WQCS00002_NOV-2020-DV-0554 Response_20210204

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1 FEB , 202,
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0 / NIC DENR Raleigh Regional office
Raleigh Water
February 41h, 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-0554
Sanitary Sewer Overflows — November 2020
Permit No. WQCS00002
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-0554) received on January 215t, 2021. This document contains
narratives regarding pending violation actions of (9) Sanitary Sewer Overflows (550) events, which
occurred in month of November 2020 within the City of Raleigh Collections System Ill. 5 of these events
were the result of a severe weather event that produced a record rainfall for the month of November.
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-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-NOl
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 to the Division as stipulated in Conditiert IV92�. This Includes
SSOs that were caused by severe natural conditions or exceptional events unless the Permittee demonstrates through properly signed, epnlemp_rdneous operating
logs, or other relevant evidence that;
[a.j The SSO was caused by severe natural conditions; there were no feasible alternatives to the S50, 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 reasonable engineering judgment, the Permittee should have installed auxiliary or additional collections system components,
wastewater retention or treatment facilities, adequate 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;"
PaaP 1 of 17

Incident Number # 202002900—11/2/2020 — 6012 Viking Dr., Raleigh, NC
This spill was neither willful nor intentional; it was the result of a grease build-up, restricting the
sewer flow within a section of 12-inch ductile iron gravity sewer main. This build-up led to a sewer spill
of approximately 12,750 gallons of untreated wastewater reaching an unnamed tributary within the
Turkey Basin.
On 11/2/2020, at approximately 9:28 AM, Sewer Maintenance staff was notified of a sewer spill
emanating from a manhole located on an easement near 6012 Viking Dr., Raleigh. The responding staff
arrived at 10:15 AM and commenced taking all reasonable steps to stop and mitigate the discharge's
impact, gaining control of the spill event by 12:18 PM on the same day. Crews utilized hydraulic jetting
to remove the blockage source within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill
containment site at approximately 1600 ft downstream of the affected area. This approach was
intended to contain sewer flow and minimize the environmental impact on the surrounding land. At
approximately 1:16 PM, responding crews initiated collecting the untreated wastewater from the
containment site and re -introduced it to the collection system. 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 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 remove sewer traces 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 was conducted immediately following the spill event on 11/03/2020 to
identify the root cause of grease accumulation. The CCTV assessment determined that the line needed
additional hydra -jet cleaning to remove debris consistent with street paving. The source of this debris
cannot be determined.
The cost associated with the mitigation of this event amounted to $13,868.36. The approximate
cost to the Utility to have treated 12,750 gallons of wastewater would have been approximately $19.12.
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 South of Glenwood Avenue,
providing sewer collection services to several multi -dwelling properties. There has been no history of
sewer spills associated with this section of the sanitary sewer collection system.
A press release notification associated with this event was requested to be published in the
Raleigh News & Observer on November 2nd, 2020. Information literature was sent to residents within
the affected area. The outreach literature to be delivered explains the need for customers to properly
use the sanitary sewer collection system. 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.
Page 2 of 17

Prior to this event, maintenance records show that sections of this collection system were
assessed as follows:
Flushing
activities
Inspection activities
Easement
maintenance
4/10/11
12/11/2014
11/6/2018
4/26/2018
12/23/11
12/11/2014
01/10/2020
12/24/11
2/1/2015
04/20/2020
CCTV activities
10/6/2012
8/6/2015
06/11/2020
4/23/10
10/6/2012
8/6/2015
06/16/2020
8/12/2015
12/4/2014
8/6/2015
06/19/2020
12/4/2014
8/7/2015
06/29/2020
12/4/2014
8/7/2015
10/7/2020
12/4/2014
8/7/2015
12/4/2014
8/11/2015
12/4/2014
8/12/2015
3/12/2019
There have been no additional issues associated with this section of the collection system since
the last sewer event. This site remains an active maintenance spot until all street paving debris has been
reduced or eliminated.
PaPP i of 17

Incident Number # 202003121 — 11/12/2020 — 4790 Wendell Blvd., Wendell, NC
This sewer spill event resulted from severe natural conditions and a heavy flooding weather
event that resulted in an unexpected sanitary sewage spill of approximately 57,230 gallons of untreated
sewer from an 8-inch gravity sewer main. This spill took place within the Little S. Basin. The weather
event produced a record rainfall of 2.94 inches for November 12th, 2020 (NOOA, Monthly Climatological
Report for Raleigh NC, see attachment # 1). This weather event was responsible for other sewer spill
events within the Raleigh service area.
Sewer Maintenance staff knew of the overflow on 11/12/20 at approximately 8:53 AM. The
responding staff took all reasonable steps to monitor the discharge's impact as soon as they arrived until
the weather event ceased the spill event at approximately 6:43 PM. Mitigation of this event was limited
since the rain event was actively ongoing. The rain assisted in defusing the sewage downstream. There
was no indication of solids or debris in the surrounding area. Crews conducted an area assessment
downstream of the event to ensure no traces of sewage and debris associated with the spill. Crews did
not find any indication of sewage nor indications of observed fish kill related to this SSO. The total cost
of the City's response and remediation effort for this spill event was $331.17.
A press release was issued for this spill event, including other simultaneous spills resulting from
this rain event.
There have been no previous recorded spills for this section of the sewer system. Prior to the
weather event, the most recent record of routine maintenance in this area was conducted on
12/14/2016.
Pursuant 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 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,
Page 4 of 17

Incident Number # 202003123—11/12/2020 — 3316 Allegheny Dr., Raleigh, NC
This sewer spill event resulted from severe natural conditions and heavy flooding weather event
that resulted in an unexpected sanitary sewage spill of approximately 77,200 gallons of untreated sewer
from a 36-inch gravity sewer main. This spill reached the surface waters of Crabtree Creek within the
Crabtree Basin. The weather event produced a record rainfall of 2.94 inches for November 12th, 2020
(NOOA, Monthly Climatological Report for Raleigh NC, see attachment # 1). This weather event was
responsible for other sewer spill events within the Raleigh service area.
Sewer Maintenance staff had knowledge of the overflow on 11/12/20 at approximately 11:04
AM. The responding staff took all reasonable steps to monitor the discharge's impact as soon as they
arrived until the weather event ceased the spill event at approximately 5:30 PM. Mitigation of this event
was limited since the rain event was actively ongoing. The rain assisted in defusing the sewage
downstream. There was no indication of solids or debris in the surrounding area. Crews conducted an
area assessment downstream of the event to ensure no traces of sewage and debris associated with the
spill. Crews did not find any indication of sewage nor indications of observed fish kill associated with this
550. The total cost of the City's response and remediation effort for this spill event was $161.91.
A press release was issued for this spill event, including other simultaneous spills resulting from
this rain event.
There have been no previous recorded spills for this section of the sewer system. Prior to the
weather event, the most recent record of routine maintenance in this area was conducted on 8/6/2010.
Pursuant 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 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.
Papa5nf17

Incident Number # 202003125—11/12/2020 — 3900 Quail Hallow Dr., Raleigh, NC
This sewer spill event resulted from severe natural conditions and a heavy flooding weather
event that resulted in an unexpected sanitary sewage spill of approximately 87,780 gallons of untreated
sewer from an 8-inch gravity sewer main. This spill reached the surface waters of Big Branch Basin. The
weather event produced a record rainfall of 2.94 inches for November 12th, 2020 (NOOA, Monthly
Climatological Report for Raleigh NC, see attachment # 1). This weather event was responsible for other
sewer spill events within the Raleigh service area.
Sewer Maintenance staff had knowledge of the overflow on 11/12/2020 at approximately
12:52:00 PM. The responding staff took all reasonable steps to monitor the discharge's impact as soon
as they arrived until the weather event ceased the spill event at approximately 6:00 PM. Mitigation of
this event was limited since the rain event was actively ongoing. The rain assisted in defusing the
sewage downstream. There was no indication of solids or debris in the surrounding area. Crews
conducted an area assessment downstream of the event to ensure no traces of sewage and debris
associated with the spill. Crews did not find any indication of sewage nor indications of observed fish kill
associated with this SSO. The total cost of the City's response and remedlation effort for this spill event
was $172.83.
A press release was issued for this spill event, which also included other simultaneous spills
resulting from this rain event.
Maintenance records show that the last spill event in this section of the sewer system was
recorded on 11/30/2018. The most recent record of routine maintenance in this area was conducted on
11/12/2020.
Pursuant 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 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.
Page 6 of 17

Incident Number # 202003126—11/12/2020 —1500 Banbury Rd., Raleigh, NC
This sewer spill event resulted from severe natural conditions and a heavy flooding weather
event that resulted in an unexpected sanitary sewage spill of approximately 22,448 gallons of untreated
sewer from an 8-inch gravity sewer main. This spill reached the surface waters of Southwest Prong
Beaverdam Creek within the Beaver SW Basin. The weather event produced a record rainfall of 2.94
inches for November 12th, 2020 (NOOA, Monthly Climatological Report for Raleigh NC, see attachment
# 1). This weather event was responsible for other sewer spill events within the Raleigh service area.
Sewer Maintenance staff had knowledge of the overflow on 11/12/2020 at approximately 4:00
PM. The responding staff took all reasonable steps to monitor the impact of the discharge as soon as
they arrived until the weather event ceased the spill event at approximately 8:15 PM. Mitigation of this
event was limited since the rain event was actively ongoing. The rain assisted in defusing the sewage
downstream. There was no indication of solids or debris in the surrounding area. Crews conducted an
area assessment downstream of the event to ensure no traces of sewage and debris associated with the
spill. Crews did not find any indication of sewage nor indications of observed fish kill associated with this
SSO. The total cost of the City's response and remediation effort for this spill event was $143.18.
A press release was issued for this spill event, which also included other simultaneous spills
resulting from this rain event.
There have been no previous recorded spills for this section of the sewer system. The most
recent record of routine maintenance in this area was conducted on 09/15/2020.
Pursuant 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 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.
Page 7 of 17

Incident Number # 202003127—11/12/2020 —1212 Riverview Dr., Raleigh, NC
This sewer spill event resulted from severe natural conditions and a heavy flooding weather
event that resulted in an unexpected sanitary sewage spill of approximately 56,000 gallons of untreated
sewer from a 66-inch gravity sewer main. This spill reached the surface waters of the Neuse River Basin.
The weather event produced a record rainfall of 2.94 inches for November 12th, 2020 (NOOA, Monthly
Climatological Report for Raleigh NC, see attachment # 1). This weather event was responsible for other
sewer spill events within the Raleigh service area.
Sewer Maintenance staff had knowledge of the overflow on 11/12/2020 at approximately 4:00
PM. The responding staff took all reasonable steps to monitor the impact of the discharge as soon as
they arrived until the weather event ceased the spill event at approximately 8:15 PM. Mitigation of this
event was limited since the rain event was actively ongoing. The rain assisted in defusing the sewage
downstream. There was no indication of solids or debris in the surrounding area. Crews conducted an
area assessment downstream of the event to ensure no traces of sewage and debris associated with the
spill. Crews did not find any indication of sewage nor indications of observed fish kill associated with this
SSO. The total cost of the City's response and remediation effort for this spill event was $157.33.
A press release was issued for this spill event, which also included other simultaneous spills
resulting from this rain event.
There have been no previous recorded spills for this section of the sewer system. The most recent
record of routine maintenance in this area was conducted on 11/12/2020.
Pursuant 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 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.
Page 8 of 17

Incident Number # 202003184—11/13/2020 — 5839 Capital Blvd., Raleigh, NC
This spill was neither willful nor intentional. It was the result of a grease build-up, restricting the
sewer flow within a section of 12-inch ductile iron gravity sewer main. This build-up led to a sewer spill
of approximately 900 gallons of untreated wastewater in which approximately 100 gallons reached an
unnamed tributary within the Perry Basin.
On 11/13/2020, at approximately 12:31 PM, Sewer Maintenance staff was notified of a sewer
spill emanating from a manhole located near 5839 capital Blvd., Raleigh. The responding staff arrived at
1:00 PM and commenced taking all reasonable steps to stop and mitigate the impact of the discharge,
gaining control of the spill event by 1:34 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 and collection of this spill event consisted of employing a temporary spill
containment downstream of the affected area. This approach was intended to contain sewer flow and
minimize the environmental impact on the surrounding land. At approximately 2:30 PM, responding
crews initiated collecting the untreated wastewater from the containment site and re -introduced it to
the collection system. 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 remove sewer traces 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 was conducted immediately following the spill event on 11/23/2020 to
identify the root cause of grease accumulation. The CCTV assessment determined that the root cause of
this overflow was determined to be a main break in SGMN118016 located 332.1' downstream from
SMH122011. While this defect is not severe, it is suspected that the break disrupted the flow and
allowed the collection of solids and debris over an extended period, thus producing a blockage. An
additional break found in SGMN118010, located 134.5' upstream from SMH122011, may have also
contributed to the blockage by presenting another collection point for solids and grease. Work orders
for both defects have been submitted to Sewer Maintenance Repair for correction.
Paee 9 of 17

The cost associated with the mitigation of this event amounted to $1,023.17. 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 section of the collection system is in a commercial zone along the Capitol Blvd corridor. This
sewer main provides sewer collection services to several vehicle service stations. There has been no
history of sewer spills associated with this section of the sanitary sewer collection system.
A press release notification associated with this event was not required since the event was
below the 1000 gallons threshold. Information literature was sent to residents within the immediate
affected area. The outreach literature to be delivered explains the need for customers to properly use
the sanitary sewer collection system. 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
Repair Activities Inspection activities CCTV activities
11/3/2011
11/3/11 01/05/2010 Smoke Test 3/6/2013
11/7/2011
5/2/10
11/9/2011
1/4/2012
11/21/2011
11/21/2011
2/2/2015
10/29/2015
There have been no additional issues associated with this section of the collection system since
the last sewer event. This site continues to remain an active maintenance spot pending repair work.
Page 10 of 17

Incident Number # 202003270—11/15/2020 — 975 Buffalo Rd., Garner, NC
This spill was neither willful nor intentional; it resulted from a sewer force main failure,
disrupting the flow of gravity sewer main. This asset failure led to a sewer spill of approximately 242,000
gallons of untreated wastewater reaching surface waters of Buck Branch and Swift Creek within the
Benson Basin.
On Sunday, November 15th, 2020, at approximately 12:03 PM, Sewer Maintenance staff was
notified of a sewer spill emanating from a manhole located on an easement near 975 Buffalo Rd.,
Garner, NC. Upon arrival, the responding staff commenced taking all reasonable steps to stop and
mitigate the discharge's impact.
Upon arrival, Raleigh Water Sewer Maintenance Division identified that the spill's source was a
failed sewer force main. Responding Crews immediately contacted Raleigh Water engineers and on -call
contractors to develop an immediate corrective action. The immediate corrective action involved a
temporary bypass to route the sewer away from the affected force main. Additional coordination was
made to control the sewer flow from two pump stations upstream of the spill event, PS 90-Greenspring
Valley and PS 97-Vandora Pines. Once sewer flow control was established, crews were able to excavate
a sump to contain the wastewater and expose the affected sewer force main. Crews took control of the
situation completing the repair and stopping the overflow at approximately 8:19 AM on Monday,
November 16th,2020.
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 no fish kill
or unnecessary vegetative damage occurred. The sewer run-off site was treated accordingly with an
application of lime and restored with grass seed and straw.
The cost associated with the mitigation of this event amounted to $74,662.86. The approximate
cost to the Utility to have treated 242,000 gallons of wastewater would have been approximately
$363.00. 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 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. There has been no history of spills in this part of
the sewer system.
A press release notification related to this event was requested to be published in the Raleigh
News & Observer on Monday, November 16th, 2020. There have been no other sewer events associated
with this location.
Pauw 11 of 17

Incident Number # 202003373—11/28/2020 —1117 Beacon lake Dr., Raleigh, NC
This spill was neither willful nor intentional. It was the result of a grease build-up, restricting
the sewer flow within a section of an 8-inch polyvinyl chloride (PVC) gravity sewer main. This build-up
led to a sewer spill of approximately 4,450 gallons of untreated wastewater reaching an unnamed
tributary within the Crabtree Basin.
On 11/28/2020, at approximately 8:41 AM, Sewer Maintenance staff was notified of a sewer spill
emanating from a manhole located near 1117 Beacon lake Dr., Raleigh, NC. The responding staff arrived
at 9:07 AM and commenced taking all reasonable steps to stop and mitigate the impact of the discharge,
gaining control of the spill event by 10:10 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 and collection of this spill event consisted of employing a temporary spill
containment site at approximately 1,150 ft downstream of the affected area. This approach was
intended to contain sewer flow and minimize the environmental impact on the surrounding land. At
approximately 10:45 AM, responding crews initiated collecting the untreated wastewater from the
containment site and re -introduced it to the collection system. 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 remove sewer traces 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 was conducted immediately following the spill event on 11/03/2020 to
identify the root cause of grease accumulation. The CCTV assessment determined that the line needed
additional hydro -jet cleaning to remove debris consistent with street paving. The source of this debris
cannot be determined.
The cost associated with the mitigation of this event amounted to $2,813.51. The approximate
cost to the Utility to have treated 4,450 gallons of wastewater would have been approximately $6.67.
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 and commercial area South of new Bern
Avenue and provides sewer collection services to several properties and commercial establishments.
There has been no history of sewer spills associated with this section of the sanitary sewer collection
system.
A press release notification associated with this event was requested to be published in the
Raleigh News & Observer on November 28th, 2020. Information literature was sent to residents within
the immediate affected area. The outreach literature to be delivered explains the need for customers to
properly use the sanitary sewer collection system. 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.
Page 12 of 17

Raleigh Water Responds to Sanitary Sewer Spills
On Saturday, November 281h 2020. at approx matey 09 07 AM. Raleigh Water - Sevier
Maintenance Envision staff responded to a sanitary sewer overflow located at 1117
Beacon Lake Of Raleigh NC The cause of the overflow was related to grease
accumulation blocking the flow of an 8-Inch PVC sewer gravity main The responding
staff took all reasonable steps to stop and mitigate the overflow's impact as soon as
they arrived The North Carolina Department of Environmental Quality Division of
Water Resources was notified of the overflow
Raleigh Water - Sewer Maintenance Division staff. stopped the overflow at
approximately 1010AhI on the same day It Is estimated that the overflow discharged a
volume of approximately 4 450 gallons of untreated wastewater into an unnamed
tributary of Crabtree Creek Restoration associated with this sewer event trill be
completed by this evening There was no observed fish killed or vegetative damage
associated ►nth this event
• Raleigh Water has an aggressive education and enforcement program to prevent
the discharge of grease debris wipes rags. diapers and other improper materials
In the sewer system and to take enforcement action where appropriate If these
items make ft into the sewer system they may cause a spill which can have an
adverse impact on veater quality and endanger those who come into contact with
the affected areas
• Water human waste. and toilet tissue are the only items permitted to be
discharged Into the sever system. Ad other items will cause damage to the se►vef
system and are not permitted
■ If you experience excessive sewer smells or see sewer spilling from manholes or
pipes, please call 919.99&3245 to report immediately
• For more information about how you can help prevent sanitary sewer spills
please visit- www ralelghnc goviwaler
This news telease is requked by NCGS Ardde 21 Chapter 143 2151 C
Papp 11 of 17

Prior to this event, maintenance records show that sections of this collection system were
assessed as follows:
Flushing activities
2/24/2012
12/2/2012
7/2/2015
8/31/2012
2/6/2013
7/16/2015
9/6/2012
2/14/2013
8/10/2015
9/12/2012
2/25/2013
8/25/2015
9/19/2012
3/4/2013
11/13/2015
10/17/2012
2/24/2014
12/15/2015
10/19/2012
7/18/2014
12/18/2015
10/19/2012
5/9/2015
11/5/2012
Repair activities
Easement
maintenance
12/19/2015
11/1/11
06/5/2019
05/24/19
07/23/2019
06/05/19
05/24/2019
07/23/19
03/23/20
06/23/20
Inspection
CCTV activities
06/24/20
activities
3/1/11
83 inspection from
7/20/11
03/9/2018-
01/13/2021
This section of the sewer system experienced a spill on 07/20/2005, in which 4,500 gallons of
untreated wastewater was released as a result of a contractor activity in the area. There have been no
additional issues associated with this section of the collection system since the last sewer event. This
site continues to remain an active maintenance spot.
Page 14 of 17

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 Water Quality Collection
System permit requirements. 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 258111 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 $2,360,241.57 121, approximately 13% of the Division's annual operating budget.
The 560,758 gallons of untreated wastewater spills identified in this letter cost the Utility $93,334.32 to
mitigate. The City's cost of sewer treatment per gallon is $.0015 131. At this rate, it would have cost the
City $841.14 to treat the entire volume of sewer spilled. The City saved no money from these spills. The
costs of mitigation well 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. 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 1.14
total SSO rate [4[ per 100 miles of pipe, compared to the Southeastern Region of the US, of 7.0 spills per
100 miles of line.
[1] 186 miles represents 8%of the sanitary sewer collection system
121 Associated operational cost year to date for FY2021
OPERATION LINEAR FEET COST
CCTV 220,357.31 $ 249.703.36
Flushing 1,134,893.96 $ 384,789.17
Repair 4,810 $1,451,831.56
Total-1,360,062.27 Ft Total cost of
258 MILES Business to Date
$2,086,324.09
1315.0015 Is based on the annual water treatment operating cost compounded by the total treated effluent.
[4[ .24%attributed 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.
Paap 15 of 17

Raleigh Water has an aggressive educational outreach initiative to address illicit discharges such
as wipes, fats, oil, and grease to commercial and residential users. Raleigh Water has developed a
complimentary property managers resource kit that provides best practice resources for establishing a
property -specific awareness program. Each kit contains brochures and complimentary gadgets to help
residents manage grease and fat collection and disposal. The resource kit also features a multimedia
flash drive with videos and reproducible educational material that property managers can use to
educate tenants to reduce the risk of sewer backups caused by the introduction of solids through their
residential piping. Each kit costs Raleigh water approximately $85.00 to produce and is provided free of
charge to the property management. Raleigh Water is continuously developing initiatives to increase
residential and commercial customer partnerships to address grease accumulation and prevent illicit
discharges. The educational material and videos can be accessed through social media and the Raleigh
Water website httPs:Hraleighnc.gov/sewer-maintenance
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. 1 hese 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 hoping that citizens and customers would become more
aware of the signs of an emerging system problem causing the 550 occurrence and become proactive in
helping the City 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 the discharge of grease into the sewer system and the effects of such
deposits. Whenever possible, and upon investigating 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-2020 NOI-0054 issued for the
month of December 2020 be fairly reviewed, considering 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 Raleigh Water Director, at [phone].
e�
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.peremamachoCuraleiehnc.Gov
CC. Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance Division
Page 16 of 17

These data are preliminary and have not undergone final quality control by the National
Climatic Data Center (NCDC). Therefore, these data are subject to revision. Final and
certified climate data can be accessed at the NCDC - httR:Hwww.ncdc.noaa.gov.
Climatological Report (Daily)
000
CDUS42 KRAH 130643
CLIRDU
CLIMATE REPORT
NATIONAL WEATHER SERVICE RALEIGH NC
143 AM EST FRI NOV 13 2020
...THE RALEIGH-DURHAM INTL AIRPORT NC CLIMATE SUMMARY FOR NOVEMBER 12 2020...
CLIMATE NORMAL PERIOD 1981 TO 2010
CLIMATE RECORD PERIOD 1887 TO 2020
WEATHER ITEM OBSERVED TIME RECORD YEAR NORMAL DEPARTURE LAST
VALUE (LST) VALUE VALUE FROM YEAR
NORMAL
.......................................................
TEMPERATURE`
YESTERDAY
MAXIMUM 71 723 AM 80 2003 65 6 56
MINIMUM 59 1159 PM 22 1957 42 17 29
AVERAGE 65 53 12 43
PRECIPITATION (IN)
YESTERDAY
2.94
3.17 2018 0.10
2.84
0.94
MONTH TO DATE
3.55
1.26
2.29
1.12
SINCE SEP 1
11.30
8.87
2.43
5.59
SINCE ]AN 1
47.83
38.41
9.42
37.56
SNOWFALL (IN)
YESTERDAY
0.0
1.2 1968 0.0
0.0
T
MONTH TO DATE
0.0
0.0
0.0
T
SINCE SEP 1
T
0.0
0.0
T
SNOW DEPTH
0
DEGREE DAYS
HEATING
YESTERDAY
0
12
-12
22
MONTH TO DATE
65
126
-61
181
SINCE SEP 1
169
314
-145
254
SINCE JUL 1
169
315
-146
254
COOLING
YESTERDAY
0
0
0
0
MONTH TO DATE
12
1
11
0
SINCE SEP 1
277
280
-3
467
SINCE ]AN 1
...................................................................
1845
1721
124
2087
WIND (MPH)
HIGHEST WIND SPEED 22 HIGHEST WIND DIRECTION SE (120)

HIGHEST GUST SPEED 30 HIGHEST GUST DIRECTION SE (120)
AVERAGE WIND SPEED 6.0
SKY COVER
POSSIBLE SUNSHINE MM
AVERAGE SKY COVER 1.0
WEATHER CONDITIONS
THE FOLLOWING WEATHER WAS RECORDED YESTERDAY.
HEAVY RAIN
RAIN
LIGHT RAIN
FOG
RELATIVE HUMIDITY (PERCENT)
HIGHEST 100 400 AM
LOWEST 93 100 PM
AVERAGE 97
THE RALEIGH-DURHAM INTL AIRPORT NC CLIMATE NORMALS FOR TODAY
NORMAL RECORD YEAR
MAXIMUM TEMPERATURE (F) 65 Be 1931
1945
1955
MINIMUM TEMPERATURE (F) 42 23 1976
1977
SUNRISE AND SUNSET
NOVEMBER 13 2020...... SUNRISE 650 AM EST SUNSET 509 PM EST
NOVEMBER 14 2020...... SUNRISE 651 AM EST SUNSET 508 PM EST
- INDICATES NEGATIVE NUMBERS.
R INDICATES RECORD WAS SET OR TIED.
MM INDICATES DATA IS MISSING.
T INDICATES TRACE AMOUNT.
CLIMATE REPORT
NWS FORECAST OFFICE
NCSU CENTENNIAL CAMPUS
RALEIGH, NC
' flyo Q11YaI9L 42_1i011;
MINIMUM TEMPERATURE... 58
PRECIPITATION... 3.42
The U.S. Naval Observatory (USNO) data is currently unavailable. The links provided are from
other US Government sources. When USNO data is returned to service, the links will be updated.

ROY COOPER
MICHAE; S. REGAN
S"R'I:„y
S. DANIE1 SMITH
Dfrmtor
CERTIFIED MAIL:7017 2680 0000.2219 6289
RETURN RECEIPT _REQUESTED
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
FqN y1 r
NOR fII CAHQI INA
EnrfronrienfulQuality
December 15, 2020
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2020-DV-0554
Sanitary Sewer Overflows - November 2020
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
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 violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Minn) location Cause (Gals) (Gals) DWR Action
202002900 11/2/2020 170 6012 Viking Dr.
202003121 11/12/2020 590 4790 Wendell Blvd
Grease 12,750 12,000 Notice of Violation --
Notice of intent
Severe Natural 57,230 57,230 Notice of Violation
Condition
202003123 11/12/2020 386 33316 Allegheny Dr. Severe Natural 77,200 336 Notice of Violation
Condition
.�V h]4^Q-) �L GtpS M1R+rt :4$n'r rmt=LL 4L 4r' i G5'L :r :L 1: LL47F.7;�rpLL
~' RLej,FL;:reCiftLIiE:7ELi+tt::,;IKi3gcf{ciL•:Ls,fa: E6'

Total Vol
Total
Surface
Incident
start
Duration
Vol
Water
Number
Date
(Mins)
Location
Cause
(Gals)
(Gals)
DWR Action
202003125
11/12/2020
308
3900 Quail Hollow Dr
Severe Natural
87,780
87,780
Notice of Violation
Condition
202003126
11/12/2020
255
1500 Banbury Rd
Severe Natural
22,44E
22,448
Notice of Violation
Condition
202003127
11/12/2020
280
1212 Riverview Dr.
Severe Natural
56,000
56,000
Notice of Violation
Condition
202003184
11/13/2020
63
5839 Capital Blvd
Grease
900
100
Notice of Violation
202003270
11/15/2020
1,216
975 Buffalo !toad,
Other, Pipe Failure
242,000
242,000
Notice of Violation -
Garner, NC
(Break)
Notice of Intent
202003373
11/28/2020
89
1117 Beacon Lake Drive Grease
4,45D
4,450
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 hlayeswith the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Sincerely,
A"4--u- �2A4.t_
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
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