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HomeMy WebLinkAboutWQCS00002_NOV-2020-DV-0271 Response_20200610ROY COOPER (:Hurt+uw eb �� MICHAEL S. REGAN '�` .• S. DANIEL SMITH NORTi 1 CAROLINA DOW— Enrlranmcnfal Qualify CERTIFIED MAIL: 7016 3560 0000 4428 694 RETURN RECEIPT REQUESTED June 10, 2020 Robert Massengill, Director Public Utilities City of Raleigh PO Box 590 Raleigh, NC 27602 SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY Tracking No.: NOV-2020-DV-0271 Sanitary Sewer Overflows - May 2020 Collection System Permit No. WQCS00002 Raleigh Collection System Wake County . Dear Mr. Massengill: V JUN 19 20211 NC DeptOfEnvironincnlai �- JUL j [i 2(12[j Raleigh i�cginrr;�l r I,., 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 to why the City of Raleigh should not be assessed a civil penalty for the violations that are summarized below: Total Vol Total Surface Incident Start Duration Vol Water Number Date (Mins) Location Cause (Gals) (Gals) DWR Action 202001324 5/4/2020 159 3151 CAPITAL BLVD Grease 1,575 1,000 Notice of violation 202001325 5/4/2020 113 1511 GRADUATE LN, Roots 3,000 3,000 Notice of violation Raleigh Notice of Intent 202001335 5/6/2020 61 808 Navaho Drive Grease 6,700 Notice of Violation Qrw kart-Cin ri Dips ntiittdEr;r 9116 j Rt :, I GYl :• titfr613;l ril Ev-ia TSe%a� rr;• rt_�r :ir i ..'cv? Incident start Duration Number Date (Mina) Location 202001341 5/7/2020 497 4020 Tryon Road 202001378 5/14/2020 67 202001567 5/26/2020 13 202001722 5/29/2020 41 202001779 5/30/2020 144 Cause Pipe Failure (Break) 2421 Foxtrot road, Grease Raleigh 4029 Deep Hallow Dr., Grease Raleigh 141 Cotton Paws Pump station Street equipment failure 514 West Cambridge Grease Drive Total Vol Total Surface Vol Water (Gals) (Gals) DWR Action 49,149 13,000 Notice of violation Notice of Intent 871 800 Notice of Violation 900 600 Notice of Violation 1,640 1,640 Notice of Violation 3,180 3,180 Notice of Violation Notice of Intent 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 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, �T2 Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCD£Q Cc: Raleigh Regional Office - WQS File Laserfiche Section e-mail to Carlos Perez carlos.perezftraleiahnc.gov Qom• hvvcv'I y.* JV.I:•.f 1: ISI-AIMr;!! D ,.r k!*(IF*(:rI-" *I°C.:EranDf%t r!1(• Fi:Y:t.r*;'E.� '00 �10 110 Raleigh Water July 9, 2020 Mr. Scott Vinson 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-2020-DV-0271 Sanitary Sewer Overflows - May 2020 Permit No. WQCS00002 Dear Mr. Vinson: JUL -.q 2020 4 R"kvidl 001w Please forgive the delay with this response letter. The development of this document, within the allotted 10 business days', was a challenge due to restrictions imposed by COVID-19. However, allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty document (NOV-2020-DV-0271) received on June 19th, 2020. This document contains narratives regarding pending violation actions of (8) Sanitary Sewer Overflows (SSO) events, which occurred during the month of May 2020 within the City of Raleigh Collections System fll. The noticed events occurred while the City operated its collection system, according to WQC500002, dated June 6th, 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. This document will establish a reasonable explanation of the actions taken to stop the spill; contain the released wastewater; collect the wastewater and reintroducing it to the collection system; and finally, restoring the possible environmental impacts brought by the release of the SSO events, listed with the intended NOV-NOI action. 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 tc the Division as stipulated In Condition IV92). This Includes SSOs that were caused by severe natural conditions or ex=eptional events unless the Permittee demonstrates through properly signed, contemporaneous operating logs, or other relevant evidence that: Ia.] 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 -nfiltration, 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 collections system components, wastewater retention or treatment facditles, adequ, to 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 550 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 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 on Recycled Paper Incident Number # 202001324 — 5/4/2020 — 3151 Capital Blvd. This spill was neither willful nor intentional, it was the result of a grease build-up, restricting the sewer flow within a section of 8-inch sewer gravity main. This build-up led to a sewer spill of approximately 1,575 gallons of untreated wastewater of which about 1,000 gallons reached surface waters through a stormwater channel within the Marsh Basin. Most of the wastewater rested within the natural topography of the land not reaching other major surface waters. On 5/4/20, at approximately 5:06 PM, Sewer Maintenance staff was notified of a sewer spill emanating from a manhole adjacent to 3151 Capital Blvd., 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 7:45 PM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring sewer flow. Containment, collection, cleanup, and restoration of this spill event consisted of employing a temporary spill containment site downstream of the affected area. This approach was intended to contain the flow of sewer and minimize the environmental impact on the surrounding land. This spill was contained without a significant environmental impact to 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. During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and to remove traces of sewer from the area surrounding the manhole and the downstream stormwater system. Crews employed pumps at the temporary containment site, to recover flushed wastewater and any evidence of sewer. The areas around the manhole were cleared of debris and washed with potable water. No lime, seed, and straw was required as this asset is located on the paved surface. A follow CCTV assessment, conducted on 05/6/2020, determined that a portion of the sewer main presented an offset joint which could have led to the grease accumulation and subsequent spill. A repair operation to address the issue was consequently performed on 06/22/2020. CCTV assessment is scheduled to verify the effectiveness of the repair and minimize the potential of a re -occurrence. No further issues have occurred at this site since this event. The cost associated with the mitigation of this event amounted to $1618.81. The approximate cost to the Utility to have treated 1,575 gallons of wastewater would have been approximately $2.36. 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 the cost to treat the greater volume of sewage created by the spill. This section of the collection system serves a wide commercial area within the Capital Boulevard Corridor, providing sewer collection services to several commercial establishments. The last recorded sewer spill associated with this section of the sanitary sewer collection system occurred on 09/04/2000 where approximately 1,800 gallons of untreated water was released as the result of a plug left within the sewer main by a contractor. 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 A press release notification, associated with this event, was requested to be published in the Raleigh News & Observer on 5/6/2020 6:33 AM. Outreach information was delivered to a hotel property where the affected asset is located. This outreach literature explains the need for customers to use the sanitary sewer collection system properly. It also serves as an opportunity for citizens to partner with Public Utilities to protect the City's water quality and the sewer collection infrastructure. Prior to this event, maintenance records show that sections of this collection system were assessed as follows: Flushing activities 12/02/03 05/22/14 06/30/14 04/14/15 Repair activities 06/22/2020 06/25/2020 06/24/2020 CCTV activities 05/20/2020 Inspection activities 09/20/2018 Easement maintenance 02/12/2019 06/16/2020 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 Incident Number # 202001325 — 5/4/2020 —1511 Graduate Ln., Raleigh This spill was neither willful nor intentional, it was the result of root intrusion, which blocked a portion of an 8-in" gravity sewer main. The root intrusion led to a sewer spill of approximately 3,000 gallons of untreated wastewater reaching surface waters through an unnamed tributary in Bushy Basin. On 5/4/2020, at approximately 3:07 PM, Sewer Maintenance staff was notified of a sewer back- up behind the residences located at 1511 Graduate Ln., Raleigh. Upon arrival, it was discovered that untreated sewer was emanating from an adjacent manhole (SMH2O3876). 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 5:00 PM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage within the affecting asset thus restoring sewer flow Containment, collection, cleanup, and restoration of this spill event consisted of employing a temporary sewer containment site downstream from the SSO location to stop the flow of sewer into the stream. Crews used pumps at the temporary containment site, to recover the remaining sewer back into a downstream sewer manhole. During the restoration phase of the operation, crews utilized water from adjacent hydrants to defuse and flush the affected area. The area around the manhole was cleared of debris, treated with an application of lime, and restored with grass seed and straw. This spill was contained without a significant environmental impact to 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. The cost associated with the mitigation of this event amounted to $2889.54. The approximate cost to the Utility to have treated 3,000 gallons of wastewater would have been approximately $4.50. 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 the cost to treat the greater volume of sewage created by the spill. This section of the collection system serves a residential area South of Gorman St., Raleigh. This system provides sewer collection to several multi -dwelling properties. A press release notification associated with this event was published in the Raleigh News & Observer on 5/5/2020. Before this event, maintenance records show that sections of this collection system were assessed as follows: Flushing activities 05/15/2003 08/24/2003 03/24/2004 07/05/2005 05/10/2009 12/20/2012 3/20/2014 5/18/2014 02/21/2018 Inspection activities 84 High priority Inspections of assets located within the sanitary sewer easement were inspected between 02/7/2018 and 03/19/2020 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 latest maintenance/inspection assessment for this site was conducted on 7/6/2020. Visual inspection of the upstream and downstream manholes determined that sewer flow within the pipe is consistent. This assessment was conducted using flow monitors to verify flow velocity equalization on the downstream and upstream manhole in order to determine potential blockages that may reduce sewer flow. There have been no additional issues associated with this section of the collection system since the last sewer event. This site has been added to the Hot Spot Management Program for debris management with a recommended maintenance interval of every 30 days. 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 an Recycled Paper Municipal Building 222 West Hargett Street Raleigh, North Carolina 27601 incident Number # 202001335 — 5/6/2020 — 808 Navaho Dr., Raleigh This spill was neither willful nor intentional, it was the result of a grease build-up, restricting the sewer flow within a section of 8-inch Vitrified Clay Pipe sewer gravity main. This build-up led to a sewer spill of approximately 6,700 gallons of untreated wastewater. The spilled wastewater rested within the natural topography of the land not reaching nearby major surface waters. This event occurred within the Big Branch Basin. On 5/6/20, at approximately 6:39 PM, Sewer Maintenance staff was notified of a sewer spill emanating from a manhole behind an apartment complex located on 808 Navaho Dr., 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 8:00 PM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring sewer flow. Containment, collection, cleanup, and restoration of this spill event consisted of employing a temporary spill containment site downstream of the affected area. This approach was intended to contain the flow of sewer and minimize the environmental impact on the surrounding land. This spill was contained without a significant environmental impact to 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. During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and to remove traces of sewer from the area surrounding the manhole and the downstream stormwater system. Crews employed pumps at the temporary containment site, to recover flushed wastewater and any evidence of sewer. The areas around the manhole were cleared of debris and washed with potable water. The area around the manhole was cleared of debris, treated with an application of lime, and restored with grass seed and straw. A follow CCTV assessment, conducted on 05/8/2020, determined that the main was in structurally sound condition. The assessment also recommended that the invert of an upstream manhole be addressed along with more hydro jetting cleaning along with the affected assets downstream of the spill event. A repair operation to address the issue has been scheduled. A follow-up CCTV assessment will be scheduled to verify the effectiveness of the repair and minimize the potential of a re -occurrence. An electronic flow monitor has been installed downstream of the affected manhole in order to serve as an early warning device with the intent to alert responding crews before an overflow occurs. No further issues have occurred at this site since this event. The cost associated with the mitigation of this event amounted to $2,570.58. The approximate cost to the Utility to have treated 6,700 gallons of wastewater would have been approximately $10.05. 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 the cost to treat the greater volume of sewage created by the spill. This section of the collection system serves a vast residential area West of Wake Forest Rd. and north of 1-440, providing sewer collection services to several multi -dwelling properties. The last recorded sewer spill associated with this section of the sanitary sewer collection system occurred on 11/19/2002. 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 A press release notification, associated with this event, was requested to be published in the Raleigh News & Observer on 5/11/20201:55 PM. Due to Statewide restrictions of COVID-19, outreach information was delivered on 06/16/2020.378 door hangers were delivered to the office manager of the affected apartment complex. The office was to deliver educational information to their tenants. This outreach literature explains the need for customers to use the sanitary sewer collection system properly. It also serves as an opportunity for citizens to partner with Public Utilities to protect the City's water quality and the sewer collection infrastructure. Prior to this event, maintenance records show that sections of this collection system were assessed as follows: Flushing activities Inspection activities 01/07/2010 2/18/2011 12/13/2013 12/3/2018 02/08/2010 3/18/2011 1/20/2014 02/10/2010 3/22/2011 3/6/2014 3/24/2010 5/28/2011 4/20/2014 CCTV activities 4/10/2010 6/5/2011 5/27/2014 05/8/2020 6/1/2010 7/8/2011 6/6/2014 6/8/2010 7/11/2011 6/10/2014 6/14/2010 8/1/2011 6/23/2014 6/28/2010 11/7/2011 8/19/2014 7/6/2010 12/6/2011 10/9/2014 07/08/2010 3/9/2012 12/26/2014 7/13/2010 6/12/2012 4/14/2015 7/14/2010 7/4/2012 4/16/2015 8/15/2010 9/4/2012 7/20/2015 8/19/2010 12/11/2012 7/22/2016 9/19/2010 3/21/2013 7/23/2016 12/11/2010 5/13/2013 03/19/2018 12/12/2010 6/11/2013 02/21/2018 2/10/2011 9/3/2013 05/17/2017 2/14/2011 10/14/2013 09/13/2017 02/15/2011 10/17/2013 02/21/2018 2/16/2011 10/20/2013 03/7/2018 2/17/2011 12/12/2013 10/17/2018 Easement maintenance Repair activities 05/28/2019 The latest maintenance/inspection assessment for this site was conducted on 7/6/2020. Visual inspection of the upstream and downstream manholes determined that sewer flow within the pipe is consistent. This assessment was conducted using flow monitors to verify flow velocity equalization on the downstream and upstream manhole in order to determine potential blockages that may reduce sewer flow. There have been no additional issues associated with this section of the collection system since the last sewer event. This site has been added to the Hot Spot Management Program for debris management with a recommended maintenance interval of every 30 days. One Exchange Plaza City of Raleigh Municipal Building i 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 Incident Number # 202001341— 5/7/2020 — 4020 Tryon Rd. Raleigh This spill was neither willful nor intentional, it was the result of a failed pipe that restricted sewer flow of an 8-inch Ductile Iron Pipe sewer gravity main. This asset failure led to a sewer spill of approximately 49,149 gallons of untreated wastewater in which approximately 13,000 gallons reached surface waters within Marks Upper Basin. On 5/7/20, at approximately 11:28 AM, Sewer Maintenance staff was notified of a sewer odor. The upstream assessment identified sewer emanating from the ground near manhole SMH108644 located in the vicinity of 4020 Tryon Rd., Raleigh. Upon arrival, it was determined that a section of pipe had collapsed, resulting in reduced flow capacity. 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 7:45 PM on the same day. Containment, collection, cleanup, and restoration of this spill event consisted of employing several temporary spill containment sites downstream of the affected area (see pictures below). This approach was intended to contain the flow of sewer and minimize the environmental impact on surrounding land and surface waters. This spill was contained without a significant environmental impact to 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. Maintenance/inspection assessment for this site was conducted on 7/6/2020. Visual inspection of the upstream and downstream manholes determined that sewer flow within the pipe is consistent. This assessment was conducted using flow monitors to verify flow velocity equalization on the downstream and upstream manhole in order to determine potential blockages that may reduce sewer flow. There have been no additional issues associated with this section of the collection system since the last sewer event. This site has been added to the Hot Spot Management Program for debris management with a recommended maintenance interval of every 30 days. During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and to remove traces of sewer from the area surrounding the manhole and the downstream stormwater system. Crews employed pumps at the temporary containment site, to recover flushed wastewater and any evidence of sewer. The areas around the manhole were cleared of debris and washed with potable water. The area around the manhole was cleared of debris, treated with an application of lime, and restored with grass seed and straw. The restoration to this site was completed on 05/14/2020 cleaning approximately 5,000 ft of surrounding surface waters and adjacent land. (See picture below) 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 Retytled Paper A follow CCTV assessment completed on 06/23/2020, determined that the main was heavily tuberculated minimizing adequate flow capacity. Through this assessment, it was recommended that approximately 2,000 ft of sewer pipe needed to be replaced. The Utility summoned a Utility Contractor to establish a sewer by-pass and conduct the necessary repairs; currently on -going. A follow-up CCTV assessment will be scheduled to verify the effectiveness of the repair and minimize the potential of a re- occurrence. The cost associated with the mitigation of this event has amounted to $ 37,388.17. The approximate cost to the Utility to have treated 6,700 gallons of wastewater would have been approximately $73.72. 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 the cost to treat the greater volume of sewage created by the spill. Repairs are currently ongoing which could incur higher costs for complete mitigation. 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 Prior to this event, maintenance records show that sections of this collection system were assessed as follows: Easement Flushing activities Repair CCTV activities Inspection activities Maintenance activities Activities 3/30/2010 6/5/2014 No records of 06/12/2017 04/6/2020 02/16/2018 5/15/2010 8/6/2014 repairs or 09/25/2017 10/11/2018 3/23/2012 12/28/2014 improvements 06/02/2020 12/19/2018 9/22/2012 4/18/2015 for the last10 06/03/2020 05/6/2019 12/29/2012 9/10/2015 years 06/10/2020 07/12/2019 3/10/2013 05/01/2018 06/22/2020 08/6/2019 6/12/2013 02/21/2018 06/24/2020 3/20/2014 This section of the collection system serves a commercial and residential area south of 40 and West of Gorman St., providing sewer collection services to several multi -dwelling properties and various commercial establishments. The last recorded sewer spill associated with this section of the sanitary sewer collection system occurred on 3/21/2009. A press release notification, associated with this event, was requested to be published in the Raleigh News & Observer on Friday, May 8, 2020. See picture below. NOTICE OF DISCHARGE OF UNTREATED WASTE Cily of Raleigh Mink Utilities Department on re- sources was nottliea at the avertfow. Raleigh Water - Sewer Mainlenonce Division staff, stopped the overflow at approximately 7:40 PM on the some day. II is estimated that the overflow discharoed a volume at approximately 4,145 gallons of untreated waslawater, of which approximately 13,000 gallons reached an VAnomed tributary of Wal- nut Basin. Restoration associated to this sewer event is angoing. There were no observed fish killed or vegetative dom• aged associated with Ihisevent. The City of Raleigh has an aggressive education and enforcement program to prevent the discharge of grease, debris, old other Improper materials In the sewer system and to take enforcement colon where appropriate. Only water, human waste, and loilat tissue are Per - mined to be discharged into the sewer system. This news release is required by NCGS Article 21, Chapter 143115LC For more Information. contort public U11111- ies Director Robert Mossengill or assis- lont Public Utilities Director T.J. Lynch 01919A9 oo. North Carolina Department Environ- ment and Natural Resources, Division at Water Duality was notified of the over- flow. NLO: May 10. 2020 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 Incident Number # 202002378 — 05/14/2020- 2421 Foxtrot Rd., Raleigh This spill was neither willful nor intentional, it was the result of a grease build-up, restricting the sewer flow within a section of 8-inch sewer gravity main. This build-up led to a sewer spill of approximately 871 gallons of untreated wastewater of which about 71 gallons reached surface waters through an unnamed tributary within the Perry Basin. On 5/14/20, at approximately 4:53 PM, Sewer Maintenance staff was notified of a sewer spill emanating from an adjacent manhole (5MH127801) at 2421 Foxtrot Rd., 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 6:00 PM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring sewer flow. Containment, collection, cleanup, and restoration of this spill event consisted of employing a temporary spill containment site downstream of the affected area. This approach was intended to contain the flow of sewer and minimize the environmental impact on the surrounding land. This spill was contained without a significant environmental impact to 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. During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and to remove traces of sewer from the creek. Crews employed pumps at the temporary containment site, to recover flushed wastewater and any evidence of sewer back into a downstream sewer manhole. The areas around the manhole were cleared of debris, treated with an application of lime, and restored with grass seed and straw. The cost associated with the mitigation of this event amounted to $7,333.56. The approximate cost to the Utility to have treated 871 gallons of wastewater would have been approximately $1.30. 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 the cost to treat the greater volume of sewage created by the spill. This section of the collection system serves a residential area South Rock Quarry Rd., providing sewer collection to over 170 properties. The last recorded sewer spill associated with this section of the sanitary sewer collection system occurred on 04/12/2010 (2410 Creech Rd.). A press release notification associated with this event was requested to be published in the Raleigh News & Observer on Friday, May 15, 2020. Due to COVID-19 restrictions Outreach Information has not been delivered. 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 Prior to this event, maintenance records show that sections of this collection system were assessed as follows: Flushing activities Repair activities Inspection activities 4/12/10 6/26/11 9/13/2013 4/13/10 5/23/11 4/14/10 7/2/11 9/15/2013 10/23/2014 12/28/10 5/14/10 7/4/11 9/25/2013 6/3/11 5/6/11 6/16/10 12/5/11 10/5/2013 11/9/2012 5/17/11 9/7/10 5/10/2012 11/9/2013 10/3/10 10/12/2012 8/2/2014 CCTV activities 10/28/10 11/1/2012 8/15/2014 12/2/10 11/3/2012 10/10/2014 10/22/2014 12/13/10 11/9/2012 10/13/2014 9/17/2013 5/23/11 12/4/2012 2/10/2015 11/9/2012 5/24/11 6/17/2013 10/15/2015 5/18/11 5/25/11 8/23/2013 05/15/2020 5/26/11 9/11/2013 07/07/2020 Easement Maintenance Activities 5/18/11 2/9/2015 The latest maintenance/inspection assessment for this site was conducted on 7/6/2020. Visual inspection of the upstream and downstream manholes determined that sewer flow within the pipe is consistent. This assessment was conducted using flow monitors to verify flow velocity equalization on the downstream and upstream manhole to determine potential blockages that may reduce sewer flow. There have been no additional issues associated with this section of the collection system since the last sewer event. This site has been added to the Hot Spot Management Program for debris management with a recommended maintenance interval of every 30 days. 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 Incident Number # 202001567 — 05/26/2020- 4029 Deep Hollow Dr., Raleigh This spill was neither willful nor intentional, it was the result of a grease build-up, restricting the sewer flow within a section of 8-inch ductile iron pipe sewer gravity main. This build-up led to a sewer spill of approximately 900 gallons of untreated wastewater of which about 600 gallons reached surface waters through an unnamed tributary within the Crabtree Basin. Approximately 300 gallons remained within the surrounding ground without (see picture below). On 5/26/20, at approximately 8:37 AM, Sewer Maintenance staff was notified of a sewer spill emanating from a manhole (SMH116600) at 4029 Deep Hollow Dr., 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 8:50 AM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring sewer flow. Containment, collection, cleanup, and restoration of this spill event consisted of employing a temporary spill containment site downstream of the affected area (see picture below). This approach was intended to contain the flow of sewer and minimize the environmental impact on the surrounding land. This spill was contained without a significant environmental impact to 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. 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 During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and to remove traces of sewer from the creek. Crews employed pumps at the temporary containment site, to recover flushed wastewater and any evidence of sewer back into a downstream sewer manhole. The areas around the manhole were cleared of debris, treated with an application of lime, and restored with grass seed and straw. The cost associated with the mitigation of this event amounted to $5,477.67. The approximate cost to the Utility to have treated 900 gallons of wastewater would have been approximately $1.35. 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 the cost to treat the greater volume of sewage created by the spill. This area serves a large apartment complex with a history of spills associated with debris and grease accumulation. Before 05/26/2020 incident, the most recent incident occurred on February 3, 2020 (incident # 202000226), where 3,950 gallons of untreated wastewater was lost. This SSO was also caused by a buildup of flushed wipes just as the event on 05/26/2020. This site has been identified as a frequent site for continued assessment. A recent visual assessment of the collection system determined that the spilled manhole (SMH116600) requires a drop manhole to be installed. This installation would decrease damage to the invert from a flow 6-ft above. This repair would ease continued sewer flow downstream as well a minimize the possibility of a spill reoccurrence. The repair was completed on 06/01/2020. A follow-up assessment is scheduled for verification of effectiveness. Prior to this event, maintenance records show that sections of this collection system were assessed as follows: Inspection Easement Flushing activities Repair activities activities Maintenance Activities 10/22/10 10/3/2012 8/19/2015 01/15/2020 3/10/2012 3/4/11 11/1/10 10/4/2012 02/16/2017 06/01/2020 2/28/11 3/7/11 11/2/10 10/6/2012 01/30/2018 2/23/11 10/20/2012 09/14/2018 3/7/11 3/7/2013 05/3/2019 CCTV activities 3/25/11 4/26/2013 05/9/2019 11/2/10 5/24/11 4/30/2013 10/29/2019 1/5/11 12/9/11 5/8/2013 10/15/2019 10/15/2012 4/4/2012 9/18/2014 03/12/2020 3/27/2013 4/18/2012 8/6/2015 02/11/2020 3/25/11 7/3/2012 8/7/2015 06/22/2020 09/23/2019 9/25/2012 09/20/2019 09/20/2019 10/22/2019 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 Raleigh, North Carolina 27601 (Mailing Address) Printed on Recycled Paper The latest maintenance/inspection assessment for this site was conducted on 7/6/2020. Visual inspection of the upstream and downstream manholes determined that sewer flow within the pipe is consistent. This assessment was conducted using flow monitors to verify flow velocity equalization on the downstream and upstream manhole in order to determine potential blockages that may reduce sewer flow. There have been no additional issues associated with this section of the collection system since the last sewer event. This site has been added to the Hot Spot Management Program for debris management with a recommended maintenance interval of every 90 days. 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 Incident Number # 202001722 — 05/29/2020-141 Cotton Paws St., Rollesville This spill was neither willful nor intentional, it was the result of a broken check valve on a forced main. This asset failure led to a sewer spill of approximately 1,640 gallons of untreated wastewater reaching an unnamed tributary in Smith Creek Basin. On Friday, May 29, 2020, at approximately 12:57 PM, Raleigh Water - Resource Recovery Division contacted the Sewer Maintenance Division requesting assistance with a broken check valve at Pump Station 113-Granite Acres, located at 141 Cotton Paws St, Rolesville, NC 27571. Operators onsite reported that the isolation valve could not be turned and would need to be excavated in order to exercise the valve or replace it. A Sewer Maintenance repair crew was dispatched and began reparations to excavate the damaged valve. Upon arrival, pump station operators where onsite managing the station, and no overflow was occurring. The check valve was excavated and found to be damaged. The isolation valve could not be exercised. The crew proceeded to cut the damaged valves from the force main at which point wastewater began to backflow into the excavated trench. The flow was managed until a pump truck that was assisting with the repairs, filled resulting in access wastewater to overflow the excavated trench ultimately spilling into an adjacent creek. This event occurred at approximately 6:24 PM. Crews took control of the situation completing the repair and stopping the overflow at approximately 7:05 PM on the same day. This spill was contained without a significant environmental impact to 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. The Backup ORC observed no solids, and or wastewater within the creek. Flow in the creek was high due to heavy rainfall over the preceding 72 hours, which helped defuse the wastewater downstream before crews could arrive to contain or collect the discharge. The site of the sewer run-off was treated with an application of lime and restored with grass seed and straw. The cost associated with the mitigation of this event amounted to $1,284.16. The approximate cost to the Utility to have treated 1,640 gallons of wastewater would have been approximately $2.46. The City saved no money from this spill. Its costs for cleanup and repair exceeded the cost of treating the volume of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the spill. The failed ball valve and check valve for force main SFMN10041 are intended to allow discharge from the wet well. The ball valve could not be exercised to isolate the force main. There were no records of mechanical issues with the device prior to this event. The last maintenance record for this device was conducted on May 28, 2020. The events leading to this spill can be considered exceptional, unintentional, temporary, and caused by factors beyond our reasonable control. Furthermore, the SSO 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. A press release notification related to this event was requested to be published in the Raleigh News & Observer on May 29th, 2020. There have been no further sewer events associated with this location. See picture below. 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 Raleigh Water Responds to a Sanitary Sowor Spill Cn FRCay, rda( 2 P. 2320, at ap onnti" 6 2x Pet, FUwp Wow. Sw*t tdsmea arvw fkidrn staff t&ir rA&1 in a esikaq vmwt n tidL-kw laratad n ties %ici* of Ill C0001 Parrs Sk AOW4, Pit Th4 cam :f aM "rlF w ►vas rotated to a ripair tmedodtd an (alledequpmc-m at the &andekcm p *stathn The hapon&*q ataE tosk all rswwtsb a hope to -4Wp and r+IW"te 1hr impact eF 04 evo& w as soon as dour arcked The Marth Carotna Department of ErYir&wrmdid Oual ty Mis+on atWaler Risouxoswai mttsedof ro emisev Raaeigtl Water . Slow Mama[[ me OU&tan stall, sta"" tro erMllfDty st apprwtaaaiety jr OS -am on t* some [lay n is esur acm that v% mmcw dts kw9ei a vo%orm of a@prarietsltly 1_618 4O*" at unNaatad wovWx- 11r. ar eI mf ieb rok4md anuralrlamed v ttitaty ofihe Senih Qft*Basn, Fosbceatien anodated to this w%*r evtm has Caen cwpWW 'here lwtrt ma obwrved lsh Wed or .e Iath-s dama p assodttcd nth 1h6 evem • Rakish Wmer has an aggressiverducation and rnimmemem program to prevrnt no disehago of gme3*,deh is.*ripts. rsys.d:apenawdaeter &np om materials in [the seraer syrstan and to tttile onfame mmiacdon %harr appropdaaa.11dwso !gets make it into tht sutler spun awl may dose a spill whkh can havven adverse impact on water quaEltyarnd ■ndmVor d hbmo vAm eaa" imn cantaet with the alfaetsrl am%. • Waw her"m-nattls.8mttoibt stout are the *"IV imams paamnrtfad to be discharged ireo t:se sewer symem Al other b ms 1A 1 copse damage to the smw system and are no permitted., • 11yot, euperkncotatotrssve sewer smols or msemi VINirg hem mantules of pupas piawse catl 5'94"G-V45 to tgxm rownedaletx • Far Iatwe lwthYrrl LkM alsuut bUWYua ceTV Merit prawn[ slaAWY sewer spill% p6&m visit: tab;2hnt _9omht w. �7�iy /resat tatwtieia r.yu;.�1 ts)r rtCl3s�ti.ta 2t, slty�en is,3 tt5.1C 11= 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 incident Number # 202001779 -- 05/30/2020- 514 West Cambridge Dr., Raleigh This spill was neither willful nor intentional, it was the result of a grease build-up, restricting the sewer flow within a section of 8-inch PVC sewer gravity main. This build-up led to a sewer spill of approximately 3,180 gallons of untreated wastewater. Reaching an unnamed tributary of Little 5 Basin. On Saturday, May 30, 2020, at approximately 3:12 PM, Sewer Maintenance staff was notified of an active sewer overflow occurring at 514 W Cambridge Dr, Zebulon, NC. 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 5:36 PM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring sewer flow. Crews also utilized hand tools to scrape heavy grease deposits from the affected assets. Containment, collection, cleanup, and restoration of this spill event consisted of employing a temporary spill containment site downstream of the affected area. This approach was intended to contain the flow of sewer and minimize the environmental impact on the surrounding land. This spill was contained without a significant environmental impact to 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. During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and to remove traces of sewer from the area surrounding the manhole and the downstream surface waters. Crews employed pumps at the temporary containment site, to recover flushed wastewater and any evidence of sewer. The area around the manhole was cleared of debris, treated with an application of lime, and restored with grass seed and straw. A follow CCTV assessment, conducted on 05/30/2020, determined that the main was in structurally sound condition. No further issues have occurred at this site since this event. The cost associated with the mitigation of this event amounted to $ 3,096.68. The approximate cost to the Utility to have treated 3,180 gallons of wastewater would have been approximately $4.77. 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 Citystill had to pay the cost to treat the greater volume of sewage created by the spill. This section of the collection system serves a residential area North of West Gannon Ave. in Rolesville, providing sewer collection services to several multi -dwelling and single-family properties. The last recorded sewer event within this section of the collection system occurred on 10/14/2028 as a result of grease accumulation. A press release notification, associated with this event, was requested to be published in the Raleigh News & Observer on Saturday, May 30, 2020. Due to Statewide restrictions of COVID-19, outreach information was delivered on 06/03/2020.38 door hangers were delivered to the affected area. This outreach literature explains the need for customers to use the sanitary sewer collection system properly. It also serves as an opportunity for citizens to partner with Public Utilities to protect the City's water quality and the sewer collection infrastructure. 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 Prior to this event, maintenance records show that sections of this collection system were assessed as follows: Flushing activities 11/24/2015 12/21/2015 12/1/2015 10/11/2017 12/10/2015 06/6/2018 10/17/2018 Inspection activities 18 sewer assets located within the sanitary sewer easement were inspected between 05/21/2018 and 03/27/2020 CCTV activities 10/17/2018 07/23/2018 Easement maintenance 09/6/2019 10:52 AM Repair activities 07/15/2019 The latest maintenance/inspection assessment for this site was conducted on 7/7/2020. Visual inspection of the upstream and downstream manholes determined that sewer flow within the pipe was not consistent. Consequently, a follow-up flushing was conducted on the same day. This visual assessment was conducted using flow monitors to verify flow velocity equalization on the downstream and upstream manhole in order to determine potential blockages that may reduce sewer flow. There have been no additional issues associated with this section of the collection system since the last sewer event. This site has been added to the Hot Spot Management Program for debris management with a recommended maintenance interval of every 90 days. 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 Summary The Division of Sewer Maintenance, Public Utilities Department, strives in developing initiatives that improve operational reliability with the goal to meet customer expectations and to meet or exceed the requirements of the Water Quality Collection System permit. Our operations are focused on continual improvement, the prevention of pollution, and increase efficiency in environmental performance. This is greatly noted as the Division continues to operate an ISO Certified Environmental Management System governed by the 14001-2015 Standards. As part of these initiatives, the Division operates a comprehensive reactive and preventative maintenance program whose goal is not only to maintain over 2600 miles of sanitary sewer pipe but also to minimize the accidental release of untreated wastewater. Since July 1, 2019 (Fiscal Year 2020), the Utility has maintained approximately 382 [1] miles of gravity sewer mains, by flushing with hydraulic jetting, CCTV assessments, repair operations, easement maintenance, and inspections. The fiscal year 2020 cost of these operations amount to $3,102,022.92, approximately 23% of the Division's annual operating budget. The total volume of sewer spills identified in this letter adds up to 55,740 gallons at a total mitigating cost of $ 61,659.17. The City saved no money from these spills. Their costs for cleanup exceeded the cost of treating the volume of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by these spills. The City's cost of sewer treatment per gallon is $.0015 [2]. At this rate, it would have cost the City $83.61 to treat every gallon of sewer spilled. This fiscal comparison shows the City's commitment to environmental protection sparing no cost regardless of the severity and complexity of the spill event. The City continues to demonstrate due diligence in environmental performance by allocating the necessary resources to a spill event regardless of the associated cost. This effort is noted in the City's low SSO performance rate of 2.25 spills per 100 miles of pipe, compared to the Southeastern Region of the US, of 7.0 spills per 100 miles of pipe. 11) 382 miles represents 14% of the sanitary sewer collection system 121$.0015 is based on the annual water treatment operating cost compounded by the total treated effluent. 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. 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 It is essential to mention that the reportable sewer events identified in this letter (January — March 2020) show that 33% of SSOs were related to grease; a 15 % increase from events occurred during the same period in 2019. Between January 1st and July 1st, 2020, 40% of reportable spills have been related to grease accumulation. Public Utilities continues to increase its educational outreach to reduce this trend. The Department has developed new educational material as well as informational videos 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 material and videos can access through social media and our Department's website https://raleighnc.gov/sewer-maintenance 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. The City continues its monetary reward program or bounty program, which pays out fifty ($50) dollars to any citizen that observes and reports an SSO 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 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 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 that the NOV-NOI issued for the first quarter of 2020 be fairly reviewed taking into consideration 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, please contact Matthew Vessie, Sewer Maintenance Superintendent (919) 996- 2312 or T.J. Lynch, Assistant Public Utilities Director, at (919) 996-2316. 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 erely, Carlos M Perez, ORC Assistance Superintendent, Sewer Maintenance Division City of Raleigh Public Utilities Department P.O. Box 590 Raleigh, NC 27602-0590 919-996-5929 office 919-278-6020 cell Carlos. aerezcamacho@raleighnc Gov CC: Robert Massengill, Public Utilities Director T. J. Lynch, Assistant Public Utilities Director - Wastewater Matthew P Vessie, Superintendent Sewer Maintenance Division 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