WQCS00002_NOV-2024-DV-0269_20240715

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Raleigh Water
July 15", 2024
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDE=Q
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Response to NOV-2024-DV-0269
Sanitary Sewer Overflows — May 2024
Permit No. WQCS00002
Dear Mrs. Manuel:
Please allow this letter to respond to the Notice of Violation document (NOV-2024-DV-0269) dated June
13th, 2024, and received by Raleigh Water on June 25th, 2024. This document contains the narrative regarding
the pending Notice of Violation action of 3 Sanitary Sewer Overflow (SSO) incidents reported during May 2024
within the City of Raleigh Collections System [1]. This document also provides exhibits to prove our efforts to
mitigate the sewer incident. The noticed incidents occurred while the City operated its collection system,
according to WQCS00002, dated June 06th, 2017. The permit includes the language outlined in footnote one
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 incident, listed with the intended NOV-NOI action.
Please find below the additional information requested for the SSO incident.
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;
[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 backup equipment, or an increase in the capacity of the system. This provision is not
satisfied if, in the exercise of reasonable engineering judgment, the Permittee should have installed auxiliary or additional collections system components, wastewater
retention or treatment facilities, adequate backup equipment, or should have reduced inflow and infiltration or
[b.i The 550 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 or collection facilities or components (e.g.,
adequately enlarging treatment of collection facilities to accommodate growth or adequately controlling and preventing infiltration and inflow[; preventative
maintenance; or installation of adequate backup equipment;"

Incident Number # 202400855 — 5/3/2024 —10320 Globe Road, Morrisville, NC, 27560
This incident was neither willful nor intentional; it was identified during a site assessment in which dry paper
debris (consistent with untreated wastewater debris) was recognized to have been discharged around a sewer
manhole connected to a 30-inch sewer gravity main. The identified debris field was consistent with
accumulating approximately 5,498 gallons of untreated wastewater without evidence that the flow reached
surface waters. The root cause of this event was not identified, as the connecting sewer main was flowing as
designed during the initial response. The specific timeframe of this incident was not determined. The incident
was recorded within the Little Brier Basin (see exhibit 1—Area of Operation)
The restoration of this operation consisted of mechanical removal of sediments from the topsoil. The area
around the manhole was cleared of debris, treated with lime, and restored with wood chips for natural
coverage.
Exhibit 2 - Restoration Effort.
The cost associated with mitigating this incident amounted to $10,558.54. The approximate cost to the Utility to
treat 5,498 gallons of wastewater would have been $8.24. 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 to treat the greater volume of sewage created by the spill.
This section of the collection system is located downstream of an industrial /commercial area. The pipe size is
designed to self -scour hydraulically, moving debris downstream without requiring conventional flushing
cleaning. Within the last ten years, this specific portion of the collection system has yet to experience any 550.
Sanitary sewer assets in this area have been routinely maintained.

A press release notification was requested to be published in the Raleigh News & Observer as required by NCGS
Article 21, Chapter 143.215.1C. See Exhibit 3 — Press release.
Exhibit 3 — Press release
Raleigh Water Responds to a Sanitary Sewer Overflow
on Fdday, May 3,d, 2a2a M appratdemlely 2 3a PM. Raleigh W,ln sLdlware
Upon
nod9ed of a sam'!ary sewer everflawneer 1g320 Globe Rd-. Mnnisvaa, faC.
a_al "ily Responders Mentlaed that a sewn arerAow had —red the rod cause
is under hrvosdgadm This Inddent heard aNeded the rwnrvl goo of unhealed
waslawelerfro. the 304,oh sewer gravlly road. Th. re.poma.g 9.10 we tairinq an
aeaname seepsm mitlgale doe ovnAwrs envlmrunemazlmpad The NoAfi Cerebra
Ceparinwal of Emhormenlal Natty. Ohdaian f%tm Raw —. has hean noHRed
of New 11—
Based g ar inodent assassmerrL it Is satimated that the overflow mq have
dscharprl appmaunaldy 5.900 gaaans .f ert awled waslawanr. W kh remained In
the nalrral topography and dfd nM reach the stale ssvten welers Resldah¢nfe IN,
'ncident 1, -going
• Rafelo Water has an agg—Na edbwbn and erA—menl onaTam to
I. M he &a6.ge of grease d h,8. vAp. rage, diapma and other krrpropa•
materials In the sower system and to lake eMmce M action where
npgopdam 11 Mesa Bare make a into the sewer system Meg may "me a
spill *kh ran have an ad —impact an warn w.kly and endanger Urn..
who cone has comes Ydffi d1e effeaed arai9
• Waterhuman want., and Ickal ti are the only items perrAed to ire
da ,rd Isla Ure Soper Syslem. All nrher h.rrb pe 4aaTe damu]. la R.
sewer sy.tam and are ..I pematted
II you e.pe"—eaoesetae sewer smeh ar sne sawm p0ling from manhol..
a plpas. pease cap 919-996-12451. '.pod immaa.lag
For mare krfarm-lion eb.A how you can help pravam 1111A.V firer spills
pleaoe v{vl raleighno geVAYas.
This nets rekes. is regrlred by NCGS A16:1.21, M ptar 1 d321SAC
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 CCTV Repair Easement
Inspections Activities
Maintenanc
activities Activities Activities a Activities
Manhole
Sewer High -Priority Inspection
Inspection
5/4/2024 5/3/2024 5/20/2024 12/7/2022
9/27/2017
11/15/2017
8/6/2020
4/13/2023
9/28/2017
11/16/2017
9/16/2020
5/29/2024
9/29/2017
11/17/2017
10/19/2020
6/28/2024
5/11/2021
5/3/2018
4/9/2021
5/12/2021
9/26/2018
10/6/2021
3/14/2022
9/26/2018
10/12/2021
12/28/2023
9/28/2018
3/14/2022
10/2/2018
10/14/2022
10/12/2018
10/17/2022
5/8/2019
3/27/2023
5/9/2019
7/11/2023
10/31/2019
7/19/2023
3/30/2020
3/27/2024
3/30/2020
It's important to reiterate that no additional sewer issues have been associated with this section of the
collection system since the last sewer incident. This positive progress is a testament to the effectiveness of our
maintenance efforts, making this site an active maintenance spot pending the completion of further CCTV
assessment, sewer main cleaning, and chemical root control application.

Incident Number # 202400944 — 5/16/2024— 7401 Sandy Creek Dr., Raleigh
This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of an 8-in
gravity sewer main. The root intrusion led to a sewer spill of approximately 2,600 gallons of untreated
wastewater reaching an unnamed tributary within the Mine Basin (see exhibit 1—Area of Operation)
On 5/16/24, at approximately 6:45 PM, Raleigh Water staff responded to a sanitary sewer overflow emanating from a
sanitary sewer manhole (affected sewer asset SMH127474, see exhibit 2 - Affected Asset / Root Intrusion) located near
7401 Sandy Creek Dr., 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 8:20 PM on the same day. Crews utilized hydraulic jetting to remove the
source of the blockage within the affecting asset, thus restoring sewer flow.
Exhlbit 2 - Affected Asset / Ront Intruslon
4

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. See Exhibit 3 — Restoration
Efforts.
Exhibit 3 — Restoration Efforts
The cost associated with the mitigation of this incident amounted to $5,793.60. The approximate cost to the
Utility to treat 2,600 gallons of wastewater would have been approximately $3.90. 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 to treat the greater volume of sewage created by the spill.
This section of the collection system is located downstream of a residential area. It provides sewer collection
services to several residences surrounding the spill incident. Within the last ten years, this specific portion of the
collection system has not experienced a root intrusion SSO. Sanitary sewer assets in this area have been
routinely maintained with 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 5 — Press release.
5

Exhibit 5 — Press Release
Raleigh Water Responds to a Sanitary Sewer Overflow
On Thursday, May 16th, 2024, at approximately 6 45 PM, Raleigh Water staff
were notfied of a sanitary sewer overflow near 7401 Sandy Creek Dr., Raleigh_ NC.
Upon arrival, Utility Responders identified an active sewer overflow from a sewer
manhole. affecting the normal flow of untreated wastewater from the connecting sewer
gravity main The responding staff took all reasonable steps to mitigate the overflow's
environmental impact. The North Carolina Department of Environmental Quality,
Division of Water Resources, has been notified of the overflow,
Based on a site assessment it was estimated that the overflow may have
discharged approximately 2 600 gallons of untreated wastewater. reaching the surface
waters of an unnamed tributary within Mine Basin No vegetative damage or fish kill
was observed related to this event Restoration for the Incident was completed on the
same day
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debris. wipes. rags. diapers and other improper
materials in the sewer system and to take enforcement action where
appropriate. If these Items make fl into the sewer system, they may cause a
spill which can have an adverse impact on water quality and endanger those
who come into contact with the affected areas.
• Water, human waste, and toilet tissue are the only items permitted to be
discharged into the sewer system An other items will cause damage to the
sewer system and are not permitted_
• If you experience excessive sewer smells or see sewer spilling from manholes
or pipes please call 919-996-3245 to report Immediately_
• For more Information about how you can help prevent sanitary sewer spills.
please visit raleighnc govhvater.
This news release is required by NCGS Article 21, Chapter 143.215.1C.
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
10/26/2017
10/9/2018
8/29/2019
9/3/2019
9/4/2019
9/5/2019
9/6/2019
5/20/2024
5/21/2024
6/20/2024
Easement
Inspection
11/14/2022
12/30/2022
4/26/2023
5/16/2023
6/5/2023
Manhole
Inspection
11/24/2020
12/14/2020
Inspections Activities
Sewer High Priority
Inspection
1/10/2018 4/19/2021
4/25/2018 8/30/2021
9/27/2018 4/5/2022
9/28/2018 9/16/2022
3/21/2019 3/1/2023
3/29/2019 7/26/2023
8/16/2019 11/2/2023
1/23/2020 1/24/2024
10/21/2020 4/15/2024
CCTV Activities
3/9/2017
2/22/2023
6/28/2024
7/11/2024
Easement
Maintenance
Activities
7/26/2023
5/4/2023
5/5/2023
5/8/2023
5/9/2023
5/10/2023
Repair Operations
1/28/2021

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. The "Zone of Influence" below was identified for further chemical root
control.

Incident Number # 202400949 — 5/17/2024 — 7104 Great Laurel DR. Raleigh
This spill was neither willful nor intentional; it resulted from a short circuit interruption that caused a
momentary shutdown of power, causing both pumps to stop generating a sanitary sewer overflow of
approximately 500 gallons of untreated wastewater outside of the confines of the station's wet well.
On the night of 05/17/2024, Raleigh Water's SCADA (supervisory control and data acquisition) recorded a high
wet well alarm from pump station #40-Brighton PS, located at 7104 Great Laurel Dr, Raleigh. Responding crews
arrived on -site 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 09:12 AM on the same day.
To mitigate the incident, responding crews utilized a vacuum truck to keep the flow of untreated wastewater
below spill levels and within the station's wet wells. Crews immediately re-established electrical power and
returned the pump to operation without damaging the electrical components.
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 500 gallons of untreated wastewater to reach an unnamed
tributary within Neuse Basin.
The cost associated with mitigating this event was $1,482.68. The approximate cost to the utility to treat 500
gallons of wastewater would have been approximately $.75. 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.
There has been no history of asset failures associated with this Sewer Network Structure.
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.
Incident Number # 202401026 — 5/31/2024 — 5265 Six Forks Rd., Raleigh
This incident was not an event experienced within the Raleigh Collection System. No work record or call in our
database indicates a collections system's SSO at this location on this date. A Basin -wide Incident Management
Report was initiated but not by Raleigh Water representatives. The report offered no information about the
incident, the incident's impact, volume, or specific timeline. We request that this incident be stricken for our
records as no SSO event is associated with the public infrastructure maintained by Raleigh Water at this address.

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 1,420 [1] 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 $2,735,282.91 [2],
approximately 2% of the Division's annual operating budget.
The mitigation of the 8,598 gallons of untreated wastewater identified as notice of violations in this letter cost
the Utility approximately $17,834.82. The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate,
treating the untreated wastewater spilled would cost the City $12.89. The City saved no money from these spills.
The mitigation costs well exceeded the cost of treating the volume of sewage had no spill occurred.
Furthermore, the city still had to pay to treat the greater sewage volume created by these spills. This fiscal
comparison shows the City's commitment to environmental protection, sparing no cost regardless of the spill
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 2.00 total SSO rate [4) per 100 miles of pipe, compared to the Southeastern
Region of the U.S., of 7.0 spills per 100 miles of line.
[1] 1,420 miles represents approximately 54% of the entire sanitary sewer coliection system
[2] Associated operational cost year to date for FY2024
OPERATION
LINEAR FEET
Linear Miles
COST
CCTV
585,531
Ill
$341,318.75
Repair
4,260
.80
$1,430,784.85
Flushing
2,334,592
442
5699,743.41
Easement
578,116
109
$263,435.90
Easement Inspection
3,995,104
757
N/A
Total- 7,498,603 Ft / 1,420 MILE5
The total cost of Business to Date is
$2, 735, 282.91
j3] F.Y. 2024 annual Divisional budget- $15,058,291
[4] $.o015 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 2.00
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
0

with other utilities nationwide through the National Association of Clean Waters Agencies (NACWA), the Water
Environment Foundation (WEF), and the American Public Works Association (APWA) to challenge INDA and
current industry standards, recognizing that they do not support compatibility in sanitary sewer collections
systems nationally. These agencies work collectively to challenge the testing protocols, assessment guidelines,
and consumer education and labeling of these non -dispersible.
Raleigh Water has an aggressive educational outreach initiative to address illicit discharges to commercial and
residential users, such as wipes, fats, oil, and grease. 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://raleighnc.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-2024-DV-0269 issued for May 2024 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
perintendent, 919-996-5929.
inc4reiy, Co!
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
[e-mail]
10

DocuSign Envelope ID: AEA9BC1MC244C01-8291-6742371862B7
JUN 2 5 2024
ROY COOPER
ELIZABETH S. BISER
RICHARD E. IZDGERS,.JR,
ihn+ I -a
Certifier! Mail # 7017 0190 0000 2486 1022
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
rnvironmrnraf Quuliry
June 13, 2024
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0269
Sanitary Sewer Overflows - May 2024
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as
to why the City of Raleigh should not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mips) Location Cause (Gals) (Gals) DWR Action
202400855 5/3/2024 100 10320 Globe Road, Other 5,498 5,498 Notice of Violation -
Morrisville, NC, 27560 Intent to Assess
202400944 5/16/2024
95 7401 SANDY CREEK Roots 2,600 2,600
DRIVE, RALEIGH,
27615
Notice of Violation -
Intent to Assess

DocuSign Envelope ID: AEA9B01B-9C24-4=-8291-6742371862B7
Total Vol
Total
Surface
Incident
Number
Start
Date
Duration
(Mins)
Location Cause
Vol
(Gals)
Water
(Gals) DWR Action
202400949
5/17/2024
64
7104 GREAT LAUREL Pump station
5,000
500 Notice of Violation
DRIVE, RALEIGH, equipment failure
27616
202401026
5/31/2024
Unknown
5265 SIX FORKS ROAD, Other
1,000
1,000 Notice of Violation
RALEIGH,27609
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 919-791-4261 or via email at [e-mail].
Sincerely,
I-, DocuSigned by:
uAw 'sso, f . h d
— 82916EOA832144F
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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