WQCS00002_DV-2024-0127 Civil Penalty Folder_20241028

ROY COOPER
Coverno-
MARY PENNY KELLEY
'WI-efory
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7017 0190 0000 2485 9333
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
October 28, 2024
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-2024-0127
Wake County
Dear Permittee:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $851.00 ($750.00 civil penalty
$101,00 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.l(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)(]) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
North Carolina Department of Enoronmrntal Quality I O1vhlon of Water Resources
Raleigh Regional Office 1 3800 Barrett OrWe : RateNK North Carohna 27609
y v+.� 919,791.4200

Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, 1, Vanessa
Manuel, Assistant Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against
City of Raleigh:
750.00 For 1 of the 3 violations of Collection System Permit No. WQCS00002 and G.S. 143-215. I (a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
750.00 TOTAL CIVIL PENALTY
101.00 Enforcement Costs
$851.00 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. 143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not inchrcle 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 143B-282. I (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 Stiaulation of Facts" fonn 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: (9 l 9) 431-3100
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
dateltime 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.fowlerr.a;deq.nc.gov.
Sincerely,
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Laserfiche

JUSTIFICATION FOR REMISSION RE UEST
Case Number: DV-2024-0127 County: Wake
Assessed Party: City of Raleigh
Permit No.: WQCS00002 Amount Assessed: $851.00
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.rtture occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty tivill prevent yot(from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF WAKE
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
City of Raleigh )
Raleigh Collection System )
PERMIT NO. WQCS00002 ) CASE NO. DV-2024-0127
Having been assessed civil penalties totaling 851.00 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated October 28, 2024, 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
I_\0]01R*Xy
TELEPHONE
SIGNATURE
, 20

ATTACHMENT A
City of Raleigh
CASE NUMBER: DV-2024-0127
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
202400855
5/3/2024 CSO/SSO(Sewer Overflow) Discharge without valid permit
5,498
$0.00
202400944
5/16/2024 CSO/SSO(Sewer Overflow) Discharge without valid permit
2,600
$750.00
202400949 5/17/2024 CSO/SSO(Sewer Overflow) Discharge without valid permit 5,000 $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-2024-0127
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 2,600 gallons of wastewater overflowed from the Raleigh Collection System due to roots. 2,600 gallons of
wastewater flowed to an unnamed tributary to the Neuse River, classification B;NSW in the Neuse River Basin. Nutrients
and pathogens to surface waters.
2) The duration and gravity of the violation;
The SSO started on 05.16.2024 at 06:45 pm and ended the same day at 08:20 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 provided cost of rectifying the damage was $5,793.00.
5) The amount of money saved by noncompliance;
It is believed that no money was saved by 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 2 enforcement case within the past 12 months.
8) The cost to the State of the enforcement procedures.
S 101.00
odob,e- Z81 7--> 2 f
Date
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

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Raleigh Water Ra.!-'jv
August 191h, 2024
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
Re: Response to NOV-2024-DV-0317 (Revision for 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-0317 dated July
31st,2024, and received by Raleigh Water on August 16th, 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). The circumstances and SSO mitigation actions in this document
were previously addressed in a response letter dated July 15th, 2024. The noticed incidents occurred while the
City operated its collection system, according to WQCS00002, dated June 6th, 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.) 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 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 tittle 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 Erort,
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 SSO.
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
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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
activities Activities Activities Maintenanc
e 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.
Exhibit Z Affected Asset / Root Intrusion
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 notified of a sanitary sewer overflow nea, 7401 Sandy Creek Dr . Raleigh, NC
Upon arrival Utility Responders Identified an adfve sewer overflow from a sewer
manhole. affecting the normal low of untreated wastewater from the connecting sewer
gravity main The responding staff took all reasonable steps to nOggate 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 unheated wastewater reaching the surface
waters of an unnamed tnbulary within Mine Basin No vegetative damage orfish kit
was observed related to this event Restoraliog for the Incident was completed on the
same day
• Raleigh water has an aggressive education and enforcement program to
prevent the discharge of grease. debAs wipes. rags, diapers and other Improper
materials In the Sewer system and to take enforcement adlon where
appropriate If these items make h 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.
• Waist human waste. and toilet tissue are the only items permitted to be
discharged Into the sewer system. Al other hems will cause damage to the
sewer system and are not pem filled.
• If you experience excessive sewer smells or see sewer spilling from manholes
or pipes. please cal 919-996-3245 to report Immediately
• For more Information about how you can help prevent sanitary sewer spills,
please visit: raleighnc.govAvater
This news release Is required by NCGS Amide 21 Chapter 143.2161C
#0
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 $35. 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.
8

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 [zi.
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 collection system
[2] Associated operational cost year to date for FY2024
OPERATION
LINEAR FEET
Linear Miles
COST
CCTV
586,531
111
$341,318,75
Repair
4,260
.80
$1,430,784.85
Flushing
2,334,592
442
$699,743,41
Easement
578,116
109
$263,435.90
Easement Inspection
3,995,104
757
N/A
Total- 7,498,603 Ft/ 1,420 MILES
The total cost of Business to Date is
$2,735,282.91
[3] F.Y. 2024 annual Divisional budget - $15,058,291
[4] $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[5] The current SSO Rate for F.Y. 24 is 2.00
Note
In FY-2023, the Raleigh Water -Sewer Maintenance Divislon 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
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:llrpk-iphnc.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-0317 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
Superintendent, at 919-996-5929.
5' ncerely
arlos M Perez, ORC
As istance 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
Ca rlos.perezcamacho rPraleighnc.Gov
10

Docusign Envelope ID: 5ED9E5EE-D6$4-4750-9BA0-013106014DC5
ROY COOPER
Go'-.' .r
ELIZABETH S. BISER
RICHARD E. ROGERS. 12
Ikr.YON
Certified Mail # 7017 0190 0000 2485 9012
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
July 31, 2024
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0317
Sanitary Sewer Overflows - May 2024
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
p�@T0TT
AUG 16 M4
AUK 9202
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 550 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 (Mina) Location Cause (Gals) (Gals) DWR Action
202400855 5/3/2024 120 10320 Globe Road, Other
Morrisville, NC, 27560
202400944 5/16/2024
95
7401 SANDY CREEK
DRIVE, RALEIGH,
27615
Roots
5,498 0 Notice of Violation
2,600 2,600 Notice of Violation -
Intent to Assess
�.re,,.lrIN-1th p�rrmpq e•{n,.L 1rt[Ir.J,li,p I. L" M1 rllsn!
�` k..MA, k,:ie,r,.,inl1'.r l+r[n h:r+n�h.,,r k,.4.J t,,•"�-r i „a5..;'
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Docusign Envelope ID. 5ED9E5EE-D684-4750-9BA0-D131D8014DC6
Incident Start Duration
Number Date (Mina) Location
202400949 5/17/2a24 64 7104 GREAT LAUREL
DRIVE, RALEIGH,
27616
Total Vol
Total Surface
Vol Water
Cause (Gals) (Gals) DWR Action
Pump station 5,000 500 Notice of Violation
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 919-791-4261 or via email at [e-mail].
Cc. Laserfche
Sincerely,
CUo[uSigned by
Uav t,ss& f . Al.al.l t,ut,f,
62916EOAB32144E
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
r—

Docusign Envelope ID: 5ED9E5EE-06t'4-4750-9l3A0-D131D13014DC5
ROY COOPER '� 1M,
ELIL CBE. I I-1 S B1SER
RICE 1ARD E_ ROCKERS. IR. W)P Fr I CAR-L INA
. Environmental Quality
July 31, 2023
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
Subject: Retraction ofNOV-2024-DV-0269
Sanitary Sewer Overflows - May 2024
Collection System Permit No. WQCS00002
Wake County
Dear Mr. Wheeler:
In a letter dated June 13th, 2024 (NOV-2024-DV-0269), you were notified of multiple sanitary sewer overflows
that took place within the Raleigh collection system in the month of May-2024. In an email correspondence from
Carolos Perez dated 6/26/2024, Mr. Perez provided more data on two of the overflows that were covered in that
notice of violation. Mr. Perez comments on the two incidents are covered below:
Incident # 202400855 (10320 Globe Road)
o Mr. Perez indicated that no wastewater reached surface water with this spill. He indicated that
the 5-day report that indicated it did reach surface water was filled out incorrectly. According to
the email, all wastewater was pooled in a natural depression.
• DWR Staff Comment -The 5-day report has since been updated to reflect no
wastewater reaching surface waters. This update in volume reaching surface water
will be indicated on a new notice of violation letter.
Incident #202401026 (5265 Six Forks Road Raleigh)
o Mr. Perez indicated that this was not an event within the Raleigh Collection System. No work
record of calling exist in their database.
• DWR Staff Comment - After investigation, it was determined the DWR staff on
phone duty the day of the spill incorrectly associated the spill with Raleigh
Collection System's permit number. The overflow took place on private property
through a cleanout. This overflow did not fall under City of Raleigh collection
system responsibility.
After communicating with Mr. Perez and reviewing submitted information, this office has determined that
NOV-2024-DV-0269 did not contain accurate information and is hereby rescinded. However, a new updated
\onl,C:u,dinaDcpannwmc,FF.nvoronukulall?u:dtty I DntsumofllalrrR�cnurec;
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Dorusign Envelope 10 5ED9E5EE-D684.4750-96A0-0131DB014DC5
Page 2 of 2
notice of violation letter will be issued to cover the system overflows that occurred in May 2024. This new notice
of violation tracking number is NOV-2024-DV-0317 and is dated 7/31/2024.
We appreciate Mr. Perez communicating with staff about this matter and have updated our files and database
system accordingly. If you have questions concerning this matter, please contact this office at 919-791-4200.
Sincerely,
Docu5igned by
Vain LSSa 'e. M-. I a
—8291GdA812-46F
Vannessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc Laserftsche
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��S 511\unhSaIi.hun-Slmvl I loll Mal lServiceCenter I Raleigh.\arth 173ro1ina27h99-1611

Docusign Envelope ID: 5ED9E5EE-D684A750-9BA0-D131DB014DC5
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7017 0190 0000 2485 9012
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
July 31, 2024
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0317
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 ;
(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 (Mina) Location Cause (Gals) (Gals) DWR Action
202400855 5/3/2024 120 10320 Globe Road, Other
Morrisville, NC, 27560
5,498
Notice of Violation
202400944 5/16/2024 95 7401 SANDY CREEK Roots 2,600 2,600 Notice of Violation -
DRIVE, RALEIGH, Intent to Assess
27615
D � ��� lior�h C�roina Drpartmm� of Enrirone,ern[al Qua6iy Dirision o[ Wain Resourcry
Raleigh Rryia.al0ffi4c ; 3800 Barrrit prier I Rekigh,North Caroina 27609

)cusign Envelope ID: 5ED9E5EE-D6$44750-9BA0-D131DB014DC5
Incident Start Duration
Number Date (Mips) Location Cause
202400949 5/17/2024 64 7104 GREAT LAUREL Pump station
DRIVE, RALEIGH, equipment failure
27616
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
5,000 500 Notice of Violation
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,
DOCUSiyned by
E
�aUi t,SSa -e. A ctla L a
82916EBA632144F
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
D_North C� u6na Departmern of Environ ental Quality Division of Winer Rewurcei
Raleigh Regiotvl Office 38008affeti Drive! Raleigh North Carohr 27604
F
�Q 90791,4200

DocusLgn Envelope ID 5ED9E5EE-D684-4750.9BA0-D13108014DC5
ROY COOPER
t., , ,
E LI"ZABE I'll 5 RISER
RICHARD E R()URS lR
Certified Mail # 7017 0190 000112485 9012
ftturn Receipt R@quested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
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July 31, zvz
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0317
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 Reports submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the: land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as
11ri not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
A �tal Surface
i Complete items 1, 2, and 3.
Print
01 Water
A SrgnatLue als) (Gals) DWR Action
Your name and address on the reverse
so that we can return the card to
X �,498 0 Notice of violation
Attach this card to the you.
t.� ❑ Aelant
or on the ace�k ai the mailpiece,
front 17 SI?` permits.
8. Received by i>'►irrtLad "p �
C. Data of Delivery
! 2,600 2,600 Notice of Violation -
I10ENIHEELER,ASSrpIREr�pR
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DWR
Divislon of Water Resources
PART I:
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
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 #: 202400944
Owner: City of Raleigh
City: Raleigh County: Wake
Region: Raleigh
Source of SSO (check applicable): [1 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): 7401 SANDY CREEK DRIVE, RALEIGH, , 27615
Manhole #: SMH127474
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 05/16/2024 Time: 6:45 pm
(mm-dd-yyyy) (hh:mm AMIPM)
Estimated Volume of the SSO: 2,600
Describe how the volume was determined
Weather conditions during the SSO event:
Incident End Dt: 05/16/2024 Time: 08:20 pm
(mm-dd-yyyy) (hh:mm AM/PM)
gallons Estimated Duration (Round to nearest hour): 1:35 hours
Duration & Flow rate
dry/clear
Did SSO reach surface waters? 2 Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 2600
Surface water name: Unnamed Tributary near Neuse
Did the SSO result in a fish kill? ❑ Yes 0 No ❑ 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 ): Dorothy M Robson
0 DWR ❑ Emergency Mgmt Date (mm-dd-yyy):
05/17/2024
Time (hh:mm AMIPM): 09:46:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director Division of Water Resources may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form Page: 1

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? [I Yes C No ❑ NA NE
Describe
Raleigh water has the use of a private contractor to
Have cleaning and inspections ever been increased at this location because of roots W Yes ❑ No F- NA M NE
Explain:
Since the overflow several work orders were generated to further investigate the surrounding, man holes in the area for
potential root related issues
What corrective actions have been accomplished at the SSO location (and
surrounding system if associated with the SSO)?
Crews were able to manually remove all the roots from the man hole and the apartment complex has had a plumber com(
on site to remove the roots from the service and replace the service line in the MH
What corrective actions are planned at the SSO location to reduce root intrusion?
Has the line been smoke tested or videoed within the past year?
If Yes, when?
Comments:
Pending work order for CCTV
System Visitation
ORC
Backup
Name:
Carlos Perez
Cert#
1003875
Date visited:
05/17/2024
Yes W No ❑ NA ❑ NE
V. Yes
F Yes
CS-SSO Form Page: 2

Time visited:
11:38AM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Sewer Maintenance were dispatched this evening for a sewer manhole overflow @ 7401 Sandy Creek Dr. First crew on s
identified SMH127474 discharging at time of arrival 7:15PM. Crews determined SMH127474 would be the affected asset
causing the sewer overflow. Crews immediately broke the blockage a(D8:20PM. Untreated wastewater did indeed reach th
storm drain basin located on Sandy Creek Dr. Crews on site set up a containment site on the drainage basin in the rear o
7324 Sandy Creek discharging into SMH127474. Crews flushed the storm drains stem in efforts to remove any remainin
debris, as well as washed the pond bank. The root cause of this SSO was determined to roots built up in the manhole.
As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim
Signature
Telephone Number:
Carlos Manuel Perez
Date: 05/21/24 11:30 am
Title:
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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NO
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
FOR THE
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, Gamer, 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
Wnrcnnnn7

1. PERFORMANCE STAND x }
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 or collection 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 II, 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.143-215.96; 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]
Page 2 of 8
ILIA P[MM7

6. Overflow piping from ma es and pump stations, excluding pipo o 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 pump station containing multiple pumps fails, the process of repairing or replacing the pump
shall 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. [1SA NCAC 02T .0305 (h) (1)]
B. 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.
115A 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.
115A NCAC 02T .0305 (h) (1)]
11. 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. [15A NCAC 02T .0108 (b)]
II. OPERATION AND MAINTENANCE REQUIREMENTS
I. 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 ORC 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.]
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.
[I SA NCAC 02T .0108 (b)]
Page 3 of 8
wnrcnnnm

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 (i.e. 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) (2) (A)]
6. 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 property 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 SSOs 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 SSO location within two
hours. 115A NCAC 02T .0108 (b)]
Page 4 of 8
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