Miler, 919-996-324S
Raleigh Water Responds to a Sanitary Sewer Spill
On Monday, October 25. at approxhmately 6:50 AM, Raleigh Water - Sewer
Maintenance Melon staff responded 10 a sanitary sewer spill located at 1902
Glenwood Avenue, Raleigh, NC The cause of the spirt was related to asset faiiure
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
spa
Raleigh Water staff contained the apUl al approximately 3:45 PM on the same
day. It Is estimated that the spirt discharged a volume of approximately 5,000 gallons of
untreated wastewater reactdng the Oxford Branch Tri urary of Crabtree Creek.
Restoration for this event Is on -going No vegetative damage or fish Idfl 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, dispars and other
improper materials In the sewer system and to lake enforcement action
where appropriate.1f these items make it into the sewer system, they may
cause a sp81 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.
• ff you experience excessive sewer smells or see sewer spilling from
manholes or pipes, please call 919-990-3245 to report immediately.
• For more Information about how you can help prevent sanitary sewer
spills, please visit: raietghnc.govlwater.
This news release Is regedred by NCOS Article 21, Chapter 143.215.1 C

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
' 2.2 f t . thr7PN,.. �; �: -;,,.
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

Exhltlt 3 — Press release
07 Raleigh
NEWS RELEASE
(;oh1r,AUIJI(;All(Irv; I11:l'Alli(',1CrJI
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Raleigh Water Responds to a Sanitary Sewer Spill
On Monday, October 18, 2021, at apprordanately 130 PM, Raleigh Water- Sewer
Maintenance DMsion staff responded to a sanitary sewer spill located at 120 Forest
Road, Raleigh, NC. The cause of Ole spN was related to a telephone pole instatlatlon
disrupting the collection system. The responding staff took s0 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 noltiied of the
apt.
Raleigh Water staff contained the spill immediately upon arrival on the name day
O Is estimated that the spill discharged a volume of apprordmately 3,600 gallons of
untreated wastewater 1000 ganona 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 WI has been observed related to this event
• Raleigh Water has an aggresshve education and enforcement program to
prevent the discharge of grease, debda, wipes, rags, diapers and other
improper material' 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 919-906-3246 to report immediately.
• For more information about how you can help prevent sanitary sewer
spills, please visit ratetghnc.govfwater.
This news release is required by NCCS Article 21, Chapter 143.215.1C_
OAS
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 81vd., 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.
N
C Dept of Environmental Quality
DEC 10 11321
Raleigh Regional Office
9

Exhibit ] -Damned nine
Exhibit 2-Soil Containment
10

Exhibit 3— Press release
Raleigh
NEWS RELEASE
[;Uli111JI[;;r1IONS 1)(.I?fl O ra
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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 sander/ sewer spill located at 0 Wendell
Blvd, Wendell, NC. The cause of Ore spill was related to contractor damage disrupting
the collection system The responding staff took al reasonable steps to stop and
mitigate the impact oldie spit as soon as they arrived. The North Carotins Department
of Environmental Quality, Division of Water Resources was no8fled of the eptil
Raleigh Water staff contained the spill at appro:dmately 4:48 PM on Ole same
day. U fs estimated that fie spat dlsd,arged a volume of approximately 8,000 ga0ons cf
untreated wastewater, none of which reached surface waters_ Restoration for this evens
was completed on the same day. No vegetative damage or fish kll has bean observed
related to 0ds event.
• Raleigh Water has en eggreasive educadon and enforcement program to
prevent the discharge of grease, debris, wipes, rags, dispers and other
bnproper materials In the sewer system and to take enforcement action
where appropriate. linen Items make it into the sewer system, they may
cause a spill which can have en adverse Impact on water quality and
endanger those who come into contact with the affected areas.
• Water, human waste, end toilet deem are the only Items permitted to be
discharged into the sewer system. AU other Items will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or see sower spilling from
manholes or pipes, please call 019-998 3245 to report hnmedlateiy.
• For more information ebout how you can help prevent sanitary sewer
spills, Meese visit relelghnc.govlwater.
This news release Is required by NCOS Article 21, Chapter 143.215.1C.
NC Dept rr +
RateighRegional Office
1J

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 de ionstrateidue 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 14] 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
COY 387,943.05 73.47 $ 393,735.68
Flushing 1,865,983.86 353A1 $ 678,392.25
Repair 8,06000 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

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ROY COOPER
Governor
El1ZABETH S. BISER
Secretary
S. DANIEL SMITH
Wafer
Certitisci Mail # 7020 31610=41MAZI
Robert Massengill, Dir Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROUNA
Environmental Qualm
November 15, 2021
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 1
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SS0 (Sanitary Sewer Overflow) to the land or surface waters and the SS0 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
Inddent 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
Worth Carew DepMripederr armw+al SpiryI Dirlelos of WieerIaeween
Math bu enaOffice 7110011aneeDeAe i PAO"Noah Ones 23110!
919211.4100

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 dedsions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the 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].
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
IIeMOroan.DepoemmntdDhYvedanpMQiMN I ObrknafwonrI000ucu
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MILL ,
ROY COOPER
oovenor
ELIZABETHS. BISER
*mean
S. DANIEL SMITH
Certlfied_Mail # 7020 3160 0000 41.15 6473
Robert Massengill, Dlr Public Utilities
City of Raleigh
PO Boot 590
Raleigh, NC 27602-0590
NORTH CAROLINA
EatIronmenkdOidtty
November 15, 2021
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 condudes that the City of Raleigh violated Permit Condition 1
(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
linddent Start Duration Vol Water
Number Date (Nina) Lecatlon (Mae (Gab) (Geis) 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 Nodal of Violation
202102094 10/25/2021 537 1902 Gieawood Ave Pipe Failure (Break) 5,000 5,000 Nod= of Violation -
Notice of intent
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ROBERT MASSENGILL, DIRECTOR
PUBLIC UTILITIES; CITY OF RALEIGH
PO BOX S90
RALEIGH, NC 2760Z MO
NOV.2021-DV-0464 / N(Y .INIENT TO ASSESS / 20211115
RALEIGH COLLEC0ON SYS rEM / WQCS00002 / WAKE CN1Y
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NCAEQ DIVISION OF WATER QUALITY
RALEIGH REGIONAL OFFICE
3800 BARRETT DRIVE
RALEIGH, NC 27609
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ROY COOPER
Governor
EUZABETH S. BISF.R
Secneary
S. DANIEL SMITH
Director
Certified Mall # 7020 3160 0000 4115 6471
Robert Massengill, Dir Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH ROLINA
nv menarQuamy
November 15, 2021
IC F I} t
�1 NOV 7. 3 My' [1:ji
Uy,
NCnbpt o
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SOOLGO
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. Massenglll:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Reports submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215,1.
The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as
to why the City of Raleigh should not be assessed a civil penalty for the violations that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Nino) 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
e+arlficemlinaD.pr are tiBulmoisetalQuallt,I Ogden .fWater geiouea
Meth Region'omee I WOO lanseeDeft I mMl7leWorth Cordon tno9
9eA791A200

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 dull 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
pacts to -public health, fish kiills or recreational area closures. 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 anypuestlons, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Off4 at 919-791-4200 or via email at [e-mail].
Cc: Raleigh Regional Office - WQS File
i.aserflche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
North Cram Depareatera ertirarso-mblQualleyll Oldtlenof MUTResoum.a
CdelphRtglenelO1►v 13 OO Cans! Mtn 1 Mieghtittthuraim trios
919.191,1200

Water Resources
ENVIRONMENTAL OUAL.Ty
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
secrrrary
S. JAY ZIMMERMAN
Director
a�OTT
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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).
State of North Caroline I Environmental Quality
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-707.9000

Raleigh Collection System
June 6, 2017
A reportable SSO is an SSO greater than 1,000 gallons to the ground or an SSO of any amount that reaches
surface water (including through ditches, storm drains, etc.). Reporting requirements including the required
verbal report and written report to the appropriate regional office are referenced in Condition IV(2). Form
CS-SSO can be downloaded from the SSO Reporting area at: htto://oortal.ncdenr.ors/web/wa/swolos/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 SSD 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,
La.,,tt"sp_
for S. Jay Zimmerman, P.G.
Director, Division of Water Resources
by Deborah Gore, Supervisor
Pretreatment, Emergency Response, Collection System Unit (PERCS)
endosure: Permit No. WQCS00002
cc: Raleigh Regional Office, Water Quality Regional Operations
Water Resources Central Files — WQCS00002
Maureen Kinney, NC Operators Certification Program (electronic)
PERCS Files (electronic)

Permit Enforcement History Details by Owner
City of Raleigh
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Total Balance Due : $9,609.19
Sum Of Total Paid:$51,061.78
Total Enforcement Cost $1,300.97
Total Penalty Amount: $63,400
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Total Cases:
Total Penalties After Remissions : $60,670.97
Sum of Total Case Penalties: $64,700.97