WQCS00002_NOV-2019-DV-0397 Response_20191118

City of Raleigh
North Carolina
November 18th, 2019
Mr. Rick Bolich
Surface Water Assistant Supervisor
NCDEQ- DWR
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Response to NOV-2019-DV-0397
Sanitary Sewer Overflows: July, August, September 2019
Permit No. WQCS00002
Dear Mr. Bolich:
NC Dept of Environmental Quality
NOV 2 2 2019
Raleigh Regional Office
Please allow this letter to serve as a response to the Notice of Violation that was received on
November 4th, 2019, regarding pending violation actions of (6) Sanitary Sewer Overflow (SSO) events
which occurred during the third quarter of the 2019 calendar year within the City of Raleigh Collections
System ill. The noticed events occurred while the City operated its collection system, according to
WQCS00002, dated June 6, 2017. The permit includes the language outlined in footnote 1 and applies to
the SSOs upon which NOVs with the notice of intent (NOV-NOI) were based. For the SSO events listed
with intended NOV-NOI action, the City of Raleigh (COR) contends that the defenses in its Permit protect
it from any action brought for an SSO. Please find below, the additional information requested for each
of the SSO events.
1. "The Director may take enforcement action against the Permittee for SSOs that must be reported to the Division as stipulated In Condition IV92). This Includes
SSOs that were caused by severe natural conditions or exceptional events unless the Permittee demonstrates th"ough 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 facitlti as, retenti-n 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 I s not
satisfied If, In the exercise of reasonable engineering judgment, the Permlttee should have installed auxiliary or additional collections system c:)mponents,
wastewater retention or treatment facilities, adequate back-up equipment or should have reduced Inflow and infiltration; or
[b.] The S50 was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the Permittee; the SSO could not have beer
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 fact ,ties to accommodate growth or adequately controlling and preventing infiltration and inf'ow};
preventative maintenance; or Installation of adequate back-up equipment;"
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed an Recycled Paper

Spill event # 20191135 — 07/02/2019 - 735 Crestwood Dr. Garner
This sewer spill event was the direct result of severe natural conditions in which a large tree fell
onto an 8-inch vitrified clay pipe. The direct damage to the pipe resulted in approximately 7,256 gallons
of untreated -sewer to spill into a wetland. This spill took place within the Benson Basin.
The Sewer Maintenance staff were notified of the overflow on 07/02/2019 at approximately
11:25 AM. The responding staff took all reasonable steps to mitigate the impact of the discharge as soon
as they arrived, gaining control of the spill event by 3:50 PM. Mitigation of this event consisted of the
placement of a temporary sewer by-pass to maintain sewer flow, removal of a large tree trunk, and
repair of the damaged section of pipe. Crews established two temporary containment sites downstream
to collect any accumulated sewer, thus minimizing further environmental impact to the wetland. Crews
also removed sewer -saturated -soil from the surrounding area adjacent to the damaged pipe. Ample
potable water was utilized to defuse the site restoring the wetland and its surrounding environment.
To identify the extent of the spill, crews conducted an area assessment that extended to
approximately 20,000 ft' surrounding of the spill event. Crews did not find traces of sewage and debris
associated with the spill beyond 1,200 ft downstream of the spill. There was no observed fish kill
associated with this SSO. The total cost of the City's response and remediation effort for this spill event
was $15,762.08, and it was completed on 7/8/2019. The cost to treat 7,256 gallons in lieu of the clean-
up cost would have been approximately $10.88.
A press release was issued for this spill event on July 3, 2019 (see attachment # 1).
There has not been a history of sewer spills in this section of sewer main. The most recent
record of routine assessment to this site was conducted on 04/23/2019 (high priority inspection for
aerial pipe asset # SGMN115840). The inspection found no issues with the sewer main. This section of
the sewer system is inspected twice a year and it was last assessed on 12/6/2017.
According to our Sanitary Sewer Collection System Permit, the cause of this SSO was
exceptional, unintentional, temporary, and caused by factors beyond our reasonable control.
Furthermore, the 550 could not have been prevented by the exercise of reasonable control, such as
routine operations and maintenance, adequate treatment facilities, or collection system facilities or
components.
Spill event # 201901228 - 7/13/19 — Intersection of South Taylor St. and Wait Ave., Wake Forest, NC
This sewer spill event was the result of debris build-up (rags and flushed wipe material) blocking
a portion of an 8" Vitrified Clay Pipe (VCP). This build-up led to a sewer spill of approximately 1,400
gallons of untreated sewage, in which approximately 400 gallons reached surface waters through an
unnamed tributary in the Smith Creek basin. The untreated sewer traveled approximately 250 ft
downstream into an adjacent depression, which prevented its continued flow downstream.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

The Sewer Maintenance staff were notified on 07/13/2019 at 11:25 AM. 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 event by 1:55 PM on the same day. The cleanup of this spill event consisted of
dislodging the source of the blockage with hydraulic -jetting, reestablishing flow. Crews positioned a
debris -collection basket on the downstream manhole to receive and collect debris being flushed. Crews
employed a temporary sewer containing site (dam) downstream from the SSO location with the intent
to minimize the flow of sewer into the unnamed tributary. During restoration operations, crews utilized
water from an adjacent hydrant to flush the affected area. The paved surface around the manhole was
cleared of debris and flushed with potable water from an adjacent hydrant. The remaining sewer was
collected and re -introduced into an adjacent manhole. The area was then treated with an application of
lime and restored with grass seed and straw. There was no observed fish kill or unnecessary vegetative
damaged associated with this SSO. The cost associated with the mitigation of this event amounted to
$777.05. The cost to treat the wastewater would have been approximately $2.10.
A CCTV follow-up on 07/30/2019 determined that a section of sewer, approximately 41 ft.
downstream of this event was found to be damaged. Repair crews responded immediately to repair and
replace the damaged section of the sewer main. It is possible that the damaged pipe may have
contributed to the previous sewer event. Because of this event, CCTV is widely utilized downstream,
immediately following a spill event, to ensure cleaning efficiency, as well as verification that the sewer
main is in satisfactory condition. Before this spill event, this section of the sewer collection system was
last assessed on 08/11/2017.
Outreach information was delivered to the immediate area addressing the need for customers
to follow proper disposal of materials unauthorized for discharge into the collection as well as what
steps to take to protect the City's water quality and the sanitary sewer collection system.
Spill event ## 201901422 — 08/29/2019 — Coolridge Ct., Raleigh
This sewer spill event was the result of a build up of grease and debris, blocking a portion of an
8" Reinforced Plastic (Truss) Pipe. This build-up led to a sewer spill of approximately 6,732 gallons of
untreated sewage, in which approximately 3,920 gallons of untreated sewer reached surface waters
through an unnamed tributary in the Beaver East basin.
On 8/29/2019, at approximately 4:24 PM Sewer Maintenance staff was notified of a sewer back-
up that led to a spill within the private sewer collection system of the apartment complex. Upon arrival,
the crews found that the event had ceased and proceeded to clean and collect any remaining sewer off
the ground. Cleanup and restoration of this spill event consisted of employing a temporary sewer
containment site (dam) downstream from the SSO location with the intent to minimize the flow of
sewer into the unnamed tributary. Crews also employed pumps from the temporary containment site,
to pump the remaining sewer back into a downstream sewer manhole. During restoration operations,
crews utilized water from adjacent hydrants to flush the affected area. The areas around the manhole
were cleared of debris, treated with an application of lime and restored with grass seed and straw.
There was no observed fish kill or unnecessary vegetative damaged associated with this SSO. The cost
One Exchange Plaza
1 Exchange Plaza. Suite 1020
Raleigh, North Carolina 27601
City of Raleigh
Post Office Box 590 • Raleigh
North Carolina 27602-0590
(Mailing Address)
Printed on Recycled Paper
Municipal Building
222 West Hargett Street
Raleigh, North Carolina 27601

associated with the mitigation of this event amounted to $11,165.88. The cost to treat 3,920 gallons of
wastewater would have been approximately $5.88.
This section of the collection system serves a residential area south of Spring Forest Rd., Raleigh.
The last sewer spill near this address was recorded on 7/18/2017. Maintenance records show that
sections of the collection system were addressed on 02/22/2010. A follow-up CCTV inspection,
conducted on 09/10/2019, showed no infrastructure issues with the sewer main.
On 09/03/2019, outreach information was delivered to approximately 455 residents within the
affected area. This informational literature explained the need for customers to properly use the
collection system and how to protect the City's water quality and the sanitary sewer collection system.
Spill event f# 20191421— 08/29/2019 —1600 Marlboro Rd., Raleigh
This spill event was the direct result of structural pipe failure of a 12- inch Reinforced Concrete
Pipe (RCP) that discharges into a 72-inch sewer main. This pipe failure led to a sewer spill of
approximately 10,546 gallons of untreated sewage; most of it remained within an adjacent depression.
However, approximately 1,000 gallons of sewer reached surface waters through a stormwater
conveyance discharging into Crabtree creek. This section of the collection system serves a large
residential and commercial area covering over 1 square mile east of North Raleigh Boulevard.
On 8/29/2019 Sewer Maintenance staff were investigating a sewer backup complaint when they
found a standing manhole. At approximately 9:00 PM, crews found a section of sewer easement under
approximately 2 ft. of untreated sewer. 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 event by 10:25
PM.
The cleanup of this spill event consisted of dislodging the source of the blockage with hydraulic -
jetting, reestablishing flow. The flooded section of easement receded immediately when the blockage
was removed. Crews employed a temporary sewer containing site (dam) downstream from the 550
location with the intent to minimize the flow of sewer into the stormwater conveyance. During
restoration operations, crews utilized water from an adjacent hydrant to flush the affected area. The
surface surrounding the easement was cleared of debris and flushed with potable water from an
adjacent hydrant. The site where the sewer remained was collected and re -introduced into an adjacent
manhole. The area was then treated with an application of lime and restored with grass seed and straw.
There was no observed fish kill or unnecessary vegetative damaged associated with this SSO. The cost
associated with the mitigation of this event amounted to $4,543.80. The cost to treat the 1,000 gallons
of lost wastewater would have been approximately $1.50.
A CCTV assessment determined that a 260 ft section of sewer main was badly deteriorated
along its length prompting the pipe for immediate replacement. Replacement of the pipe was
completed the first week of September at a cost of $43,654.98
One Exchange Plaza
i Exchange Plaza, Suite 1020
Raleigh, North Carolina 27601
City of Raleigh
Post Office Box 590 - Raleigh
North Carolina 27602-0590
(Mailing Address)
Printed on Recycled Paper
Municipal Building
222 West Hargett Street
Raleigh, North Carolina 27601

This section of the sewer coliection system has a history of spills associated with grease
accumulation. Because of these spills, this portion of the collection system was placed on a high priority
maintenance cleaning schedule. It was last cleaned on 03/13/2019. Prior to the incident on August 29th,
this section of sewer was maintained frequently with recorded maintenance operations as follows:
3/13/2011- flushed sewer gravity main
8/8/2011- Inspected sewer easement
12/5/2011- flushed sewer easement
9/19/2012 - flush sewer easement
11/27/2012 - flushed sewer gravity main
12/28/2012 - flushed sewer gravity main 6/28/12. flushed sewer gravity main
6/2/2013 • flushed sewer gravity main
12/6/2013 - flushed sewer easement found nothing
5/27/2014 - flushed sewer gravity main
8/7/2014 - flushed sewer gravity main
12/27/2014 - flushed sewer easement
4/4/2015 • flushed sewer gravity main
6/23/2015 -flushed sewer gravity main found minor root intrusion
7/6/2015 - flushed sewer gravity main
04/19/2017 - flushed sewer gravity main
05/09/2017 - flushed sewer gravity main
08/30/2017 - flushed sewer gravity main
10/03/2017 - flushed sewer gravity main
12/11/2017 - High Priority Inspection
03/28/2018 - High Priority Inspection
04/04/2018 - flushed sewer gravity main
10/29/2018 - High Priority Inspection
11/01/2018 - flushed sewer gravity main
11/01/2018 - flushed sewer gravity main
01/23/2019 - CCTV
02/15/2019 - CCTV
03/13/2019 - flushed sewer gravity main
03/12/2019 - High Priority Inspection
07/25/2019 - High Priority Inspection
Due to these past incidents, educational outreach was utilized to raise customer's awareness
regarding the proper use of the sewer collection system.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Spill event # 201901558 — 09/23/2019 — 3701 Dade St., Raleigh
This spill event was the direct result of a contractor damaging an 8 -inch Vitrified Clay Pipe
(VCP). This pipe failure led to a sewer spill of approximately 1,050 gallons of untreated sewage, reaching
an unnamed tributary in the Crabtree Basin.
On 09/23/2019 at approximately 2:09 PM The Sewer Maintenance staff were notified of a
damaged pipe at 3701 Dade St., Raleigh. 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 event by 3:20
PM on the same day.
Mitigation of this event consisted of repairing and replacing a 10-foot section of pipe,
reestablishing flow. Crews employed a temporary sewer containment site (dam) at approximately 600 ft
downstream from the SSO with the intent to minimize the flow of sewer into the unnamed tributary.
During restoration operations, crews utilized water from an adjacent hydrant to flush the affected area.
The paved surface around the damaged pipe was cleared of debris and flushed with potable water from
an adjacent hydrant. Crews also flushed all 600 ft of the creek, ensuring no traces of sewer debris was
present. Sewer from the containment site was collected and re -introduced into an adjacent manhole.
The area was then decontaminated with the application of lime and restored with grass seed and straw.
There was no observed fish kill or unnecessary vegetative damaged associated with this SSO. The cost
associated with the mitigation of this event amounted to $311.98. The cost to have just treated the
1,050 gallons of wastewater would have been $1.57.
According to our Sanitary Sewer Collection System Permit, the cause of this 550 was
exceptional, unintentional, temporary, and caused by factors beyond our reasonable control.
Furthermore, the S50 could not have been prevented by the exercise of reasonable control, such as
routine operations and maintenance, adequate treatment facilities, or collection system facilities or
components.
Spill event # 201901533 — 09/15/2019 — 5005 Oak Park Rd., Raleigh
This sewer spill event was the result of debris build-up (rags and flushed wipe material) blocking
a portion of an 8-inch Ductile iron pipe (DIP). This build-up led to a sewer spill of approximately 13,400
gallons of untreated sewage reaching surface waters via an unnamed tributary in the Crabtree basin.
The Sewer Maintenance staff were notified on 09/15/2019 at 5:53 PM. 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 event by 8:07 PM on the same day. The cleanup of this spill event consisted of
dislodging the source of the blockage with hydraulic -jetting, reestablishing flow. Crews employed a
temporary sewer containing site (dam) downstream from the SSO location with the intent to minimize
the flow of sewer into the unnamed tributary. During restoration operations, crews utilized water from
an adjacent hydrant to flush the affected area. The area around the manhole was cleared of debris and
flushed with potable water from an adjacent hydrant. The remaining sewer was collected and re-
introduced into an adjacent manhole. The area was then treated with an application of lime and
restored with grass seed and straw. There was no observed fish kill or unnecessary vegetative damaged
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

associated with this SSO. The cost associated with the mitigation of this event amounted to $20,621.58.
The cost to have just treated the lost sewer would have been $20.10.
Upon request of NCDEQ— DWR, several water samples were collected downstream of the SSO
and sent to the Neuse River Resource Recovery Facility laboratory for analysis. The requested samples
tested for Ammonia, COD, Nitrates, and Fecal Coliform. The test results show no significant traces of the
parameters requested. A copy of these laboratory analyses is included in this letter.
This section of the collection system has a history of sewer spills; the most recent occurred on
02/01/2019. As a result of this event, approximately 4000 feet of sewer pipe and the area adjacent to
the discharging manhole was assessed. Following the event of September 15th, however, over 12,000
feet of sewer were flushed and CCTV to identify any conditions that would indicate critical pipe failure or
discrepancies. CCTV footage showed that approximately 2,000 ft. of sewer main had debris inconsistent
with sewer material. Crews spent approximately two weeks removing gravel, rocks, and grit from this
section of the sewer system.
This section of the collection system serves over 500 residential and commercial properties
covering over 130.52 acres south of Glenwood Ave. On 09/19/2019, there were 218 letters mailed and
277 door hangers delivered with information addressing the need for customers to follow proper
disposal of the foreign material as well as what steps to take to protect the City's water quality and the
sanitary sewer collection system.
Summary
The City of Raleigh has a very aggressive preventative maintenance program to maintain its
2600 miles of sanitary sewer. Since January 2019 (Fiscal Year 2020), the Utility has maintained
approximately 362.67 miles of the sanitary sewer by flushing sewer mains with high-pressure nozzles,
CCTV, repair operations, and SSO mitigation. The year to date cost of these operations amount to
$3,588,055.96, approximately 18°Y of the Division's annual operating budget. The total volume of sewer
spills identified in this letter add up to 40,384 gallons at a total mitigating cost of $53,118.37. The City's
cost of sewer treatment per gallon is $.0015 r21 At this rate, it would have cost the City $42.03 to treat
every gallon of sewer spilled. This fiscal comparison shows the City's commitment to environmental
protection sparing no cost regardless of the severity and complexity of the spill event. The City continues
to demonstrate due diligence in environmental performance by allocating the necessary resources to a
spill event regardless of the associated cost. This effort is noted in the City's low S50 performance rate
of 2.23 spills per 100 miles of pipe, compared to the Southeastern Region of the US, of 7.0 spills per 100
miles of pipe.
121 $ 0015 is based on the annua' witer treatment operating cost compounded by the total treated effluent
The City of Raleigh maintains approximately 1009 miles of sanitary sewer easements within our
jurisdiction. The manholes within every easement in our service area are inspected at least once per
year and in most cases, more frequently. Trees and brush must be cut away from these areas to
maintain access to the sewer line for maintenance work such as inspection and cleaning, and it removes
root materials from the proximity of the sewer mains. We currently employ five easement maintenance
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

crews that continually cut and maintain easements for access and inspections. Approximately 110 miles
of our sanitary sewer easements have experienced substantial tree growth and require more extensive
clearing operations. The City of Raleigh Public Utilities Department contracts with a private tree service
to assist with those removal operations, and we have spent over five hundred thousand dollars
($500,000) throughout the past four years on this contract.
Additionally, City of Raleigh Assistant Public Utility Directors and Collections System staff has
become involved in challenging the standards of the nonwoven fabrics industry to bring about a better
understanding by 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 non -woven 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 are working collectively to challenge the testing
protocols, assessment guidelines, and consumer education and labeling of these non -dispersible.
It is essential to mention that the City has seen an increase in the trend of grease related SSOs.
As of today, 65% of 2019 reportable spills have been related to grease accumulation. Public Utilities has
increased its educational outreach to reduce this trend. The Department's Fats, Oil, & Grease Program
has developed new educational material (included in this letter) as well as an informational video
designed to reach not only food service establishments but residential customers as well. The City is also
developing initiatives to increase partnerships with residential customers to address grease
accumulation and proper disposal. The educational FOG video can be accessed by accessing the
following link htt s: yimeo.com/362624139 Password: RW2019
In 2018 the Public Utilities Department increased the efforts of community outreach to further
inform the community throughout direct participation in the City's Citizens Advisory Committees.
Through this initiative, the Public Utilities Department has been able to reach numerous Council Districts
with a consistent message of collaboration and environmental partnership. The Department is currently
developing year three of this effort. Furthermore, this message has been made available not only to the
community but to City Council officials as well. A sample of this message is attached to this letter for
reference.
Raleigh continues to implement a seasonal collection of residential cooking oils from curbside
pickup along with customer garbage, recycling, and yard waste. The goal of this program is to prevent
these oils from being deposited within the sanitary sewers and to help prevent grease buildup and
blockages leading to SSO's. Since its implementation in 2010, the program has successfully collected
over 1,000 gallons of residential cooking oils.
The City continues its monetary reward program or bounty program, which pays out fifty ($50)
dollars to any citizen that observes and reports an 550 or conditions that may cause a spill event. 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
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

billboards spreading our message of prevention and offering contact information, throughout the
service area each day. This program was developed with the hope 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 to prevent these occurrences. Additionally, all customers are
notified via their water and sewer utility bills not to discharge improper materials into the sanitary
sewer mains. The City also circulates information regarding discharging of grease into the sewer system
and the effects of such deposits. Whenever possible, and upon the investigation of the root cause of a
spill event, PUD Code Enforcement officers develop and send registered informational letters about the
spill event to the customer base serviced by the line where the SSO has occurred. This is done to
educate our customers in the proper use of the sanitary sewers in an attempt to prevent 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 the NOV-NOI issued for the third quarter of
2019 be rescinded as allowed in the Collections System Permit. If additional information is required,
please contact Matthew Vessie, Sewer Maintenance Superintendent [phone] or T.J. Lynch,
Assistant Public Utilities Director, at [phone].
S' erely,
� kw
�osM Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh Public Utilities Department
P.O. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
Carlos. perezcamacho(@raleiehnc.Gov
CC: Robert Massengill, Public Utilities Director
T. J. Lynch, Assistant Public Utilities Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance Division
Attachments:
1. NCDE NOV Letter, Received Nov 4, 2019
2. Press release issued July 3, 2019
3. Laboratory Analysis
4. Fats, Oil, & Grease Program educational material
5. CAC Message
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

ROY COOPER
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CERTIFIED MAIL # 7017 2680 D 2236 7634
RETURN RECEIPT REQUESTED
October 28, 2019
Robert Massengill, P.E., Public Utilities Director
City of Raleigh
PO Box 590
Raleigh, NC 27602
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2019-DV-0397
Sanitary Sewer Overflows — July, August, September 2019
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by City of Raleigh Indicates violations of
permit conditions stipulated in the subject permit and North Carolina G.S. 143-215.1. Violations include failing to
effectively manage, maintain, and operate the subject collection system so that there is no SSO to the land or
surface waters and making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a
permit is required.
Specific Incident(s) cited in the subject report include the following: Total Vol
Total Surface
Incident Start Duration VolWater
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
201901533 9/15/2019 134 5005 Oak Park Road, Debris In line 13,400 13,400 Notice of Violation
Raleigh, NC Notice of Intent
201901S58 9/23/2019 70 3701 Dade Street Pipe Failure (Break) 1,050 0 Notice of Violation
201901421 8/29/2019 85 1600 Marlboro Rd., Pipe Failure (Break) 10,546 1,000 Notice of Violation
Raleigh, NC
201901422 8/29/2019 20 Coolridge Ridge Rd.,
Raleigh, NC Pipe Failure (Break) 6,732 3,920 Notice of Violation
Grease, Debris in line
201901228 7/13/2019 150 S. Taylor St and Wait Ave Debris in line
Raleigh, NC
1,400 1,400 Notice of Violation
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R���i� S1�hnt.pL`«E I MOEurtaorto 192 11-.Furth Crte ri'a7£03

Incident Start Duration
Number Date (Mips) Location
201901135 7/01/2019 230 735 Crestwood Dr.,
Garner, NC
Total Vol
Total Surface
Vol Water
Cause (Gals) (Gals) DWR Action
Other, Pipe failure 7,256 7,256 Notice of Violation
(Break)
Remedial actions, if not already implemented, should be taken to correct the above noncompliance. Please submit
a written response to this Notice of Violation. Your response is to be received by the regional office within 15
business days following receipt of this violation. Please include any additional documentation about this incident(s)
In the response. The submittal will be considered in determining whether the Division will assess a civil penalty for
the cited violations.
If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at mitch.hayes@ncdenr:gov.
Sincerely,
S. ]ay Zimmerman P.G., Chief
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQ5 File
Central Files, Water Quality Section
T.J. Lynch, PE - Assistant Director of Wastewater Operations, City of Raleigh, PO Box 590, Raleigh, NC
27602
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City of Raleigh Responds to Sewer Spill
Prepared Ev: Jacob D, Barnhart, Community Relations Coordinator, Public Utilities
Department, 919-315-7-950
For "lore Information: Robert "ia%wng 1L Public Utilities Director,or T_J_ Lynch;
Assistant Public Utilities Director, 919-99&3245
Jul}• 3, 2019
Ciry of Raleigh Responds to Sewer Spill
On Tuesdav July' 2, 2019, at approximately 12:45 p.m_, the City of Raleigh Public
Utilities Department responded to a sanitary sewer spill due to a damaged server maul pipe
at 735 Crestwood Dr. Garner, 1-C_ The damage to the sever pipe was caused by a doilmed
tree. The North Carolina Department of Environmental Quality Division of Water
Resources t«s notified of the spill,
City of Raleigh Public Utilities crews took all reasonable steps to stop and mitigate
the impact of the spill as soon as they arrived on scene. Crews removed large portions of
the dotrned tree and stopped the spill at approximately 3:30 pm. on Tuesday July 2, 2019.
and clean up related to this spill is ongotng. The estimated volume of the spill is
approximately 7,256 gallons which reached portions of a wetland within Benson Basin.
Crews will be workitig throughout the night to restore the site.
This netc-s release is required by \ CGS mcle 21, Chapter I.13.215. C. For more
information, contact Public Utilities Director Robert Nfassengill or:Assistant Public Utilities
Director T.J. L`mch at 919-996-3245.
If �HNRC
View as a W6 Page

NORTH CAROLINA
September 3, 2019
Mr. Rick Bolich
Surface Water Assistant Supervisor
NCDEQ- DWR
1628 Mail Service Center
Raleigh, NC 27699-1628
Carlos M Perez
Sr. Utilities Analyst
Public Utilities Department
Sewer Maintenance Division.
Re: Request for laboratory testing related to an SSO (incident Number 201901533)
Dear Mr. Bolich,
Thank you for your patience in waiting for the laboratory results you requested related to
sanitary sewer incident # 201901533. This letter is intended to identify the steps taken
during the collection.
The sample collected were in response to a sanitary sewer spill located 5005 Oak Park Road,
Raleigh, NC, which occurred on September 15th, 2019. This incident spilled approximately
13,400 gallons of untreated sewer into an unnamed tributary of the Crabtree basin.
In your request, you specified that the following test were conducted: COD, Ammonia,
Nitrate, Nitrite, and Fecal Coliform. These tests were collected and delivered to the Public
Utilities laboratory, located and the Neuse River Resource Recovery Facility, on 09/18/2019.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Ralergh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

The samples were collected on four separate locations downstream of the spill, which
stretched to approximately 2,400 ft. from the site of the spill to the spill collection site.
a
i:;1L7A=jSPILL SITE
t SAMPLE 1
SHM106732
# r
SAMPLE 2
SH M 125400
SPILL
CONTAINMENT
SITE i
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Sample # 1- Located immediately adjacent to the spill site.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 - Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed an Recycled Paper

Sample # 2 - Located approximately 700 ft. downstream of the spill site.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Sample # 3 - Located approximately 100 ft south of Weaver Dr. along the course of the creek
and adjacent to the spill collections site, where the last visual trace of sewer debris was
visually identified.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Sample # 4 - Located south of Oak Park Rd. on the creek.
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 - Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

The time and location of each sample along with its result are included with this letter.
Please do not hesitate to contact my office if there are additional concerns regarding the
information provided and the samples collected.
Sincerely,_
Carlos M Perez
Sr. Utilities Analyst
Public Utilities Department
Sewer Maintenance Division.
Carlos. perezcamacho P raIeiehn,c.gov
Office [phone]
Cell [phone]
One Exchange Plaza City of Raleigh Municipal Building
1 Exchange Plaza, Suite 1020 Post Office Box 590 • Raleigh 222 West Hargett Street
Raleigh, North Carolina 27601 North Carolina 27602-0590 Raleigh, North Carolina 27601
(Mailing Address)
Printed on Recycled Paper

Neuse River Resource Recovery Laboratory
Phone [phone]
EPA Laboratory Code NCO 1029
+kcA*
DWR Certification #51
ANAD Certificate FIAT-2593
Customer: Sewer Maintenance
Results Report
20-Sep-19
Order ID: 19091805
Sam le
Date
Samt)IeType
Parameter
Metbod
Result Qualifier
SMHI06732
9/10019
Grab
Ammonia
Ski 4500 NH3 H (2011)
0 20 MOIL
Sh111106732
9/182019
Grab
COD
Hach 14tcthod 9000
<20 mg(L
SM11106732
9/18/2019
Grab
Nitrate
EPA 300.0 2.1 (1993)
0 85 m8/L
SMI1106732
9118/2019
Grab
Nitrite
EPA 300.02 1 (1993)
<0,01 ms/L
SMIH25400
91c82019
Grab
Ammonia
SM 4500 NH3 H(2011)
1.00mg/L
ShIH 125400
911=019
Grab
COD
Hach Method 9000
<20 mg1L
SMH125400
9/18/.2019
Grab
Nitrate
EPA 300 0 2 1 (1993)
0,55mg/L
SM11125400
9/18/2019
Grab
Nitrite
EPA 300 0 2 1 (1993)
0,08 mglL
ShIH125349
9/192019
Grab
Atnatania
SM 4500NI13 H (2011)
3,55 mg1L
SRIH 125349
9/18/2019
Grab
COD
Hach McOwd 8000
24 0 mg1L
S61H125349
91182019
Grab
Nitrate
EPA 300.0 2.1 (1993)
0A4n411L
SMI1125349
9/182019
Grab
Nitrite
EPA 300,021(1993)
<0.01mg1L
SM11125375
91182019
Grab
Ammonia
SM 4500 NH3 11(2011)
3 07 mg1L
SMH 125375
9/182019
Grab
COD
I lack Method 8000
35.0 mg1L
SNIH125375
9/182019
Grab
Nitrate
EPA 300.02 1 (1993)
0.81 mg(L
SM11125375
9/182019
Grab
Nitrite
EPA 300.0 2 1 (1993)
0.08mgti,
Reviewed by: Tamika Black 1abaratoryscientist
Approved by: Rabin Scudclnri Laboratory Scientist
The following parameters are not included in the ISO 17025 Scope of Accreditation_
pi-1, conductivity, tempemturc, dissolved oxygen and turbidity.
Results apply to the sample as received unless otherwise noted Revised 11127/2018. SM-001
Page 7 of 2

RECEIVED ���LS
ORDER IU#:_�� --
City of Raleigh Resource Recovery -Facility Chain of Custody
8500 Battlebridge Road, Raleigh, NC 27610
Phone:[phone] Fax:[phone]
Certification No. 51
Customer Name:
Address,
Page_ of
u
rk
Received hyr.
Dais' / 4
�/ (�1 F
Tema• %
Z `�
Receipt Conditions (Lab Use only):
5am a Temp CCj2y Chlorine Residual? d Y o N
Acid Preservation: pH Q3 Y O N Base Preservation: pH >107 o Y o N
R u' dr.
Received by
Date:
Time:
Comments. S a'e'ti` G:.2r— G 1 d to
Relinquished try
Received by
Oats:
Time:
�, �j
Cnilad 2M L RGYb" 2=II

Neuse River Resource Recovery Laboratory
Phone [phone]
EPA Laboratory Code NCO 1029
DWR Certification #51
ANAB Certificate #AT-2593
Customer: Sewer Maintenance
Results Report
2G-Sep-19
Order ID: 19092007
Sample
Date
SampleType
Parameter
Method
Result Qualifier
samplea1
9/20/2019
Grab
Fecal Coliform (NIPN)
XColitcribi9(MPN)1Aq.
397Ml'N'100ml
Sample N2
9120/2019
Grab
Fecal Coliform (MPN)
X ColilenVI8 (MPN)(Aq-
214 MPN., 100ml
Sample N3
9120/2019
Grab
Feral Colifann (MPN)
X ColilenVI8 (MPN)(Aq
�2420 MPN.,I00ml
Sample #4
9/20/2019
Grab
Fecal Coliform (MPN)
X Colilcnffi18 (MPN)(Aq
1986 M]'N! 100ml
Reviewed by: Tamika
Black
LaboramryScientist
;.J,?a ,t-
Approved by: t7an*11
Crews
LaburalorySupervisor
?)(t41 k1("
The following parameters arc not included in the ISO 17025 Scope of Accreditation
pH, conductivity, temperature, dissolved oxygen and turbidity
Results apply to the sample as received unicss otherwise noted. Revised 11 /27/2018, SM 001
Page 1 of 2

City of Raleigh Resource Recove Facility Chain of CustoDER iD#:
"8500 Sattlebridge Road, Raleigh, NC 27610
Phone:[phone] Fax.[phone]
Certification No. 51
Customer Name /' &2re Page of 1
Address:
MUM,
��UARIM
��.o■■■o■■■:II�IaE
Wd
A d by
Received by
Qate: I
�t ?A f
Timo:
Receipt Conditions Use Only):
sample romp VC) --' Chkvft Bask mn fl Y'
Acid Preservadan: pH <27 ❑ Y 0 N Rasa PreservaB= PH at0? n Y C N
ReYnquahed by
Rekn4WSW by
Received by.
ROMWed by
Date:
Dale:
Time:
Time:
Comments:
Cw%d yens. RwW z= e

I
iMantenga la grass fuera del desague!
Leis grasas v Ios aceites c anon nuestro sistemo cue agua
Nunea de ,echo por el dren !'e 4
E J - �"Qum sc..,uponc qur_ debo hater
estas fuertites de gr�ar,7 y aceite: con las ;rasaa y xv-tes, como la
■ Restos de carne y comida grasa de tocino?
■ Des ues de cocinar tocino -
■ Manteca de cerdo/vegetal P MANTENGA LA5
y otras carries, escurra la
a Aceite grasa en un contenedor de GRASAS Y LOS ACElTES
■ Salsas recoleccion, puede serun FUERA DEL FREGADERO.
■ Grasa de tocino y otros caldos frasco de vidrio a una lata de
grasosos soya vacia.
■ Productos lacteos coma: ■ Una vez que se enfrfe la grasa
d t l frasco a contenedor
yogur, queso, crema espesa en e�
cerrado, puede tirarlo a la
■ Granos de cafe basura. J
■ Crema para cafe ■ Use una espatula de hule
■ Productos horneados a una toalla de papel para
eliminar los restos de comida
Las tuberias tapada> pEIF-IdOn y la grasa del sarten y
salir costosas y pror,ucir viertaios en un contenedor
de ;bord,imiento dol desague que se pueda cerrar a en la iSE DEBEN TIRAR
sanitario basura. A LA BAS U RA!
Con el tiempo, las grasas y aceites
se coagulan y se endurecen. Esa iC1u`r cieha dejar do hikcE?E'?
repugnante acumulacidn grasosa ■ No vierta grasa par del
restringe el flujo del agua par las desague.
tuberias. A la larga, el bloqueo ■ No lave freldoras, parrillas, r I
produce desbordamiento de las alias o sartenes con agua de I
canerias de desague. Las aguas la Have sino hasty que hays
negras pueden regresar a su jardin eliminado toda la grasa y el
a al interior de su casa. iUsted aceite.
NO querra tener que lidiar con
un desbordamiento de canerfas
de desague! El desbordamiento S.�3�;1"("IC I(15 1)U!' 1J(i17('I" (1('
�bl�i LS$E3d qU4'...
de las canerias de desague entre S11 port(' 1 am CiV11dal
su casa y !a conexion al sistema Las sistemas de aguas de la
de la Ciudad de Raleigh es Ciudad no estan disenados ni a 1)roteCger C1 a(pla do
responsabilidad de LISTED- esto equipados para tratar el agua con RaI(,jg11.
resulta costoso y puede ser una grasas y aceites que se acumula
experiencia traumatizante. en las tuberias de recoleccion del
desague.
Para obtener mas information,
visite raleighnc.gov a bien, co- ` *4 0
munfquese con el Departamento de �` 00 Raleigh
Servicios Publicos al 919-996-3245. 1
000 Water
raleighncagov

I ESID[ENTIAL
Keep Grease Out of the Drain!
fats. Oi?, and Grease (FOG) Have-n Our -Water System
Never send these sources of What Am I Supposed to Do
FOG down the drain: with FOG like Bacon Grease?
■ Meat and Food Scraps
■ Lard/Shortening
■ Oil
■ Sauces
■ Bacon grease & other fat
drippings
■ Dairy products like Yogurt,
Cheese, Heavy Cream
■ Coffee Grounds
■ Coffee Creamer
■ Baking Goods
Blacked pipes can be
expensive and lend to sanitary
.sewer overflow
Fats and grease congeal and
harden over time. That nasty,
oily buildup restricts water
flow through pipes. Eventually,
there is blockage that can lead
to a sewer backup. Untreated
waste can come back onto
your lawn or inside your home.
You do NOT want to deal
with a sewer backup! A sewer
backup between your home
and the connection to the City
of Raleigh system is YOUR
responsibility - it's expensive
and can be a traumatic
experience!
■ Drain fats from cooking
bacon or other meats int.,
a collection container like
a glass jar or empty soup
can.
■ Once the drained cooking
grease in sealed container
has cooled, you can place
the container in the trash.
■ Use rubber scraper or
paper towel to remove
remaining grease and food
scraps from the pan into a
sealable container or the
trash.
Whet do I need to stop doing?
■ Do not pour grease down
the drain
■ Do not wash fryers,
griddles, pots or pans with
water until all the oil and
grease has been removed
Did You Know?
City water systems are not
designed or equipped to treat
the FOG that accumulates in
sewer collection pipes.
For more information
visit raleighnc.gov or contact
the Public Utilities Department
at 919-996-3245
raleighnc.gov
5W
Jkl
KEEP FATS, OILS,
AND GREASE
OUT OF: THE SINK.
THEY BELONG IN
THE TRASH!
Thankyou
for doing your part
to 110P Protect
Rr11c ig11 1441teI-!
0
, Raleigh
*4) :.
S0,00 Water

11/19/2019
A .." &-
CITIZENS
ADVISORY COUNCIL
PRIVATE COLLECTION SYSTEM
�r
f Home plumbing fixtures
f Backwater valves
f
}Service clean cuts Z
#Private sewer lateral
�'Sewerservice connection
.nW.w.n
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Tarr .ram - .
- F
.2Underground Systems —Stoimwars _ saltary,t3arll�sr,
I
a iii - a
PUBLIC COLLECTION SYSTEM
+Starts at the service connection
V5ewer Main
Service Manhole & covers
Mom ►RX=
my =
'Trunks ;r .
Syphon bens
.,Pumpstations/liftstations ryr .e
• Waste water treatment plant vr...�w� ¢t
xrarlrsxrrsrrvr
MAINTENANCE RESPONSIBILITY
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yrrf.r.an.dn1padf.rNbi1 um by o.d.rerfan and
rahc411r.Mir
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IM � Mawrr.rtl WrW.
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11/19/2019
COMMON ISSUES WITH PRIVATE SEWER SERVICES
✓Sewer bar kupsdoe to ebackned terva$s - Qk
✓ Misslny or defective bRckwRtervelve
✓ Miss nj or Inadegtsete sewer ckRna41 j
✓ Rmt intrusic i Into p pe cracks
✓ Sewer od ar rrr11�
✓ Oder pipe fal ures u ,
WHAT CAN WE DO TO PARTNER TO PROTECT RALEIGH'S
SANITARY SEWER COLLECTION SYSTEM
� MAVl ACiRI11e0/YYYRLR RNIRAI6Y M►6TAeRY RIRe1r1W 7C11
CAKIIINTROUNINTHEIRMIXIMMORMILM
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w[nCfis ORr/AnAR.
+ AeeRONAL/YogAltiR1N tAN u IRAl7Ca
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COMMON ISSUES WITH PRIVATE SEWER SERVICES
Solid Waste Services Department
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