WQCS00002_NOV-2021-DV-0177 Response_20210420

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APR 7 t; 2021 F
0 NC DENR Raleigh Regional Othoe
Raleigh Water
April 201h, 2021
Mr. Scott Vinson
Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources NCDE:Q
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Response to NOV 2021-DV-0177
Sanitary Sewer Overflows — February 2021
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-2021-DV-0177) received on April 6th, 2021. This document contains the
narrative regarding a pending violation action of (1) Sanitary Sewer Overflow (550) event, which
occurred during the month of February 2021 within the City of Raleigh Collections System [1). The
noticed event 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-N01) 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 reintroduce it to the collection system; and finally, restoring the possible environmental
impacts brought by the release of the SSO event, listed with the intended NOV-N01 action. Please find
below, the additional information requested for the single SSO event.
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 exceptional events unless the Permittee demonstrates through properly signed, contemporaneous operating
logs, or other relevant evidence that:
[a.) The S50 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 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 collectlons 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 SSO 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;"
PAPP 1 of fi

Incident Number # 202100388 — 02/02/2021— 600 Rawls Dr., Raleigh, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the
sewer flow within a section of 8-inch ductile iron pipe gravity sewer main. This build-up led to a sewer
spill of approximately 3,380 gallons of untreated wastewater reaching an unnamed tributary within the
Crabtree Basin. (See exhibit 1—SSO Area of Operation, pg. 4)
On 02/02/2021, at approximately 11:28 AM, Sewer Maintenance staff was notified of a sewer
spill emanating from a manhole located near 600 Rawls Dr., Raleigh. The responding staff arrived at
approximately 11:41 AM and commenced taking all reasonable steps to stop and mitigate the impact of
the discharge, gaining control of the spill event by 5:10 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 two temporary spill
containment sites downstream of the affected area. This approach was intended to contain wastewater
flow and minimize the environmental impact on the surrounding land. Responding crews employed
pumps at the temporary containment sites to recover flushed wastewater and any evidence of sewer
completing the operation by re -introducing the wastewater to the collection system. This spill was
contained without a significant environmental impact on 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
conveyance. 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 on 01/05/2021 to identify the root cause of grease
accumulation. The CCTV assessment did not find any infrastructure issues that may have led to the
grease accumulation.
The cost associated with the mitigation of this event amounted to $8,296.38. The approximate
cost to the Utility to have treated 3,380 gallons of wastewater would have been approximately $5.70.
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 located in a residential area. It provides sewer collection
services to several properties upstream of the spill event. The last recorded sewer spill in this area was
recorded on February 21, 2000.
A press release notification associated with this event was requested on 2/3/2021(see exhibit 2,
p.4). Outreach information literature was also requested to be sent to the immediate -affected area. The
requested outreach literature would explain 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.
Page 2 of 6

Before this event, maintenance records show that sections within the zone of influence M of this
collection system were assessed as follows:
Flushing activities
1. 1/2/2013 - 608 Donald Ross Dr
2. 12/14/2009 - 503 Donald Ross Dr,
3. 7/26/2012 - 504 Donald Ross Dr
4. 1/2/2013 608 Donald Ross Dr
5. 10/1/10 619 - Donald Ross Dr
6. 3/18/2013 - 619 Donald Ross Dr
7. 12/7/2015 - 3205 Harmony Ct
8. 9/11/11- 3027 Haven Rd
9. 5/21/11- 3000 Poole Rd
10. 4/3/10. 600 Rawls Dr.
11, 10/21/2009 - 604 RAWLS DR
12. 5/18/11- 708 Rawls Dr
13. 10/21/2008 3100 Woodpecker Ct
14. 5/5/11 •3117 and 3118 Woodpecker Ct
CCTV activities Inspection
1. 7/25/2012 - 504 Donald Ross Dr 1. 9/3/10 - 2911 Haven Rd (Smok• test)
2. 10/5/2012 .3029 Poole Rd 2. 8/7/2014. 712 Rawls Dr
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 completion of
further sewer main cleaning and CCTV assessment.
2. Zone of Influence— residential or commercial area upstream of the affected asset that may have Influenced the sewer event. This area is selected based on
continuous sanitary sewer collection connect'on towards the affecting asset. Selection of this area Is cr.ticai for sewer events Involving grease accumulation
that may result In a subsequent enforcement action.
paRP 3 of 6

Exhibit 2 - Press Release
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep Fats, Oils, and Grease Out of the Drain
on Tuesday Fatma" x 7071 at 1111 AN, PAkbh Water
Sewer Matdenan'a DarNon atM tasperad a a nrraily Ferrer epe lotalad al
600 PAWp Drha, RWGWk NC. TM Cauem of pm SPB Wa# mtatad o Craw
SCUM SAW WL an W*W Wool maw The maptll . 0 staff tool am mAwabla mope
to smp and mega# tw Wood of"%A as sorer of My wNed. %a None Camhta
Depaamnl d EavhmmmaW Duaay. Dhneon of Want RAawcp was mdbad Of tla
We.
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apprmdnaoy S-10 Pea on Um tam day R It as - m W mat me "N dild argod
appmrinaoy 3,]ao Canna d ur&aaod wea mwater. maddfp armrace wabn of
Crew" BAWL Reelnaawrnaoetaod wth ark sewn eyed h aydYq. T1rew hA
not been arp 001elYod bh mad 0 YagMENVO damage amOCU"d Wet itch awmf.
Raleigh Wan has a sggmaeom mdmwtldn ad mdorcamred progrmn to
pored am dlmeh" of Wean, darts. wlpoe, rage, dtapom and Dear
MWgper maMdYa In the town system and to Lke edorcomed median
VA om appmpMeta. a trap Mms make R into the sawst eystw4 May may
coup a opal Which can have an advano hnpeet and daor auaW art
andonger ttmmm who came Wo eantsd wah the elleclad area.
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Page 4 of 6

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 350.44 (1[ 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 $2,733,105.51121, approximately 13% of the Division's annual operating budget.
The 3,380 gallons of untreated wastewater spill identified in this letter cost the Utility approximately
$8,534.88 to mitigate. The City's cost of sewer treatment per gallon is $.0015 [31. At this rate, it would
have cost the City $5.07 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 1.39
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.
[11 350 miles represents 13% of the sanitary sewer collection system
(2[ Associated operational cost year to date for FY2021
OPERATION LINEAR FEET Linear Miles COST
CCTV 300,937.72 57.00 S 301.50124
Flushing 1,544,267.87 29247 $ 518,170.38
Repair 5,144.00 0.97 S 1,913,433 89
Total-1,850,349.59 Ft Total cost at Buslnrss to Date
350.44 MILES $ 2,733,105.51
(3( $.0015 Is based an the annual water treatment operating cost compounded by the total treatrd effluent
(41.24%attributed to dry weather 550s
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.
Pai:p 5 n f 6

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://raleighnc.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. 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 hoping 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 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-2021 NOI-0177 issued for the
month of February 2021, 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-
12 or T.J. Lyn , Assistant Raleigh Water Director, at [phone].
cerely,
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. erezcamacho ralei hnc.Gov
cc: Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance Division
Page 6 of 6