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HomeMy WebLinkAboutWQCS00002_NOV-2020-DV-0504 Response_2020121600 F'F 0 �, 00 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 Rvthrir.+�+F+rtrr+rt:f'crrr_rm+ait•¢ltvIDV1vt:f%"&11rAis::r:1i �r/'b A1'a t, 6tY or.+ Oft:aJ -M E+rnnD).tt I No t {•,H.rt•.:or: r+ 27i-.