WQCS00013_Return_20220923

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Jamie Revels, Utilities Director
Town of Cary
PO Box 8005
Cary, NC 27512-8005
Dear Permittee:
NORTH CAROLINA
Environmental Quality
09/23/2022
Subject: REMISSION REQUEST
CIVIL PENALTY ASSESSMENT
Town of Cary
Cary Collection System
Wake County
PERMIT NO: WQCSS00013
CASE NO: DV-2022-0075
This letter is to acknowledge your request for remission of the civil penalty levied against the
subject facility. Unfortunately, the Division received the request after the allotted thirty (30) days
from your receipt of the assessment. Therefore, the request for remission cannot be accepted.
Please find attached the originally submitted request for remission.
If you have any questions about this matter, please contact me at [phone] or via e-mail at
[e-mail].
cc: Enforcement File# DV-2022-0075
NPDES Program Files
Raleigh Regional Office
1:tE
NORTH CAROLINA
Department of Environmental Duali�
Sincerely,
A9/ edadoLS1,-
Celeste Sugg
Division of Water Resources
Water Quality Regional Operations
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

September 13, 2022
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
TOWN OF CARY
RECEIVED
SEP 2 0 2022
NCDEQIDWRINPDES
CERTIFIED MAIL
Subject: Notice of Violation and Assessment of Civil Penalty (Case DV-2022-0075)
Dear Mr. Vinson:
On August 15, 2022 the Town of Cary Utilities Department received a Notice of Violation (NOV)
and Assessment of Civil Penalty (DV-2022-0075) letter dated August 2, 2022 from the North
Carolina Department of Environmental Quality, Division of Water Resources — Raleigh Regional
Office for a sanitary sewer overflow (SSO) that occurred on February 12, 2022. The letter
assesses a penalty of $500 plus enforcement costs for the February 12 SSO. The NOV provides
Cary the option to 1) submit payment for the penalty, 2) submit written request for remission or
mitigation, or 3) file a petition for an administrative hearing within 30 days from receipt of the letter
to address the NOV and civil penalty assessment for the SSO.
Incident #
Violation
Date
Violation Type
Violation Description
Total
Volume
(Gal)
Penalty
Amount
202200217
2/12/2022
CSO/SSO
(Sewer Overflow)
Discharge without a valid
permit
4,665
$500.00
Cary takes pride in protecting the environment by providing exceptional wastewater collection and
treatment services for which we have been recognized by our peers as industry leaders. The top
priority for our wastewater utility is to provide safe and reliable wastewater collection and
treatment services that are properly operated and maintained to exceptional professional
standards that meet and surpass all federal and state requirements for environmental and
community protection. We appreciate the opportunity to provide additional justification for
remission of the $536.57 civil penalty assessment. Pursuant to NCGS 143B-282.1(c) remission
of a civil penalty may be granted only when one or more of the following 5 factors apply:
a. One or more of the civil penalty assessment factors in NCGS 143B-282.1(b) were
wrongfully applied to the detriment of the petitioner
b. The violator promptly abated continuing environmental damage resulting from the violation
c. The violation was inadvertent or a result of an accident
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
action
TOWN Of CARY
400 James Jackson Avenue • Cary, NC 27513 • PO Box 8005 • Cary, NC 27512-8005
tel [phone] • fax [phone] • www.townofcary.org

Notice of Violation and Assessment of Civil Penalty September 13, 2022
We believe that factors b, c, and d apply and should be considered in remising the civil penalty
assessment.
Remission Factor b: The violator promptly abated continuing environmental damage
resulting from the violation.
Cary responded quickly to stop the sewer spill, once onsite staff immediately removed the
blockage from the 8-inch sewer line causing the SSO and began cleaning up the spill. Clean up
efforts included pumping approximately 1,100 gallons of ponded wastewater back into the sewer
system and collected solids around the manhole. A temporary dam was constructed downstream
approximately 1,200 feet beyond the sewer spill. Pumps were set up and the creek was flushed
with 144,000 gallons of dechlorinated potable water. The wastewater and flushing waters were
pumped into the sanitary sewer system for treatment. Cary response allowed the sewer spill to
be contained and mitigated in the creek before reaching Regency Park Lake, abating continuing
environmental damage. The intermittent creek did not have any stormwater flow at the time of the
spill, so all sewer was intercepted and pumped back into the sewer system for disposal and
treatment.
Cary added the sewer line segment and manhole to its high priority line inspection list that now
includes inspections every 6-months. Roots were present in the sewer manhole but were not a
significant contributor to the blockage. The increased inspection will help abate reoccurrence of
a blockage.
The sewer manhole (SP75112055) that overflowed and was partially covered with sediment and
leaves was raised 6-inches immediately following the SSO to ensure that the manhole would not
be covered in the future leaving the manhole visible at all times. The partially covered manhole
was not a factor or cause that contributed to the sewer line blockage.
In addition to the required 24-hour news release reporting on the sewer spill caused by the large
volume of sanitary wipes and paper debris, a Nextdoor post was published and distributed to 5
surrounding neighborhoods further notifying of the spill and cause. Cary regularly provides
information to the public and out community on how users of the sewer system can help keep
pipe -clogging material out of the sewer pipes. Although Cary regularly provides sewer users
reminders and participates in reoccurring civic events for educating the public, it does not prevent
the use or the disposal of materials that can accumulate and lead to sewer blockages and
overflows. We rely on the support of our community to help Cary keep our sewer lines free flowing.
As you may be aware, blockages can occur quickly and without warning anywhere within a sewer
system, especially if an excessive number of sanitary wipes are used and accumulate in the
system. Over the last few years there has been a national focus on flushable wipes and
problematic symptoms of sanitary wipes in sewer systems in the US and worldwide. The issue is
of such a scale and magnitude that lawsuits on flush -ability and pipe clogging have been initiated
and litigated. Cary and sewer utilities throughout North Carolina are not immune to the use of
sanitary wipes and the significant problems they can cause in sewer system operations.
Remission Factor c: The violation was inadvertent or a result of an accident
The sewer spill was inadvertent due to the volume of sanitary wipes and paper debris removed
causing the blockage. It was inadvertent as users of the sewer system were disposing of sanitary
wipes and paper products that unknowingly flushed would accumulate and lead to a blockage in
the sewer system. If the number and volume of sanitary wipes were not used, the condition of
the sewer system would have supported normal and predictable system use and design
principles. Cary maintains a robust inspection and cleaning program where in fiscal year 2022,

Notice of Violation and Assessment of Civil Penalty September 13, 2022
22-percent of the gravity collection system was video inspected or acoustically assessed and 13-
percent of the system was cleaned. This aggressive assessment and cleaning program that
exceeds minimum permit requirements, illustrates Cary's commitment to reduce and prevent
sewer blockages and overflows. There are inadvertent circumstances that contribute to
unpreventable blockages and overflows in sewer systems regardless of how often a sewer system
is inspected or cleaned and we believe that inadvertent disposal of a large volume of debris
flushed lead to the February 12 blockage and sewer overflow.
Remission Factor d: The violator had not been assessed civil penalties for any previous
violations
Cary has not been assessed any civil penalties for any collection system (WQCS00013) violations
within the last 5-years or sewer blockages and SSO caused by excessive sanitary wipe and paper
accumulation. Cary is unaware of what delineates this civil penalty assessment from past debris
accumulation related SSO and non -issuance of civil penalties. Cary's sewer collection system
records do not identify manhole SP75112055 or the associated sewer line segment to have any
past compliance or repeated debris accumulation issues.
We appreciate the opportunity in being able to provide additional information and our perspective
on this unfortunate sewer spill. This instance is the only sewer spill that has occurred in the
specific area identified within our collection system and immediate action was taken to prevent a
SSO reoccurrence. We respectfully request that NCDEQ remove the $536.57 civil penalty
assessment by further evaluating our response to this sewer spill, the cause, and Cary's
exceptional record of wastewater collection system compliance. If we can answer any questions
or provide any additional information, please feel free to contact Mr. Donald Smith, Wastewater
Collection System Manager at [phone].
Sincerely,
amie Revels, P.E.
Utilities Director
Cc: Donald Smith, Wastewater Collection System Manager
Paul Campbell, Wastewater Collection System Operator
PERCS Branch, Division of Water Resources
Attachments:
• NCDEQ Notice of Violation and Assessment of Civil Penalty — DV-2022-0075
® Justification for Remission Request Form and Stipulation of Facts Form — DV-
2022-0075
© NCDEQ Notice of Violation — NOI to issue Civil Penalty — NOV2022-DV-0069
• News Release — Sanitary Wipes and Paper Debris Cause Sewer Spill in Cary
• Collection System Sanitary Sewer Overflow Reporting Form — Incident #
202200217
• 2020-2021 Cary Annual Wastewater Report
O 2021-2022 Cary Annual Wastewater Report

Rece, va Vic
ROY COOPER
Governor
ELIZABETH S. 81SER
Sev war
RICHARD E. ROGERS, IR.
e`!h"7:Y
Certified Mali a 7020 31611 0000 41Q4 6258
Return Receipt Requested
Jamie Revels, Utilities Director
Town dui Chary
Pi) Box 8005
Cary, NC 275 I2-8005
NORTH CAROLINA
Envtroaneentat Quality
August 2. 2022
SUBJECT: Notice of Violation and Assessment of Civil Penalty.
for Violations of North Carolina General Statute (G.S.) 143-215.1(aX6)
and Collection System Permit No. WQCS00013
Town of Cary
Cary Collection System
Case No, DV-2022.0075
Wake County.
Dear Mr. Revels:
This letter transmits a Notice of Violation and assessment of civil penalty in thc amount of 5536.57 ($500,00 civil penalty
S36.57 enforcement costs) against Town of Cary.
This assessment is based upon the following facts: a review has been conducted of the Sanitary Sewer Overflow (SSO)
5-Day Report submitted by Town of Cary_ This review has shown the subject facility to be in violation of the requirements
found in Collection System Permit No. WQCS00013 and G.S. 143-215.1(aX I )_ 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 Town olCary violated the terms, conditions, or requirements
of Collection System Permit No. WQCS00013 and G.S. 143-215 t(aX1) in thc manner and extent shown in Attachment A.
In accordance with the maximums established by G.S. 143.215.6A(02), 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).
EraCreMOepamnntdtmrverrrilQuay pnaaenjrWOK Mwuetf.
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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, 1, Scott
Vinson, Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against Town
of Cary:
$500.00 For 1 of the 2 violations of Collection System Permit No. WQCS00013 and G.S. 143-215.1(a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
$500.00 TOTAL CIVIL PENALTY
$36.57 Enforcement Costs
$536.57 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)
(2)
(3)
Submit payment of the penalty, OR
Submit a written request for remission, OR
Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282,1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties.
Waiver of Right to an Administrative Hearing. and Stipulation of Facts" form within thirty (30) days of receipt of this
notice. The Division of Water Resources also requests that you 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 regardigthe filino tee and/or the details of the
filingprocess.
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].
ncdenr.gov.
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
PERCS Compliance/Enforcement Unit - Enforcement File

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2022-0075
Assessed Party: Town of Cary
Permit No.: WQCS00013
County: Wake
Amount Assessed: $536.57
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. I43B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e.. explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION: [

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF WAKE
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
Town of Cary
Cary Collection System
PERMIT NO. WQCS00013
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. DV-2022-0075
Having been assessed civil penalties totaling $536.57 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated August 2, 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
13
RECEIVED
P 2 0 2022
NCDEQIDWRIRPDES
day of T ,., ../
S
ADDRESS
GNATUR
400 city -1 CicAL__5o` NOE
TELEPHONE

PERMIT NO: WQCS00013
FACILITY: Cary Collection System
Other Violations
ATTACHMENT A
Town of Cary
CASE NUMBER: DV-2022-0075
REGION: Raleigh
COUNTY: Wake
INCIDENT VIOLATION TOTAL VOLUME PENALTY
1 NUMBER DATE VIOLATION TYPE VIOLATION DESCRIPTION (GALLONS) AMOUNT
202200217 2/12/2022 CSO/SSO(Sewer Overflow) Discharge without valid permit 4,665 $500.00
202200228 2/16/2022 CSO/SSO(Sewer Overflow) Discharge without valid permit 440 $0.00

TOWN OF CARY
April 6, 2022
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
CERTIFIED MAIL
Subject: Notice of Violation (NOV-2022-DV-0069): Notice of Intent to Issue Civil Penalty
Dear Mr. Vinson:
On March 24, 2022 the Town of Cary Utilities Department received a Notice of Violation with
a Notice of Intent (NOV-NOI) letter dated March 14, 2022 from the North Carolina Department
of Environmental Quality, Division of Water Resources — Raleigh Regional Office for two
sanitary sewer overflows (SSO) that occurred on February 12 and February 16. 2022. The
NOV letter identifies the February 12 SSO with a notice of intent to enforce the violation and
allows Cary the ability to provide evidence or justification within 10 business days from receipt
of the letter to address cause of non-compliance, remedial actions, and actions to prevent
recurrence of the SSO.
Incident # Start Date Duration I Location
(min)
202200217 2/12/2022 105
202200228 2/16/2022
100 Block
Greyfriars Ln
421 S. West St.
Cause
Debris
in line,
Roots
Roots
Total Total Volume
Volume Surface Water
Gal (Gal)
4,665 3,565
440
440
DWR
Action
Notice of
Violation —
Notice of
Intent
Notice of
Violation
Cary takes pride in the operation and management of our nearly 1,000 miles of wastewater
collection system. We are an award winning and progressive wastewater utility that has very
few reportable or large volume SSO. We place emphasis on responding quickly to sewer
emergencies to prevent and minimize any spills that impact our citizens, community, and
environment. We appreciate the opportunity to provide information on the recent sewer
overflows, our efforts, and justification for why additional enforcement action or civil penalty
should not be assessed to the Town of Cary.
TOWN of CARY
400 James Jackson Avenue • Cary, NC 27513 • PO Box 8005 • Cary, NC 27512-8005
tel [phone] • fax [phone] • wwsv.townofcary.org

SSO Notice of Violation - Notice of Intent April 6, 2022
INCIDENT # 202200217 — 100 Block Greyfriars Lane
Sewer Overflow Cause - On February 12, 2022 town staff received a phone call at 7:45 PM
from a citizen from the vicinity of Greyfriars Lane in Cary, calling about an odor and water
flowing in a creek that is normally dry. Cary wastewater collection system staff immediately
responded to investigate the call. Staff observed an overflowing manhole (SP75112055) that
was partially covered with sediment and leaves. Sewer was exiting the manhole from a single
three-quarter inch vent hole. The sewer was exiting at a height of approximately 3 inches.
Wastewater accumulated and ponded around the manhole with flow from the area entering
and flowing in a small stream. The Sewer Spill Estimation Guide provided on the NCDEQ
website along with site conditions was used to estimate the total sewer spilled and volume
that was ponded and returned to the sewer system not reaching the stream. Cary staff used
a hydraulic sewer jetting machine to clear the blockage and stop the sewer overflow at 9:30
PM. While clearing the blockage, an excessive amount of sanitary wipes and paper material
was removed that caused the blockage and obstructed the wastewater flow in the 8-inch
ductile iron pipeline. Following the removal of the blockage, a root was found in the manhole
growing through a wall joint which may have contributed to the blockage but was not large
enough to be the primary cause for the blockage.
Sewer Spill Cleanup — After stopping the sewer spill, Cary staff immediately began cleaning
up the spill and pumped approximately 1,100 gallons of ponded wastewater back into the
sewer system and collected solids around the manhole. A temporary dam was constructed
downstream approximately 1,200 feet beyond the sewer spill. Pumps were set up and the
creek was flushed with 144,000 gallons of dechlorinated potable water. The wastewater and
flushing waters were pumped into the sanitary sewer system for treatment. Cleaning and
flushing occurred for approximately 7 hours.
Sewer Spill Assessment - The Town performed conductivity readings following the overflow
and during the spill cleanup to assess the spill and cleanup efforts. The following table
provides a summary of the data collected at the time of the SSO and with sewer spill cleanup.
No fish kill or visible impacts were identified following the spill cleanup.
Date/Time =>
Location
CONDUCTIVITY
February 12, 2022 February 13, 2022
9:45 PM 6:30 AM
Result (pS/cm) Result ( S/cm
Unaffected water body nearby spill
SSO entry point to creek
50' Upstream in creek
100' Downstream in creek
150' Downstream in creek
200' Downstream in creek
300' Downstream in creek
170
400
170
323
315
305
291
170
178
170
177
178
178
178

SSO Notice of Violation — Notice of Intent
April 6, 2022
Corrective Actions — On February 13 a news release was published and distributed within
24 hours following the sewer spill (Attachment 1.). After clearing the blockage, the area sewer
lines were hydraulicly cleaned, video inspected and acoustically assessed (approximately
1,350 feet) to ensure there were no additional accumulations or partial sewer line blockages.
The video assessment identified some tuberculation (Figure 1.) and corrosion (Figure 2.) on
the interior of the ductile iron pipe but is in generally good condition. We are adding this sewer
line segment to our programming for future rehabilitation.
USMH: SP75112055
DSMH: SP75112048
r figure i. - Interior pipe tuberculation
USMH: SP75112055
DSMH: SP75112048
SCP
Surface Corrosion Metal Pipe
50.4 ft.
Figure 2. — Interior surface cnrrosior
Cary's history of inspection included an easement and manhole inspections on November
15, 2021 with no issues identified at the time of the inspection. The sewer line was last
cleaned January 17, 2001. We have added this sewer line segment to our reoccurring
inspection list and will begin inspecting this sewer line segment on a semi-annual basis to
help ensure the sewer line is operating properly without any blockages. Due to the volume of
sanitary wipes and paper associated with this spill, a Nextdoor post was published and
distributed to 5 surrounding neighborhoods notifying of the sewer spill and cause. There were
214 impressions reported from Nextdoor the week following the post.
February 18 - Nextdoor Post:
As a community we work together to preserve and protect our environment and maintaining the sewer
system is an important part of that effort. We are notifying you that on February 12, 2022 Town crews
cleaned up a sewer spill near your neighborhood. It was determined that this unfortunate incident happened
because a significant amount of sanitary wet wipes and paper debris had accumulated in this area of our
system. We rely on all users of the sewer system to keep pipe -clogging material out of the sewer pipes.
Here's how you can help: Don't Rush to Flush ! click here.
The sewer manhole SP75112055 that overflowed and was
partially covered with sediment and leaves (Figure 3.), was
raised approximately 6-inches to prevent the manhole from
being covered again in the future.

SSO Notice of Violation - Notice of Intent April 6, 2022
INCIDENT # 202200228 - 421 S. West Street
Sewer Overflow Cause - On February 16, 2022 town staff received a phone call at 6:45 PM
from a citizen at the residence of 421 S. West Street reporting a blockage in their sewer
service and a sewer spill from a clean -out as a plumber, originally contacted by the citizen
attempted to clear the sewer blockage. The sewer spill stopped at 6:40 PM after the plumber
replaced the sewer clean -out cap back on the clean -out pipe. Cary staff arrived and used a
hydraulic sewer jetting machine to clear the blockage that was found in the sewer main
caused by roots in the 8-inch vitreous clay pipe.
Sewer Spill Cleanup - After stopping the sewer spill, Cary staff immediately began cleaning
up the spill. A temporary dam was constructed downstream approximately 360 feet beyond
the sewer spill. Pumps were set up and the creek was flushed with 38,000 gallons of
dechlorinated potable water. The wastewater and flushing waters were pumped into the
sanitary sewer system for treatment. Cleaning and flushing occurred for approximately 3
hours.
Sewer Spill Assessment - The Town performed conductivity readings following the overflow
and during the spill cleanup to assess the spill and cleanup efforts. The following table
provides a summary of the data collected at the time of the SSO and with sewer spill cleanup.
No fish kill or visible impacts were identified following the spill cleanup.
CONDUCTIVITY
Date/Time =>
Location
Unaffected water body nearby spill
SSO entry point to creek
50' Upstream in creek
100' Downstream in creek
150' Downstream in creek
February 16, 2022
9:10 PM
Result (pS/cm)
188
422
188
418
February 17, 2022
12:00 AM
Result (pS/cm)
178
178
420
200' Downstream in creek 413
350' Downstream in creek 398
178
179
178
180
179
Corrective Actions - After clearing the blockage the area sewer lines were hydraulicly
cleaned, video inspected to ensure there were no additional accumulations or partial sewer
line blockages. The video assessment identified roots being the primary cause for the
blockage. Cary's history of inspection included a manhole and easement inspection on
September 9, 2021. The sewer line was previously cleaned, and video inspected on May 13,
2020. This segment of vitreous clay pipe is part of Cary's existing root chemical treatment
program that occurred spring of 2018 and January 2022. This segment of sewer line will be
retreated for roots and video inspected to ensure a blockage does not reoccur. We advertise
on our website for citizens to call Cary first if they experience slow drains or sewer line
blockages so we can assess the cause of the blockage and to prevent occurrences such as
this where a clean -out cap is removed that allows sewer to escape the sewer line causing an
SSO.

SSO Notice of Violation - Notice of Intent
April 6, 2022
We appreciate the opportunity in being able to provide information on both unfortunate sewer
spills. These two instances are the only sewer spills that have occurred in those sewer line
segment areas. We appreciate NC DEQ's consideration in evaluating these sewer spills, the
cause, and Cary's record and response to remediate and help ensure that a SSO
reoccurrence does not reoccur at these locations. If we can answer any questions or provide
any additional information, please feel free to contact Mr. Donald Smith, Wastewater
Collection System Manager at [phone].
Sincerely,
Ja ie Reve,,, r
��-Utilities Director
Cc: Donald Smith, Wastewater Collection System Manager
Paul Campbell, Wastewater Collection System Operator
Attachments:
• NCDEQ Notice of Violation - NOI to issue Civil Penalty - NOV2022-DV-0069
• News Release - Sanitary Wipes and Paper Debris Cause Sewer Spill in Cary
• Collection System Sanitary Sewer Overflow Reporting Form - Incident #
202200217
• Collection System Sanitary Sewer Overflow Reporting Form - Incident #
202200228

104cce),A) /P/;4
ROY COOPER
Governor
ELIZABETH S. BISER
Secretory
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 4109 5404
Return Receipt Requested
Jamie Revels, Director of Public Utilities
Town of Cary
PO Box 8005
Cary, NC 27512-8005
�ll
NORTH CAROLINA
Environmental Quality
March 14, 2022
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2022-DV-0069
Sanitary Sewer Overflows - February 2022
Collection System Permit No. WQCS00013
Cary Collection System
Wake County
Dear Mr. Revels:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
Town of Cary. The Division's Raleigh Regional Office concludes that the Town of Cary violated Permit Condition I
(2) of Permit No. WQCS00013 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 Town of Cary an opportunity to provide evidence and justification as
to why the Town of Cary should not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202200217 2/12/2022 105 100-Block Greyfriars Ln Debris in line, Roots 4,665 3,565 Notice of Violation —
Notice of Intent
202200228 2/16/2022 5 421 S West St, Cary Roots 440 440 Notice of Violation
ftP..w")
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raklgh. North Carolina 27609
919.791.4200

This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
Laserfiche
D1\ Qr,
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive i Raleigh. North Carolina 27609
gig 791.4200

NEWS RELEASE
TOWN III (CARY .
February 13, 2022
Sanitary Wipes and Paper Debris Cause Sewer Spill in
Cary
• Cary responded last evening to a 4,665-gallon sewer spill in the area of
Greyfriars lane
• The spill was caused by blockage from a buildup of sanitary wipes and
paper debris: staff cleared the blockage as part of site clean-up and
restoration
• Cary citizens are reminded to not rush to flush disinfecting tripes baby
wiper, and paper towels should Instead he thrown in the trash for proper
disposal
:'ARY, NC — A sewer spill in Cary occurred last night near the 100 block of
3reyfriars Lane. Town staff responded to the alert that came in around 7 45 p m
ind stopped the spill at 9 30 p m The overall spill volume was 4 665 gallons a
aortion of which flowed into a creek that leads to Regency Park Lake The sever
;pill was intercepted in the creek. flushed with dechlorinated waterand pumped
hack to the sewer system for disposal with no wastewater entering Regency Park
.ake No fish kill was observed
-he spill was caused by a blockage from a buildup of sanitary wipes and paper
lebris it the sever main Town staff cleared the blockage, cleaned the site and
ipplied powdered lime to the ground to treat the soil
ary reminds citizens that disinfecting wipesbaby wipes and paper towels
houtd not be flushed down the toilet. Instead. property dispose of used sanitary
taper items in the trash
1s required by taw. additional notification has been made to the State Division of
eater Resources which will review the incident. North Carolina General Statues
equire public notice in the form: of a news release issued by wastewater utility
Iperators within 24 hours of the detection of a wastewater overflow of 1.000
capons or greater that also reaches surface waters Paid advertisements are also
ecessary for spills of 15.000 gallons or greater.
or more on Cary's 990-plus miles of wastewater pipelines, ways to reduce sewer
pills, or information on how to report a sewer spill. visit towr fir,'- or
all 311 or 1919) 469-4000 if outside Cary Town Limits
7-unary Contacts
you have specific questions about Town services or operations. dial 311
nywhere in Cary, [phone] outside town limits. or email
I(Pawn ofc rofc.
3esour'Ces
• �e:'e- ';'a'ntencince
• i=r;ni. al Waste' :a4 r P,Epert
• 71o:ow ! c? na_icthest

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: WQCS00013 (WQCS# if active, otherwise use WQCSD#)
Facility: Cary Collection System Incident #: 202200217
Owner: Town of Cary
City: Cary
County: Wake Region: Raleigh
Source of SSO (check applicable): Q 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): 100-Block Greyfriars Ln
Manhole #: SP75112055
Latitude (Decimal Degrees): Longitude (Decimal Degrees).
Incident Started Dt: 02/12/2022 Time: 7:45 pm Incident End Dt: 02/12/2022 Time: 09:30 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 4,665 gallons Estimated Duration (Round to nearest hour): 1:45 hours
Describe how the volume was determined:
Sewer Spill Estimation Guide using spill area, observed flow, and creek condition
Weather conditions during the SSO event: Clear
Did SSO reach surface waters?
0 Yes ❑ No ❑ Unknown
Surface water name: Regency Park Lake
Volume reaching surface waters (gals): 3565
Did the SSO result in a fish kill? ❑ Yes [ZENo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
Q Roots Er Debris in line
24 hour verbal notification (name of person contacted ): Marianne Nicholaysen
❑ DWR [l Emergency Mgmt Date (mm-dd-yyy): 02/13/2022 Time (hh:mm AM/PM): 10:36:00 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 111 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
Roots
Do you have an active root control program on the line / area in question? D Yes 171 No El NA ❑ NE
Describe
Roots were identified in the mantiole helpt<ugto obstruct flow along with large volume of wipes and rig material.
Have cleaning and inspections ever been increased at this location because of roots' ❑ Yes 0 No ❑ NA D NE
Explain:
Roots had not been identified in the past as a problem in this manhole or sewer line segment. Sewer line cleaning was la!
performed January 17, 2001.
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
Area sewer lines and subject manhole were hydraulically cleaned and video inspected on February 14, 2021. Acoustic
testing was performed in the surrounding sewer lines to check for obstructions or any other signs of roots.
What corrective actions are planned at the SSO location to reduce root intrusion?
The root intrusion was limited to the single manhole, roots were removed and will be monitored for regrowth.
Has the line been smoke tested or videoed within the past year? ❑ Yes 0 No ❑ NA ❑ NE
If Yes, when?
Comments:
The sewer line easement at the location of the sewer spill was last inspected on November 15, 2021. The manhole is in a
lower Tying area and had some soil and leaf litter covering the manhole at the time of the spill. The manhole ring and cov'
will be raised to prevent soil accumulation on top of the manhole lid.
Debris in line
What type of debris has been found in the line?
Sanitary wipes and paper products
Suspected cause or source of debris.
Fllusned wipes and pilperproducts
Are manholes in the area secure and intact? © Yes ❑ No ❑ NA ❑ NE
When was the area last checked/cleaned?
11/15/2021
CS-SSO Form Page: 2

Have cleaning and inspections ever been increased at this location due to previous CI Yes 17 No El NA El NE
problems with debris?
Explain:
No history of debris problems were identified in this area of the sewer system.
Are appropriate educational materials being developed and distributed to prevent futr 0 Yes ❑ No ❑ NA ❑ NE
similar occurrences?
Comments:
Public education and responsible wastewater tips are being distributed via Nexldoor to area residents.
System Visitation
ORC 171 Yes
Backup Yes
Name:
Donald Smith
Cert#
1001030
Date visited:
2/13/2022
Time visited:
7:00 AM
How was the SSO remediated (i.e. Stopped and cleaned up)?
The blockage was cleared at 9:30 PM on 2/12/2022 using a hydraulic jet truck. Wastewater around the spill site was
pumped back into the sewer system for disposal and debris tricked up, The creek was temporarily dammed and pumps
setup downstream. Dechlorinated water was used to flush the spill site and creek with all water being pumped to sewer fc
treatment. All sewer was contained in the creek which was not flowing. The sewer spill was intercepted in the creek and n
sewer discharged into the downstream Regency Park Lake. Powdered lime was applied at the spill site to treat the soil.
Conductivity readings in the creek were used to identify the spill and for cleanup efforts.
As a representative for the responsible party, l certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Donald Bradley Smith Date: 02/17/22 01:00 pm
Signature: r2'?� 1 f 5 Title: tt›O3 ANA(
Telephone Number: `I3 `T lonl
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of i
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

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: WQCS00013 (WQCS# if active, otherwise use WQCSD#)
Facility: Cary Collection System Incident #: 202200228
Owner: Town of Cary
City: Cary
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): 421 S West St, Cary
Manhole #: CLEANOUT
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 02/16/2022 Time: 6:35 pm Incident End Dt: 02/16/2022 Time: 06:40 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 440 gallons Estimated Duration (Round to nearest hour): 0.5 hours
Describe how the volume was determined: Sewer Spill Estimation Guide using spill area, observed flow, and creek condition
Weather conditions during the SSO event: Clear
Did SSO reach surface waters? El Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 440
Surface water name: MacGregor Downs Lake
Did the SSO result in a fish kill? ❑ Yes [ZNo ❑ Unknown If Yes. what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
[Jj Roots
24 hour verbal notification (name of person contacted ): Jane Bernard
DWR ❑ Emergency Mgmt Date (mm-dd-yyy) 02/17/2022 Time (hh:mmAM/PM) 10:15:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director, Division of Water Resources may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form Page: 1

PART I1:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Roots
Do you have an active root control program on the line / area in question? RI Yes E1 No NA NE
Describe
This sewer line segment is currently on a root treatment program. Chemical root treatment applied in spring 2018 and
January 2022.
Have cleaning and inspections ever been increased at this location because of roots' 17j Yes El No NA [] NE
Explain:
This line segment and area include VCP pipe and are inspected and cleaned on a 2-year cycle.
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
This sewer line wasjetted to clear the roots and blockage. A video inspection was also conducted to ensure roots were
removed. We will continue to keep this area in our chemical root treatment program.
What corrective actions are planned at the SSO location to reduce root intrusion?
The area is beingassessed for an additional chemical root treatment in addition to the cleaning that has occurred. This
VCP sewer line will continue to be cleaned and inspected on an increased 2-year cycle.
Has the line been smoke tested or videoed within the past year? ❑ Yes 171 No D NA NE
If Yes, when?
Comments:
This sewer line was cleaned, and video inspected on May 13 2020 in conjunction with our 2 year cleaning and in pectior.
program. A sewer line easement inspection and manhole inspections were performed on September 27, 2021.
System Visitation
ORC Yes
Backup Yes
Name:
Donald B. Smith
Cert#
1001030
Date visited:
2/16/2022
CS-SSO Form Page: 2

Time visited:
9:00 PM
How was the SSO remediated (i.e. Stopped and cleaned up)?
The sewer spill discharged from a cleanout that was opened by a plumber. A blockage in the sewer main caused
wastewater to back-up in the sewer line and cleanout. The spill was stopped when the plumber reinstalled the cleanout ci
after approximate y 5 minutes of spill release. A temporary dam was constructed downstream and de -chlorinated water
was used to flush the creek and the contents of the spill and cleanup waters were pumped to sanitary sewer for treatmenl
Debris around the cleanout was picked up and powdered lime was applied to the ground to treat the soil.
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 Donald Bradley Smith Date: 02/22/22 11:30 am
(� 1e
Signature: . ) Title: ,:').1 -•a—�S
Telephone Number: 91 19 - Lf f —4-oct
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