WQCS00013_NOV-2024-DV-0285_20240723

CADY
— LIVE INSPIRED'" —
July 23, 2024
Ms. Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
SCANNE
Received via email: July 23, 2024
CERTIFIED MAIL
Subject: Notice of Violation & Intent to Issue Civil Penalty: NOV-2024-DV-0285
Dear Ms. Manuel
On July 17, 2024, Cary received a Notice of Violation & Intent to Issue Civil Penalty letter
dated July 2, 2024, from the North Carolina Department of Environmental Quality, Division of
Water Resources — Raleigh Regional Office for a sanitary sewer overflow (SSO) that occurred
on June 1, 2024. The letter identifies the June 1 SSO as an NOV and requests written
response from Cary to provide additional information within 10 business days from receipt of
the letter.
Incident # Start Date :Duration
(mire)
20 2401025 1 6/ 112024 1 193
Location
309 Edgemore Debris in
Ave, Cary, 27519 line,
Grease
Total I Total Volume
DWR
Volume l Surface Water
Action
-PPA.-... Gal_
Notice of
7,720 7,720
Violation -
Intent to
Assess
Cary takes pride in the operation and management of our 1,000 miles of wastewater collection
system. We are an award winning and progressive wastewater utility that has very few
reportable or large volume SSO's. We place emphasis on responding quickly to sewer
emergencies to prevent and minimize any spills that impact our citizens, community, and
environment. We appreciate the opportunity to provide information on the recent sewer
overflow, our efforts, and justification for why additional enforcement action and civil penalty
should not be assessed to Cary_
INCIDENT # 202401025 -- 309 Edgemore Ave.
Sewer Overflow Cause -- On June 1, 2024, at 10:49AM, Cary staff received a call stating
there was a manhole overflowing along the greenway behind 309 Edgemore Ave. On -call
staff were immediately dispatched to investigate. Upon arrival, staff confirmed that manholes
SP73415001 and SP73415021 were overflowing. Staff located the downstream manhole
and proceeded quickly to clear the blockage that was caused by debris and grease with
hydraulic jetting equipment by 2:02PM.
919.469-4000 1 carync.gov
PO Box 8005 Cary, NC 27512

Sewer Spill Cleanup — After clearing the blockage and stopping the spill, staff immediately
began their sewer spill cleanup operations. Crews constructed a temporary dam, and the
creek was flushed using dechlorinated water. The sewer spill and flush water were pumped
back into the collection system for treatment and disposal.
Sewer Spill Assessment — Cary performed conductivity readings immediately following the
overflow to accurately assess the impact of the spill and to ensure we fully mitigated any
impacts to the stream. Cary staff also relied upon NCDEQ's sewer spill estimation guide to
precisely determine the spill volume.
Corrective Actions — After clearing the blockage, sewer lines in the surrounding area were
hydraulicly cleaned and video inspected to ensure there were no additional accumulations,
pipe defects, or partial sewer line blockages. On June 5, 2024, Cary's pretreatment supervisor
contacted nearby apartment communities and distributed our best management practices for
fats, oils, and grease, (FOG) minimization. Pretreatment staff performed inspections of the
two food service establishments (FSE) locations upstream of this area and noted they were
in compliance. Cary's 311 communications teams also sent out FOG best management
practices via Nextdoor to the surrounding community. Cary's Wastewater Collection System
management staff have added this area to our monthly recurring manhole inspection process.
We very much appreciate the opportunity to provide supplemental information on this
unfortunate sewer spill. We also appreciate NCDEQ's consideration in evaluating this sewer
spill, the cause, and Cary's record and response to immediately remediate and help ensure
that a SSO does not reoccur at this location. If we can answer any questions or provide any
additional information, please feel free to contact Mr. Chad Lemke, Wastewater Collection
System ORC at [phone].
Sincerely,
J 'e Revels, P.E.
Utilities Director
Cc: Chad Lemke, Wastewater Collection System ORC
Attachments:
NCDEQ Notice of Violation & Intent to Issue Civil Penalty: NOV-2024-DV-0285
• Collection System Sanitary Sewer Overflow 5-Day Report — Incident #
202401025
c :Ry

Comments:
SSO was not associated with a pump station.
Debris in line
What type of debris has been found in the line?
Rocks and sediment.
Suspected cause or source of debris
Unknown. Crews are inspectingmspecting manholes upstream of the SSO location to find potential source.
Are manholes in the area secure and intact? Q Yes ❑ No ❑ NA ❑ NE
When was the area last checked/cleaned?
Cleaned 811312016 and inspected on 5/2112024
Have cleaning and inspections ever been increased at this location due to previous ❑ Yes [0 No ❑ NA ❑ NE
problems with debris?
Explain:
Are appropriate educational materials being developed and distributed to prevent futi ❑ Yes ❑ No [0 NA ❑ NE
similar occurrences?
Comments
System Visitation
ORC ❑ Yes
Backup (0 Yes
Name:
James Bass
Cert#
1000054
Date visited:
06/01/2024
Time visited:
11:45 AM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Hvdraulic iettino eauioment was used to clear the blockage and stop the overflow —Crews constructed a temporary, darn a
the creek was flushed using de -chlorinated water. The sewerspilt and Rush water was pumped back into the sewers ste
for treatment and disoosal Sewer mains in the area were cleaned and video inspected to ensure no more blockages wer
present.
CS-SSO Form Page.- 3

As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Chad Lemke Date: 06/05/24 11:15 am
Signature: r2 Title: (Alle'k'v^ Old L
Telephone Number: Gf 1- I - 311- y S�7
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of f
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 4

State of North Carolina
DWR
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
DNIslon of Water Resources Form CS-SSO
PART 1:
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: WOCS00013 (WQCS# if active, otherwise use WQCSD#)
Facility: Cary Collection System Incident #: 202401025
Owner, Town of Cary
City: Cary County: Wake Region Raleigh
Source of SSO (check applicable): 2 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): 309 EDGEMORE AVENUE, CARY, .27519
Manhole #:
Latitude (Decimal Degrees)
Incident Started Dt: 06/01/2024 Time: 10A9 am
(mm-as-yyyy)
Estimated Volume of the SSO: 7.720
Describe how the volume was determined
Weather conditions during the SSO event:
Did SSO reach surface waters? FA Yes
Surface water name:
Bachelor Branch
Longitude (Decimal Degrees):
(nn:mm AMWIVI)
Incident End Dt: 06/01/2024 Time: 02:02 pm
(mm-dd-yyyy) (hh:mm AM/PM)
gallons Estimated Duration (Round to nearest hour): 3:13 hours
NCDEQ provided sewer spill estimation guide. Two manholes spilling with four 1"
Sunny
❑ No ❑ Unknown Volume reaching surface waters (gals): 7720
Did the SSO result in a fish kill? [] Yes [71 No ❑ Unknown If Yes, what is the estimated number of fish killed? 0
SPECIFIC cause(s) of the SSO:
M Grease [A Debris in line
24 hour verbal notification (name of person contacted ): Jerry Belcher
❑ DWR 0 Emergency Mgmt Date (mm-dd-yyy): 06/01/2024 Time (hh:mm AM/PM): 07:50:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15.000 gallons or more of untreated wastewater enters surface
waters, a rublic 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 11 must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form Page: 1

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Grease
When was the last time this specific line (or wet well) was cleaned?
08/13/2016
Do you have an enforceable grease ordinance that requires new or retrofit of grease R Yes ❑ No ❑ NA ❑ NE
traps/interceptors?
Have there been recent inspections and/or enforcement actions taken on nearby
restaurants or other nonresidential grease contributors?
Explain.
This is a residential area.
Have there been other SSOs or blockages in this area that were also caused by
grease?
When?
08/13/2016- Incident Number 201601396
If yes, describe them
Crews responded to a SSO in this area on 811312016 caused by grease.
Have cleaning and inspections ever been increased at this location?
Explain.
Have educational materials about grease been distributed in the past?
When?
February 2016 and August 2016
and to whom?
Residents in the general area of Hi hfield Ave and Glenmore Rd
Yes ❑ No RNA ❑ NE
PlYes ❑ No DNA E] NE
E]Yes RNo ❑NA F�NE
R Yes ❑ No 7 NA NE
Explain?
Residents received information about the SSO`s in the area and literature that states the detrimental effects of discharginc
grease and other unnecessary items Into the sanitary sewer system.
If the SSO occurred at a pump station, when was the wet well and pumps last
checked for grease accumulation?
Were the floats clean?
❑ Yes ❑ No 0 NA ❑ NE
CS-SSO Form Page: 2

oocu5ign Envelope lU 247Cg6l6-6E98-4CFB-8E45-829DE7360980
ROY COOPER
GwilTirif
ELIZABETH S. BISER
5'p[rpfpr�
RICHARD E. ROGERS, JR.
Oirtdor
Certified Mail # 7017 0190 000 24861046
Return Receipt Reguested
Jamie Revels, Utilities Director
Town of Cary
400 James Jackson Ave
Cary, NC 27513
NORM H CAROL NA
Environmental Qualify
July 02, 2024
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.. NOV-2024-DV-0285
Sanitary Sewer Overflows -June 2024
Collection System Permit No. WQCS00013
Cary Collection System
Wake County
Dear Permittee:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Reports submitted by
Town of Cary. The Division's Raleigh Regional Office concludes that the Town of Cary violated Permit Condition I
(2) of Permit No. WQCS00013 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 Town of Cary an opportunity to provide evidence and justification as
to why the Town of Cary should not be assessed a civil penalty for the violation(s) that are summarized below:
Incident Start Duration
Number Date (Mina)
Location
Cause
Total
Vol
(Gals)
Total Vol
Surface
Water
(Gals) DWR Action
707401D25 6/1/2024 193
309 EDGEMORE
Debris in line, Grease
7,720
7,720 Notice of Violation -
AVENIIE, CARY,
Intent to Assess
27519
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Docu5ign Envelope to: z07C961C-BE96-4CFB-6E45-R29C)E7360980
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].
Cc: Laserfiche
Sincerely,
CxuS-jnr6 oy.
97?'4ii�A9y3•s.
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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