WQCS00371_NOV-2024-DV-0438 Response to Notice_20241106

Facilities Division
Campus Operations and Maintenance
Utilities and Engineering
November 6, 2024
Ms. Vanessa Manuel
Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
Campus Box 7513
Raleigh, NC 27695-7513
P: 919.513.7151
F: 919.513.8805
Subject: Written Response to Notice of Violation & Intent to Issue Civil Penalty
Tracking No.: NOV-2024-DV-0438
Sanitary Sewer Overflows — September 2024, Incident No. 202402153
Collection System Permit No. WQCS00371
NC State University collection system
Wake County
Dear Ms. Manuel:
I am writing to provide a response to this Notice that was received on October 23, 2024 in Associate
Vice Chancellor Douglas Morton's office. This response will provide evidence and justification as to
why NC State University should not be assessed a civil penalty for the permit violation represented by
Incident No. 202402153.
On September 17, 2024, the NC State ORC was made aware of a sanitary overflow event. Once made
aware, all efforts were made to quickly stop the release to the storm drainage system and resolve the
issue that caused the sanitary release. Sanitary lines internal to the utility plant were cleaned which
allowed the sanitary system to function properly again.
Additional cleaning has been done to the sanitary system within the utility plant to ensure that the lines
are clear of debris. Camera footage indicates that the lines are not damaged. Additional education has
been provided to the utility plant to ensure that any overflow events are reported in a timely manner.
Investigation into the integrity of the plant drainage system still continues to verify there are no other
contributing factors.
The volume of the spill was estimated based on the duration of the event and the estimate flow rate of
the overflow that was witnessed by the ORC. In order to be conservative, the ORC assumed that
100% of this volume reached surface waters. The spill was discharged into the storm drainage system

Ms. Vanessa Manuel
Response to Notice of Violation
November 6, 2024
Page 2
which flows into an open channel ditch in the pasture and flowed approximately 900 feet before
discharging into House Creek. It was also raining during this time, which contributed to the dilution of
the release. There were no fish kills observed, no impacts to public health and I am not aware of any
recreational area closures.
NC State University was first issued Collection System Permit number WQCS00371 on February 10,
2010. Since that time, NC State University has experienced seven reportable SSO events prior to
2024: one in 2010(50 gallons), one in 2011(25 gallons), one in 2012(<500 gallons), two in 2013(total
of 200 gallons), one in 2018(100 gallons) and one in 2019(150 gallons).
There was no damage to the pasture drainage ditches or the surface water, therefore no cost was
incurred to make any repairs. The spill was not intentional but the result of sediment build up in the
lines. The internal cost to clean the lines was not a factor in this release.
If you have any questions, comments, or require additional information regarding this notification,
please contact me at [phone].
Sincerely,
A-1, L
' , , 1 -41 � Z'/
Alan G. Daeke, P.E.
Director, Utilities and Engineering Services
Cc: Doug Morton, NCSU (e-copy)
Allen Boyette, NCSU (e-copy)