WQCS00002_NOV-2021-DV-0264 Response_20210701

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Raleigh Water 'Weigh Regi0°al OflTce
July 15t, 2021
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-2021-DV-0264
Sanitary Sewer Overflows — April 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-0264) received on June 17th, 2021. This document contains the narratives regarding a
pending violation actions of (3) Sanitary Sewer Overflow (550) events, which occurred during the month of April
2021 within the City of Raleigh Collections System 111. This document also provides exhibits as proof of our
efforts to mitigate the sewer event. 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 spills; 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 events, listed with the intended NOV-NOI action.
Please find below, the additional information requested for the three SSO events.
1. 'The Director may take enforcement action against the Permittee for SSOs that must be reported to the Division as st pulated in Condition IV92). This includes SSOs that were
caused by severe natural conditions or exceptional events unless the Permittee demonstrates through properly signed, ccntempr,raneous operating logs, or other relevant
evidence that:
[a.I 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 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 SSO could not have been prevented by
the exercise of reasonable control, such as proper management, operation, and maimenance; 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
'rstallation of adequate back-up equipment,"

Incident Number f# 202101179 -- 04/13/2021— 400 Woods of North Bend, Raleigh, NC
This spill was neither willful nor intentional; it resulted from debris partially blocking a portion of an 8-
inch vitrified clay sewer main. The blockage led to a sewer spill of approximately 830 gallons of untreated
wastewater in which 415 gallons reached surface waters in Big Branch Basin.
On 4/13/21, at approximately 4:42 PM, Raleigh Water staff were notified of a sewer overflow located on
the right of way at 400 Woods of North Bend Dr., Raleigh, NC. Utility Responders were immediately summoned
to the spill site. They took reasonable steps to stop and mitigate the impact of the discharge, gaining control of
the spill event by 6:05 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 site
downstream of the affected area. This approach is intended to contain sewer flow and minimize the
environmental impact on the surrounding land. Responding crews initiated the collection of untreated
wastewater from both containment sites to re -introduced it to the collection system downstream. 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 remove any sewer
evidence downstream of 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.
The cost associated with the mitigation of this event amounted to $ 3,565.85. The approximate cost to
the Utility to have treated 830 gallons of wastewater would have been approximately $1.24. The City saved no
money from this spill. The 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.
A follow-up CCT assessment confirmed that the incident was isolated to only debris accumulation. CCTV
did not find any infrastructure deficiencies within the sewer main. This section of the collection system serves a
residential area north of Spring Forest Rd. It provides sewer collection services to several multi -dwelling
properties. Outreach material was requested to be delivered to the immediate affected area. There have been
no other recorded sewer spills associated with this sewer collection asset. The last maintenance was conducted
in 04/15/2021.

Incident Number # 202101209 — 04/20/2021— 7100 Great Laurel Dr., Raleigh, NC (Brighton Pump Station 40)
This spill was neither willfui nor intentional; it resulted from a sewer force main failure at Brighton Pump
Station ##40. The dresser coupling and associated bracing in the wet well that connects the suction piping to the
pump had deteriorated to the point that it was unable to hold the force of the head conditions that flowed back
toward the station after the pumping cycle had completed. The failure affected wastewater flow from an 8-inch
Polyvinylchloride (PVC) gravity sewer main. This event resulted in approximately 20,000 gallons of untreated
wastewater spilling into an unnamed tributary of the Neuse River Basin.
On 4/20/2021, at approximately 10:30 pm, Raleigh Water staff were alerted via SCADA alarm
notification that Brighton Pump Station was in a high wet well. Upon arrival, it was noticed that the pumps were
unable to keep up with the flow as most of the wastewater was draining back into the wet well after each pump
run cycle.
Containment and collection of this spill event consisted of placing a temporary containment dam
downstream of the station (see Exhibit-1). This emplacement contained filtering media to stop wastewater
debris from flowing downstream. A water pump was placed in the containment dam to collect and transfer the
wastewater from the stream and reintroduce it into the collection system. Vacuum trucks were used to
removed wastewater from the pump station returning the wastewater elsewhere into the collection system.
Fxhi:ri I —Downstream Containment Site
Restoration of this spill event consisted of washing the land
surrounding the station. Crews utilized ample potable water to flush the
affected area. Sewer debris and solids were collected and disposed of
accordingly. 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.
A subsequent investigation revealed that the pump began to
unseat from the flange at the end of the force main at the dresser
coupling, and each pump run cycle was spraying wastewater out of the
wet well. A portable bypass pump brought on site and plumbed prior to
this event was then activated to keep up with the flow of wastewater and
allow personnel to disable the station pumps and cease the flow of
wastewater out of the wet well onto the ground. A utility contractor had
been previously summoned, but they were awaiting parts and finalizing an
engineered solution to correct the issue of surging wastewater flowing back to the station after each pump run
cycle.
The cost associated with the mitigation of this event has amounted to over $1,570,85. The approximate
cost to the Utility to have treated 20,000 gallons of wastewater would have been approximately $30.81. 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 pump station services a vast residential area north and south of Louisburg Rd., providing sewer
services to approximately 580 properties. There has been no history of sewer spills associated with this section
of the sanitary sewer collection system. Before this event, maintenance records show that this station was last
serviced on 04/04/2021 and inspected on 4/07/2021
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 upgrades have been installed and test for
efficiency. The station continues to be upgraded to ensure no other malfunctions occur. A press release
notification associated with this event was requested to be published in the Raleigh News & Observer on April
23rd, 2021 (see exhibit 2).
Exh ib t 2 Press Release, News and Observer.
Inaidorrt i - 7100 Groat Laurel
Dr, lftatofgh, NC 27616
Roloo Water Responds to a Sanitary
Sowor Overflow
Can Tuesdriy, April 20, 2021, atapprox-
:matey 10.30 PM Rsleo Water staff
rospondod to a sanitary WA*r over-
flow located at 7100 Great Laurel Dr,
Raleigh, NC 27616. The overflow was
a result of the Brighton purnp etatlon
require. The responding staff took all
reasonable steps to atop end mit-
gete the overflow's impact as soon
as they arrived. The North Carolina
Department of FiMronrnental Cuefty,
0tvtswn of Water Resources has been
notified of the Overflow
Raleigh Water staff contained the
overflow at approximately 2.,00 AM the
next momfV. it is estimated that the
overflow discharged a volume of ap-
proxrnalely 20,000 gallons of untreat-
ed vrazL-emte r that readied a storm
drainage channel Within the Neuse
Basin. Owass wrips have been out
nio place until the asset can be re-
wired No vregetaltve damage or fists
Mt has been observed related to this
• Raleigh Water has an sal}
gressrve edUMtlan and enforcement
program to prevent the disdttrrge
of orease. debris calms rag& dia-
pers and other improper rnaterlais
in the sewer systm and to take on..
fercement action where appropriate.
if these Items maw it Into the sewer'
system. they roay cause a spill which
can have an adverse impact on water
quailty 2nrl endanger Mow who come
into contactwith the affected areas.
• Mtef 1 uirar3 waste, and toilet
tissue are the oniy treats permitted to
be discharged into the sower system.
All other tiaras will cause damage to
the sewer system and are not permit-
ted.
C you experierroo excosslve
sewer snails or too wmar spilling
from manholes or ppes, please Call
91f 3245 to report Immediately.
For more Infomraton about
how you can help prevent sanitary
aovror spills, please visit: raloghne.
guA%Q er
This nows release is roquirod W
NCGS Article 2', Chapter 143.21 SAC.
W000OOD00
Pubticatort Dolos

Incident Number #202101197 — 04/18/2021— 7703 Oak Marsh Dr., Raleigh.
This spill was neither willful nor intentional; it resulted from a failed 6" ductile iron sewer forced main.
This asset failure led to a sewer spill of approximately 31,700 gallons of untreated wastewater.
On Sunday, April 18th, 2021, at approximately 6:15 PM, Raleigh Water Utility Responders were notified
of wastewater emanating from the ground near 7703 Oak Marsh 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 12:01 AM the following day. Utility response crews were able to contain and collect the
wastewater by utilizing vacuum trucks in tandem and controlling wastewater flow from the nearest pump
station. Although some wastewater entered a stormwater catch basin, crews were able to collect the flow in the
tanks preventing the wastewater from continuing downstream.
Sewer Maintenance Repair crews were dispatched to begin repairing the damaged section of the force
main (see exhibit 1). The repair was made possible by reducing wastewater flow at the nearby pump station.
Once the main was excavated, crews applied a 360° containment band (see exhibit 2) covering the defected
section of pipe (approximately a 1-inch hole). Once the repair was completed, the forced main was turned back
on to verify for effectiveness, no subsequent leaks or repair failures were noted. Crews restored the site by
backfilling the excavation with stable structural aggregates and restoring the surface with seed and straw (see
exhibit 3).
Exhibit 1-Approximate 1-in force main rupture
Exh bit 3 - Site restoration
Exhibit 2 - 360" containment band

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. The Backup ORC observed no solids and or wastewater within the
stormwater system and the surrounding grounds. 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 $ 4,453.75. The approximate cost to
the Utility to have treated 31,700 gallons of wastewater would have been approximately $47.55. 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.
Before the event on 04/18/2021, this force main was assessed for a point repair on 11/16/2020. No
other maintenance issues have been noted since this incident.
A press release notification related to this event was requested to be published in the Raleigh News & Observer
on April 23rd, 2021 (see exhibit 4)
Exhnbit 4 Press release, News and Observer
Incident 2 - 7703 Oak Marsh
Dr, Raleigh, NC 27610
Ratelgt Water %5"ds to a Sanitary
Saw" OvertloN
On Sunday. April 18, 2021, at ap-
proxmatety 0615 PM, Raleigh Water
s1a0 responded to a swWary sewer
overflow located at 7703 Oak Marsh
Dr. Ralegh. NC 27616. The ovedW
was the result of a failed 6' duOdu
won presarkud sewer man. The
responding ssan took as teaaorhatlla
slaps tD stop and mitgats the over-
flow's hroact as soon as they arrived.
The North Carcllrha Deparhnert of Err
virawnental Quality, Division of Water
Fiesouces has been rhot" of the
ovorlbw.
Raleigh Water " contained the
Overflow at appinxi tawN 756 PM On
the same day. It is estmated that the
Overflow discharged a whore of ap-
proximates 31 JW gallons of untreat-
W wastewater fiat reached a sfonn
drainage channel within the Name
Basin Repair to the allectirg asset
was eum>bf d the amine clay aorhg
with restoration of the affected area.
No vegristive danhage or fish IrID has
boon obeorvod rotated b this avant
Raleigh Water has an ag-
gressive education and erdoioernent
program ID prevent the discharge
of Wease. debris, wipee, rats, dia-
pers, and ottw keproper rralorials,
in the sewer system and to kM en-
focernam action whom splImprlate.
I these items make It Irk the sewer
syatan, they may cause a opki whir h
can have an adverse la pact an water
quality end endartger those who come
into ooDTact with tlho allodod soon.
Water, hummrh waste, and IOM
Bows are the only items peasgtsd to
be discharged Into the sewer system.
All other kqns wig cause damage to
the sewer systern and are nDt pemhfl-
theh3
• t you experience exDmive
Sewer smells or we sewer spilling
frern mardnolea Or pipes, please call
919-996-U451* rapoa hnhedieteiy.
For more IrdonnaVon about
horn yea can help prevead sandary
hhowvr qAl% pkaee vkk: reblghno.
9"wmtar.
This news release is remixed by
HOGS k6cie 21. Chaplet, 143215.1C.
IT 1:^4'.'h7� s

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 significantly 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 412.09 [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
3,539,719.22 (2), approximately 27% of the Division's annual operating budget. The 52,530 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $9,590.45 to mitigate.
The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $78.00 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 2.1 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
388,577.60
73.60
$ 390,364.31
Flushing
1,779,273.18
336,98
$ 675,890.74
Repair
7,990.00
1.51
$ 2,473,464.17
Total - 2,175,840.79 Ft Total cost of Business to Date
412.09 MILES $ 3,539,719.22
[3[ $.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.
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. 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 on
the proper use of sanitary sewers to prevent the 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 -0264 issued for the month of
May 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 [phone] or T.J. Lynch, Assistant Raleigh
Water Director, at (919) 996--2316.
�W
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 raleiphnc.Gov
Cc: Robert Massengill, Raleigh Water Director
T.J. Lynch, Assistant Raleigh Water Director Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance

ROY COOPER
Gwemor
DIONNE DELL[ -GATT]
5-mary
S. DANIEL SMITH
Dlrertor
77-Pal TIT17111t
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
d INL
MN 10 •y..
NORTH CAROLINA
Envlrlonmen fal Quality
May 20, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0264
Sanitary Sewer Overflows - April 2021
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
By
KU9 T �
j uNh is 2021
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s 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 (Mins) Location Cause (Gals) (Gals) DWR Action
202101179 4/13/2021 33 400 Woods of North
Debris In line
830 415 Notice of Violation
Bend
202101197 4/18/2021 346 7703 Oak Marsh Drive,
Pipe Failure (Break)
31,700 31,700 Notice of Violation -
Raleigh, NC
Notice of Intent
202101209 4/20/2021 210 7100 Great Laural Drive
Pump station
20,000 20,000 Notice of Violation -
equipment failure
Notice of Intent
North Caratm Department of EeNramtental WtY I ohhlon of water Rnowas
Rak1ghR"WW0nke 13E009w0l0dwe I RAegh,NorthCudmum
,9*+ 91929IA200

This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.5A, 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 !tills 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 [e-mail].
Sincerely,
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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