WQCS00005_NOV-2023-DV-0133_Response Rvcd_20230410

WATER MANAGEMENT
CITY OF DURHAM
City of Durham
Department of Water Management
1100 Martin Luther King Jr Parkway
Durham, NC 27707
919-560-4344
April 6, 2023
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
NCDEQ, Division of Water Resources
3800 Barrett Drive
Raleigh, NC 27609
N(' Dept of Environmental Quality
Raleigh Regional Office
Subject: NOV-2023-DV-0133 Permit No. WQCS00005
Dated: March 13, 2023; Received: March 23, 2023
City of Durham Collection System, Durham County
Dear Mr. Vinson,
On March 23, 2023, the City of Durham Department of Water Management (DWM) received the above referenced
Notice of Violation and Intent to Issue Civil Penalty. As graciously requested in the letter, the following evidence
and justification demonstrates that these events were exceptional, unintentional, temporary, and beyond
reasonable control of the utility, and that DWM undertook significant costs to mitigate their impact. Further, it
demonstrates DWM's strong commitment to and investment in preventing and mitigating sanitary sewer
overflows (SSOs). All conditions of the City's Collection System permit are met by the Department, including
system cleaning, site visits, inspections, and easement maintenance.
As such, we respectfully request that no civil penalties be assessed for the SSOs that occurred in the City's sewer
collection system between February 1, 2023, and February 28, 2023.
Incident#202300228 -1003 Orchard Oriole Lane — February 6. 2023
On February 6, 2023, at 8:04 AM, an overflow occurred near 1003 Orchard Oriole Lane releasing an estimated 420
gallons of wastewater into an unnamed tributary of Third Fork Creek. Crews discovered that debris in the line was
the cause of the blockage and used a JetVac truck to successfully clear the line. After assessing the extent of the
spill, crews dammed the downstream creek with sandbags, set up a 4-inch pump to pump the untreated
wastewater back into the collection system, and flushed the,area using a nearby hydrant (dechlorinated water).
Crews then used a JetVac truck to clean the three upstream and three downstream pipe reaches to ensure the
pipes were clear.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the spill's
extent and advise when the site returned to normal conditions. No immediately visible adverse environmental
impacts or hazards to persons or property were observed.
A news release was issued within a 24-hour window. The cost to remediate this spill was $3,358.09.

Incident#202300358 - 500 S Pettigrew Street— February 19, 2023
On February 19, 2023, at 10:38 AM, an overflow occurred near 500 E Pettigrew Street releasing an estimated 762
gallons of wastewater into a body of water or tributary of Third Fork Creek. Crews discovered that a sewer plug left
during private contractor work prevented the normal operation of the existing sewer main and caused the
blockage. DWM has identified the contractor and is addressing the issue with them. Crews used a JetVac truck to
successfully clear the line. After assessing the extent of the spill, crews dammed the downstream creek with
sandbags, set up a 4-inch pump to pump the untreated wastewater back into the collection system, and flushed
the area using a nearby hydrant (dechlorinated water). Crews then used a JetVac truck to clean the three upstream
and three downstream pipe reaches to ensure the pipes were clear.
The City's Stormwater Services Division responded and conducted ammonia testing to help determine the spill's
extent and advise the Department when the site returned to normal conditions. No immediately visible adverse
environmental impacts or hazards to persons or property were observed.
A news release was issued within a 24-hour window. The cost to remediate this spill was $3,270.65.
Ongoing City -Wide Measures to Reduce the Occurrence of SSOs
DWM has several programs in place to prevent and reduce the occurrence of SSOs. DWM has implemented a
Collection System Management, Operations & Maintenance (CMOM) plan that expands and enhances its existing
programs.
System Flushing and Inspection: DWM routinely contracts cleaning, CCTV inspection, smoke testing, and
manhole inspections of portions of the sewer collection system. DWM completes the inspection of the
collection system systematically based on City defined geographical basins.
DWM ensures the requirements of the collection system permit are met by deploying City crews to clean at
least 10% of the collection system annually with a goal of exceeding the requirement by an additional two to
five percentage points each year. DWM measures the cleaning on a fiscal year basis starting July 1. In Fiscal
Year 2021, DWM cleaned 14.8% of the collection system. In Fiscal Year 2022, DWM cleaned 13.4%of the
collection system. As of February 28, 2023, 4.2% of the City's collection system had been cleaned by City staff
and contractors since July 1, 2023. As usual, we plan to increase our rate of sewer cleaning activity in the
spring.
• Sewer Rehabilitation Program: DWM has an active Sewer Rehabilitation Program. The program includes flow
monitoring (25 permanent monitors), CCTV inspection, manhole inspection, easement mowing, field
inspections and investigations, point repairs, line replacement, root and grease abatement and cured -in -place
manhole and line rehabilitation.
There are four full-time equivalents (FTEs) employees dedicated to DWM's system rehabilitation programs in
the Utility Engineering Division of the Department. This workgroup handles flow monitoring and system data
management and contract preparation, administration, and inspections.
There are 21 FTEs in the City's Collections Systems Maintenance (CSM) workgroup in the Water and Sewer
Maintenance (WSM) Division of DWM. This group performs CCTV inspections, hydraulic cleaning activities,
mowing, manhole inspections, and manhole repairs. They respond to all reported concerns including blockages
and overflows. In addition, the CSM crews are supported by the Excavation Services workgroup of WSM who
perform identified point repairs, line replacements, and cured -in -place lining.

In 2018, the department established the Lift Station Maintenance Division (LSM) to focus on oversight and
maintenance of the 63 lift stations throughout the service area and the 136 air relief valves (ARVs) in the
system. This workgroup of 21 FTEs conducts required daily, weekly, monthly, and annual inspections and
associated preventive maintenance activities. DWM spends more than $5,000,000 on Sewer Rehabilitation
projects annually as a part of its Capital Improvements Programs.
Fats, Oils, and Grease Program (FOG): The department's FOG education and outreach effort is conducted by
three FTEs. (Staff are shared between the Industrial Pretreatment, Septage and FOG Programs). In addition to
working with the Durham County Health Department, staff routinely inspect over 800 food service
establishments (FSEs) annually to ensure appropriate cleaning and maintenance of grease interceptors. Staff
participate in several community events, such as Earth Day, Center Fest, and the Bimbe Festival, as well as
neighborhood meetings. Department staff deliver residential Fat Trappers to increase awareness of the proper
disposal methods for waste. DWM staff also conducts post-SSO follow-up education and enforcement as
necessary. DWM invests over $50,000 per year in advertising the proper disposal of FOG on television. Staff
post to the City's quarterly newsletter, the Durham Digest, along with multiple mentions in the City Manager's
Report known as City Connect, to reach a broad range of Durham residents.
Summary:
Based upon the documented information provided above regarding these incidents, DWM believes that these
SSO's were exceptional, unintentional, temporary, and caused by factors beyond the City and Department's
control. DWM actively manages, operates, and maintains its system in such a manner as to meet or exceed all the
requirements of the Collection System permit. As detailed above, DWM systematically inspects, flushes, and
rehabilitates its wastewater collection system. The Department also actively works to regulate and educate the
community regarding what should and should not be discharged into the City's sewer collection system.
The department staff welcomes the opportunity to meet with you and your staff to review our program and
discuss constructive ways to improve what we are already doing in the City of Durham. If you have any questions
or need any additional information please do not hesitate to contact me at [phone] or via email at
[e-mail].
Sincerely,
Donald F. Greeley
Director
Attachments
C: Jason Robinson, DEQ— Water Quality Regional Operations Section, Raleigh Regional Office
Junior Mobley, Superintendent, Water & Sewer Maintenance
Scott Smart, Assistant Director
Mary Tiger, Assistant Director
Jerry Morrone, Utility Engineering Manager, Sr.

NC Dept of Environmental Quality
DWR State of North Carolina
Department of Environment and Natural Resources
UP 1 0 2013 Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
Raleigh Re+irolal Office
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: WQCS00005 (WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System Incident #: 202300228
Owner: City of Durham
City: Durham County: Durham Region: Raleigh
Source of SSO (check applicable): 0 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): 1003 Orchard Oriole Ln, Durham, NC, 27713
Manhole #: 10276
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 02/06/2023 Time: 8:04 am Incident End Dt: 02/06/2023 Time: 09:28 am
(mm-dd-yyyy) (hh:mmAM/PM) (mm-dd-yyyy) (hh:mmAM/PM)
Estimated Volume of the SSO: 420 gallons Estimated Duration (Round to nearest hour): 1:24 hours
Describe how the volume was determined: 5GPM X 84mins
Weather conditions during the SSO event: Dry
Did SSO reach surface waters? 0 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 420
Surface water name: Third Fork Creek
Did the SSO result in a fish kill? ❑ Yes ONo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
0 Debris in line
24 hour verbal notification (name of person contacted ): Dorothy M Robson
0 DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 02/06/2023 Time (hh:mm AM/PM): 12:15:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 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 reeuired 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
Debris in line
What type of debris has been found in the line?
Rocks and gravel
Suspected cause or source of debris.
Unknown source, we think line may also contain some other blockage. We are currently cleaning and will CCTV to check
for other issues in the assets.
Are manholes in the area secure and intact? 0 Yes ❑ No ❑ NA ❑ NE
When was the area last checked/cleaned?
2019
Have cleaning and inspections ever been increased at this location due to previous ❑ Yes 0 No ❑ NA ❑ NE
problems with debris?
Explain:
Now that we have found a issue in the assets we will continue to monitor the area on a 6 month basis on the hotspot
program until Department feels confident no further issues.
Are appropriate educational materials being developed and distributed to prevent futt 0 Yes ❑ No ❑ NA ❑ NE
similar occurrences?
Comments:
After CCTV crews will gain further evidence to find where and what the causes of the blockage area. If we find it is relate
to neighborhood issues, we will have the head of the FOG Program pass out educational material to all related residents
area.
System Visitation
ORC ❑ Yes
Backup 0 Yes
Name:
Larry Hughes
Cert#
1005483
Date visited:
02/06/2023
CS-SSO Form Page: 2

Time visited:
08:30am
How was the SSO remediated (i.e. Stopped and cleaned up)?
Today at 8:04am Collections Department received a call about a manhole overflowing at 1003 Orchard Oriole Ln. Crew
arrived onsite at 8:28am, when they arrived they found manhole 10276 overflowing at a rate of 5gpm. Crews set up quick
response and remediated spill by flushing and removing blockage of debris.(So far rocks is all we found). Crew remediate
spill at 9:28am for a total of 420 gallons of untreated wastewater reaching a storm drain nearby. Crew tested an area of
Third Fork Creek and tested zero for ammonia. After testing, crew set up bypass pump to remove all untreated wastewatf
in return back to the sewer manhole at manhole 10408. Crew set up sandbags also to make sure no untreated wastewate
made it past the pump. We have hydrant box and defuser set up on 1101 Orchard Oriole to help with pushing storm drain
water to pump. The customer was notified we will have meter at location and run fire hose across driveway. The crew one
also washed down area where overflow to make sure no hazards in area. Crews are currently cleaning 3 assets above ar
below to make sure problem is alleviated in area. After assets are cleaned. we will CCTV to check for issues in each
asset. Local Storm Water Quality was called on 02/7/2022 speaking with Mikel and he tested the Creek for zero ammonia
to informed Collections Maintenance we can remove the pump. We will keep these assets on a 6-month hotspot prograrr
where we will flush and CCTV in 6 months to see if issue is resolved.
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 subr
Signature:
Telephone Number: q � q- ]-LA - 3ON b
Date: 02/07123 12:27 pm
Title: 9UGP-,O-) 0ZC,
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of t
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 3

From: Lunne, Joe
Sent: Monday, February 6, 2023 4:28 PM
Subject: SSO at 1003 Orchard Oriole Lane
NC Dept of Environmental Quality
APR 10 2023
Raleigh Regional Office
COMMUNICATIONS
CITY OF DURHAM
News Media Contai
Joe Lunne, SR Public Information & Communicatic
Analy.
Water Management Dep
919.560:4381 ext. 35255 919,3976131(mobili
Joe.Lunne@DurhamNC,go�
News Release
For Immediate Release: February 6, 2023
City of Durham contains sewer spill at 1003 Orchard Oriole Lane
)URHAM, N.C. —The City of Durham Department of Water Management reports that on February 6, 2023 staff
•P,nonded to a manhole overflowing at 1003 Orchard Oriole Lane. Approximately 420 gallons of untreated wastewater
I. .ed into Third Fork Creek. The cause of the overflow was rocks in the sewer line.
itaff were notified of the overflow at 8:04 a.m. on February 6, 2023, and the spill was stopped at 9:28 a.m. Crews flushed
and removed the blockage, dammed the creek downstream, pumped the untreated wastewater back into the sewer
system, and flushed the creek. There were no observed hazards to persons, property, or the environment.
the N.C. Department of Environmental Quality Division of Water Resources was notified of the event on February 6,
2023, as required by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water &
fewer Maintenance.
101 City Hall Plaza, Second Floor, Durham, NC 27701 I 919.560.4123 DurhamNC.gov I Follow Us @CO o© rhamNNCC

t ucpr ur tnvlronmental Quality
DW
R
State of North Carolina
Department of Environment and Natural Resources
APR 10 2023 Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Raleigh Remnal OfFipP 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: WQCS00005 (WQCS# if active, otherwise use WQCSD#)
Facility: Durham Collection System Incident #: 202300358
Owner: City of Durham
City: Durham
Source of SSO (check applicable):
County: Durham Region: Raleigh
O 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): 500 S. Pettigrew St, Durham, NC, 27703
Manhole #: 53236
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 02/19/2023 Time: 10:38 am Incident End Dt: 02/19/2023 Time: 01:30 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mom (hh:mm AM/PM)
Estimated Volume of the SSO: 762 gallons Estimated Duration (Round to nearest hour): 2:52 hours
Describe how the volume was determined: 6 gal gpm xl27 min
Weather conditions during the SSO event:
Did SSO reach surface waters? O Yes
Surface water name: Third Fork Creek
fair
❑ No ❑ Unknown Volume reaching surface waters (gals): 762
Did the SSO result in a fish kill? ❑ Yes ONo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
O Other (Please explai
24 hour verbal notification (name of person contacted ): Todd Green
❑ DWR O Emergency Mgmt Date (mm-dd-yyy): 02119/2023 Time (hh:mm AM/PM): 07:45:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 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 Farm 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 II)
Describe:
Were adequate equipment and resources available to fix the problem? 0 Yes ❑ No DNA ❑ NE
If Yes, explain:
The line had a sewer plug that was stuck inside of the gravity main. We were able to remove the plug after jetting the line
removing settled debris. We unstopped the backup and removed the plug.
If the problem could not be immediately repaired, what actions were taken to lessen
the impact of the SSO?
Comments:
Comments: We are currently in the process of finding the contractor responsible for leaving the sewer plug. Afterwards wr
still cleaned the downstream assets to make sure no other instruments were left during construction.
System Visitation
ORC ❑ Yes
Backup W Yes
Name:
Calinto Parker
Cert#
999770
Date visited:
02/19/2023
Time visited:
2:OOpm
How was the SSO remediated (i.e. Stopped and cleaned up)?
The line had a sewer plug that was stuck inside of the gravity main. We were able to remove the plug after jetting the line
removing settled debris. We unstopped the backup and removed the plug.
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.
Calinto Antonio Parker
Date: 02/24/23 10:51
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of 1
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 3

From: Lunne, Joe
Sent: Monday, February 20, 2023 11:15 AM
Subject: SSO at 504 E. Pettigrew Street
COMMUNICATIONS
IONS
CITY OF DURHAM
NC Dept of Environmental Quality
Raleigh Regional Office
News Media Contai
Joe Lunne, SR Public Information & Communicatic
Analy
Water Management Dep
919.560.4381 ext. 35255 9193976131(mobil,
Joe: Lunne�DurhamNC:go�
News Release
For Immediate Release: February 20, 2023
City of Durham contains sewer spill at 504 E. Pettigrew Street
DURHAM, N.C. —The City of Durham Department of Water Management reports that on February 19, 2023 staff
•esponded to a manhole overflowing at 504 E. Pettigrew Street. Approximately 672 gallons of untreated wastewater
Flowed into Third Fork Creek. The cause of the overflow was a sewer plug left in the sewer line*.
itaff were notified of the overflow at 1:10 p.m. on February 19, 2023, and the spill was stopped at 1:30 p.m. Crews
•emoved the sewer plug and flushed the line, dammed the creek downstream, pumped the untreated wastewater back
nto the sewer system, and flushed the creek. There were no observed hazards to persons, property, or the environment.
the N.C. Department of Environmental Quality Division of Water Resources was notified of the event on February 19,
2023, as required by state regulations/law. For more information, contact Junior Mobley, Superintendent of Water &
fewer Maintenance.
"A sewer plug is a plug manually installed in the mouth of the sewer to ensure no water or untreated wastewater
infiltrates the sewer while work is being performed in the line.
101 City Hall Plaza, Second Floor, Durham, NC 27701 919.560.4123 DurhamNC.gov Follow Us @CityoffDurhamNC
© 0 0

NC Dept of Environmental
ROY COOPER
Governor
ELIZABETH S. BISER �' 0
Secretary
NORTH CAROLINA
RICHARD E. ROGERS,)R Raleigh Re jp
Director �' najoffi EnvIronmentalQuaftry
Certified Mail # 7020 3160 0000 4115 6358
Return Receipt Reauested
March 13, 2023
Donald F Greeley
City of Durham
101 City Hall Plaza
Durham, NC 27701-3329
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2023-DV-0133
Sanitary Sewer Overflows - February 2023
Collection System Permit No. WQCS00005
Durham Collection System
Durham County
Dear Mr. Greeley:
RECEIVED
City of Durham
MAR 2 3 2023
Office of the Director
Dept. of Water Management
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by City of Durham indicates violations
of permit conditions stipulated in the subject permit and North Carolina G.S. 143-215.1. Violations include failing to
effectively manage, maintain, and operate the subject collection system so that there is no SSO to the land or
surface waters and making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a
permit is required.
Specific incident(s) cited in the subject report include the following:
Total Vol
Total
Surface
Incident
Start
Duration
Vol
Water
Number
Date
(Mins)
Location Cause
(Gals)
(Gals) DWR Action
202300228
2/6/2023
84
1003 Orchard Oriole Debris in line
420
420 Notice of Violation
Ln, Durham, INC,
27713
202300358
2/19/2023
172
500 S. Pettigrew St, Other
762
762 Notice of Violation
Durham, NC, 27703
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Remedial actions, if not already implemented, should be taken to correct the above noncompliance. Please submit
a written response to this Notice of Violation. Your response is to be received by the regional office within 15
business days following receipt of this violation. Please include any additional documentation about this incidents)
in the response. The submittal will be considered in determining whether the Division will assess a civil penalty for
the cited violations.
If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Laserfiche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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