HomeMy WebLinkAboutWQCS00002_NOV-2020-DV-0504 Response_2020121600
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Raleigh Water
December 16th, 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-0504
Sanitary Sewer Overflows - October 2020
Permit No. WQC500002
Dear Mr. Vinson:
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil
Penalty document (NOV-2020-DV-0504) received on November 25", 2020. This document contains
narratives regarding pending violation actions of (2) Sanitary Sewer Overflows (SSO) events, which
occurred in month of October 2020 within the City of Raleigh Collections System (1(. The noticed events
occurred while the City operated its collection system, according to WQCS00002, 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-NO[) 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 SSDs that must be reported to the Division as stipulated In Condition IV92). This Includes
SSOs that were caused by severe natural conditions or exceptional events unless the Permittee demonstrates through properly signed, contemporaneous operating
logs, or other relevant evidence that:
(a. [The SSO was caused by severe natural conditions; there were no feasible alternatives to the 550, such as the use of auxiliary treatment facilities, retention
of untreated wastewater, reduction of inflow and Infiltration, use of adequate back-up equipment, or an increase in the capacity of the system. This provision is
not satisfied If, In the exercise of reasonab!e engineering Judgment, the Permittee should have Installed auxiliary or additional col eclions system components,
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 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
Inf-0w); preventative maintenance; or .nstallation of adequate back-up equipment;"
0'-. I -ir 0
Restoration of this spill event consisted of washing approximately 533 ft of the surrounding land
utilizing approximately 55,000 gallons of potable water to flush the affected area from the spill site to
the containment site. The site of the sewer run-off was washed utilizing ample water to remove traces
of sewer. Sewer debris and solids were collected and disposed of accordingly. 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 $3,708.62.
The approximate cost to the Utility to have treated 575 gallons of wastewater would have been
approximately $.86. 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 provides sewer services to a residential neighborhood east
of Falls of the Neuse Rd., Raleigh. Before this incident, there have been no other sewer spills associated
with root intrusion in this area. Maintenance records show that sections of this collection system were
assessed as follows:
Flushing Activities
1/16/2010
9/20/2011
1/16/2010
9/21/2011
1/25/2010
3/20/2012
8/18/2011
9/4/2012
8/18/2011
10/16/2014
8/20/2011
8/27/2015
8/22/2011
12/18/2015
8/22/2011
12/18/2015
8/23/2011
12/26/2015
8/23/2011
12/27/2015
8/23/2011
12/27/2015
8/26/2011
10/18/2020
8/26/2011
10/12/2020
9/15/2011
10/29/2020
Repair
Inspection
CCTV Easement
Activities
Activities
Activities Activities
9/22/2011
9/22/2011
10/27/2010 2/14/2019
2/3/2012
1/16/2011
5/14/2014
9/22/2011
8/12/2013
6/19/2014
1/28/2010
5/1/2007
5/14/2014
8/12/2013
6/19/2014
The latest maintenance/inspection assessment for this site was conducted on 12/15/2020.
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. Further CCTV assessment for assets upstream and downstream of the
affected area is scheduled.
Containment and collection of this spill event consisted of placing a temporary containment
dam at approximately 1000 feet downstream of the affected sewer main (see picture 3). This
emplacement contained several hay bales to stop sewer debris from entering the stream and a pump to
remove and transfer sewer from the stream and reintroduce it into the collection system.
Picture 3
Restoration of this spill event consisted of washing approximately 1,080 ft of the surrounding
land utilizing approximately 440,520 gallons of potable water to flush the affected area from the spill
site to the containment site. The location of the sewer run-off was washed using ample water to remove
traces of sewer. Sewer debris and solids were collected and disposed of accordingly. 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 (see picture 4A-After the spill, and Picture 48-After Restoration).
Picture 4A • After the Splll
P�rtn 9 of o
Summary
The Sewer Maintenance Division of Raleigh Water strives to develop initiatives that improve
operational reliability to meet customer expectations and meet or exceed the requirements of the
Water Quality Collection System permit. Our operations are focused on continual improvement, the
prevention of pollution, and increased environmental performance efficiency. This endeavor is greatly
noted as the Division operates an ISO Certified Environmental Management System governed by the
14001-2015 Standards. As part of these initiatives, the Division operates a comprehensive reactive and
preventative maintenance program whose goal is to maintain over 2600 miles of sanitary sewer pipe
and minimize the accidental release of untreated wastewater.
Since July 1, 2020 (Fiscal Year 2021), the Utility has maintained approximately 186 11, miles of
gravity sewer mains by flushing with hydraulic jetting, conducting CCTV assessments, and performing
repair operations, easement maintenance, and inspections. The fiscal year to date cost of these
operations amounts to $1,666,978.20 [2[, approximately 12% of the Division's annual operating budget.
The 1,885 gallons of untreated wastewater spills identified in this letter cost the Utility $8,976 to
mitigate. 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 sewage volume created by these spills.
The City's cost of sewer treatment per gallon is $.0015 [3l. At this rate, it would have cost the City
$2.82 to treat the entire volume of sewer spilled. This fiscal comparison shows the City's commitment to
environmental protection, sparing no cost regardless of the spill event's severity and complexity. The
City continues to demonstrate due diligence in environmental performance by allocating the necessary
resources to a spill event irrespective of the associated cost. This effort is noted in the City's low SSO
performance rate of .63 total SSO ratej41 per 100 miles of pipe, compared to the Southeastern Region of
the US, of 7.0 spills per 100 miles of line.
[11 186 miles represents 8% of the sanitary sewer cotection system
[2[ Associated operat onal cast year to date for FY2021
OPERATION
LINEAR FEET
COST
CCTV
93,902.57
$ 193.909 01
FLUSHING
885,630.58
$ 282,18314
REPAIR
3,910
$ 1.190,886 05
[31 $.0015 Is based on the annual water treatment operating cost compounded by the total treated effluent.
[4[ .24% attr buted to dry weather SSOs
Additionally, the City of Raleigh Assistant Public Utility Directors and Collections System staff has
become involved in challenging the nonwoven fabrics industry standards to better inform consumers of
these products and their detrimental effects on the collections systems. PUD staff has personally met
with officers of INDA, the leading association of the nonwoven fabrics industry based in Cary, NC, to
communicate our concerns about these fabrics, the current industry standards, and better education for
the consumer. PUD has also joined forces with other utilities nationwide through the National
Association of Clean Waters Agencies (NACWA), the Water Environment Foundation (WEF), and the
American Public Works Association (APWA) to challenge INDA and current industry standards,
recognizing that they do not support compatibility in sanitary sewer collections systems nationally.
These agencies work collectively to challenge the testing protocols, assessment guidelines, and
consumer education and labeling of these non -dispersible.
13- T of O
Sincerely,
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. perezcamacho @raleiehnc.Gov
CC: Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance Division
CSC,..., U ..FO
�LPOL0TT
Roy COOPER
MAT~
MICHAEL S. REGAN
So,rwary
S. DANIEL SMITH
Dlrrrlar
NONt11 CAROLINA
Enrlranmrnlal Qualify
CERTIFIED MAIL # 7017 0190 0000 2569 8817
RETURN RECEIPT REQUESTED
November 16, 2020
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2020-DV-0504
Sanitary Sewer Overflows - October 2020
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
NOV 26 W(I
jr
DEC 16 2020
NC DEIVk Raleigh Ra
00al Office
44
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 incidents cited in the subject report include the following:
Incident Start Duration
Number Date (Mans) Location Cause
202002744 10/6/2020
131
1317 Wagram Court Pipe Failure (Break)
202002874 10/29/2020 170 7408 Boros Place Roots
Total Vol
Total
Surface
Vol
Water
(Gals)
(Gals)
11310
460
DWR Action
Notice of Violation
575 525 Notice of Violation
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