WQCS00002_DV-2023-0132 Civil Penalthy Assesment File_20231030

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ROY COOPER
Governot
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, f R. NORTH CAROL -NA
Direcrar Environmental Quality
Certified Mail # 7020 3160 0000 4115 0332
Return Receipt Requested
October 30, 2023
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215, 1 (a)(6)
and Collection System Permit No. WQCS00002
City of Raleigh
Raleigh Collection System
Case No. DV-2023-0132
Wake County
Dear Mr. Wheeler:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $340.68 ($250.00 civil penalty +
$90.68 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. ] (a).
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Raleigh RNonnl Office .180013-wt Drive I Ralcigh Vorth C�,Ona 27h09
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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, I, Vanessa
Manuel, Assistant Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against
City of Raleigh:
250.00 For 1 of the 4 violations of Collection System Permit No. WQCS00002 and G.S. 143-215,1(a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
250.00 TOTAL CIVIL PENALTY
90.68 Enforcement Costs
340.68 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 14313-282.1(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 I: 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 (30) days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
AND
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center, Raleigh
Raleigh, NC 27699-1628

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m, and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS § 150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions 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. -lime 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 Kevin Fowler with the Division of Water Resources staff of the Raleigh Regional
Office at [phone] or via email at kevin.fowlen;rz.!deq.nc.gov.
Sincerely,
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Laserfische

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2023-0I32 County: Wake
Assessed Party: City of Raleigh
Permit No.: WQCS00002 Amount Assessed: $340.68
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. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent fixture 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 fa);
(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.rrom 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-2023-0132
Having been assessed civil penalties totaling $340.68 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated October 30"', 2023, the undersigned, desiring to seek remission of the civil penalty, does hereby waive
the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment
document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be
submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice of
assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the
day of
ADDRESS
TELEPHONE
SIGNATURE
, 20

ATTACHMENT A
City of Raleigh
CASE NUMBER: DV-2023-0132
PERMIT NO: WQCS00002
FACILITY: Raleigh Collection System
Other Violations
REGION: Raleigh
COUNTY: Wake
INCIDENT
VIOLATION
TOTAL VOLUME
PENALTY
NUMBER
DATE
VIOLATION TYPE
VIOLATION DESCRIPTION
(GALLONS)
AMOUNT
202301200
8/16/2023
CSOISSO(Sewer Overflow)
Discharge without valid permit
3,600
$250.00
202301204
8/22/2023
CSOISSO(Sewer Overflow)
Discharge without valid permit
1,750
$0.00
202301218
8/24/2023
CSOISSO(Sewer Overflow)
Discharge without valid permit
1,500
$0.00
202301220 8/27/2023 CSOISSO(Sewer Overflow) Discharge without valid permit 1,900 $0.00

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleigh
Facility Name: Raleigh Collection System
Permit Number: WOCS00002
County: Wake
Case Number: DV-2023-0132
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 3,600 gallons of wastewater overflowed from the Raleigh Collection System due to roots. 3,600 gallons of
wastewater flowed to Mine Creek, a class C; NSW in the Neuse River Basin. Nutrients and pathogens to surface waters.
2) The duration and gravity of the violation;
The SSO started on 08.16.2023 at 05:57 PM and ended the same day at 09:40 PM.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on surface water quality include nutrients and pathogens to surface waters.
4) The cost of rectifying the damage;
The cost of rectifying the damage was $6,799.82.
5) The amount of money saved by noncompliance;
It is believed that no money was saved by the noncompliance.
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 6 enforcement cases within the past 12 months.
8) The cost to the State of the enforcement procedures.
$90.68
yl�dlrK 3v Z,2 �1,•rGy�
Date Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

Raleigh Water
October 2"1, 2023
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-2023-DV- 0342
Sanitary Sewer Overflows —August 2023
Permit No. WQCS00002
Dear Mr. Vinson:
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Please allow this letter to respond to the Notice of Violation document (NOV-2023-DV-0342) received on
September 18, 2023. This document contains the narrative regarding the pending Notice of Violation action of
(4) Sanitary Sewer Overflows (SSO) event, reported on the month of August 2023, within the City of Raleigh
Collections System III- This document also provides exhibits as proof of our efforts to mitigate the sewer events.
The noticed events occurred while the City operated its collection system, according to WQCS00002, dated June
6, 2017. The permit includes the language outlined in footnote 1 and applies to the SSOs upon which NOVs with
the notice of intent (NOV-NOI) were based. This document will establish a reasonable explanation of the actions
taken to stop the spills, contain the released untreated wastewater, collect the wastewater and reintroduce it to
the collection system; and finally, restore the possible environmental impacts brought by the release of the SSO
events, listed with the intended NOV-NOI action. Please find below the additional information requested for the
SSO events.
1. "The Director may take enforcement action against the Permittee for SSOs that must be reported to the Division as
stipulated in Condition IV92). This includes SSOs that were caused by severe natural conditions or exceptional events
unless the Permittee demonstrates through properly signed, contemporaneous operating logs or other relevant
evidence that:
Ia.I The $50 was caused by severe natural conditions; there were no feasible alternatives 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 provn:on is not
satisfied if, in the exercise of reasonable engineering judgment, the Permittee should have installed auxiliary or additional collections system components, wastewater
retention or treatment facilities, adequate backup equipment, or should have reduced inflow and infiltration or
(b.I The SSO was exceptional, unintentional, temporary, and caused by factors beyond the reasonable control of the Permittee; the SSO could not have bean prevented
by the exercise of reasonable control, sur.h as proper management, operation, and maintenance; adequate treatment or collection facilities or components (e.F.,
adequately enlarging treatment of collection facilities to accommodate growth or adequately t ontrolling and preventing infiltration and-nflow); preve-itative
maintenance; or installation of adequate backup equipment;"
1

Incident Number # 202301200 — 8/16/2023 —1115 Temple St., Raleigh
This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of an 8-in
Vitrified -Clay Pipe gravity sewer main. The root intrusion led to a sewer spill of approximately 3,600 gallons of
untreated wastewater reaching an unnamed tributary within the Mine Basin (see exhibit 1— Area of Operation)
On 08/16/2023, at approximately 5:57 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH113461) located near 1115 Temple St.,
Raleigh, NC. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge,
gaining control of the spill incident by 09:40 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 incident consisted of employing a temporary spill containment site
downstream of the affected area, restricting sewer flow to downstream surface waters. 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 reintroducing 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 lime, and restored with grass seed and straw.
2

A CCTV assessment identified root intrusion as the incident's root cause (see Exhibit 2 — Affecting Assets with
Root Intrusion).
The cost associated with the mitigation of this incident amounted to $6,799.82. The approximate cost to the
Utility to have treated 3,600 gallons of wastewater would have been approximately $5.40. 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 for treating 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 residences surrounding the spill incident (see Exhibit 3- Future root control services). Within
the last ten years, this specific portion of the collection system experienced a non -reportable SSO related to root
intrusion in which approximately 495 gallons of untreated wastewater spilled onto the ground. The SSO was
mitigated with hydraulic jetting and mechanical root cutters. Sanitary sewer assets in this area have been
routinely maintained with subsequent chemical root control treatment.
3

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.
Raleigh Water Responds to a Sanitary Sewer Overflow
On Wednesday August t* 2023 at OpoMd ity 5 Sea PM. RWgh WOW flirt
wan r"%d *1 A sanfary sev oyarfw at t 115 Ter a St Ra ftlt NC. Upon
amval LMreswn r*idereeedanaa+wsawaramw—aauang"Mroot
i vWWt. TNa Uridmd of ctod Me few of unYeatod wariowuhtw Irm an B-irCh tnarea
Ctay serer g'M� ppe. Thp MIPW atg $teeteah of nasonaM fops te"was
mtigae ate rmdewa hrtpad as soon as they dared. The rsdrin C&*&m paparnlam
of Enwonrertsr Uuawy tJnven at Wa+WHasoraoas. w Wth6doreeovedtPw
Ra'aprl Wow stall conttanp Pa ~?&f 21 dppd.+Mt*V B 40 PM as dra
same day h Is es0aated *vs de o.etpow dsdmgm aWa.W-4aly 3.600 gaawm of
ulasied ueasw. w. reaching an unnamed VW" redtia Mhe Bash Peumden
br phe IrPtlert li engprrtg.
PAIL" WOW has an agpassire edtaWn"rMw srt ant prupem w
prevent the dad'aw of gnaw, deer*. wipes, rap.
VA . dwsms and Ww i ww"
MrWnd mas A tv sower system ato teQ snwomeNO*hare
apFww'. 090140 "a
rm mob h rte the ".wear /yawn, eti may OWN a
tpa W." ran ha.e an adverse now m -M we. ty and atdongdr ft"
weo MOO .*o WWI W th the alwetad areas.
Water. rNTan waft. and MdM anve wo CY dory semi Parnsnd to a
do" god ddo tins sawae system. N dta Kann we cause damage to the
sewer system and the not ptmV*d
It you **wwnce ax—rNe won- %Tura w sw seha spaaag hen nu&06n a
po". pee"ate9rBA90J2.5=-apmtr'm Sty
For more eftrnahM aeon tew you can Mvp prarara famary sane ■Paf
please r.srt 1swgNK g00'afar
This news ideaaa NO teqused dj N= At$* 21 Chapter 143.215 1C
am
Before this incident, maintenance records show that sections within the zone of influence of this collection
system were assessed within the last ten years as follows:
Flushing activities
1/26/2017
12/31/2019
12/10/2019
1/2/2020
12/11/2019
6/8/2022
12/19/2019
9/12/2023
12/23/2019
9/29/2023
Easement
CCTV
Maintenance
Activities
Activities
2/3/2017
7/25/2023
2/2/2017
7/25/2023
8/16/2023
Inspections Activities
12/15/2017
10/28/2020
5/29/2018
5/4/2021
6/6/2018
8/26/2021
10/1/2018
3/3/2022
3/13/2019
9/13/2022
3/14/2019
9/13/2022
8/6/2019
2/22/2023
1/15/2020
2/27/2023
10/16/2020
7/20/2023
Since the last sewer incident, no additional sewer issues have been associated with this section of the collection
system. This site remains an active maintenance spot pending the completion of further sewer main cleaning
and chemical root control application.
4

Incident Number # 202301204 — 8/22/2023— 2609 Spring Forest Rd., Raleigh
This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of an
8-in ductile iron pipe -gravity sewer main. The root intrusion led to a sewer spill of approximately 1,750 gallons of
untreated wastewater reaching an unnamed tributary within the Mine Basin (see exhibit 1— Area of Operation)
On 08/22/2023, at approximately 12:34 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH156784) located near 2609 Spring Forest
Rd., Raleigh, NC. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge,
gaining control of the spill incident by 01:30 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 incident consisted of employing a temporary spill containment site
downstream of the affected area, restricting sewer flow to downstream surface waters. 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 reintroducing 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. See Exhibit 2 — Containment and Collection.
5

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 lime, and restored with grass seed and straw.
A CCTV assessment identified root intrusion as the incident's root cause (see Exhibit 3 — Affecting Assets with
Root Intrusion).
The cost associated with the mitigation of this incident amounted to $8,488.14. The approximate cost to the
Utility to have treated 1,750 gallons of wastewater would have been approximately $2.62. 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 for treating the greater volume of sewage created by the
spill.
This section of the collection system is located downstream of a commercial area. It provides sewer collection
services to several establishments surrounding the spill incident. This specific portion of the collection system
has not experienced an SSO within the last ten years. Sanitary sewer assets in this area have been routinely
maintained for subsequent chemical root control treatment.
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.
6

Exhibit 4 - Press release
Raleigh Water Responds to a Sanitary Sewer Overflow
On Tuesday August 22, at approxmaety 12:34 PM, Raioign Water stall
were f*09a are sanilary sewer overflow near 2809 Spdrrg Fareal Rd Ralollih NC.
Upon amval, Ulifly Responders Identned an *Cdva sewerovereew iseLlAg from a
blockage ct Pooh in the sewer gravity main The responding staN look as reasarreale
steps to stop and m hgale the oae*-vA impact as soon as they arrived the North
Carolina 4epartmert of E,vi ormental Quality Division cf Water Resources. has been
notit ed at do overflow
Rwagq Wear stall contained the oveftw at approximately 144 PM on Me
same day. It Is estlwts9 that pie ovortlow discharged a volume cf approdmately 1750
gasons of urlmated was nvaler win ch dd reach a *totem drain and ul9r.Wafy reac'ad
an i.nrWned fntn.tary to Marsh Creek Restoration rot Iles evard has ham%oonpleled
No vWlatve damage or !sh ka related In Utis event nu dean observed as the
wastewater did nol reach wrface waler
Raleigh Water has an aggre*eive education and enhorcsment program to
prevent the discharge of gnat*, debris, w4na, rage, diapers and other
Improper materials In the sewer system and to Costa enforcemsm action when
appropriate. If those llama make it Into the sower "am, they may cause ■
split which can have on adverse Impact on water quality and endanger those
who rams Into contact with the allerlad areas
writer, human wants, and toilet Ussus a s the only Items permitted to be
discharged into the sewer system. All other Items will cause damage to the
sewer system and an not permitted.
Nyou oaparienco onesslve sawor sm fts or sea sower spilling from
manholes or pipes, please bah $1941963346 to report immediately.
For men Information about how you can help prevent """ sewer *pips.
Please visit: ralsighnc.govlwatar.
This rare relesse a required by NCG$Aftle 21. Chapter 143.215 IC.
ens
Before this incident, maintenance records show that sections within the zone of influence of this collection
system were assessed within the last ten years as follows:
Flushing
activities
2/8/2018
4/13/2021
2/15/2018
5/18/2021
3/9/2018
6/24/2021
7/31/2018
9/10/2021
2/24/2021
8/15/2023
3/2/2021
8/22/2023
CCTV Activities Repair Activities
5/2/2017
9/24/2021 10/11/2018
5/5/2017
8/15/2023
3/8/2018
8/28/2023
7/31/2018
8/28/2023
4/9/2021
7/12/2021
Inspections Activities
10/31/2019
I1/4/2019
11/17/2022
6/17/2022
5/12/2023
Since the last sewer incident, no additional sewer issues have been associated with this section of the collection
system. This site remains an active maintenance spot pending the completion of further sewer main cleaning
CCTV assessment and chemical root control application.

Incident Number # 202301218 — 8/24/2023 — 701 Van Buren Road., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a collapsed 8" sewer gravity main resulting from a
void created by a collapsed underground stormwater pipe. This asset failure led to a sewer spill of approximately
1,500 gallons of untreated wastewater, which remained within the natural topography and did not reach surface
waters. See Exhibit 1— Area of Operations
On 08/24/2023, at approximately 2:11 PM, Sewer Maintenance staff was notified of a sewer odor near 701 Van
Buren Road. Raleigh, NC. Upon arrival, it was determined that a section of the gravity main had failed (see
Exhibit 2 — Damaged Section of Gravity Main). The pipe collapse directly resulted from a collapsed stormwater
pipe that eroded the surrounding ground, creating a void that undermined the sewer gravity main. 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 incident by 7:15 PM on the same day.

Containment, collection, cleanup, restoration, and repair of this spill incident consisted of employing a vacuum
truck to minimize the flow of untreated water downstream and isolating the site for the repair to be completed.
Repair crews repaired the damaged section of the sewer pipe and stormwater pipe accordingly (see Exhibit 3 —
Completed Repair). Normal sewer flow was restored on the same day.
Exhibit 3—Completed kpair
This spill was contained without a significant environmental impact on the adjacent area and its natural
resources. Visual inspection of the affected area and downstream waters confirmed that the spill did not reach
any surface waters of the state.
Crews utilized ample water during the restoration phase of the operation to flush the surrounding affected area.
The site of the sewer run-off was treated with an application of lime and restored with grass seed and straw.
The cost associated with the mitigation of this incident amounted to $5,681.07. The approximate cost to the
Utility to have treated 1,500 gallons of wastewater would have been approximately $2.25. The City saved no
money from this spill. Its costs for cleanup and repair exceeded the cost of treating the volume of sewage had
no spill occurred. Furthermore, the City still had to pay for treating the greater volume of sewage created by the
spill.
The incidents leading to this spill can be considered exceptional, unintentional, temporary, and caused by
factors beyond our reasonable control. Furthermore, the SSO could not have been prevented by exercising
reasonable control, such as routine operations and maintenance, adequate treatment facilities, or collection
system facilities or components. This asset has been identified for additional assessment and a possible capital
improvement project for replacement.
A press release notification related to this incident was requested to be published in the Raleigh News &
Observer on August 28 and August 28, 2023. There have been no further sewer incidents associated with this
location. See Exhibit 4 — Press Release
No additional issues have been associated with this section of the collection system since the last sewer
incident.

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10

Incident Number # 202301220 — 8/27/2023 — 5042 Tryon Road., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a large quantity of debris that entered the wet well,
affecting the pump cycle and wastewater flow capacity.
On the night of 8/27/2023 at approximately 11:10 PM, Raleigh Water's SCADA (supervisory control and data
acquisition system) received a high wet well alarm from pump station # 44-Silver Lake, located at 5044 Tryon Rd.
Responding crews arrived on site at approximately 11:30 PM on the same day and found that both pumps had
tripped an overloaded breaker. 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 incident by 2:10 AM on 08/28/2023.
To mitigate the incident, responding crews utilized a vacuum truck to keep the flow of untreated wastewater
below spill levels and within the wet wells of the station. Crews removed both pumps and cleared massive
amounts of debris and rags from their impellers and wet wells. This incident also caused a blockage in the
receiving force main that had to be removed before the pump station was returned to normal operation.
To dislodge the debris, Crews attempted to throttle the flow back and forth until the stoppage was successfully
dislodged, minimizing the continued release of untreated wastewater.
Restoration of this spill event consisted of washing the land surrounding the station. Sewer debris and solids
were collected and disposed of accordingly. Crews utilized ample potable water to flush the affected area. This
spill was contained without a significant environmental impact on the adjacent area and its natural resources.
Visual inspection of the affected area and downstream waters confirmed that no fish kill or unnecessary
vegetative damage occurred.
This event resulted in the approximate loss of 1,900 gallons of untreated wastewater reaching an unnamed
tributary to Swift Creek (Yates Mill Pond). See Exhibit 1 • Area of Operation.
Exhibit-1 Area d Operation
11

The cost associated with the mitigation of this event was $1,176.29. The approximate cost to the Utility to have
treated 1,900 gallons of wastewater would have been approximately $2.85. 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 for treating the greater volume of sewage created by the spill.
This pump station services a vast residential and commercial area within the Tryon Rd corridor. There has been
no history of asset failures associated with this Sewer Network Structure. Before this event, maintenance
records show that this station was serviced as follows:
Work Order #
Activity
Date completed
Findings
1025777
PU Suction Lift P.S. Check
2023-08-1412:41 PM
No findings
1028529
PU Suction Lift P.S. Check
2023-08-2109:28 AM
No findings
1031734
PU Suction Lift P.S. Check
2023-08-29 08:02 AM
No findings
1039414
PU Suction Lift P.S. Check
2023-09-06 09:11 AM
No findings
1040085
PU Suction Lift P.S. Check
2023-09-1312:13 PM
No findings
1046628
PU Suction Lift P.S. Check
2023-09-19 07:59 AM
No findings
1048162
PU Suction Lift P.S. Check
2023-09-27 10:00 AM
No findings
No additional issues have been associated with this section of the collection system since the last sewer event.
The station continues to be assessed to ensure no other malfunctions occur. A press release notification
associated with this event was requested to be published in the Raleigh News & Observer on August 28, 2023
(see exhibit 2 — Press Release).
Exhibit 2 - Press Release
Raleigh Water Responds to a Sanitary Sewer Overflow
On Sunday August 27, 12 41pm, Raleigh Watet ate wan mOW of a sanitary
savmr overfow h1ha vkdnty of %" Tryan Rd. ReloO NC Upon sr".INRRy
Ratpondsre kknbled an stabs sewer owrlow ('"Wag !arty" n'fulcdon wRbln
a prarnp atedon TM reapondrhp shah took al reasonable steps to slop and mwgate rim
andorrs Impact as won as d" anteed. Tho NaM Csf W a Depa *Mffl of
Emiamnental Ou*My. Dkiko of Water Rnaua:as has been naded of the owrlaw
Raleigh Wow stall ocalsirred the averfow at appmdmagFy 2.10 am an August
28 2023 h Is.admeted that the ararlow dedwged a volume or spprmdnnstsy 190
galore al untreaed waslewala wfiidr did nadh a alarm fish ere dkMlalq Mated
an u nanwd trbulary to Sdh Crank (Yaws tell p[nd}. RMoredorh for fis stare teas
been cum~- No vegetable damage w fah Ids has been obsenvd rutted to this
avant as the waste water dd reach surface water
Raleigh Wale; has in aWeaWe edmadan and enimunare program to
prevent the dls re of grease, debris. wipes. rags. dens and oehw knpr%w
matedds in the meet ayatem and fo take enfwewnwd ac8en ratan
approptWe Ifthese hems make N sea the sewer system, they may cause a
spw which can have an adverse l r"d on water quagly and arndango those
who oon» Wo wflbd with the aleded ten.
Water b nnan waste. and to$M tlssue are the only Rams panritled to be
dadwW kdo the mm system Al other itenru wil ause damage lethe
eaw« system and we net pamdtted.
Nyou n�erleaw wrcreshra eewer wnels w sae sewer aping Imm maNwles
w plpss. pkeu cal 91199E3245 to report kwnedataly
For mme WcurnMfon about hew you can help prevent swAmy serer sews.
ples"vW raieigamoftmatw
Thin news fMomm le mqukedby NCGS Article21 cu" ie3.24.1C.
MYie
12

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 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 preventive maintenance program to maintain over 2,644 miles
of sanitary sewer pipe and minimize the accidental release of untreated wastewater.
Since July 2023 (Fiscal Year 2024), the Utility has maintained approximately 503.4 11] 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 $290,055.31 [21,
approximately 1% of the Division's annual operating budget. The 8,750 gallons of untreated wastewater,
identified as notice of violations in this letter, cost the Utility approximately $22,245.32 to mitigate. The City's
cost of sewer treatment per gallon is $.0015 [3]. At this rate, treating the untreated wastewater spilled would
cost the City $13.12. 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 for treating 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
incident's severity and complexity. The City continues demonstrating due diligence in environmental
performance by allocating resources to a spill incident regardless of the associated cost. This effort is noted in
the City's SSO performance rate of 0.02 total SSO rate 141 per 100 miles of pipe, compared to the Southeastern
Region of the U.S., of 7.0 spills per 100 miles of line.
[11503.4 miles represents approximately 19%of the entire sanitary sewer collection system
]2] Associated operational cost year to date for FY2024
OPERATION LINEAR FEET
linear Miles
COST
CCTv 23.2
$94,642.00
$122,947
Repair 2667
0.5
$64,133.34
Flushing 540838.4
102.4
$111,176.25
Easement 171027
32.3
$30,103.72
Easement Inspection 1821520
345
$0.00
The total cost of Business to Date is
Total- 2,658,899 Ft 1503.4 MILES
$290,055.31
[3] F.Y. 2024 annual Divisional budget - $15,058,291
141 $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent
[5] The current 550 Rate for F.Y. 24 is 0.02
Note
In FY•2023, the Raleigh Water -Sewer Maintenance Division spent $2,054,254.45 in operations to maintain, repair, and inspect approximately 939.95 miles of
sanitary sewer infrastructure.
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
13

current industry standards, recognizing that they do not support compatibility in sanitary sewer collections
systems nationally. These agencies work collectively to challenge the testing protocols, assessment guidelines,
and consumer education and labeling of these non -dispersible.
Raleigh Water has an aggressive educational outreach initiative to address illicit discharges such as wipes, fats,
oil, and grease to commercial and residential users. Raleigh Water has developed a complimentary property
managers resource kit that provides best practice resources for establishing a property -specific awareness
program. Each kit contains brochures and complimentary gadgets to help residents manage grease and fat
collection and disposal. The resource kit also features a multimedia flash drive with videos and reproducible
educational material that property managers can use to educate tenants to reduce the risk of sewer backups
caused by the introduction of solids through their residential piping. Each kit costs Raleigh Water approximately
$85.00 to produce and is provided free of charge to the property management. Raleigh Water continuously
develops initiatives to increase residential and commercial customer partnerships to address grease
accumulation and prevent illicit incident discharges. The educational material and videos can be accessed
through social media and the Raleigh Water website: https:Hraleighnc.gov/sewer-maintenance
The City continues its monetary reward or bounty program, which pays out fifty ($50) to any citizen who
observes and reports an SSO or conditions that may cause a spill incident. 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 prevention message and
offering contact information throughout the service area daily. 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 materials that could block the flow of the sanitary
sewer mains. The City also circulates information regarding grease discharge into the sewer system and the
effects of such deposits. Whenever possible, and upon investigating the root cause of a spill incident, PUD Code
Enforcement officers develop and send registered informational letters about the spill incident to the customer
base serviced by the line where the SSO has occurred. This educational outreach 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-2023-DV-0342 issued for the month of August
2023 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, don't
hesitate to contact Matthew Vessie, Sewer Maintenance Superintendent, at [phone] or Carlos M. Perez,
-.ORC, Assistance Su erintendent, at 919-996-5929.
a�3
n rely,
Carlos M Perez, ORC
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-2erezcamacho r�raleighnc.Gov
14

ROY COOPER
C2wr! nor
ELIZABETH S. BISER
SE: rN�rti
RICHARD E. ROGERS. JR.
dhr r[ for
Certified Mail # 7020 3160 0000 4115 0189
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environrnenial Quality
September 06, 2023
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2023-DV-0342
Sanitary Sewer Overflows - August 2023
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition )
(2) of Permit No, WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as
to why the City of Raleigh should not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202301200 8/16/2023 223
202301204 8/22/2023
56
202301218 8/24/2023 304
1115 TEMPLE STREET, Roots
RALEIGH, , 27609
2609 SPRING FOREST
ROAD, RALEIGH, ,
27616
701 VAN BUREN ROAD,
RALEIGH, , 27604
3,600 3,600 Notice of Violation -
Intent to Assess
Roots 1,750 1,750 Notice of Violation
Pipe Failure (Break)
1,500 0 Notice of Violation
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D �� �:s'ri�4k Rr��rrv.l Cffllr.• tifkl)&kllk�kl 0� :k• i Ra3ryjl�. �i�.7�l:enkLrl:r 7il.h�1
a141NIA200

Incident Start Duration
Number Date (Mina) Location Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals)
DWR Action
202301220 8/27/2023 190 5042 TRYON ROAD, Pump station 1,900 1,900 Notice of Violation
RALEIGH, , 27606 equipment failure
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Kevin Fowler with the Water Quality Section in the
Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Cc: Laserfische
Sincerely,
OocuSigned by:
t/aln t.SSa f . M.avuAd
92916EBA632144F
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
ilhrtslon of Water Resources Form CS-SSO
PART I:
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00002
(WQCS# if active, otherwise use WQCSD#)
Facility: Raleigh Collection System Incident M 202301200
Owner: City of Raleigh
City: Raleigh County: Wake
Region: Raleigh
Source of SSO (check applicable): 0 Sanitary Sewer ❑ Pump Station 1 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): 1115 TEMPLE STREET, RALEIGH, , 27609
Manhole #: SMH113461
Latitude (Decimal Degrees): Longitude (Decimal Degrees):
Incident Started Dt: 08/16/2023 Time: 5:57 pm Incident End Dt: 08/16/2023 Time: 09:40 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 3,600 gallons Estimated Duration (Round to nearest hour): 3:43 hours
Describe how the volume was determined: 15 gal min x 240 minutes
Weather conditions during the SSO event: dry
Did SSO reach surface waters?
Surface water name: Mine Creek
0 Yes [:]No ❑ Unknown Volume reaching surface waters (gals): 3600
Did the SSO result in a fish kill? ❑ Yes MNo ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
W Roots
24 hour verbal notification (name of person contacted ): Tyler Clark
[� DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 08/17/2023 Time (hh:mm AMIPM): 01:13:00 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 Form Page

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Roots
Do you have an active root control program on the line 1 area in question? ❑ Yes 2 No 0 NA NE
Describe
This will be added to our root control program.
Have cleaning and inspections ever been increased at this location because of roots' Yes [0 No E NA NE
Explain:
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
The segments of line upstream and downstream will be cleaned using root cutters and then they will be CCTV'd to see
conditions of the assets.
What corrective actions are planned at the SSO location to reduce root intrusion?
This segment of sewer will be added to the root control program that we have established.
Has the line been smoke tested or videoed within the past year?
If Yes, when?
Comments:
System Visitation
ORC
Backup
Name:
Michael S Carpenter
Cert#
1009023
Date visited:
08/16/2023
Time visited:
06:40 PM
Yes JZ No ❑ NA C NE
❑ Yes
W Yes
CS-SSO Form Page: 2

How was the SSO remediated (i.e. Stopped and cleaned up)?
Crews pulled hose to the downstream manhole and using hydraulic netting were able to break the blockage. Containment
was set up in the storm drainage ditch downstream and the crews washed the area around the manhole and also using a
fire hydrant and a dechlorinator ran water in the channel to reduce any contamination. They then washed any areas that
may have had residual waste. The area around the manhole had lime, seed, and straw for restoration.
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: David Raymond Jackson
Date: 08/23/23 08:18 am
Signature: Title:
Telephone Number:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of i
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 3

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} � Y

STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
SYSTEM -WIDE COLLECTION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable laws, Rules, and Regulations, permission is hereby granted to the
City of Raleigh
WQCS00002
FORTHE
operation and maintenance of a local sewer permitting program, pursuant to the local permit program
approval for public gravity sewers granted by the North Carolina Environmental Management Commission
effective May 1,1986, and in conformity with 15A NCAC 2T .0306 and other supporting data subsequently
filed and approved by the Department of Environment and Natural Resources and considered a part of this
permit; and
operation and maintenance of a wastewater collection system consisting of, at the time of permit issuance,
approximately 2283 miles of gravity sewer, approximately 112 miles of force main, 517 simplex pump
stations that discharge to a pressure sewer and serve a single building and 4 simplex pump stations without
permanent pump reliability that serve more than one building,107 duplex pump stations, and all associated
piping, valves, and appurtenances required to make a complete and operational wastewater collection
system to serve the City of Raleigh, Garner, Wake Forest, Rolesville, Knightdale, Wendell, Zebulon and any
deemed permitted satellite communities and the tributary wastewater collection systems serving the
Towns of Apex, Clayton and Middlesex subject to their own individual collection system permit, pursuant
to the application received May 19, 2015, and in conformity with the documents referenced therein and
other supporting data subsequently filed and approved by the Department of Environmental Quality and
considered a part of this permit.
This permit shall be effective from June 6, 2017 until January 31, 2024, and shall be subject to the following
specified conditions and limitations:
Page 1 of 8

i. PERFORMANCE STANDk a
1. The sewage and wastewater collected by this system shall be treated in the properly permitted
Wastewater Treatment Facility identified in the permit application and documented in the Division's
database. [15A NCAC 02T .0108 (b)]
2. The Director may take enforcement action against the Permittee for SSOs that must be reported to the
Division as stipulated in Condition IV (2). This includes SSOs that were caused by severe natural
conditions or exceptional events unless the Permittee demonstrates through properly signed,
contemporaneous operating logs, or other relevant evidence that:
a. The SSO was caused by severe natural conditions; there were no feasible alternatives to
the SSO, such as the use of auxiliary treatment facilities, retention of untreated wastewater,
reduction of inflow and infiltration, use of adequate back-up equipment, or an increase in
the capacity of the system. This provision is not satisfied if, in the exercise of reasonable
engineering judgment, the Permittee should have installed auxiliary or additional collection
system components, wastewater retention or treatment facilities, adequate back-up
equipment or should have reduced inflow and infiltration; or
b. The SSO was exceptional, unintentional, temporary and caused by factors beyond the
reasonable control of the Permittee; the SSO could not have been prevented by the
exercise of reasonable control, such as proper management, operation and maintenance;
adequate treatment facilities orcollection system facilities or components (e.g., adequately
enlarging treatment or collection facilities to accommodate growth or adequately
controlling and preventing infiltration and inflow); preventive maintenance; or installation
of adequate back-up equipment;
The Permittee can submit a claim to the Division Regional Office that the SSO meets the criteria of
this condition. The Permittee has the option of submitting this claim along with the spill report
required by Condition IV(2) (i.e., within five business days) in order to be considered for immunity
from enforcement action. Form CS-SSO Part 11, or most current Division approved form, shall be
used for any claims. The Permittee has the burden of proof that the above criteria have been met.
[G.S. 215.6A;15A NCAC 02T .0108(b)]
3, The Permittee shall establish by ordinance, inter -local agreement or contract its legal authority to
require new sewers be properly constructed; to ensure proper inspection and testing of sewer mains
and service laterals; to address flows from satellite systems and to take enforcement action as required
by Condition 1(4). [G.S.143-215,98; G.S.143-215.1(f)(1.))
4. The Permittee shall develop and implement an educational fats, oils and grease program that shall
include at least semiannual distribution of educational material targeted at both residential and non-
residential users. The Permittee shall also develop and implement an enforceable fats, oils and grease
program for non-residential users under which the Permittee can take enforcement against users who
have not properly installed, operated and maintained grease traps or grease interceptors as directed
or otherwise violated the terms of the enforcement program pertaining to fats, oils and grease.
115A NCAC 02T .0108 (b)]
5. The Permittee shall adopt and implement a Capital Improvement Plan (CIP) to designate funding for
reinvestment into the wastewater collection system infrastructure. The CIP should address the short-
term needs and long-term "master plan" concepts. The CIP should typically cover a three to five year
period and include a goal statement, description of the project area, description of the existing facilities,
known deficiencies (over a reasonable period) and forecasted future needs. Cost analysis is integral to
the CIP. [G.S. 143-215.9B)
PROP 7 of R

6. Overflow piping from mal Fes and pump stations, excluding pip io approved equalization
structures, known or discovered after permit issuance shall be immediately removed or permanently
capped. Plugged or valved emergency pumping connections are allowable for portable pumping or
rerouting without intentionally bypassing the wastewater treatment facility.
[15A NCAC 02T .0108 (b)]
7. The Permittee shall maintain a contingency plan for pump failure at each pump station. If one of the
pumps in a pumpstation containing multiple pumps fails, the process of repairing or replacing the pump
shalt be initiated Immediately and the new parts or pump shall be installed as soon as possible. The
permittee shall provide justification for delay in Initiating the process for repair or replacement at the
Division's request. If the pump in a simplex pump station serving more than a single building or pump
stations not capable of pumping at a rate of 2.5 times the average daily flow rate with the largest pump
out of service fails, it shall be replaced immediately. (15A NCAC 02T .0305 (h) (1))
8. Each pump station shall be clearly and conspicuously posted with a pump station identifier and an
emergency contact telephone number at which an individual who can Initiate or perform emergency
service for the wastewater collection system 24 hours per day, seven days per week can be contacted.
This emergency contact telephone number shall be coupled with instructions that the emergency
contact should be called If the visual alarm illuminates, if the audible alarm sounds, or if an emergency
is apparent. [15A NCAC 02T .0305 (h) (2))
9. Pump station sites, equipment and components shall have restricted access.
[15A NCAC 02T .0305 (h) (4))
10. Pump stations that do not employ an automatic polling feature (i.e. routine contact with pump stations
from a central location to check operational status of the communication system) shall have both
audible and visual high water alarms. The alarms shall be weather-proof and placed In a clear and
conspicuous location. Permits issued for the construction of pump stations that included high water
alarms in the description must maintain the alarms even if simple telemetry (i.e. notification of an alarm
condition initiated by the pump station control feature) is installed.
[15A NCAC 02T .0305 (h) (1))
12. For all newly constructed, modified and rehabilitated pump stations, all equipment and components
shall be sealed within a corrosion -resistant coating or encasement to the extent practicable and
equivalent to the minimum design criteria unless the permittee can demonstrate it is not practicable
or another form of corrosion resistance is employed. 115A NCAC 02T ,0108 (b)j
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. Upon classification of the collection system by the Water Pollution Control System Operators
Certification Commission (WPCSOCC), the Permittee shall designate and employ a certified operator to
be in responsible charge (ORC) and one or more certified operator(s) to be back-up ORC(s) of the
facilities in accordance with 15A NCAC 8G .0201. The ©RC shall visit the system within 24 hours of
knowledge of a bypass, spill, or overflow of wastewater from the system, unless visited by the Back -Up
ORC, and shall comply with all other conditions of 15A NCAC 8G .0204.
[15A NCAC 08G .0200 et.seq.I
2. The Permittee shall develop and adhere to a schedule for reviewing all inspection, maintenance,
operational and complaint logs. If the review process results in the identification of any recurring
problem In the wastewater collection system that cannot be resolved in a short time period, the
Permittee shall establish a plan for addressing the problem(s). 115A NCAC 02T .0108 (b))
3. The Permittee shall develop and adhere to a schedule for testing emergency and standby equipment.
[15A NCAC 02T .0108 (b)]
Page I of R

4. The Permittee shall develop and implement a routine pump station inspection and maintenance
program which shall include the following maintenance activities:
a. Cleaning and removing debris from the pump station structure, outside perimeter, and wet
well;
b. Inspecting and exercising all valves;
c. Inspecting and lubricating pumps and other mechanical equipment; and
d. Verifying the proper operation of the alarms, telemetry system and auxiliary equipment,
[15A NCAC 02T .0108 (b)]
5. for each pump station without pump reliability (Le. simplex pump stations serving more than a single
building or pump stations not capable of pumping at a rate of 2.5 times the average daily flow rate with
the largest pump out of service), at least one fully operational spare pump capable of pumping peak
flow shall be maintained on hand. [15A NCAC 02T .0305 (h) (1) (A)]
5. The Permittee shall maintain on hand at least two percent of the number of pumps installed, but no
less than two pumps, that discharge to a pressure sewer and serve a single building, unless the
Permittee has the ability to purchase and install a replacement pump within 24 hours of first knowledge
of the simplex pump failure or within the storage capacity provided in a sewer line extension permit.
[15A NCAC 02T .0108 (b)]
7. Rights -of -way and/or easements shall be properly maintained to allow accessibility to the wastewater
collection system unless the Permittee can demonstrate the ability to gain temporary access in an
emergency situation where existing land -use conditions do not allow the establishment and
maintenance of permanent access. in this case, the Permittee shall continue to observe the lines
visually, utilize remote inspection methods (e.g. CCTV) and use the opportunity of drier conditions to
perform further inspections and necessary maintenance. [15A NCAC 02T .0108 (b)]
8. The Permittee shall assess cleaning needs, and develop and implement a program for appropriately
cleaning, whether by hydraulic or mechanical methods, the wastewater collection system. At least 10
percent of the gravity wastewater collection system, selected at the discretion of the ORC, shall be
cleaned each year. Preventative cleaning is not required for sewer lines less than five years old unless
inspection otherwise reveals the need for cleaning or cleaning is required by a sewer line extension
permit. [15A NCAC 02T .0108 (b)]
9. The Permittee shall maintain a Response Action Plan that addresses the following minimum items:
a. Contact phone numbers for 24-hour response, including weekends and holidays;
b. Response time;
c. Equipment list and spare parts inventory;
d. Access to cleaning equipment;
e. Access to construction crews, contractors and/or engineers;
f. Source(s) of emergency funds;
g. Site restoration and clean up materials; and
h. Post-SSO assessment.
[15A NCAC 02T .0108 (b)]
10. The Permittee, or their authorized representative, shall conduct an on -site evaluation for all 55Os as
soon as possible, but if feasible no more than two hours after first knowledge of the SSO. The Permittee
shall document in its 5-day report why it was unable to initially respond to any 5SO location within two
hours. 115A NCAC 02T .0108 (b)]
pave a of R

11. In the event of an SSO or bl e within the wastewater collection syst( ) he Permittee shall restore
the system operation, remove visible solids and paper, restore any ground area and restore the
surroundings. [15A NCAC 02T.0108 (b)]
Ill. RECORDS
1. Records shall be maintained to document compliance with Conditions 1(4),11(2) - II(4), II(7) - II(8), IV(3)
and V(1) -V14). Records shall be kept on file for a minimum of three years. [15A NCAC 02T.0108 (b)]
2. The Permittee shall maintain adequate records pertaining to SSOs, and SSO or wastewater collection
system complaints for a minimum of three years. These records shall include, but are not limited to,
the following information:
a. Date of SSO or complaint;
b. Volume of wastewater released as a result of the SSO and/or nature of complaint;
c. Location of the SSO and/or complaint;
d. Estimated duration of the SSO;
e. Individual from the Division who was Informed about the SSO and/or complaint, when
applicable;
f. Final destination of the SSO;
g. Corrective actions;
h. Known environmental/human health impacts resulting from the SSO; and
I. Mow the SSO was discovered.
[15A NCAC 02T.0108 (b)]
3. The Permittee shall maintain an up-to-date, accurate, comprehensive map of its wastewater collection
system that also notes the locations where other wastewater collection systems become tributary. If
a comprehensive map of the collection system has not been established, a rough sketch shall be drawn.
The Permittee shall map approximately 10 percent of its existing collection system each year for the
next ten years beginning at the original permit issuance date, or until complete, whichever is sooner.
The comprehensive map shall include, but is not limited to: pipe size, pipe material, pipe location, flow
direction, approximate pipe age, and each pump station identification, location and capacity. 115A
NCAC 02T .0108 (b)]
4. The Permittee shall maintain records of all of the modifications and extensions to the collection system
permitted herein. The Permittee shall maintain a copy of the construction record drawings and
specifications for modifications/extensions to the wastewater collection system for the life of the
modification/extension. Information concerning the extension shall be incorporated into the map of
the wastewater collection system within one year of the completion of construction. The system
description contained within this permit shall be updated to include this modification/extension
Information upon permit renewal. 115A NCAC 02T.0108 (b)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. In the event of an $50 the Division may require monitoring that is necessary to ensure surface water
and groundwater protection and an acceptable sampling and reporting schedule shall be implemented.
[15A NCAC 02T.0108 (c)]
Pace 5 of 9

2. The Permittee shall ven report to_ Division of Water #tesour Itaff member at the Raleigh
Regional Office, at telephone number [phone] as soon as possible, but in no case more than 24
hours following first knowledge of the occurrence of the following circumstances within the collection
system which is under the Permittee's ownership or maintained and operated by the Permittee through
a perpetual legal agreement:
a. Any SSO and/or spill over 1,000 gallons to the ground; or
b. Any SSO and/or spill, regardless of volume, that reaches surface water.
Voice mail messages or faxed information shall not be considered as the initial v, erbal report. SSOs (and
other types of spills) occurring outside normal business hours may also be reported to the Division of
Emergency Management at telephone number [phone] or [phone].
Persons reporting any of the above occurrences shall file a spill report by completing Part I of Form CS-
SSO (or the most current Division approved form), within five business days following first knowledge
of the occurrence. This report shall outline the actions taken or proposed to ensure that the problem
does not recur. [G.S.143-215.iC(a1)]
3. The Permittee shall meet the annual reporting and notification requirements provided in North Carolina
General Statute §143-2151C.
V. INSPECTIONS
1. The Permittee or the Permittee's designee shall inspect the wastewater collection system regularly to
reduce the risk of malfunctions and deterioration, operator errors, and other issues that may cause or
lead to the release of wastes to the environment, threaten human health or create nuisance conditions.
The Permittee shall keep an inspection log or summary including, at a minimum, the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken by the
Permittee. [15A NCAC 02T.0108 (b)]
2. Pump stations that are not connected to a telemetry system (i.e., remote alarm system) shall be
Inspected by the permittee or its representative every day (i.e., 365 days per year). Pump stations that
are connected to telemetry shall be inspected at least once per week. [15A NCAC 02T .0108 (b)]
3. A general observation by the permittee or its representative of the entire wastewater collection system
shall be conducted at least once per year. [15A NCAC 02T .0108 (b)]
4. Inspections of all high priority lines (i.e. aerial line, sub -waterway crossing, line contacting surface
waters, siphon, line positioned parallel to stream banks that are subject to eroding in such a manner
that may threaten the sewer line, or line designated as high -priority in a permit) shall be performed at
least once per every six-month period of time. A list of high -priority lines is presented as Attachment A
and is hereby incorporated into this permit condition. New high priority lines installed or identified
after permit issuance are incorporated by reference and subject to this permit condition until permit
renewal where they shall be referenced in writing in Attachment A. [15A NCAC 02T .0108 (b)]
Vl. GENERAL CONDITIONS
1. This permit is not transferable, in the event that the Permittee desires to transfer ownership of the
wastewater collection system or there is a name change of the Permittee, a formal permit modification
request shall be submitted to the Division. The request shall be accompanied by documentation from
the parties involved, and other supporting materials as may be appropriate. Such request will be
considered on its merits and may or may not be approved. 115A NCAC 02T .0104; G.S. 143-215.2(d)(3)]
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2. Failure to abide by the conk �s and limitations contained in this permlti * )y subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statute §143-215.6A
through §143-215.6C, and a sewer moratorium may be established. [15A NCAC 02T .0104]
3. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances that may be imposed by other government agencies (i.e., local, state,
and federal) having jurisdiction. [G.S.143-215.1(b)]
4. The issuance of this permit does not prohibit the Division from reopening and modifying the permit,
revoking and reissuing the permit or terminating the permit as allowed by the laws, rules, and
regulations or as needed to address changes in federal regulations with respect to the wastewater
collection system, in accordance with required procedures. [G.S. 143-215.1(b)(4)]
5. The Permittee shall pay the annual fee within thirty (30) days after being billed by the Division. Failure
to pay the fee accordingly may cause the Division to initiate action to revoke this permit.
(15A NCAC 02T .0110 (4)]
6. The Permittee shall file an application for renewal of this permit at least six months prior to the
expiration of this permit. Upon receipt of the request, the Director will review the adequacy of the
wastewater collection system described therein, and if warranted, will extend the permit for a period
of time and under such conditions and limitations, as the Director may deem appropriate. [15A NCAC
02T .0109]
7. The Permittee shall notify the Division's Pretreatment, Emergency Response and Collection Systems
Unit in writing at 1617 Mail Service Center, Raleigh, North Carolina 27699 of any changes to the name
and/or address of the responsible party (i.e. mayor, city/town manager) of the wastewater collection
system. (15A NCAC 02T .0106 (c)]
B. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the collection system at
any reasonable time for the purpose of determining compliance with this permit, may inspect or copy
any records that must be maintained under the terms and conditions of this permit, and may obtain
samples of wastewater, groundwater, surface water, soil, or plant tissue.
[15A NCAC 02T .0110 (3)]
9. The Permittee or their authorized representative shall have available a copy of this permit to present
upon request by any duly authorized officer, employee, or representative of the Division.
[15A NCAC 02T .o104]
Vll. Special Conditions
The local sewer permitting program that has been delegated to the Permittee by the Environmental
Management Commission (EMC) may be suspended or revoked unless the documentation within the
approved delegation application package and any modifications thereto are valid, the requirements in
15A NCAC 2T .0306 and General Statute §143-215.1(9 are met, the conditions of this permit are met,
and the wastewater collection system extensions are constructed in accordance with the conditions
and specifications of the delegated program. [G.S.143-215.1(f)(1))
2. The local sewer permitting program shall require that all wastewater collection system extensions meet
the minimum design requirements in 15A NCAC 2T .0305 as well as any Division adopted minimum
design criteria. (G.5.143-215.1(f)]
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3. The local sewer permittir+, ogram shall obtain approval from the Ralt :Regional Office, at telephone
number [phone], prior to issuing any permits for wastewater collection system extensions in
accordance with the agreement between the Regional Office Regional Office and the Delegated
Program for block flow allocation. 115A NCAC 02T .0306 (d) (1)l
4. The local sewer permitting program shall submit quarterly reports to the appropriate Division Regional
Office on forms provided or approved by the Division. [15A NCAC 02T .0306 (d) (2))
5. The Division shall continue to permit activities not delegated to the Permittee as specified in the
delegation approval letter or in accordance with 15A NCAC 02T .0306(a). [15A NCAC 02T .0306 (a))
Permit issued this the Wh of June, 2017
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
for S. Jay Zimmerman, P.G.
Director, Division of Water Resources
By Authority of the Environmental Management Commission
by Deborah Gore, Pretreatment, Emergency Response, Collection System Unit Supervisor
Division of Water Resources, NCDEQ
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