WQCS00002_DV-2022-0121_20221026

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleigh
Facility Name: Raleigh Collection System
Permit Number: WOCS00002
County: Wake
Case Number: DV-2022-0121
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;
An estimated 9,550 gallons of sewage leaked from a broken line into Swift Creek, a WS-111, NSW, CA, in the Neuse River
Basin. All 9,550 gallons of sewage flowed into Swift Creek. Nutrients and pathogens to surface waters/ Ewe eAr a'ta-
2) The duration and gravity of the violation;
The SSO began 05.09.2022 at 9:24 pm and ended 05.10.2022 at 12:35 am. Nutrients and pathogens to surface waters.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on surface water quality includes increased nutrients and pathogens which could cause water quality stream d-
violations.
4) The cost of rectifying the damage;
The cost of rectifying the SSO amounted to $182,075.75.
5) The amount of money saved by noncompliance;
The approximate cost to have treated 9,550 gallons of wastewater is approximately$14.32.
6) Whether the violation was committed willfully or intentionally;
It is believed that the violation was not committed willfully or intentionally.
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority;
There have been 10 enforcements within the past 12 months.
8) The cost to the State of the enforcement procedures.
$36.57
19-3 L0Z2
Date
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7020 3160 0000 4109 0553
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
October 26, 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-2022-0121
Wake County
Dear Mr. Wheeler:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $536.57 ($500.00 civil penalty +
$36.57 enforcement costs) against City of Raleigh.
This assessment is based upon the following facts: a review has been conducted of the Sanitary Sewer Overflow (SSO)
5-Day Report submitted by City of Raleigh. This review has shown the subject facility to be in violation of the requirements
found in Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1). The violation(s) that occurred are
summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that City of Raleigh violated the terms, conditions or
requirements of Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
North Carolina Department of Environmental Q altty I Division of Waler Resources
Raleigh Regional Office 13600 Barrett Drive Raleigh NonhCarolina 27609
919.791A200

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:
$500.00 For 1 of the 2 violations of Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
$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) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

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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 Ri ht 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 (I) 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

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Case Number: DV-2022-0121
Assessed Party: City of Raleigh
Permit No.: WQCS00002
JUSTIFICATION FOR REMISSION REOUEST
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. 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-2022-0121
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 October 26, 2022, the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the day of , 20
SIGNATURE
ADDRESS
TELEPHONE

PERMIT NO: WQCS00002
FACILITY: Raleigh Collection System
Other Violations
ATTACHMENT A
City of Raleigh
CASE NUMBER: DV-2022-0121
INCIDENT VIOLATION
NUMBER DATE VIOLATION TYPE
VIOLATION DESCRIPTION
REGION: Raleigh
COUNTY: Wake
TOTAL VOLUME PENALTY
(GALLONS) AMOUNT
202200705 5/4/2022 CSOISSO(Sewer Overflow) Discharge without valid permit
1,200 $0.00
202200737 5/9/2022 CSO/SSO(Sewer Overflow) Discharge without valid permit 9,550 $500.00

2:
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August 111", 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
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Raleigh Water ITC Der 0FEnvironmental Qualit}
AUG 11 2012
Ra1,eigh Regional Office
Re: Response to NOV-2022-DV-0193
Sanitary Sewer Overflows — May 2022
Permit No. WQCS00002
Dear Mr. Vinson:
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil
Penalty document (NOV-2022-DV-0193) received on July 21r, 2022. This document contains the
narrative regarding pending violation actions of (2) Sanitary Sewer Overflow (SSO) events, reported on
the month of May 2022 within the City of Raleigh Collections System (1). This document also provides
exhibits as proof of our efforts to mitigate each of the sewer events. The noticed events occurred while
the City operated its collection system, according to WQCS00002, dated June 661, 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 untreated wastewater; collect the wastewater and
reintroduce it to the collection system; and finally, restore the possible environmental impacts brought
by the release of the SSO events, listed with the intended NOV action. Please find below, the additional
Information requested for the SSO events.
1. "The Director may take enforcement action against the Permittee for SSOs that must be reported
to the Division as stipulated in Condition IV92). This includes SSOs that was caused by severe
natural conditions or exceptional events unless the Permittee demonstrates through properly
signed, contemporaneous operating logs, or other relevant evidence that:
la.1 DiaSSO was caused by severe natural conditions; there were no feasible sitemativesto the 550, such as the use of auxiliary treatment facilities,
retention of untreated wastewater, reduction of inflow and infiltration, use of adequate backup 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 backup equipment or should have reduced inflow and infiltration; or
lb.) The SSO was exceptional, unintentional, tempoary, and caused by factors beyond the reasonable comrol of the Permittee; the 550 could not have
been prevented by the exercise of reasonable control, such as proper management operation, and maintenance; adequate treatment or collection
fadlities or components le.g., adequately enlarging treatment of collection fadildesto accommodate growth or adequately controlling and preventsne
infiltration and Inflow); preventative maintenance; Or knstelletion of adequate backup equipment;'
Page 1 of 11

Incident Number # 202200705 — 05/04/2022 — 208 Blanchard St., Raleigh
This spill was neither willful nor intentional, It was the result of grease accumulation, which
blocked a portion of a 6-inch vitrified clay pipe gravity sewer main. The grease accumulation led to a
sewer spill of approximately 1,200 gallons of untreated wastewater reaching a nearby stormwater
channel within the Wildcat Basin. The wastewater was contained within the stormwater ditch and did
not reach Wildcat Brainch. See exhibit 1— Area of Operation
fahib:t 1— Are. ofOperation
On 05/04/2022, at approximately 10:56 AM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH120251 1) located near 208
Blanchard St., Raleigh NC. The responding staff took all reasonable steps to stop and mitigate the impact
of the discharge, gaining control of the spill event by 11:56 AM on the same day. Crews utilized hydraulic
jetting to remove the source of the blockage within the affecting asset 2, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
approximately 570 ft downstream of the affected area restricting sewer flow on the stormwater
channel. This approach was intended to contain wastewater flow and minimize the environmental
impact on the surrounding land. Responding crews employed pumps at the temporary containment site
to recover flushed wastewater and any evidence of sewer completing the operation by re -introducing
the wastewater to the collection system. This spill was contained without a significant environmental
impact on the adjacent area and its natural resources. Visual inspection of the affected area and
downstream waters confirmed no fish kill or unnecessary vegetative damage.
During the restoration phase of the operation, crews utilized ample potable water to flush the affected
area and remove sewer traces from the surrounding area and downstream conveyance. The area
around the manhole was cleared of debris, treated with an application of lime, and restored with grass
seed and straw.
1 AKected Asset: Structure within tie collection system that allowed the release of untreated wastewater into the environment, typically* sewer manhole
2. Affecting Asset: Structure within the collection system that housed ablockage which resulted in an SSO.typically .sewer cavity train
Page 2 of 11

A CCTV assessment did not identify any infrastructure deficiencies that may have contributed to the
grease accumulation. No further maintenance or follow-up service was recommended. See Exhibit 2 —
CCTV Assessment
Exhibit 2 CCTV Assessment
USMH: SMH120251
DSMH: SMH152173
The cost associated with the mitigation of this event amounted to $713.83. The approximate cost to the
Utility to have treated 1,200 gallons of wastewater would have been approximately $1.80. Raleigh
Water saved no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of
sewage had no spill occurred. Furthermore, Raleigh Water still had to pay the cost to treat the greater
volume of sewage created by the spill.
This section of the collection system is located downstream of a residential area. it provides sewer
collection services to over 88 properties surrounding the spill event (see Exhibit 3- Zone of Influence 3),
Within the last ten years, this specific portion of the collection system has not experienced a grease
related SSO event. This area has been placed on routine maintenance.
Exhibit 3. Zone of nguence
3. Zone of Influence: Area upstream from an 550 that contains homes or businesses whose disdsarge of wastewater may have contributed to the
creation of a system Mockup Identfying this area is crusts! 10 amain ng potent al sources of illicit discharges such as grease or rags that generate
blockages, es wen as detain ning where educat.ona matenats can be drstnbvted post -incident to educate residents regarding the proper use of the
cotection system
Page 3 of 11

A press release notification was requested to be published in the Raleigh News & Observer as required
by NCGS Article 21, Chapter 143.215.1C. See Exhibit 4 — Press release. Outreach information literature
was requested to be sent to the immediate -affected area. The requested outreach literature explains
the need for customers to use the sanitary sewer collection system properly. it also serves as an
opportunity for citizens to partner with Public Utilities to protect the City's water quality and the sewer
collection infrastructure.
& ilt 4 Preis release
'Raleigh
NEWS RELEASE
L1rM.51�2 -C i ;7tr".R rk'Elir
01P
'.1 it' P . :.�..i Ate �inlw �an[�: F,'dU�s�lri R�fh'{}/� ,:,iri 41494r. : r
Raleigh Water Responds to a Sanitary Bawer spell
On Wednesday May 4 2022 at epptc ca dy 10:56 AU Raleigh Water stag
lime milled of a eanlfary sewer warder a the vidhhey of 20S 81anchard St,
Raleigh NC Upon antral, Ism! raepaFdere 1dse50ed an aceve sewer eveeersi g
remei g tram grease wI0dn the &inch sever main The 1ss cn gag ataR look al
reasonable slope 1a stop and WINK. the overeesfe Impact as soon as they arrived
The North Careens Departsment et Erodrawrraal Rushy, Maier at Water Resources
has been i dleed of the aysrlaw
Raleigh Waler staI removed pre blockage mime and contained Ike ovateow at
ayprcximaiciy 1156 NA an the same day 11 is estimated tree the overflow dleeharged a
volume of a$pre dmatIIy 1,200 galena of unheated wastwvatmin which tee 1200
gases was colluded before reading surface waters Rsamralan for this event has
been caepletsd lease was no abearvsd es h eel or unnecessary vegetative damage
reshdene *mein sewer event
• Raleigh Water has an agoreselve education and entarsarent program to
prevent Me Mechem of grease, deeds, *pee, rags, dispels and other
Improper materials In the Bawer system end to take enlbresment whoa
whore appropriate. N those Items make it Wolfer sewer system, they steel
cause a spill which nen have en edema helped on water wisely and
endanger those who mime Into contacted& Ore allotted areas.
• Warm, boson wasta, and toilet deem are the only Items permitted to be
dlsehsrged Into the sewer system. All other items will sense damage to the
stem, system end are not permitted.
• Mr you snpedencs eicesslve svelter edtets Of sow sewer spllllrg from
asenholss ter pipes, cisaee call 0104003246 to report immediately.
• For more tciouinatao abort how you can help prevent sarhtaly sewer
Bela, please Meth ratrlohno,govilrster.
This nevra reluee is required by NCGS Adlds 21. Cnt,pls:143.215.1C
m
Page 4 of 11

Before this event, maintenance records show that sections within the zone of influence of this collection
system were assessed within the last 10 years as follows:
Repair Inspections Acthrtties
Flushing activitles ankles Acthrities (Manhole Inspection
Sewer Hlgh Prlorlty InspectIon)
3/22/2012 10/16/2014 3/27/2012 9/24/2018 22/15/2021 3/23/2020
3/27/2012 12/22/2015 10/16/2014 3/6/2017 3/5/2018 11/5/2020
3/29/2012 1/29/2018 2/20/2017 1/30/2018 6/13/2018 9/10/2020
8/1/2013 9/25/2018 1/30/2018 3/28/2019 6/13/2018 2/16/2021
8/2/2013 9/26/2018 10/8/2018 8/22/2018 1/31/2019 8/20/2021
10/8/2013 10/8/2018 10/9/2018 6/20/2019 3/14/2022
10/21/2013 10/10/2018 10/10/2018 6/19/2019 8/1/2022
9/10/2014 10/10/2018 12/17/2019
10/18/2018
8/22/2019
There have been no additional issues associated with this section of the collection system since the last
sewer event. this site continues to remain an active maintenance spot pending completion of further
sewer main cleaning and CCTV assessment.
Page 5 of 11

Incident Number 0 202200737 — 05/09/2022 —1530 5. Gleneagles Dr. Garner
This spill was neither willful nor intentional, it resulted from a failed 12-inch reinforced concrete
pipe gravity sewer main. This asset failure led to a sewer spill of approximately 9,550 gallons of
untreated wastewater reaching surface waters of Buck Branch, within the Benson Basin.
On 5/9/2022, at approximately 09:24 PM, Raleigh Water staff was notified of a sewer spill emanating
from the ground, near 1530 S. Gleneagle Dr., Garner. Upon arrival, crews proceeded to break the
blockage but encountered a large amount of silt and sand, indicative of a possible main break. Crews
also identified a sinkhole on the easement aligned with the sewer main. Due to these observations, it
was determined that the sewer spill was attributed to a possible pipe collapse. See Exhibit 1— Damaged
Section of Gravity Main
:.ham .... fiamahal Caeilebek,,.t2-
A CCTV assessment was utilized to attempt to confirm the condition of the sewer main and to determine
the scope of repair needed. This assessment focused on the affecting asset, SGMN128887, which is
located on a sanitary sewer easement in Garner that runs through a residential area. This outfall
originates near the US Hwy 70 and Yeargan Rd intersection and captures primarily residential flow, with
some commercial input as well. Commercial users include two food service establishments and one
public school. The CCTV confirmed that repair would be required and that due to the pipe diameter and
its wastewater flow the work would be referred to the Raleigh Water Capital Improvements Division for
contractor support. The responding staff took all reasonable steps to stop and mitigate the impact of the
discharge as soon as they arrived. The asset was placed on bypass to eliminate the overflow, containing
the spill event by 12:35 AM the following morning. See Exhibit 2 —Temporary Sewer by-pass.
Collection efforts of this spill event consisted of employing a temporary spill containment site
downstream of the affected area restricting sewer flow on the creek. This approach was intended to
contain wastewater flow and minimize the environmental impact on the surrounding land. Responding
crews employed pumps at the temporary containment site to recover flushed wastewater and any
evidence of sewer completing the operation by re -introducing the wastewater to the collection system.
This spill was contained without a significant environmental impact on the adjacent area and its natural
resources. Visual inspection of the affected area and downstream waters confirmed no fish kill or
unnecessary vegetative damage.
Page 6 of 11

EKhba 2 — Temporary Sewer bypass
During the restoration phase of the operation, crews removed the contaminated soil from the affected
area to include the downstream conveyance. The surrounding area was then treated with an application
of lime and properly restored with grass seed and straw Once the bypass was established crews
proceeded to clean the adjacent creek removing sewer traces from the downstream conveyance.
Repair efforts to address this sewer main were relinquished to a licensed utility contractor. Contractors
successfully replaced approximately 360 ft of concrete pipe with 12-inch PVC. See Exhibit 3 —Scope of
Repair Effort.
EKhb4 3 -So a e o+Ryo+r Effort
Page 7of11

The cost associated with the mitigation of this event amounted to $182,075.75. The approximate cost to
the Utility to have treated 9,550 gallons of wastewater would have been approximately $14.32. The City
saved no money from this spill. its costs for cleanup and repair exceeded the cost of treating the volume
of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater
volume of sewage created by the spill.
The events leading to this spill can be considered exceptional, unintentional, temporary, and caused by
factors beyond our reasonable control. Furthermore, the SSO could not have been prevented by the
exercise of reasonable control, such as routine operations and maintenance, adequate treatment
facilities, or collection system facilities or components.
A press release notification related to this event was requested to be published in the Raleigh News &
Observer on May 10th, 2022. There have been no further sewer events associated with this location.
Erhlblt 4 — Press felons
Raleigh
NEWS RELEASE
.'I: Wi .I. ...'ti-1 J:1
Raleigh water Responds to a Sanitary Seim Spill
O@ Monday. May 9 2022. al approsdesWp 924 PM Raleigh Wafer staff me
=Wed al a ender, sewer ovaft= In the Mdsly of 19f10 S Omagh Dr
Gamer NC Upon antral U1iq Respmadms weaeewd en aive sower ovea9ew
remain hen asset him wards the 124erteedn The aerpondhg stafftookaB
feasonalu stops he etap and maple the avaeoMs broad as loan as rwy w*.ed
The Rath Carcass Depamwest of Erntea@mma' Cutesy Olvbloo et Water Resources
leas been monied dew maim
R0Ylpb Water statwartud to remove the blockage i01eq and determined ale
ha resat raise The omit* was slopped at app1IYsdaty 12 3SAM an Tuesday uay
i 10 2022 It is ee5mefed drat to swim dialsoagri a volnns o1 appraodmrbry
4 S50 SAWS of unhooked wads water reached Mace waters Wail the fled Creek
Weer Barba Romanis kedge math mmfloyamotto apea9aa Then was es
abavrd file 00 sr vdaeceseuy MOM* Magi as$ckg hoar fhb fewer evict
• Rakish Wales hes an apoes0' education and enforcement program b
preventlhs discharge of grouse,debrle, wipes, fps, diaper end odor
Improper mated&s by the sewer system and to tetae enforcement Min
when dpproldab. M these !tame snake It Into Os sewer system, they may
cause a spat which can Isere ea adverse tnpact on water qualfy end
@Wanrietheta who coma Into contact with the @fleeted am.
• winter. hum waste, end kind time ors fie only Maas merited b be
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Page 8 of 11

Before this event, maintenance records show that sections within the zone of influence of this collection
system were assessed within the last 10 years as follows:
Flushing activities
CCTV
Activities
Easement Inspections Activities
Activities (Manhole Inspection
Sewer High Priority Inspection)
5/19/2022 6/29/2020 5/13/2022 1/11/2018 10/11/2019
12/8/2017 6/3/2022 6/9/2022 1/12/2018 1/6/2020
12/8/2017 5/10/2022 6/15/2022 1/16/2018 1/22/2020
12/8/2017 5/19/2022 4/3/2018 4/20/2020
9/18/2017 7/6/2022 4/10/2018 6/3/2020
12/8/2017 12/11/2020 10/18/2018 7/17/2020
7/6/2022 4/12/2019 7/20/2020
10/31/2019 7/13/2020
There have been no additional issues associated with this section of the collection system since the last
sewer event. This site continues to remain an active maintenance spot pending completion of further
sewer main cleaning and CCTV assessment.
Page 9 of 11

Summary
The Sewer Maintenance Division of Raleigh Water strives to develop initiatives that improve
operational reliability to meet customer expectations and meet or exceed the Water Quality Collection
System permit requirements. Our operations are focused on continual improvement, the prevention of
pollution, and increased environmental performance efficiency. This endeavor is significantly noted as
the Division operates an ISO Certified Environmental Management System governed by the 14001-2015
Standards. As part of these initiatives, the Division operates a comprehensive reactive and preventative
maintenance program whose goal is to maintain over 2,566 miles of sanitary sewer pipe and minimize
the accdental release of untreated wastewater.
Additionally, the City of Raleigh Assistant Public Utility Directors and Collections System staff have
become involved in challenging the nonwoven fabrics industry standards to better inform consumers of
these products and their detrimental effects on the collections systems. PUD staff has personally met
with officers of INDA, the leading association of the nonwoven fabrics industry based in Cary, NC, to
communicate our concerns about these fabrics, the current industry standards, and better education for
the consumer. PUD has also joined forces with other utilities nationwide through the National
Association of Clean Waters Agencies (NACWA), the Water Environment Foundation (WEF), and the
American Public Works Association (APWA) to challenge INDA and current industry standards,
recognizing that they do not support compatibility in sanitary sewer collections systems nationally.
These agencies work collectively to challenge the testing protocols, assessment guidelines, and
consumer education and labeling of these non -dispersible.
Raleigh Water has an aggressive educational outreach initiative to address illicit discharges such as
wipes, fats, oil, and grease to commercial and residential users. Raleigh Water has developed a
complimentary 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, ail 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.
Page 10 of ii

On behalf of the City of Raleigh, I am requesting that the NOV 2022-DV-0193 issued for the month of
May 2022 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 (919) 996-
312, or Carlos M. Perez, ORC, Assistance Superintendent 919-996-5929.
as
' cerely,
Carlos M Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh, Public Utilities Department
P.Q. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
Carlos.perezcamacho grale atom. Go++
Page ii of ii

ROY COOPER
Garner
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
4109 6135
Certified Mali # 7020 3160 0000 4109 6135
NAIIMIEMEttEiMialted
Whit Wheeler, Assistant Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
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SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2022-DV-0193
Sanitary Sewer Overflows - May 2022
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
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
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system
that there is no SSO (Sanitary Sewer
outlet to waters of the State for
143-215.1.
SENDER: COMPLF: rr bias 5iLCTION
s Complete Items 1, 2. and 9.
The Raleigh Regional Office is prc >~ � aYtlenallie and adlfreas pto ye terse
to why the City of Raleigh should isaach eft Card to nle tic of the mellPiacel
or on the front If epaoe permits.
1. Mlcl° Addressed to:
Ynddent Start
Number Date
Duration
(Mine) L
202200705 5/4/2022 60 21
202200737 5/9/2022 191 1:
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ROY COOPER
Gowns,
EUZABETH S. BISER
Slaviarr
RICHARD E ROGERS. JR.
Director
Certified Mail # 7020 3160 0000 41Q9S13E
Whit Wheeler, Assistant Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH Lally
July 12, 2022
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Traddng No.: NOV-2022-DV-0193
Sanitary Sewer Overflows - May 2022
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as
to why the City of Raleigh should not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mies) Location Cause (Gals) (Gals) DWR Action
202200705 5/4/2022 60 208 Blanchard St. Grease 1,200 1,200 Notice of Violation
202200737 5/9/2022 191 1530 South Glen Eagle Pipe Failure (Break) 9,550 9,550 Notice of Violation -
Dr Notice of Intent
North Craft Depormatel6owarrrirlQuality I aMltlenaltiNer$euerraaa
R/eigheeywndollbe • waoWrweonw 1 #dtl+%NaldtCraMrFW01
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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 dosures. Other factors
considered in determining the amount of the dvil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section 1n
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 Offlce - WQS File
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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 f:
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 #: 202200737
Owner: City of Raleigh
City: Garner
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): 1530 South Gleneagle Dr
Manhole #: 117916
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 05/09/2022 Time: 9:24 pm Incident End Dt: 05/10/2022 Time: 12:35 am
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy (hh:mm AM/PM)
Estimated Volume of the SSO: 9,550 gallons Estimated Duration (Round to nearest hour): 3:11 hours
Describe how the volume was determined: 50gpm x 191 min
Weather conditions during the SSO event: dry/clear
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown
Surface water name: Swift Creek (Lake Benson)
Volume reaching surface waters (gals): 9550
Did the SSO result in a fish kill? ❑ Yes El No ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
[l Pipe Failure (Break)
24 hour verbal notification (name of person contacted ): Molly Nicholson
DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 05/10/2022 Time (hh:mm AM/PM): 11:32:00 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 altemative 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 (Breakl
Pipe size (inches)
12'
What is the pipe material?
Concrete
What is the approximate age of line/pipe? (years old)
55vear
Is this a gravity line? 171 Yes ❑ No ❑ NA ❑ NE
Is this a force main line? ❑ Yes WI No ❑ NA ❑ NE
Is the line a "High Priority" line? ❑ Yes 171 No ❑ NA D NE
Last inspection date and findings
1/19/2022
At time of inspection MH was stated to be in good condition
If a force main then,
Was the break on the force main veritical? El Yes D No 171 NA E NE
Was the break on the force main horizantal? ❑ Yes [j No 171 NA ❑ NE
Was the leak at the joint due to gasket failure? D Yes 171 No D NA D NE
Was the leak at the joint due to split bell? D Yes 171 No El NA E NE
When was the last inspection or test of the nearest air -release valve to determine of
operable?
N/A
When was the last maintenace of the air release performed?
N/A
If gravity sewer then,
CS-SSO Form Page: 2

Does the line receive flow from a force main immediately upstream of the failed sect'. ❑ Yes RI No ❑ NA ❑ NE
of pipe?
If yes, what measures are taken to control the hydrogen sulfide production?
N/A
When was the line last inspected or videoed?
1/19/2022
If line collapsed, what is the condition of the Tine up and down stream of the failure?
Yet to camera upstream due to pump around operations at this time. Have videoed and inspected down stream and the
downstream section is in good condition
What type of repair was made?
Currently running a bypass from SMH128845 to SMH162549. Private contractors scheduled to begin repair 5/16/2022
Is the repair temporary or permanent?
permanent
If temporary, when is the permanent repair planned?
NIA
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 [ Yes
Backup ❑ Yes
Name:
Carlos Perez
Cert#
Date visited:
05/10/2022
Time visited:
12:25AM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Flush crews arrived on site and began flushing operations in attempt to break the blockage. Crews utilized the Wolf and
Heavy debris nozzles to break the blockage. Crews were able to flush 282ft and were constantly hitting an obstruction in
the sewer gravity main. During the flushing operations the lead operator noticed dirt and sand in the sewer gravity main tc
which would indicate a possible break in the sewer main. Proceeded to contact CCTV operations to assist in closed
camera television of the sewer gravity main in Question. Due to a determined asset failure and the SGMN not being able 1
be properly flushed. crews set up a bypass utilizing SMH186545 as the suction and SMH162549 as the discharge. once
implementing the bypass SMH117916 did stop surcharging a12:35AM 5-10-2022. Crews utilized the bypass throughout
the night as well as into the next day. Repair crews have been notified of findings and have began the repair process. As
5/13/2022 the sewer bypass is currently being utilized and a permanent repair for the deteriorated SGM is scheduled to
begin 5-16-2022. COR sewer maintenance will continue to monitor the bypass until the repairs have been completed.
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: 05/16/22 08:00 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 t
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

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Water Resources
aNVMOMtn TALOU*Ur
r
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
Generator
MICHAEL S. REGAN
secretary
S. JAY ZIMMERMAN
Director
In accordance with your application received May 19, 2015 and Settlement Agreement (16 EHR 00538 and
16EHR 00843), we are forwarding herewith Permit No. WQCS00002, dated June 6, 2017, to the City of Raleigh
for the operation and maintenance of the subject wastewater collection system.
This permit shall be effective from June 6, 2017 until January 31, 2024 and shall be subject to the conditions
and limitations specified herein. It is your responsibility to thoroughly review this permit. Please pay particular
attention to the monitoring and reporting requirements in this permit and any special conditions.
For purposes of permitting, the collection system is considered to be any existing or newly installed system
extension up to the wastewater treatment facility property or point of connection with a separately owned
sewer system. The collection system Is considered all gravity lines, pump stations, force mains, low pressure
sewer systems, STEP systems, vacuum systems, etc. and associated piping, valves and appurtenances that
help to collect, manage and transport wastewater to a wastewater treatment plant under the Permittee's
ownership or maintained and operated by the Permittee through a perpetual legal agreement. Satellite
systems are systems tributary to the Permittee's collection system but those collection systems are not owned
or maintained by the Permittee. The system description provided on Page 1 of this permit is meant to provide
a general idea about the size of the system and may not be all inclusive of the collection system at the time of
permit issuance or afterward.
A discharge of wastewater to the environment from the Permittee's wastewater collection system prior to
reaching the wastewater treatment facilities is referred to herein as a Sanitary Sewer Overflow (SSO). The
evaluation of enforcement options after an SSO will be determined considering all relevant information
available or requested of the Permittee. Compliance with all conditions of the permit as well as all statutes
and regulations pertaining to the wastewater collection system must be maintained or appropriate
enforcement actions may be taken as noted in Condition VI(2).
Stele of North Carolina I Environmental Quality
1617 Mail Service Cuter 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://nortaI.ncdenr.ore/web/wa/swn/os/cs/sso
A notice of deficiency (NOD), notice of violation (NOV), civil penalty, and/or a moratorium on the addition of
waste to the system may be issued if adequate justification for an SSO 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 fotbwing the receipt of this permit
This request must be in the form of a written petition, conforming to Chapter 190B of the North Carolina
General Statutes, and flied 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,
Asb,
for 5. !ay Zimmerman, P.G.
Director, Division of Water Resources
by Deborah Gore, Supervisor
Pretreatment, Emergency Response, Collection System Unit (PERCS)
enclosure: Permit No. WQCS00002
cc: Raleigh Regional Office, Water Quality Regional Operations
Water Resources Central Files — WQC500002
Maureen Kinney, NC Operators Certification Program (electronic)
PERCS Files (electronic)