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HomeMy WebLinkAboutWQCS00002_DV-2023-0010 case file_20230125DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT Violator: City of Raleigh Facility Name: Raleigh Collection System Permit Number: WOCS00002 County: Wake Case Number: DV-2023-0010 Incident 202201195 ASSESSMENT FACTORS 1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; A total amount of 3,600 gallons overflowed from a pipe failure at 6321 Winter Spring Drive, Wake Forest, NC. All of the volume reached an UT to Austin Creek, class C; NSW in the Neuse River Basin. Nutrients and pathogens to surface waters. 2) The duration and gravity of the violation; The SSO started on 07.26.2022 at 10:41 am and ended the same day at 02:15 pm. 3) The effect on ground or surface water quantity or quality or on air quality; The effect on surface water quality include increased nutrients and pathogens. 4) The cost of rectifying the damage; The cost of rectifying the damage was $47,208.83. 5) The amount of money saved by noncompliance; The cost to treat 3,600 gallons of wastewater would have been approximately $5.40. 6) Whether the violation was committed willfully or intentionally; It does not appear that the violation was committed willfully or intentionally. 7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; There have been 1 I enforcements within the past 12 months. 8) The cost to the State of the enforcement procedures. $38.85 Date Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT Violator: City of Raleigh Facility Name: Ralcigh Collection System Permit Number: W CS00002 County: Wake Case Number: DV-2023-0010 Incident 202201201 ASSESSMENT FACTORS 1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; A total amount of 4,800 gallons overflowed due to a blockage in the manhole invert. All of the volume reached an UT to White Oak Creek class C; NSW in the Neuse River Basin. Nutrients and pathogens to surface waters. 2) The duration and gravity of the violation; The SSO started on 07.27.2022 at 1:45 pm and ended the same day at 03:57 pm. 3) The effect on ground or surface water quantity or quality or on air quality; The effect on surface water quality include increased nutrients and pathogens. 4) The cost of rectifying the damage; The cost of rectifying the damage was $3,885.92. 5) The amount of money saved by noncompliance; The cost to treat 4,800 gallons of wastewater would have been approximately $7.20. 6) Whether the violation was committed willfully or intentionally; It does not appear that the violation was committed willfully or intentionally. 7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; There have been 11 enforcements within the past 12 months. 8) The cost to the State of the enforcement procedures. $38.85 , gar 2 , Z'Z3 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 4115 5764 Return Receipt Requested Whit Wheeler, Assistant Director City of Raleigh PO Box 590 Raleigh, NC 27602-0590 NORTH CAROLINA Environmental Quality January 24, 2023 SUBJECT: Notice of Violation and Assessment of Civil Penalty for Violations of North Carolina General Statute (G. S.) l 43-215.1(a)(1) and Collection System Permit No. WQCS00002 City of Raleigh Raleigh Collection System Case No. DV-2023-0010 Wake County Dear Mr. Wheeler: This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $538.85 ($500.00 civil penalty + $38.85 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. l 43-215. l (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. l (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). ,9�pwNatncaroko Deer kofErnlmnneMICmdhr I DtvftlonofW&WR swans Rafth Re WW Oake I NM Barret) Dnve I Ra ftk Plonk carolna 27609 919.79U700 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, [, Scott Vinson, Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against City of Raleigh: 500.00 For 2 of the 4 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 38.85 Enforcement Costs 538.85 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. 143 B-282. I (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: (I) Submit payment of the penalty, OR (2) Submit a written request for remission, OR (3) Submit a written request for an administrative hearing Option 1: Submit payment of the penalty: Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s). Please submit payment to the attention of. Attn: PERCS Branch Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Option 2: Submit a written request for remission or mitigation including a detailed justification for such request: Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing, such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below. In determining whether a remission request will be approved, the following factors shall be considered: (1) whether one or more of the civil penalty assessment factors in NCGS 143 B-282. I (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 complte and submit the enclosed "Request for Remission of Civil Penalties,, - Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thigy (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 § 15013-23.2) 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 filing12rocess. 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: (919) 431-3000 Fax: (919) 431-3100 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 (919) 791-4200 or via email at mitch.hayes@ncdenr.gov. Sincerely, ,0 , 0� � 06 /0,z e �r.1e Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Laserfiche JUSTIFICATION FOR REMISSION REQUEST Case Number: DV-2023-0010 County: Wake Assessed Party: City of Raleigh Permit No.: WQCS00002 Amount Assessed: $538.85 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. § 14313-282.1(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. 14313-282. 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 ) WAIVER OF RIGHT TO AN OF CIVIL PENALTIES AGAINST } ADMINISTRATIVE HEARING AND STIPULATION OF FACTS City of Raleigh ) Raleigh Collection System ) PERMIT NO. WQCS00002 ) CASE NO. DV-2023-0010 Having been assessed civil penalties totaling $538.85 for violation(s) as set forth in the assessment document of the Division of Water Resources dated January 24, 2023, 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 ADDRESS TELEPHONE SIGNATURE 20 ATTACHMENT A City of Raleigh CASE NUMBER: DV-2023-0010 PERMIT NO: WQCS00002 FACILITY: Raleigh Collection System Other Violations INCIDENT VIOLATION NUMBER DATE VIOLATION TYPE 202201041 7/4/2022 CSOISSO(Sewer Overflow) 202201195 7/26/2022 CSOISSO(Sewer Overflow) 202201201 7/27/2022 CSOISSO(Sewer Overflow) 202201208 7/28/2022 CSO/SSO(Sewer Overflow) REGION: Raleigh COUNTY: Wake TOTAL VOLUME PENALTY VIOLATION DESCRIPTION IGALLONSI AMOl1NT Discharge without valid permit Discharge without valid permit Discharge without valid permit Discharge without valid permit 1,600 $0.00 3,600 $250.00 4,800 $250.00 4,000 $0.00 October 11ih, 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 Re: Response to NOV-2022-DV-0236 Sanitary Sewer Overflows —July 2022 Permit No. WQCS00002 Dear Mr. Vinson: `/ 1 � 0 NC 0Dcp off Qua>3tf 0 �/ OCT 112022 Raleigh Water Rai" Arc bept eEInnvironmental Quality Ralcigh Rcgional omee Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty document (NOV-2022-DV-0236) received on August 20"r, 2022. This document contains the narrative regarding pending violation actions of (4) Sanitary Sewer Overflow (SSO) events, reported on the month of July 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 6th, 2017. The permit includes the language outlined in footnote 1 and applies to the SSOs upon which NOVs with the notice of intent (NOV-NOI) were based. This document will establish a reasonable explanation of the actions taken to stop the spills; contain the released 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-NOI 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: (a.1 TheSSO was caused by severe natural condltlow, there were r+o fessbie alternatives to the SSO, such as the use of auxlYary treatment facilities, retention of untreated wastewater, reduction of inflow and Infiltration, use of adequate backup equipment, or an increase In the cap" at the system, This provision is not satisfied if, in the exercise of eeasoeabie errglneerhtj Judgment. the Permittee should have installed audliary or aihlltionatcoGeetbons system components, wastewater retention or treatment facilities, adequate back-up equipmentorshouid have reduced Inflow and infiltration: or (b.l The SSO was exceptional, unintentional, temporary, and caused byfactors beyond the reasonable control of the Farmlttee: the SSO could notftave been prevented by the exercise of reasonable control, such as proper management, operation, and maintenance: adequate treatment or collection facilities or components (e4, adequately enlarging treatment of collection faciibes to accommodate~h or adequately controlling and preventingInAlretion and Inilowl: preventative maintenance: or Installation of adequate back-up equipment;" Incident Number 0 202201041— 07/04/2022— 7703 Oak Marsh Dr., Raleigh NC This spill was neither willful nor Intentional; it resulted from a failed 6" ductile iron sewer forced main. This asset failure led to a sewer spill of approximately 1,600 gallons of untreated wastewater remaining within the natural topography and not reaching surface water of the state (see exhibit 1— Area of Operation). On Monday, July 4th, 2022, at approximately 12:05 PM, Raleigh Water Utility Responders were notified of wastewater emanating from the ground near 7703 Oak Marsh Dr., Raleigh. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived, gaining control of the spill event by 2:05 PM. Utility Responders were able to contain and collect the wastewater by utilizing vacuum trucks in tandem and controlling wastewater flow from the nearest pump station. Crews were able to collect the untreated wastewater flow in tanks preventing the wastewater from continuing downstream. The natural topography of the surrounding land, downstream of the affected asset, served to partially contain approximately 1,600 gallons of untreated wastewater. The ground surrounding the affected manhole absorbed a vast portion of untreated water before it reached surface waters of the Neuse River. See Exhibit 2 —Temporary containment. This spill was temporarily 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. 2 During the restoration phase of the operation, repair crews replaced the damaged section of force main (see Exhibit 3 - Damaged Pipe and Subsequent Repair). The repair was made possible by reducing wastewater flow at the nearby pump station. Once the force main was excavated, crews applied a 36W containment band replacing approximately 4 ft. of ductile iron pipe. Once the repair was completed, the force main was pressurized to verify the effectiveness of the repair, and no subsequent leaks or repair failures were noted. Crews restored the site by backfilling the excavation with stable structural aggregates and restoring the ground surface with seed and straw. Sewer -contaminated soil was mechanically removed and the area surrounding the pipe break was cleaned with ample potable water to remove sewer traces from the surrounding area, and downstream conveyance. The area was then treated with an application of lime and restored with grass seed and straw. See Exhibit 4 — Site Restoration. The cost associated with the mitigation of this event (including the repair efforts) amounted to $5,208.3S. The approximate cost to the Utility to have treated 1,600 gallons of wastewater would have been approximately $2.40. The City saved no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the spill. 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 5 — Press Release. See brhM 5 - Pan Rdme GdAA Mk�arftwroada m sw+krr fawr cal OaUw�r JuM �. MI2, dafprarkaaMl/ 1.1f PII Na1wp Waver � aaaar�awwavwfwakrardrTN3Oaku"DlRa-10 NC of IftmpaWbgardwakafawaoadaWp aarpaadaYlfwlm awalaM k►Aagwaaaamir�aokadlkaNa�lPirOW d Gatiaram :Qa�.OAYandWrwfyawaarllaaOaaanoiftldMwM4r. RalgphWawntdaagakndbwwfar rappw� 7tK ik4anfr aaaMdark4riewadUwfMewfaardlwdiraapkan aapodow4a afof falnwaluwaradwaaMrawr lhaarfawOdnalwad�aa�r rpasden aw.�atrf» allaefrgaaarwaaaaaeaaud anfn wrey+krgwM nrarwaaf»afaaard raaafwMnda�fawfahlNkwkawabawwo rNareaafwaaw . IbYlpklMwrkaa„ doewbernl-lerean --p enno prawatfladaekarsa gumdabd�w4 N@%`dpwaaMadar Ipiop�aw4.1i i. da uam gamin m "ho scam Ubanapprapd %oft ak7rrwakrkkmtlwwWerM�er me wra• afrVM60Wfwean alnrw kopef a aMwgrfg aehnfn�.e. aa� aareoMaaea wfh�M dNenOanriw . tkaar.kmanarr..Mnreuawrramo.Mkaeal mka db"g*d kmdrawaw araaan madhukwn a0 arar a..y. mrka uaar eraaaw and ar as oweYleaL pYauWarlrwamwlft w wndbat uaaawrrpiYoipn awrfgln orplpaa, paaMd flfpf.lilSm rpweiaoradlrary �anka4pwaNSWAMI am Tlearawrwawfuw�aekpnorisMaaa Ckgaartus�ft€ 00 Prior to this sewer event, this asset experienced ruptures which have been noted and placed in a future Capital Project for improvement. In the last ten years this asset has been addressed as follows: Previous Ssos Previous Repair Activities 4/19/2021 2/13/2018 4/23/2022 11/3/2020 s/30/2021 11/23/2020 7/17/2021 4/19/2021 11/8/2021 4/23/2022 6/6/2022 5/28/2021 6/7/2022 7/17/2021 7/4/2022 11/8/2021 6/6/2022 7/4/2022 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 spot pending the completion of further Capital Improvements. Incident Number # 20220119S — 07/26/2022 — 6321 Winter Spring Dr., Wake Forest NC This spill was neither willful nor intentional. It resulted from a broken r PVC pipe located 40' upstream from sewer manhole SMH130985. This pipe failure restricted the normal flow of untreated wastewater leading to the sewer spill of approximately 3,600 gallons of untreated wastewater reaching an unnamed tributary within Smith Creek Basin. See Exhibit 1—Area of Operation and Damaged Section of Pipe. b&blt 1- Ann of 0mradan and Oamand %M" of Vim �4- On 07/26/2022, at approximately 10:41 AM, Raleigh Water staff responded to a sanitary sewer overflow emanating within an unnamed tributary located near 6321 Winter Spring Dr., Wake Forest NC. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge, gaining control of the spill event by 02:15 PM on the same day. Containment and collection of this spill event consisted of emplacing a sewer bypass and rerouting untreated wastewater flow from manhole SHM132959 to manhole SMH130985 thus isolating the damaged segment of the sewer main from continuing to flow into the stream (see Exhibit 2 — Bypass Operation). This approach was Intended to contain wastewater flow and minimize the environmental impact on the surrounding land. Responding crews also employed debris pumps at the temporary containment site to recover untreated wastewater and any evidence of sewer debris 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. 5 During the restoration phase of the operation, repair crews replaced the damaged section of the sewer gravity main (see Exhibit 3 — Sewer Main Repair Effort). The repair was made possible by eliminating wastewater flow utilizing a sewer bypass (see Exhibit 3 — Sewer by-pass). Once the sewer gravity main was excavated, crews applied a 360' containment band replacing approximately 20 ft. of ductile iron pipe. Once the repair was completed, the sewer main was inspected through CCTV to verify the effectiveness of the repair. CCTV confirmed that no subsequent leaks or repair failures were noted. Crews restored the site by armoring the creek's bank with stable structural aggregates and restoring the ground surface with seed and straw. Sewer - contaminated soil was mechanically removed and the area surrounding the pipe break was cleaned with ample potable water to remove sewer traces from the surrounding area, and downstream conveyance. The area was then treated with an application of lime and restored with grass seed and straw. See Exhibit 4 — Site Restoration. 6 Exhibit 0 - Ske Retomdon The cost associated with the mitigation of this event (including the repair efforts) amounted to $47,208.83. The approximate cost to the Utility to have treated 3,6W gallons of wastewater would have been approximately $5.40. The City saved no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the spill. This section of the collection system Is located within a residential area. It provides sewer collection services to approximately 360 residences. This specific portion of the collection system has not experienced an SSO event within the last ten years. 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 5 — Press release. aabt;lrWAVa"W"to• s•abrr $~ loin 001-1 tar J*n nn ataPp atbgr"AMP"hwow1w gtpaaYdb■aa�raaaawaPrttaardatdS 1VVA r"Gr W8WFW tNC. 27rtf 1Mt�watMraWlNatMMwu�rfr�/+rMa.tlM.rlpemMptlasleat M etafanaMa asps b adp acid u�ar ea apfa biped s• sma a.lfw aidtM 1!t "MOM a- 929000.at416aronopfM�latb OwWa�atu►+tultaaeleawllu Haan aedAad NYM aP11. aitf� WMIt ttlf OpaLkb rN t0eal I�dhMegr i.OPPP1 as ea aaraa Ma n is aaeaabe"Ida "O -I I a V*M af+PP ftWW M@ PMtnt w gnurae..utr<,www�nrrrnrrwal�arwwe�nm.anrlce.e e..in irpairwraOttM►paawtYaaM�absowMhwMoraPaadMaAacladyN Ns aniraaaaary aapaYatadraapa a lids l0 EY wnlaUalaad talatad b era nad e~ W - bla asa>mradw adaaaesaaad Mlblparntllt P/agtaal to pgratl dr dladrar� d pgaaR, eMrlti fit. pOb dlapwa and atlrar bm a M4ftftbMvWaalrwa-- aaal>ebMankmawaatadman 06M apprapdab. if urea Nam XM" 11 boom a myattn, VWWAV aauaaa a+lll ad11oY am hawaA adwa. MlPattOtl+rra9M and MMkMWftWadpe rtooarda Vftelaalbabda L taf tMnY� �aaa4 aldtOYlY{MM alb MIn M� idO. PnflYttad So M dMtlrtpadYrb dra awip ayttta� Atl Olbi binq wdl OWaM dphtp tp MM wow I gtfa"9 aff 0 d PMk/dttad. 111a raeaMr.pwrana0rdrMOWW@PWft*= rMR%du ar Ptpaa. PbW W!ILl/S4M1e wP, YrnadkW • ►w mama rbfRMdW a00 ft*W V= as boom M Mnlry aatrar apm,p1Naavia ltttyt q..rw. 7NlaaaheraI - bra0"' OYMMAMM21 ChlOW1433MIG 09 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: Hushing acdivitles Repair CCFV ActWMN Inspections Activities 7/23/2020 8/8/2022 9/26/2017 There have been 77 inspections completed 7/24/2020 7/27/2022 7/26/2022 between 3/15/2018 and 0/29/2022 9/15/2020 9/21/2020 8/1/2022 1. Manhole In4ections-10 8/8/2022 2. sewer High Priority Inspections —67 5/25/2022 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. Incident Number B 202201201— 7/27/2022 — US 70-BR E., Garner, NC This spill was neither willful nor intentional; it resulted from an obstruction In the invert Impeding the normal flow of untreated wastewater. This obstruction resulted in approximately 4,800 gallons of untreated wastewater to reach White Oak Creek located within the White Oak Basin. See Exhibit 1— Debris in the manhole. On 07/27/2022, at approximately 1.45 PM, Raleigh Water staff responded to a sanitary sewer overflow emanating from a sewer manhole near the exit ramp of US HW 70 East, Garner, NC. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge, gaining control of the spill event by 3:57 PM on the same day. FAIM 1— Mbrb in the manhole Crews utilized hydraulic jetting and manual tools to remove the source of the blockage from the affecting asset thus restoring sewer flow. Upon further assessment it was observed that the cause of the blockage was a dislodged manhole step that laid at the bottom of the manhole invert causing a disruption of normal flow. It was also noted that although grease did not contribute to the spill, there was grease accumulated within the confines of downstream manholes. As a precaution a temporary spill containment site was emplaced downstream of the affected area to contain the flow of untreated wastewater and minimize the environmental impact to the surrounding land. The manholes found to have grease accumulation were serviced with hydraulic jetting and degreaser. Restoration of this spill event consisted of washing the land surrounding the affected asset. Sewer debris and solids were collected and disposed of accordingly. Crews utilized ample potable water to flush the affected area. This spill was contained without a significant environmental impact on the adjacent area and its natural resources. Visual inspection of the affected area and downstream waters confirmed that no fish kill, or unnecessary vegetative damage occurred. See exhibit 3 — Restoration Efforts. Fth4R3 -R"Umbn900 The cost associated with the mitigation of this event amounted to approximately $3,88S.92. The approximate cost to the Utility to have treated 4,800 gallons of wastewater would have been approximately $7.20. The City saved no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the spill. This section of the sanitary sewer collection system services a vast commercial complex housing several food - service establishments within the Gamer Service area. A F.O.G. consultation found only two restaurants (out of 29) not in compliance and subsequently were assessed notice of violations. There have been no additional issues associated with this section of the collection system since the last sewer event. This site remains an active maintenance spot. A press release notification associated with this event was requested to be published in the Raleigh News & Observer on July 28th, 2022 (see Exhibit 4 — Press Release). Before this event, maintenance records show that sections within the collection system were assessed in the last 10 years as follows: Flushing actiwides 11/12/2017 3/1/2oi8 11/28/2017 3/6/2018 11/30/2017 4/9/2o18 12/1/2017 7/19/2022 12/2/2017 Repair espections Activities 4/9/2018 There have been a Easement Inspections completed between 8/8/2018 and 10/27/2022 1. Manhole Inspections-1 2. Sewer High Prlority Inspections - 7 There have been 119 FOG assessments completed between 8/8/2018 and 10/27/2022 10 Eehm 4 - Press Release Re dpbplater Raeponde m a serdbry fewer" On Wednesday. July v 2m s♦ agnsrk m* 146 PM. A 1.10 Waur scan rapende I Is a sa "m server spa beam near the go ramp on U3 To t"hway E damn The spa Was per rs W efdebde aeamub M on a marrfrae The nepandhq "atoek so rsesoaable stops b slap and m ftale the spit roved as coon a they arrived The tbdh Caraloa Oepartnrena of Ew*onweMd Chu" CMaton of We* Reseumas hu been na99ed e1 ba spa A I ldh WNW etee oftisbad Me so of approodmafeb 3,57 Pm on On cams day n Is eafineaed fhat the spa detlumW a voWme of app udmd* 6.600 gdeee of w*s0W wsdewdw of whkb rougkgr 4 900 gaIons nuked Whits Oek Crack tAuft Pmbl %tM fhe Whoa flak 6asht Materafbn ettne atfsefsd sera tru eompbad on Theft J* 28 No a necesemy vspetrlhe damage or Oeh a has been a mrved allkd b ftu erase • ftWo taper has an agpmsfin edscal m and errferamml prapram to prawnitM dlaeRarge ar greaea, de3As, wipes, rags, dUpan and otMr knprWu meadau to the sewer evels. and to take 411faca,mi mcbm rvhsrr approprlete. n that hems mete N Into an eewsr eYstsm, (hay am muse a aptr whwh can have an edrene Inpest on rratar goofy and eudaeraer tftose rrla eeme ktto eentaaY rrRh Ito enee4rd tree. • wave, heaven wuta, end mlbt blew we fie only Items pwmMvd to to daWnped knto the easier ayatem. All amsr name wtf cause dmam la Ito saw sysbm and an nel pernrnfrd. • It you aapeft a /SCeesiw sewer nags or see sewer spi ft bon awww" or pates. pbasoeasIms$9s424s to report krmtad bly Pon more bftmedon about how Yea an help peerent eantbry sewer eptfe, pbeae vidl arblghno4svi MW— Thhaernfdo- abrsgralsdbyWG0$Pud0a2t Chaptert4.7.21&IC Sm I Incident Number 8 202201209 — 07/28/2022 — intenection of Major Slade Rd / Smithfeld Rd, Knightdale, NC This spill was neither willful nor intentional; it resulted from a failed 16' Polyvinyl Chloride Pipe force main. This asset failure led to a sewer spill of approximately 4,000 gallons of untreated wastewater to spill unto the land. Approximately 1,000 gallons reached an unnamed tributary within Poplar Basin (see exhibit 1— Area of Operation). On Thursday, July 2r, 2022, at approximately 6:45 AM, Raleigh Water Utility Responders were notified of wastewater emanating from the ground near the intersection of Major Slade Rd & Smithfield Rd, Knightdale, NC. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived, gaining control of the spill event by 3:08 PM, Utility Responders were able to contain and collect the wastewater by utilizing vacuum trucks and controlling wastewater flow from the nearest pump station, The natural topography downstream of the affected asset, and the excavation surrounding the affected force main served to partially contain approximately 3,000 gallons of untreated wastewater before it reached surface waters. See Exhibit 2 — Temporary containment. This spill was temporarily 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. 12 During the restoration phase of the operation, repair crews replaced the damaged section of force main (see Exhibit 3 - Damaged Pipe and Subsequent Repair). The repair was made possible by reducing wastewater flow at the nearby pump station. Once the force main was excavated, crews applied a 350' containment band replacing approximately several feet of ductile iron pipe. Once the repair was completed, the force main was pressurized to verify the effectiveness of the repair, and no subsequent leaks or repair failures were noted. Crews restored the site by backfilling the excavation with stable structural aggregates and restoring the pavement to travel conditions. Sewer contaminated soil was mechanically removed and the area surrounding the pipe break was cleaned with ample potable waterto remove sewer traces from the surrounding area, and downstream conveyance. See Exhibit 4 — Site Restoration. 13 The cost associated with the mitigation of this event (including the repair efforts) amounted to $18,809.16. The approximate cost to the Utility to have treated 4,000 gallons of wastewater would have been approximately $6.00. The City saved no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of sewage had no spill occurred• Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the spill. 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 S — Press Release. Sa Exhibit S Ilr+w rrr rrr.lu r. r.rr, /...r yw wrrr, rrfl.� rr�Msara wrrrw .Awrwr.r,IrrrrwrrWA�.wrawl�lf iYIY{ r.r,Ar r,rr lrwwrwllr.l.twwirw n+ rrwryl/lw rwwr/w IIIIrr.yrrrl0"W"M W www.n.1 r14'rCrinEYrl.rMMwr.r�lOWI.CMiY.r MrrMrrrl fir rw rMN M r lrrt Ili jiw�4 71M �MM W / M 10rllM^.rMMM r r Yr. �l, rr.r.i.frM r��1M4M.wrw.fw.r/.iMYl- lamer IrlrrrrrrrMMMr/R l allM.www.M.M...MF �lrrrtMrrrrrrrrrirgarww Arwrirrw. rrq^�lw MRrr.w1lrrt.�M�.w..w..wMl�Jrr Jl lrp rrrrrrrrw,.IrwwylwMt�r llNwr/ir/rM. r.lw . rrlMtarrrrM�rMlr lrrrr.rawirwrw�r.r ,wlwr�wM�lr.irr.ww� �.r.r� rp�A..+iiM r rr w.w qw. � r rr..rr.rlr.Mr .rw.Ml+r.lr..ra.rr rr.rrr rrwrr►rrw .M..Mll+ri 1rY..rMwrri,rlw�rr�ry W rYr/Irr�1rM M.a..rp.lrrMrr/www Iwn Iw.wN►wrrNtwrww r.wrrprrurl. I.M.yI/ rM M .•r• q� Y.rY.IY M r.l. rr,.1 M r.•1.r.YaY�wYf}.�� • Ilw.�ll.�nwrw.M.rr�lrwrrglYl�.lw wr.rr r,rlw rrr. � N MlFilli r Awl Yrw iMr. . IMr.rrM�W.r.iir.rr W My/rrrMrl�• yr►,W.MIr I.Yylrp.wr�. r,.Fwwr..wrw.wlll>L.�*� arr.+atlsR r There is no history of infrastructure failure with this asset prior to this sewer event. There have been no additional Issues associated with this section of the collection system since the last sewer event. 14 Summary The Sewer Maintenance Division of Raleigh Water strives to develop initiatives that Improve operational reliability to meet customer expectations and meet or exceed the Water Quality Collection System permit requirements. Our operations are focused on continual improvement, the prevention of pollution, and increased environmental performance efficiency. This endeavor is significantly noted as the Division operates an ISO Certified Environmental Management System governed by the 14001-2015 Standards. As part of these initiatives, the Division operates a comprehensive reactive and preventative maintenance program whose goal is to maintain over 2,566 miles of sanitary sewer pipe and minimize the accidental release of untreated wastewater. Since July 2022 (Fiscal Year 2023), the Utility has assessed approximately 66.58111 miles of gravity sewer mains by flushing with hydraulic jetting, conducting CCTV assessments, and performing repair operations, easement maintenance, and inspections. The fiscal year-to-date cost of these operations amounts to $ 885,577.46121, approximately .06% of the Division's annual operating budget. The 14,000 gallons of untreated wastewater spills Identified in this letter cost the Utility approximately $75,112.26. to mitigate. The City's cost of sewer treatment per gallon is $.0015131. At this rate, It would have cost the City $21.00 to treat the entire volume of sewer spilled. The City saved no money from these spills. The costs of mitigation well exceeded the cost of treating the volume of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater sewage volume created by these spills. This fiscal comparison shows the City's commitment to environmental protection, sparing no cost regardless of the spill event's severity and complexity. The City continues to demonstrate due diligence in environmental performance by allocating the necessary resources to a spill event irrespective of the associated cost. This effort is noted In the City's low SSO performance rate of 0.65 total SSO rate 14' per 100 miles of pipe, compared to the Southeastern Region of the US, of 7.0 spills per 200 miles of line. In the previous Fiscal year 22 total performance miles assessed were 417.34 Miles at a cost of $ 2,829,598.09. (11$6.58 m[les repmMts M025%of the sanitary Sewer tollecHOn system 121 Auoclated operatlonal cost year to date for FY2023 011 MIM UNWIFM UnaartA to cop CM 13%1&n 21M 11a,2tlD.aa flepalr 1.11a 0.25 i 052.20M "Oft214 nu 41.77 S 12Mt'1.Sa Toth. 221,stfaIFtJsmMILO Turdaortofilu lomtoDate f ftiS MAG 131 S.0015Is based on the annual water trealrnpn operating tot compounded by the total treated effkwt. 141 The current SSO Rate for FY 23 Is 0.6S 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. 15 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 httos.11raleiahnc.novisewer-maintgnan; The City continues its monetary reward program or bounty program, which pays out fifty ($50) dollars to any citizen that observes and reports an SSO or conditions that may cause a spill event. This program has been advertised via printed material, a television advertisement campaign, and graphic design "wraps" on Sewer Maintenance vehicles. These graphics on our vehicles function as mobile billboards spreading our message of prevention and offering contact information throughout the service area each day. This program was developed hoping that citizens and customers would become more aware of the signs of an emerging system problem causing the SSO occurrence and become proactive in helping the City prevent these occurrences. Additionally, all customers are notified via their water and sewer utility bills not to discharge improper materials into the sanitary sewer mains. The City also circulates information regarding the discharge of grease into the sewer system and the effects of such deposits. Whenever possible, and upon investigating the root cause of a spill event, PUD Code Enforcement officers develop and send registered informational letters about the spill event to the customer base serviced by the line where the SSO has occurred. This is done to educate our customers on the proper use of sanitary sewers to prevent the disposal of non-flushable items and items harmful to the continuous operation of the collections system. On behalf of the City of Raleigh, I am requesting that the NOV 2022-NOI.0236 issued for the month of July 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 Vessle, Sewer Maintenance Superintendent (919) 996-2312, or Carlos M. Perez, ORC Assistance Superintendent 919.996 5929. Carlos M Perez, ORC-NC WPCSOCC # 1003875 Assistance Superintendent, Sewer Maintenance Division City of Raleigh, Public Utilities Department P.O. Box 590 Raleigh, NC 27602-0590 919-996-5929 office 919-278-6020 cell Card .eetezcamachoL@raieiithnc_Cov 16 ROY COOPER CWAM or ELIZABETH S. BISER skrmy RICHARD E R4GEPAJR. LYnvnr Whit Wheeler, Assistant Director City of Raleigh PO Box 590 Raleigh, NC 27602-0590 WORD August 18, 2022 SUBJECT: NOTICE OF VIOLATION & INTENT TO MUE CURL PENALTY Traddng No.: NOV-2022-DV 0236 Sanitary Sewer Overflows - July 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 Reports submitted by City of Raleigh. The Divislon'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 pnMding the city of Raleigh an opportunity to provide evidence and justification as to why the City of Raleigh should not be assessed a civil penalty for the violations that are summarized below: TOW Vol Total Surface Incident Start Duration Vol Water Number Date (Mina) location Cause (Gals) (Gals) DWR Action 202201041 7/4/2022 202201195 7/26/2022 120 7703 Oak Marsh Dr, Pipe Failure (Break) Raleigh, NC, 27616 214 6321 Winter Spring Dr, Pipe Failure (Break) Wake Forest, NC, 27587 202201201 7/27/2022 132 US-70-BR E, Garner, NC, Other 27529 1,600 undetermined Notice of violation 3,600 3,600 Notice of Violation - Notice of Intent 4,= undetermined Notice of violation - Notice of intent MerlaCrroln�fi�wtawifdYen4a��lt�r I �MYo�dMhevtnaran ...� R�NgbRwen10111a I l�ODlrwtrG�Me I >Rir0l�liaeh�a��o� fnddent 14art Duration Number Dift (Mims) MR Cousin 202201208 7/28/2022 S03 1600-15S4 Major Slade Pipe Failure (Break) Rd, Knotaale, NC, 2754S Tole! Vol Total Surface Vol Warder (Gals) (Gab) DWR Action 4,000 1,000 Moe of Violation rhis Notice of Violation / Notice of Intent to Enfiorace (NOV/NOI) is being Issued for the noted violation. Pursuant 3o G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the teams, conditions, or requirements of any xwmt issued pursuant to G.S. 143-215.1. rhis 011kS requests dM you respond to this Noft% In writing, within 10 bu dness days of its receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other actions taken to prevent the recurrence of similar situations. The response to this correspondence will be :onsidered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface +eaters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors :onsidered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of vctifying the damage, whether the spill was intentional and whether money was saved by non-compliance. If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section In :he Raleigh Regional Office at 919-791-4200 or via email at mitch.hayes@nodenr.gov. Sincerely, Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ :c: Raleigh Regional Office - WQS Rle Larserfiche +wta .. o-co �. O QF 1C� USE ROY COOPER �. Ir To ELJiJIBE?NS. BI5ER �� �� ° s I�"t1rbMaUA'e'o ••' ❑❑ : s� . Q FLhen n - o (Wetr-o Poatmpk RIICHARD E. ROGERs, JR, NORTH CAROLR a p ftW$*11KI 6,_. — HUG D&KIW Em l" Qw C3 ❑ A" aWman Antricre Odmy t _ -D , WHET WHEELER, ASST DIRECTOR Pi I CITY OF RALMGH fll /O BOX 590 0 671 JIALEIGH, NC 17602~ WQ: ttOV i Intent to Iuue Clrtl FerE/N0V-2022-DV-023S/9AN SEWER Q Sfise/ DtiERILOWS—JULY20211VermiteWQCS00002(RAIEIGMCOILECnON - August 18, 20 rti %%s-EM/WAKE Net M0316000D IOWNS MAu23/2022 Whit Wheeler, Assistant Director t City of Raleigh PO Box 590 Raleigh, NC 27602-0590 SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY Tracking No.: NOV-2022-DV-0236 Sanitary Sewer Overflows - July 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 Reports submitted by City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition I (2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so that there Is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S. 143-215.1. The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as to why the City of Raleigh should not be assessed a civil penalty for the violations that are summarized below: Total Vol Total Surface Incident Start Duration Vol Water Number Date (Mina) Location Cause (Gals) (Gala) DWR Action 202201041 7/4/2022 120 7703 Oak Marsh Dr, Pipe Failure (Break) 1,600 undetermined Notice of Violation Raleigh, NC, 27616 202201195 7/2612022 214 6321 Winter Spring Dr, Pipe Failure (Break) 3,600 3,600 Notice of Violation - Wake Forest, NC, Notice of Intent 27587 202201201 7/27/2022 132 US-70-BR E, Gamer, NC, Other 4,800 undetermined Notice of Violation - T ^y 27529 Notice of Intent NathC�a/»Deprtr+MdErnko�MdOe6tf DtrYatlMMerMuwm. tfilk it OHbe 1 3M tttiFelT plet I te4yL Nero E'ieeiteztege ep.7eL,NoO 9/23(22, 4 36 PM USPS.com® - USPS Tracking® Results USPS Tracking® Tracking Number. 70203160000041090089 Copy Add to Informed Delivery (httpsJ/Informeddellvery.usps.com/) FAOs > Remove X Latest Update Your item was picked up at a postal facility at 8:42 am on September 19, 2022 in RALEIGH, NC 27602. Delivered Delivered, Individual Picked Up at Postal Facility RALEIGH, NC 27602 September 19, 2022, 8:42 am Available for Pickup RALEIGH, NC 27602 September 16, 2022, 9:34 am Arrived at Post Office RALEIGH, NC 27602 September 16, 2022, 9:31 am Departed USPS Regional Facility RALEIGH NC DISTRIBUTION CENTER September 16, 2022, 1:11 am In Transit to Next Facility September 2, 2022 Arrived at USPS Regional Facility RALEIGH NC DISTRIBUTION CENTER August 28, 2022, 8:27 am ro M 0. Cr W n httpsJRools.usps-oonVgorrrackConfirmAcbon7gtc tLebels1=70203160000041090089 112 State of North Carolina Department of Environment and Natural Resources Division of Water Resources Collection System Sanitary Sewer Overflow Reporting Form 0a of War Rao+ines Form CS-SSO PART I: This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the sanitary sewer overflow (SSO). Permit Number: WQCS00002 (WQCS# if active, otherwise use WQCSD#) Facility: Raleigh Collection System Incident #: 202201195 Owner: City of Raleigh City: Raleigh Source of SSO (check applicable): County: Wake Region: Raleigh [Z Sanitary Sewer ❑ Pump Station I 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): 6321 Winter Spring Dr, Wake Forest, NC, 27587 Manhole #: Latitude (Decimal Degrees): Longitude (Decimal Degrees): Incident Started Dt: 07/26/2022 Time: 10:41-am Incident End Dt: 07/26/2022 Time: 02:15 pm (mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy (hh:mm AMIPM) Estimated Volume of the SSO: 3,600 gallons Estimated Duration (Round to nearest hour): 3:34 hours Describe how the volume was determined: Weather conditions during the SSO event: clear/dry Did SSO reach surface waters? [1 Yes No ❑ Unknown Volume reaching surface waters (gals): 3600 Surface water name: Unnamed Tributary to4n*6�ek A e, e,4 ,i `„ 0 -, le - Did the SSO result in a fish kill? [] Yes RINo ❑ Unknown If Yes, what is the estimated number of fish killed? SPECIFIC cause(s) of the SSO: 0 Pipe Failure (Break) 24 hour verbal notification (name of person contacted ): Alys K Hannum 0 DWR E] Emergency Mgmt Date (mm-dd-yyy): 07/27/2022 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. 143-215.1 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 II: ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I (In the check boxes below, NA = Not Applicable and NE = Not Evaluated) A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS Pipe Failure (Break) Pipe size (inches) 811 What is the pipe material? PVC What is the approximate age of line/pipe? (years old) Unknown Is this a gravity line? Is this a force main line? Is the line a "High Priority" line? Last inspection date and findings 02/23/2022 Glen, Justin C none If a force main then, Was the break on the force main veritical? Was the break on the force main horizantal? Was the leak at the joint due to gasket failure? Was the leak at the joint due to split bell? 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, W Yes No ❑ NA NE Yes [Z No NA ❑ NE W Yes ❑ No [] NA NE Yes W No ❑ NA ❑ NE Yes ❑ No W NA ❑ NE ❑ Yes ❑ No 0 NA ❑ NE Yes No 0 NA ❑ NE CS-SSO Form Page: 2 Does the line receive flow from a force main immediately upstream of the failed secti. C) Yes W No ❑ NA ❑ NE of pipe? If yes, what measures are taken to control the hydrogen sulfide production? NA When was the line last inspected or videoed? 5/25/2022 A. Guerra If line collapsed, what is the condition of the line up and down stream of the failure? Per video the remaining sections of the main are in good condition What type of repair was made? The broken section of the ravi main was removed and replaced with a new section Is the repair temporary or permanent? permanent If temporary, when is the permanent repair planned? NA Have there been other failures of this line in the past five years? If so, then describe NA System Visitation ORC Backup Name: Carlos Perez Cert# 1003875 Date visited: 07/26/2022 Time visited: 01:40PM How was the SSO remediated (i.e. Stopped and cleaned up)? Yes [7 No ❑ NA ❑ NE W Yes Yes Crews arrived onsite at armroximately 10:41AM and witnessed the affected assest SGMN124867 surchargina at the rate 15gpm. The main was flushed and CCTV crews performed an evaluation and the SSO was determined to be a break in i sewer main. A tem ora containment site was established 2:00 pm on 437 Boardwalk Dr. utilizing a 4 gumpandstr� to prevent any untreated wastewater from reaching further down stream utilizing SMH100221 to reintroduce back into the sewers stem. A bypass plug was established and started 0,215 om diverting sewer from SMH132959 to SMH130985. Sewer maintenance crews started a hydrant at 2:30 on the intersection of Winter Sorina Dr & Silent Brook Rd to assist wi the flushin-q of the creek. Crews are still on site flushing the creek and easement crews are working diligently to gain access to the easement for the re air crews. Once crews ained access the repair crews removed the damacled section a the main and made a Rermanent repair of the gravity main. CS-SSO Form Page: 3 As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the best of my knowledge. Person submitting claim: Carlos Manuel Perez Date: 07/29/22 02:30 pm Signature: Title: Telephone Number: 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: 4 State of North Carolina Department of Environment and Natural Resources DWR Division of Water Resources Collection System Sanitary Sewer Overflow Reporting Form DlrWon of Wa#er Resources Form CS-SSO PART I: This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the sanitary sewer overflow (SSO). Permit Number: WQCS00002 (WQCS# if active, otherwise use WQCSD#) Facility: Raleigh Collection System Incident #: 202201201 Owner: City of Raleigh City: Raleigh County: Wake Region: Raleigh Source of SSO (check applicable): 0 Sanitary Sewer ❑ Pump Station I 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): US-70-BR E, Garner, NC, 27529 Manhole #: 117586 Latitude (Decimal Degrees): Longitude (Decimal Degrees): Incident Started Dt: 07/27/2022 Time: 1:45 pm Incident End Dt: 07/27/2022 Time: 03:57 pm (mm-dd-yyyy) (hh:mm AM/PM) (mm-d -yyyy) (hh:mm AM/PM) Estimated Volume of the SSO: 4,800 gallons Estimated Duration (Round to nearest hour): 2:12 hours Describe how the volume was determined: Weather conditions during the SSO event: clear/dry Did SSO reach surface waters? ❑ Yes []No 0 Unknown Volume reaching surface waters (gals): Surface water name: Did the SSO result in a fish kill? ❑ Yes DNo ❑ Unknown if Yes, what is the estimated number of fish killed? SPECIFIC cause(s) of the SSO: 0 Other (Please explai 24 hour verbal notification (name of person contacted ): Curtis R Tyree 0 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 07/28/2022 Time (hh:mm AM/PM): 09:25:00 am If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped. Per G.S. 143-215.1 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 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 Other (Please explain in Part Ill Describe: While attempting to break the blockage in SGMN138588 crews utilized the retriever to remove a broken step from blockin the flow at the invert. once the step and surrounding debris was removed and the MH cleaned the flow was fully restored Were adequate equipment and resources available to fix the problem? V Yes No ❑ NA 0 NE If Yes, explain: A damaaed step that had fallen in the sewer manhole was the contributina factor to this SSO. Once the step was removes the flow was restored. If the problem could not be immediately repaired, what actions were taken to lessen the impact of the SSO? This particular sewer gravity main has been added to a high priority checklist to ensure more frequent investigations and flushing operations Comments: NA System Visitation ORC Yes Backup r Yes Name: Carlos Perez Cert# 1003875 Date visited: 7/27/2022 Time visited: 03:00PM How was the SSO remediated (i.e. Stopped and cleaned up)? Sewer maintenance arrived on site and attempted to break the blockage from SMH115484. Crews observed SMH117586 surcharging untreated wastewater at a rate of 50gpm. The responding staff took all reasonable steps to stop the blockage Crews attempted utilized hydraulic netting to remove the source of the blockage. The blockage was deemed a asset failun due to a broken step that had became dislodged and became wedged in the invert. Once the step was removed and the I cleaned -thoroughly the flow was restored. Clean up consisted of the sewer maintenance crews as well as easement crew using a skid steer to remove the contaminated soil and apply lime, seed, and straw to the affected area. CS-SSO Form Page: 2 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: Signature: Telephone Number: Carlos Manuel Perez Date: 08/01/22 12:00 pm Title: 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). 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Events Reg. Activities AOfliations Permit YQCS00002 Version: �.0 Status: Permit Type: Collection system management and operation Permit Class ification:Individual Primary Related Permit Program Category. Non -discharge Admin Region: Raleigh Facility. Raleigh Collection System getails.:. County: .wake Owner. City of Raleigh Dgtas... ProjectType: Renewal — Dates -- Issued: 12115J2015 Odg Issued: 102272005 Effective: 02/01/2016 Statutory: 0117MI15 Expire: 0113112024 Inactive: SOC: Details... Last Updated By: bimsprod.cron ❑✓ [Major Permit ❑ Has Subsurface Drams Irat O New Farm Q Existing Farm Farm #: ❑ Innovative AvalI. Acres: ❑ Rainbreaker Device ❑ OIC Present Last Updated On: 112016 1:33 AM