WQCS00002_DV-2023-0033_20230301

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7020 3160 0000 4115 6211
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
March 01, 2023
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(])
and Collection System Permit No. WQCS00002
City of Raleigh
Raleigh Collection System
Case No. DV-2023-0033
Wake County
Dear Mr. Wheeler:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $220.72 ($125.00 civil penalty
$95.72 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).
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Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, 1, Scott
Vinson, Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against City of
Raleigh:
125.00 For 1 of the 5 violations of Collection System Permit No. WQCS00002 and G.S. 143-215. l (a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
125.00 TOTAL CIVIL PENALTY
95.72 Enforcement Costs
220.72 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty 1 have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document_ Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 14313-282.1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty 001 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 hearim with the Office of Administrative Heariny-s:
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
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,
�cott 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-2023-0033 County: Wake
Assessed Party: City of Raleigh
Permit No.: WQCS00002 Amount Assessed: $220.72
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 f thtre 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-2023-0033
Having been assessed civil penalties totaling $220.72 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated March 01, 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

PERMIT NO: WQCS00002
FACILITY: Raleigh Collection System
Other Violations
INCIDENT
NUMBER
VIOLATION
DATE VIOLATION TYPE
ATTACHMENT A
City of Raleigh
CASE NUMBER: DV-2023-0033
VIOLATION DESCRIPTION
REGION: Raleigh
COUNTY: Wake
TOTALVOLUME
(GALLONS)
PENALTY
AMOUNT
202201249 8/4/2022 CSOISSO(Sewer Overflow)
Discharge without valid permit
1,575
$0.00
202201270 8/8/2022 CSOISSO(Sewer Overflow)
Discharge without valid permit
3,200
$0.00
202201271 8/9/2022 CSOISSO(Sewer Overflow)
Discharge without valid permit
3,150
$125.00
202201326 8/20/2022 CSOISSO(Sewer Overflow)
Discharge without valid permit
1,920
$0.00
202201373 8/30/2022 CSOISSO(Sewer Overflow) Discharge without valid permit 371 $0.00

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleisih
Facility Name: Raleigh Collection System
Permit Number: WOCS00002
County: Wake
Case Number: DV-2023-0033 Incident No. 202201271
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
A total of 3,150 gallons of sewage overflowed from a manhole due to grease blockage. 2,850 gallons reached Crabtree
Creek a class C; NSW in the Neuse River Basin. Nutrients and pathogens to surface waters. Water quality standard
violations.
2) The duration and gravity of the violation;
The SSO started on 08.09.2023 at 02:07 pm and ended the same day at 03: 10 pm.
3) The effect on ground or surface water quantity or quality or on air quality;
Nutrients and pathogens to surface waters which can cause stream standard violations.
4) The cost of rectifying the damage;
The cost of rectifying the damage amounted to $7,023.05.
5) The amount of money saved by noncompliance;
The approximate costs to treat 3,150 gallons of wastewater would have been $4.72.
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 five enforcement cases within the past 12 months.
8) The cost to the State of the enforcement procedures.
$95.72
Date /-Y,--Water
Scott Vinson, Regional Supervisor
Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

!� .1 / � NC De% of Envii�menull QuaHW
0 0OCT 14 2022
Raleigh Water pawah R40nd Offilm
October 14th, 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-0273
Sanitary Sewer Overflows — August 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-0273) received on September 2811, 2022. This document contains the narrative
regarding pending violation actions of (5) Sanitary Sewer Overflow (SSO) events, reported on the month of
August 2022 within the City of Raleigh Collections System III- 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 S50s 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:
Ia.1 The SSO was caused by severe natural conditions; there were no feasible atternahves to the SSO, 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 proviiion is not
satisfied it, in the exercise of reasonable engineer ingjudgment, the Permittee should have ,nstalled auxiliary or additional collections system components. wastewater
retention or treatment facilities, adequate back-up equipment or should have reduced inflow and infiltration, or
1b-1 The SSO was exceptional, unintentional, temporary, and caused by factors bryond the reasonable control of the Permittee: the SSO cou,d not have been prevented
by the exercise of reasonable control, such as proper management, operation, and maintenance; adequate treatment or collection facilities or components I e g,
adequately enlarging treatment of collection facilities to avcommodate growth or adequately controlling and preventing infiltration and inflow); preventative
maintenance; or installation of adequate back-up equipment;"

Incident Number 4 202201249 — 8/04/2022 — 5500 Crossfleld Dr., Raleigh
This spill was neither willful nor intentional, it was the result of root intrusion, which blocked a portion of an 8-in
gravity sewer main. The root intrusion led to a sewer spill of approximately 1,575 gallons of untreated
wastewater in which roughly 975 gallons reached a nearby storm drain in the Sycamore Creek Basin (see Exhibit
1— Area of Operation)
Exhibit L - Area of Operation
On 08/04/2022, at approximately 5:48 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH110b44) located near 5500 Crossfleld Dr.,
Raleigh IBC. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge,
gaining control of the spill event by 07:33 PM on the same day. Crews utilized hydraulic jetting to remove the
source of the blockage within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
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. See Exhibit 2
—Site Restoration.
2

A follow up CCTV assessment did not identify any infrastructure deficiencies that would indicate root intrusion
through a gap, crack or opening. Subsequently the sewer main was further cleaned to remove potential root
intrusion. The CCTV assessment did not identify any other deficiencies requiring further maintenance.
The cost associated with the mitigation of this event amounted to $1,203.92. The approximate cost to the Utility
to have treated 1,575 gallons of wastewater would have been approximately $2.36. 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 100 properties surrounding the spill event (see Exhibit 3- Zone of Influence). This area has been
placed on routine maintenance for chemical root control.
Exhibit 3• Zone of Influence
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.

MIbit 6 — press release
Raaigh Water Respads to a Ssnitwy Sewer Split
On Thursday August 4. 2022 at approdrsatehy 6 49 PM Rdsigh Water staff
responded to a smeary ewer 00 located at 6600 Cmsdold Way 11"gh NC The
nspardnng staff took of tononelha steps to atop and ht09- th o st0s krW as
soon as OM arrived. The North Cardin Oepartrnent of Enw rnra Quslity
Division d Water Rosanas has been rw0rd of de spR
RAWO Water stall corratrud the spill at ape m nla* 133 PM on the awn
day it is es*nated that due spit dls bwW a vokana of approA"&e 1 676 gallons of
uMnatad watawater In which apprrxknotafy 976 gh lwo read W a no" storm drain
in the Sycamore Creek basin Realoratkn kR this evard has bean car.-1.r..i Then
was hw observed 60 hit of ur mensery vagetadvo damage resulting from thh server
evert
Raleigh Wear has an aggressive education and enfacen ni progrun to
prawhtt due dlsdwp of groves, debris, vripW rags, diapers aid other
improper wetsrbb In the eernr aptern end to tab utforceffWa action
where app atAft. If these kerns make It Into the server sysutn "may
cause a split which can ben an adverse Impact an watar quality and
ardurger those who care Into contecl wW de dlected areas,
Water. buman sees". end twist dseus an the only kerns pumltsw to be
discharged Into tin eswer system AN other kerns will cause damage to the
sewer sysam and we no permitted.
If you erperkwo erohsssln MW womb or on aawer "Wing from
manhobs or Pips, please Cog 919.996J243 to reponr Irrrsdptehy.
For mot Idormatim about how you an help prevant sanitary sewer
Willa. Oases vislc rWlghrw.gov-ow.
This rheas please Is reguIred by NCf3S Article 21 Chapter 143 215 1 C
#00
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:
Easement
Flushing
activities
CCTV Activities
Maintenance
Activities
3/9/2017
11/30/2017
9/14/2017
2/2/2018
3/10/2017
12/1/2017
10/2/2017
8/9/2018
4/4/2017
12/5/2017
10/11/201
6/22/2020
5/16/2017
12/7/2017
10/17/201
6/15/2017
12/11/2017
11/30/201
6/16/2027
2/23/2018
3/17/2018
6/20/2017
4/21/2022
3/1/2020
8/14/2017
08/5/2022
3/8/2021
08/27/2022
Repair Activities Inspections Activities
9/27/2017 313 sewer asset
inspections since 2018
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, CCTV assessment, and chemical root control application.
4

Incident Number # 202201270 — 8/8/2022 — 3101 Compatible Way, Raleigh, NC
This spill was neither willful nor intentional; it resulted from a private land -clearing activity in which sections of
the manhole top were mechanically dislodged causing damage to the manhole cover. A broken section of the
manhole cover was found inside the sewer manhole which created a blockage that disrupted normal
wastewater flow within a portion of an 8-inch Polyvinyl Chloride gravity sewer main (see Exhibit 1— Broken
manhole cover). The blockage led to a sewer spill of approximately 3,200 gallons of untreated wastewater in
which approximately 3,000 gallons reached a stormwater channel never reaching surface waters. Approximately
200 gallons remain on the ground. The spill flow was contained within the stormwater channel at approximately
1100 ft. before it reached an unnamed tributary of Walnut Basin. See Exhibit 2 - Area of Operation.
Exhibit 1— Broken manhole cover Exhibit 2 — Area of Operation
On 08/08/2022, at approximately 2:32 PM, Raleigh Water staff were notified of a manhole spilling over. Utility
responders were immediately summoned to respond and mitigate the spill. The responding staff took all
reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived, gaining control of the
spill event by 4:40 PM on the same day. Utility Responders utilized hydraulic jetting and manual debris removal
tools to rid the source of the blockage within the affecting asset, thus restoring sewer flow. See Exhibit 3 — Spill
Mitigation Efforts.

Exhibit 9 - Spill Mftatlon Efforts,
Containment and collection of this spill event consisted of employing a temporary spill containment site
downstream of the affected area. This approach was intended to contain sewer flow and minimize the
environmental impact on the surrounding land. Responding crews initiated the collection of untreated
wastewater from the containment site to re -introduced it to the collection system downstream. This spill was
contained without a significant environmental impact on the adjacent area and its natural resources.
During the restoration phase of the operation, crews utilized several thousand gallons of potable water to assist
in washing the creek and remove all evidence of sewer downstream of the affected area. The area around the
manhole was cleared of debris, treated with an application of lime, and restored with grass seed and straw.
Repair crews repaired and replaced the damaged section of the manhole with a new ring and cover (see Exhibit
4 — Repair and restoration efforts).
Exhibit 4 , Repair and restoration efforts

A follow-up CCTV investigation (conducted after the SSO mitigation and repair efforts) did not find any further
evidence of infrastructure deficiencies that would have influenced the SSO. The broken manhole cover was
identified as the root cause of this SSO. Additionally, the CCTV investigation identified a buried manhole
downstream of the spill site. As a result of this finding, Crews were able to raise the manhole to adequate
engineering specifications (see Exhibit 5 — Manhole Raising Efforts), Visual inspection of the affected area and
downstream waters confirmed no fish kill or unnecessary vegetative damage occurred.
Exhibit S— Manhole Raising Efforts
The cost associated with the mitigation of this event amounted to $7,437.88. The approximate cost to the Utility
to have treated 3,200 gallons of untreated wastewater would have been approximately $4.80. The City saved no
money from this spill. The costs for cleanup exceeded the cost of treating the volume of sewage had no spill
occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the
spill and the cost of potable water used to mitigate the event.
This section of the collection system is located downstream of a residential area. It provides sewer collection
services to a multiunit residential complex (see Exhibit 6. Zone of Influence). The fast recorded SSO for this
section of the Collection system was attributed to grease accumulation on 06/26/2019 (incident number
201901112).
7

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 7 — Press release.
Exhibit 7 — Prus relem
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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
4/2/2018
4/18/2018
4/19/2018
5/9/2018
4/11/2019
6/26/2019
8/9/2022
CCTV Activities Repair ActiviNv s
8/9/2022 8/9/2022
inspections Activities
2/28/2018
6/24/2022
4/17/2018
1/19/2021
8/20/2018
1/15/2021
2/28/2019
11/24/2021
7/30/2019
2/4/2022
2/20/2020
9/6/2022
8/13/2020
8

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 further sewer main cleaning, CCTV
assessment, and chemical -root control application. Furthermore, the assets associated with this portion of the
collection system have been added to the Hot Spot Management program and have been identified for
recurrent assessment every 30 days. No further issues have occurred since this SSO event.
Finally, we consider this SSO was exceptional, unintentional, temporary, and caused by factors beyond the
reasonable control of Raleigh Water. The SSO could not have been prevented by the exercise of reasonable
control, such as proper management, operation, and maintenance; adequate treatment or collection facilities or
components; preventative maintenance; or installation of adequate back-up equipment.

Incident Number # 202201271— 8/9/2022 — 4609 Oak Park Rd., Raleigh NC
This spill was neither willful nor intentional, It resulted from a grease buildup, restricting the sewer flow within
a section of 8-inch polyvinyl chloride (PVC) pipe gravity sewer main This build-up led to a sewer spill of
approximately 6,000 gallons of untreated wastewater remaining on the ground and not reaching the surface
waters of the state. (See Exhibit 1— Area of Operation)
On 08/09/2022, at approximately 2:07 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (SMH125400) located near 4609 Oak Park Rd., 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 3:10 PM on the same day, Crews utilized hydraulic jetting to remove the source of the
blockage within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary containment site at
approximately 3,300 ft downstream of the affected asset. 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.
10

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. The area around the manhole and containment area was
cleared of debris, treated with an application of lime, and restored with grass seed and straw.
A follow-up CCTV assessment was conducted on 08/10/2022 to identify the root cause of the SSO. Additional
flushing of sewer gravity mains upstream and downstream of the affected asset was completed on 09/08/2022.
This hydraulic flushing did not identify any major issues with the main.
The cost associated with the mitigation of this event amounted to $7,023.05. The approximate cost to the Utility
to have treated 3,1S1 gallons of wastewater would have been approximately $4.72. 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 downstream of a residential area. It provides sewer collection
services to several properties upstream of the spill event (see Exhibit 2- Zone of Influence). This specific portion
of the collection system experienced a grease -related SSO event on 09/15/2019 (incident # 201901533). This
area has been placed under routine maintenance and several assets have been placed in the Hot Spot
Management Program for continued maintenance and assessment.
Exhibit 2• Zone of Influence
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 3 —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.
Exhibit 3— Press Release
Raleloh Wear Rosponds to a Sanitary Sewer SpSI
REWNDER: Keep All Grease and Rags Out of the Shand
Solitary Sewer System
On Tlwfdq Afpaats 2027 aappoiwnafwy 2 OTpn 11wso wow sw wfn
amadM a AWWV"M Na M.+cxM M rite Oak Pick tea.
auupn eC WRY III 1 kMnatdd wt sM ww♦r lice naWlrq iwr pawlf
and rape "oft Pa awdtwy 7frf17r00 TM rwandlp 00 krf M 7MawWA
I%" b Moo a" Mao" to was M"a a fM a Wry wood. Tkf Ykre emahm
QayMOW d [MwphFHI QMW 0 r of WM ReoAm ka afM n~ 1
air dew
R~WWw sWon qd IM WKUpf afrtf awl cmUmaa Ric wO f1
•ppFaaMky LlppwMor fdAf by rkwwaMff dlalaw 1pa�Wpa!•
vdkrfa at golmdwalaM 3. ISO gMMa of Li lud rWwwww Is dlkxa 3W Pam
dldafdrarxfi+4q wfl ndnf if yfafd ffMram RfwwfOM YOI aIw nnlr s
Wa ow" Tips w o of awaiffa %a tdf W wvygkwy yAd awn of Wap
"a" rdrl"now ndM
• arfYylfdartaWMaaeauapf adKMMardfflwafrlfld pafara�l r.
WW W dr dlfarwad M W"10%dfidf. W", p• ra6WM frd fern
dlyldpw rrdflkda M er dfwdr room aM IDtadf fWleaff WwR aa9er
wrM wpeeAl+d. aww aaWa Ww r klm tlW wwd arwrW. Mr R�fr
Mft a drip %*Aci afr rf,f M adww rydat Y woM p1Ud aid
flNirpRarM fdr Barr Wr aarWN wpl tY aRrdAad Pole.
wa1u, IIIIWan rwar, W fM1N daM an 1if 01d1 Yldrla pftWlafd b a
dberwaad krd rlf Mwdf fraWlr. AN ddlW IllWr will w=dwr 1p to *ANlaft ayMf W and M1 ral pMIllraad.
• e1rollfwflWlffJafawffafwafMlMEaMafr�fffpalrerdrl
fnalYla4a p plpn, rwweMMSalF724t w taprt MrrAfMr.
Fer rare kdfdWr = Mrr1 haw rm aaa M4 pwvm ffflrYy 61+
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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
Easement
Inspections Activities
Flushing activkies
Activities
Activities
Maintenance
Activitle s
8/10/2022
8/2/2019
9/10/2022
11/8/2017
11/29/2017
Since July 2018 there has been:
10/19/2021
8/1/2019
3/19/2020
11/7/2017
8/3/2021
9-Manhole Inspections
7/7/2020
7/24/2019
11/14/2019
8/16/2017
58- High Priority Inspections
5/27/2020
7/23/2019
10/31/2019
6/14/2017
10/15/2019
4/11/2017
9/23/2019
10/19/2017
10/9/2019
2/15/2017
9/19/2019
10/15/2018
9/17/2019
12/14/2017
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 the completion of further sewer main
cleaning and CCTV assessment,
12

Incident Number N 2022002326 — 8/20/2022 — 3809 Mid Lakes Dr., Raleigh NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of a 12-inch ductile iron pipe gravity sewer main. This build-up led to a sewer spill of approximately
1,920 gallons of untreated wastewater in which roughly 920 gallons reached a private stormwater pond in the
Crabtree Basin (see exhibit 1— Area of Operation). This Stormwater pond is not considered a source of drinking
water.
Exhibit 1—Area of Ooeratfon
On 08/20/2022, at approximately 7:10 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (SMH117876) located near the intersection of Flamingo Ln. and
Crispin Ct., 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 8:46 PM on the same day. Crews utilized hydraulic jetting to
remove the source of the blockage within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
approximately downstream of the affected area restricting sewer flow onto the conveyance. This approach was
intended to contain wastewater flow and minimize the environmental impact on the surrounding land.
Responding crews employed vacuum trucks to recover 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.
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. See Exhibit 2
—Site Restoration.
13

A follow-up CCTV assessment was conducted on 09/1/2022 to identify the root cause of the SSO. The CCTV
Additional CCTV assessment and subsequent maintenance is scheduled.
The cost associated with the mitigation of this event amounted to $3,873.44. The approximate cost to the Utility
to have treated 1,660 gallons of wastewater would have been approximately $2.88. 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 3 — 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-
14

Raleigh Water Responds to a sanitary $error $pill
REMINDER: Keep All Gnaw Out of the Shared Sanitary
Sower System
on Sam" AUVM W M22 at eppraslrMl a*? In pm Raee - wdw was
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WNW M aa"My "W" lyweM TM IMpFIMI- dalrlook as Maasueh lape le No
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al tlfreWOW" OuMh Owasan of WAK Ruesurm ka been mseed of In 1pe
RAO Walef clad fsrildfad dre aaa.e. MMn all/ wsaied pM"d al
awl nMo•12" a /a PM en h "Reeder a M aelreaMtl did dM ie I 1 9N a
"Mrrae d apprlM M" I M POOM d iar' - wneeeaw to rftch on
paella nWAN a dwmwalw cwraunent peed lid dsp- - I M a afrrbrip mW
loan 'be owed amormd dYo M Cnakee eaten RMkrMa d do seeded am
it aripasrp Nei memary aagdrelied b e6
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PnlwM ell d K"W sl 91MM. "fN %*Im reel. dpU{ m d Odw
WONOM eislerMI in due aflner welael Md to new seeewCwawM adieu
elMw aplreprlds. a th M lMrrie nuke 11 kelp die WON a MIM leer El r
pule ! "0 wkkk CM bm = aideefM NOW Oe Welu gvwtlr am
andager 20M Mk0 COae Oft COaa! wile Me Dftc*d anew.
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dwdwrded ed0 as eraw eyelp. Y 011 er am an aMM damp to me
ruler -$$mn Ow an ell Plredlaad.
It rlu Comm@ meewre User sweet a ell w4m 1pdend Man
M W*KAW W POW PkM owe N!-eMiti{N+pperl kpeMdM".
I'm awe klfarfnaden alem haw rde its hey pellets mm" MUM[
@PM%PMMe Vlem rek4ow 4pww lee.
Thh MatmeleeisrowmedaeNW50m2l Chaplw1432i%%G
me
This section of the collection system is located downstream of a residential area. 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. 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
3/22/2014 6/28/2015 2020-01-2910:30 AM
8/18/2014 10/18/2015
1/5/2015 08/20/2022
4/19/201
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.
15

Incident Number # 202201373 — 8/30/2022 — 6498 Ray Rd., 3101 Compatible Way, Raleigh, NC
This spill was neither willful nor intentional; it resulted from a pipe failure resulting from possible erosion caused
by rapid moving sand sedimentation within the creek bed. This sedimentation may have been attributed to
wearing at the bottom of the gravity sewer main creating a small orifice at the bottom of an 8-inch Ductile Iron
gravity sewer main. This pipe failure did not cause any disruption to normal wastewater flow (see Exhibit 1—
Failed pipe). The pipe failure led to a sewer spill of approximately 371 gallons of untreated wastewater reaching
Hare Snipe Creek. See Exhibit 2 - Area of Operation. Based on the size of the orifice it was estimated that the
spilled flow into the creek was approximately less than 1 gallon per minute.
Exhibit 1- Failed Pipe
Exhibit 2 - Ara of Operation
On 08/30/2022, at approximately 10:15 AM, Raleigh Water staff conducting a high -priority inspection on an
aerial sewer gravity main, identified liquid flowing into Hare Snipe Creek. The responding Easement inspector
immediately requested a CCTV assessment to verify whether the liquid flow was untreated wastewater or
groundwater. CCTV Crews confirmed that the liquid flowing in the creek was untreated wastewater emanating
from the bottom of the sewer gravity pipe. Repair Crews immediately formulated a plan to correct and repair
the failed pipe. 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 4.26 PM on the same day.
16

Containment and collection of this spill event consisted of employing a temporary spill containment site
downstream of the affected area. This approach was intended to contain sewer flow and minimize the
environmental impact on the surrounding land. Responding crews initiated the collection of untreated
wastewater from the containment site to reintroduced it to the collection system downstream. This spill was
contained without a significant environmental impact on the adjacent area and its natural resources.
Exhibit 3 - Spill Mhisation Efforts.
During the restoration phase of the operation, crews utilized ample potable water to assist in washing the creek
and remove all evidence of sewer downstream of the affected area. The area around the failed pipe was cleared
of debris, treated with an application of lime, and restored with grass seed and straw. Repair crews repaired and
replaced the damaged section of the pipe according to engineering specifications. See Exhibit 4 — Repair and
restoration efforts).
Exhibit 4 - Repair and restoration efforts
17

A follow-up CCTV investigation (conducted after the SSO mitigation and repair efforts) did not find any further
evidence of infrastructure deficiencies. Visual inspection of the affected area and downstream waters confirmed
no fish kill or unnecessary vegetative damage occurred.
The cost associated with the mitigation of this event amounted to $7,437.88. The approximate cost to the Utility
to have treated 3,200 gallons of untreated wastewater would have been approximateiy $4.80. The City saved no
money from this spill. The costs for cleanup exceeded the cost of treating the volume of sewage had no spill
occurred. Furthermore,.the City still had to pay the cost to treat the greater volume of sewage created by the
spill and the cost of potable water used to mitigate the event.
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 Repair Activities
Inspections Activities
10/15/2018
9/2/2022 10/26/2017
Since July 2018 there has been:
10/15/2019
8/30/2022 10/26/2017
6 -Manhole Inspections
3/12/2019
8/30/2022
59- High Priority Inspections
8/30/2022
9/1/2022
2- Easement Inspection
9/8/2022
10/10/2022
There have been no additional issues associated with this section of the collection system since the last sewer
event. No further issues have occurred since this SSO event.
18

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
$ 885,577.46 E�1, approximately .06% of the Division's annual operating budget. The 10,216 gallons of untreated
wastewater spills identified in this letter cost the Utility approximately $25,662.58. to'mitigate. The City's cost of
sewer treatment per gallon is $.0015131. At this rate, it would have cost the City $15.26 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 141 per 100 miles of pipe, compared to the Southeastern Region of the US, of 7.0 spills per 100
miles of line. in the previous Fiscal year, 22 total performance miles assessed were 417.34 Miles at a cost of
$ 2,829,596.09.
[1] 66.58 miles represents 0.025%of the Sanitarysewei collection system
121 Associated operational conyeerto date for FrAn
OPERATION
UXEMFWr un"WFAIN
_
COST- - -
_ .CCTV
_. IN, IL71 _ 2136. _ _
S
113,200Ae ,
ftpeR
1,310 - 0.23 -
4
6S$202Aa
Ra"t
23q, M.a 41.77
S
120 VU8 ,
Tetal wst
e(awfmsto0ab
Tata1- a71,S19S1 Ft/ 665a MRFS
S
U519 7A6
[31$-0015 IF based on the annual water treatment operating cost compounded by the total treated effluent.
[4) The current SSO Rate for FY 23Is 0.65
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 consumeneducation 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
19

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-/lraleijthnc.gc�vlsewer maintenance
The City continues its monetary reward program or bounty program, which pays out fifty ($50) dollars to any
citizen that observes and reports an SSO or conditions that may cause a spill event. This program has been
advertised via printed material, a television advertisement campaign, and graphic design "wraps" on Sewer
Maintenance vehicles. These graphics on our vehicles function as mobile billboards spreading our message of
prevention and offering contact information throughout the service area each day. This program was developed
hoping that citizens and customers would become more aware of the signs of an emerging system problem
causing the SSO occurrence and become proactive in helping the City prevent these occurrences. Additionally,
all customers are notified via their water and sewer utility bills not to discharge improper materials into the
sanitary sewer mains. The City also circulates information regarding the discharge of grease into the sewer
system and the effects of such deposits. Whenever possible, and upon investigating the root cause of a spill
event, PUD Code Enforcement officers develop and send registered informational letters about the spill event to
the customer base serviced by the line where the SSO has occurred. This is done to educate our customers on
the proper use of sanitary sewers to prevent the disposal of non-flushable items and items harmful to the
continuous operation of the collections system.
On behalf of the City of Raleigh, I am, requesting that the NOV-2022-NOI-0273 issued for the month of August
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 [phone], or Carlos M. Perez, ORC
Assistance Superintendent 919-996-5929.
. U' 4
ncorely,
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
Carlos. uerezcamacho9 raleighnc.Gov
20

ROY COOPUL
Qm=or
ZAB£1'H S. BISER
WCHW E. ROGERS, JR.
Doub r
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
ft*WW=WQraffNy
September 16, 2022
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2022-DV-0273
Sanitary Sewer Overflows - August 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
oudet 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 Dabs (Mlns) Location Cause (Gals) (Gals) DWR Action
202201249 8/4/2022 105 5500 Cmssfield Or, Roots 1,575 975 Notice of VlolaWn
Raleigh, NG, 27613
202201270 8/8/2022 128 3101 Compatible way, Other 3,200 3,000 Notice of Violation -
Raleigh, NC, 27603 Notice of Intent
202201271 8/9/2022 63 4609 Oak Park Road Grease 3,150 2,850 Notice of Violation —
Notiae of Intent
ii;i�w tAfthrWomwoffim I $Won. DdW Ad*kNW&Cx0k0x&*
9MU%Am

IeddeM Start Dumtlon
Number Debt (Him) Loudon Cauca
202201326 8/20/2022
202201373 8/30/2022
96 3809 3809 Mid Lakes Grease
Dr, Raleigh, NC, 27612
371 6"8 Ray Road Aire Failure (Break)
TOW Vol
Total Suncce
Vol Water
(GRIS) (Gals) DWR Adion
1,920 920 Notice of Vitiation
371 371 Notice of Vidatim
This Notice of Violation / Notice of Intent to Enfome (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 falls 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 y In writing, within 10 business days of Us
receipt, In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, Impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Mltehell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at mltch.hayes0nedenr.gov.
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
Laselfiche
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ROY COOPER � ` CrGonmw
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RICHARD E ROGERS. JR. NORTH CAROLM C3 Oc■~ w.e R. -- d C1*WV f -�� ►+a.
MIMI, FnVhWUr 1MdQV0M M C3 Ad' SwWw@ R. d17r.�Y 6�--�—
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C3 WHIT WHEMR. ASST DIRECTOR
-a CITY OF RAU0W
Mail #_7020 3160 OQ00 4109 0270 rn # P6e0"s'0
gAIEIGH, MC 1760Z
C3 Gs• WCL NOV a INTENY YO ISSUE CMl4ENALTY/SµITARY SEWER EIGH ""
e177JNow20224ova2131v.m:e $*C$ S00002llM
ru OVERFLOWS
`Sjlel COLLECnON SYS/WAKE µ:OSR2/toel - -
: r` ��.�;, 7p1D,',6ppp0°"10="0
September 16, 20Isom Ml
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
StJB3ECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2022-DV-0273
Sanitary Sewer Overflows - August 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 prWdL
to why the City of Raleigh should no
Inddent start
Number Date
Duration
(Mine) Locat
202201249 8/4/2022 105 5500
Raleig
202201270 8/8/2022 1.28 3101,
Ralelg
202201271 8/9/2022 63 46091
! Complete (terns 1, 2. and &
■ Pdnt your game and address on the reverae
so that we can return the cared to you.
■ Attach this card to the heck of the mallplece,
or on the font tf space Permits.
r: -,1^"'YO,7 �_ _ « 2
WHIT wHEELML AM DIRECTOR
CITY OF R&EIGH
AO sox 590
AALEIGH, NC 27602
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PS Form 3811, July 2015 PSN 7r30•o24M0-90W Domeft Patum PAw

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Your item was picked up at a postal facility at 8:38 am on September 27, 2022 in RALEIGH, NC 27602.
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Division of Water Resources
PART I:
State of North Carolh
Department of Environment and Natural Resourc
Division of Water Resourc
Collection System Sanitary Sewer Overflow Reporting For
Form CS -SS
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 #: 202201271
Owner: a of Raleigh W
City: Raleigh County: Wake Region: Raleigh
Source of SSO (check applicable): Ej 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): 4609 Oak Park Road
Manhole #: 125400
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 08/09/2022 Time: 2:07 pm Incident End Dt: 08/09/2022 Time: 03:10 pm
(mm-dd-yyyy) (hh:mm AM/PM) mm-dd-yyyy) (hh:mm AM/PA
Estimated Volume of the SSO: 3,150 gallons Estimated Duration (Round to nearest hour): 1:3 hou
Describe how the volume was determined: gpm x min
Weather conditions during the SSO event: clear
Did SSO reach surface waters? E1 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 2850
Surface water name: Crabtree Creek
Did the SSO result in a fish kill? ❑ Yes Q No ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
0 Grease
24 hour verbal notification (name of person contacted ): James Westcott
0 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 08/10/2022 Time (hh:mm AM/PM): 12:30:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director, Division of Water Resources, may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED, A SIGNATURE IS REQUIRED AT THE END OF THIS FORM

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART 1 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 IE
Grease
When was the last time this specific line (or wet well) was cleaned?
10/19/2021
Do you have an enforceable grease ordinance that requires new or retrofit of grease W Yes ❑ No ❑ NA ❑ NE
traps/interceptors?
Have there been recent inspections and/or enforcement actions taken on nearby ❑ Yes ❑ No [7 NA ❑ NE
restaurants or other nonresidential grease contributors?
Explain.
This part of the sanitary sewer collection system is located in a residential area under routine maintenance.
Have there been other SSOs or blockages in this area that were also caused by ❑ Yes V No ❑ NA ❑ NE
grease?
When?
9/15119
If yes, describe them:
Last recorded SSO was related to debris such as raps and flushed wioes (Incident # 201901533)
Have cleaning and inspections ever been increased at this location? W Yes ❑ No ❑ NA ❑ NE
Explain.
Due the high frequency of sewer overflows in this area this area has been added to„Raleigh Waters hot spot priority list t
have more routine flushing cleanings
last inspected on 7/15/2022
Have educational materials about grease been distributed in the past?
When?
09/16/2019
and to whom?
Deep Hallow Neighborhood
Explain?
W Yes ❑ No ❑ NA ❑ NE
ORC meet with apartment complex manager to discuss root cause of SSO. Outreach literature as provided to Manager.
If the SSO occurred at a pump station, when was the wet well and pumps last
checked for grease accumulation?
NA

Were the floats clean? Yes [ No
Comments:
NA
System Visitation
ORC Yes
Backup ❑ Yes
Name:
Carlos Perez
Cert#
1003875
Date visited:
08/09/2022
Time visited:
4:47PM
How was the SSO remediated (i.e. Stopped and cleaned up)?
NA F- NE
Sewer Maintenance crews were dispatched this afternoon to a SSOO 4609 Oak Park Dr; Raleigh NC. Crews arrived of
at approximately 2:07rm and witnessed the affected asset SMH125400 surcharging at the rate of 50 gpm. The blockac
the affecting asset SGM186174 was eliminated at 3:10om by utilizing hydraulic ietting to remove the blockage. The cau
of this SSO was determined to be a grease and rags. The sewer maintenance crews have removed the blockage and
flushed the affected asset with hydraulic letting to ensure the main is clean and has good flow. The SSO was stopped
within 63min with 3,150 gallons of untreated waste discharging from the MH. Atemporary containment site was establis
Lai- 4424 Oak Park Dr to collect any untreated wastewater and redirect back into the sewer sanitary system. A hydrant w
started @347pm on Diamond City Ct and Connell Dr.to help with the restoration of the surrounding creek.
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: 08/15/22 10:00 am
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days o
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of
form is completed, if used).
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QCS00002 version: 2.0 Status: dive
Collection system management and operation
Individual Primary Related Permit:
'Non -discharge Admin Region: Raleigh
'Ralelgh Collection System Details County: ake
City of Raleigh Details Project Type: Renewal
-- Dates --
1211512015 Ong Issued: 110?2712005 F 1,lajor Permit
❑ Has S€sbsurtace Drains
02sr01l2016 Statutory; 0811712015
New Farm !�.� Existing Farm #
01l31l2024 Inactive
❑ Innovative Avail
�� ❑ Raj n-)rea- er D