WQCS00002_NOV-2021-DV-0336 Response_20210831

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Raleigh Water
August 315t, 2021
Mr. Scott Vinson
Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources NCDEQ 0.75.
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1628 Mail Service Center ,b Grj
Raleigh, NC 27699-1628 V. r-,
Re: Response to NOV-2021-DV-0336 a'
Sanitary Sewer Overflows —July 2021 O
,.,y
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-2021-DV-0336) received on August 18th, 2021. This document contains the narratives regarding
a pending violation actions of (5) Sanitary Sewer Overflow (SSO) events, which occurred during the month of
May 2021 within the City of Raleigh Collections System [1). 3 of these events were the result of Tropical Storm
Elsa, which produced a 2.52 inches rainfall. This document also provides exhibits as proof of our efforts to
mitigate the sewer events. 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 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 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 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;"
1

Incident Number # 202101551— 7/8/2021— 3316 Alleghany Dr., Raleigh, NC
This sewer overflow was neither willful nor intentional; it resulted from Tropical Storm Elsa, which led to
an unexpected sanitary sewage surcharge of approximately 3,300 gallons of untreated sewer from a manhole in
a 24-inch gravity sewer main. The sewer remained within the natural topography with no indication of it
reaching surface waters. The weather event produced an unprecedented rainfall of 2.5 inches for July 8th, 2021
(NOOA, Monthly Climatological Report for Raleigh, NC, see exhibit 4). This weather event was responsible for
other sewer overflow events within the Raleigh service area.
Raleigh Water staff identified signs of a surcharge immediately following the cease of the adverse
weather event. It is estimated that the weather event peak between the hours of 6:05 PM and 7:00 PM on July
8th,2021. The responding staff took all reasonable steps to mitigate the discharge's impact as soon as they
arrived. The staff identified sewer debris surrounding the affected manhole and utilized ample potable water to
flush the affected area removing sewer traces from the area surrounding the manhole. The area around the
manhole was then cleared of debris, treated with an application of lime, and restored with grass seed and straw.
Any collected debris was reintroduced into the collection system. The total cost of the City's response and
remediation effort for this spill event was.
The cost associated with the mitigation of this event amounted to $775.70. The approximate cost to the
Utility to have treated 3,300 gallons of wastewater would have been approximately $4.95. 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.
Crews conducted an area assessment downstream of the surcharge to ensure no other sewer assets
were affected by the storm. As part of a proactive post -storm assessment along the Crabtree Creek corridor,
crews found indications of another surcharge downstream near 2739 Rothgeb Drive. There was no sign of fish
kill related to this SSO.
From 2010 to 2015, the pipe system located at Alleghany Dr. has experienced five sewer overflows
resulting from excessive rain and flooding. This asset is part of an active capital project designed to increase flow
capacity and reduce inflow and infiltration 1. Before the weather event, the most recent routine maintenance
record in this area was conducted on 04/26/2021.
A press release was issued for this spill event, including other simultaneous spills resulting from Tropical
Storm Elsa. (See exhibit 1- Press Release 3316 Alleghany Dr., Raleigh, NC)
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.
1. Project WS-2014-45 Crabtree Basin Wastewater System Conveyance Improvements Phase II (Crabtree Pipeline)
2

Exhibit 1- Press Release 3316 Alleghany Dr., Raleigh, NC
■
0 Raleigh
NEWS REI 7.ASr
COMMUNICATIONS DEPARTMENT
Juty 9, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, July 8, 2021, at approximately 6 05 PM, Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 3316
Allegheny Drive, Raleigh, NC. The cause of the spill was related to rainwater
accumulation from Tropical Storm Elsa. The responding staff took all reasonable steps
to stop and mitigate the impact of the spill as soon as they arrived The North Carolina
Department of Environmental Quality, Division of Water Resources was notified of the
spill.
Raleigh Water- Sewer Maintenance Division staffstopped the spill at
approximately 7:00 PM on the same day. It is estimated that the spill discharged
approximately 3,300 gallons of wastewater which was recovered and reintroduced back
into the collection system Restoration associated with this event is expected to be
completed on Friday, July 9 There has not been any vegetative damage or fish kill
associated with 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 it into the sewer system, they may
cause a spill which can have an adverse impact on water 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 sewer system. All other items will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or see sewer spilling from
manholes or pipes, please call 919-996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer
spills, please visit: raleighnc.govlwater.
This news release is required by NCGS Article 21, Chapter 143215.1C.
3

Incident Number # 202101552 — 7/8/2021— 2739 Rothgeb Dr., Raleigh, NC
This sewer overflow was neither willful nor intentional; it resulted from Tropical Storm Elsa, which led to
an unexpected sanitary sewage surcharge of approximately 4,500 gallons of untreated sewer from a manhole in
a 36-inch gravity sewer main. The sewer remained within the natural topography with no indication of it
reaching surface waters. The weather event produced an unprecedented rainfall of 2.5 inches for July 8th, 2021
(NOOA, Monthly Climatological Report for Raleigh, NC, see exhibit 4). This weather event was responsible for
other sewer overflows events within the Raleigh service area.
Raleigh Water staff identified signs of a surcharge immediately following the cease of the adverse
weather event. It is estimated that the weather event peak between the hours of 6:05 PM and 7:00 PM on July
8th,2021. The responding staff took all reasonable steps to mitigate the discharge's impact as soon as they
arrived. The staff identified sewer debris surrounding the affected manhole and utilized ample potable water to
flush the affected area removing sewer traces from the area surrounding the manhole. The area around the
manhole was then cleared of debris, treated with an application of lime, and restored with grass seed and straw.
Any collected debris was reintroduced into the collection system. Crews did not see any further indication of
sewer surcharge nor a sign of fish kill related to this SSO along the Crabtree Creek corridor.
The cost associated with the mitigation of this event amounted to $335.00. The approximate cost to the
Utility to have treated 3,300 gallons of wastewater would have been approximately $6.75. 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.
From 2013 to 2021, the pipe system located at 2739 Rothgeb Dr. has experienced five sewer overflows
resulting from excessive rain and flooding. This asset is part of an active capital project designed to increase flow
capacity and reduce inflow and infiltration 2. Before the weather event, the most recent record of routine
maintenance in this area was conducted on 04/29/2021.
A press release was issued for this spill event, including other simultaneous spills resulting from Tropical
Storm Elsa. (See exhibit 2 - Press Release 2739 Rothgeb Dr., Raleigh, NC)
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.
2. Project WS-2014-45 - Crabtree Basin Wastewater System Conveyance Improvements Phase II (Crabtree Pipeline)
4

Exhibit 2 - Press Release 2739 Rothgeb Dr., Raleigh, NC)
%a'%: Raleigh
.i, g
NEWS RP EASE
COMMUNICATIONS DEPARTMENT
July 9, 2021
For more information_
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, July 8, 2021, at approximately 10.00 AM, Raleigh Water- Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 2739 Rothgeb
Drive, Raleigh, NC. The cause of the spill was related to rainwater accumulation from
Tropical Storm Elsa. The responding staff took all reasonable steps to stop and mitigate
the impact of the spill as soon as they arrived. The North Carolina Department of
Environmental Quality, Division of Water Resources was notified of the spill.
The overflow was contained within the natural topography with no visual
indication of debris reaching surface waters. It is estimated that the sewer overflow
event stopped on its own once the storm had passed on July8 : 2021. It is estimated
that the overflow discharged a volume of approximately 4,500 gallons of untreated
wastewater which was recovered and reintroduced into the collection system. The
sewer event occurred within Crabtree Basin Restoration for this event is expected to
be completed on July 9, 2021. No vegetative damage or fish kill was observed related
to 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 it into the sewer system, they may
cause a spill which can have an adverse impact on water 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 sewer system. All other items will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or see sewer spilling from
manholes or pipes, please call 919-996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer
spills, please visit: raleighnc.goviwater.
This news release is required by NCGS Article 21, Chapter 143 215.1C.
5

Incident Number # 202101553 — 7/8/2021— 5532 Neuse View Dr., Raleigh, NC
This sewer overflow was neither willful nor intentional; it resulted from Tropical Storm Elsa, which led to
an unexpected sanitary sewage surcharge of approximately 2,019 gallons of untreated sewer from a manhole in
a 54-inch gravity sewer main. The sewer remained within the natural topography with no indication of it
reaching surface waters. The weather event produced an unprecedented rainfall of 2.5 inches for July 8th, 2021
(NOOA, Monthly Climatological Report for Raleigh, NC, see exhibit 4). This weather event was responsible for
other sewer overflows events within the Raleigh service area.
Raleigh Water staff identified signs of a surcharge immediately following the cease of the adverse
weather event. It is estimated that the weather event peak between the hours of 6:05 PM and 7:00 PM on July
8th,2021. The responding staff took all reasonable steps to mitigate the discharge's impact as soon as they
arrived. The staff identified no sewer debris on the ground, but there were indications of a manhole surcharge
as a result of the storm. The area where the sewer may have settle was washed with potable. Crews conducted
an area assessment downstream of the surcharge to ensure no other sewer assets were affected by the storm.
Crews did not see any further indication of sewer surcharge nor a sign of fish kill related to this SSO.
The cost associated with the mitigation of this event amounted to $1,404.45. The approximate cost to
the Utility to have treated 3,300 gallons of wastewater would have been approximately $3.02. 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 asset experienced an SSO as a result of a pump station failure on 05/20/2021. Records show no
other overflows before the event on 7/08/2021. This asset is part of an active capital project designed to
increase flow capacity and reduce inflow and infiltration 3. Before the weather event, the most recent record of
routine maintenance in this area was conducted on 04/29/2021.
A press release was issued for this spill event, including other simultaneous spills resulting from Tropical
Storm Elsa. (See exhibit 3 - Press Release 5532 Neuse View Dr., Raleigh, NC)
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.
3. Project ID- WS-2017-07 West Neuse Interceptor Improvements. Replacement of approximately 26,000 linear feet of existing 48-inch and 54-inch sewer with 60- and
66-inch pipe along the west side of the Neuse River, upstream of the Neuse River Pump Station.
6

Exhibit 3 - Press Release 5532 Neuse View Dr., Raleigh, NC
Raleigh
NEWS RELEASE
COMMIJNICATiONS DEPARTMENT
July 9, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, July 8, 2021, at approximately 10 00 AM, Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 5532 Neuse
View Drive, Raleigh, NC. The cause of the spill was related to rainwater accumulation
from Tropical Storm Elsa. The responding staff took all reasonable steps to stop and
mitigate the impact of the spill as soon as they arrived. The North Carolena Department
of Environmental Quality, Division of Water Resources was notified of the spill.
The overflow was contained within the natural topography with no visual
indication of debris reaching surface waters. It is estimated that the sewer overflow
event stopped on its own once the storm had passed on July 8. 2021. It is estimated
that the overflow discharged a volume of approximately 2,019 gallons of untreated
wastewater which was recovered and reintroduced into the collection system. The
sewer event occurred within Crabtree Basin Restoration for this event is expected to
be completed on July 9, 2021 No vegetative damage or fish kill was observed related
to 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 it into the sewer system, they may
cause a spill which can have an adverse impact on water 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 sewer system. All other items will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or see sewer spilling from
manholes or pipes, please call 919-996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer
spills, please visit raleighnc.govlwater.
This news release is required by NCGS Article 21, Chapter 143.215.1C.
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Exhibit 4 - NOOA, Monthly Climatological Report for Raleigh, NC
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 - bttp://www.ncdc.noaa,gQy.
Climatological Report (Daily)
000
CDUS42 KRAH 090617
CLIRDU
CLIMATE REPORT
NATIONAL WEATHER SERVICE RALEIGH NC
217 AM EDT FRI JUL 09 2021
...THE RALEIGH NC CLIMATE SUMMARY FOR JULY 8 2021...
CLIMATE NORMAL PERIOD 1991 TO 2020
CLIMATE RECORD PERIOD 1887 TO 2021
WEATHER ITEM OBSERVED TIME RECORD YEAR NORMAL DEPARTURE LAST
VALUE (LST) VALUE VALUE FROM YEAR
NORMAL
TEMPERATURE (F)
YESTERDAY
MAXIMUM 79 1211 AM 105 2012 91 -12 89
MINIMUM 71 1159 PM 53 1979 70 1 74
AVERAGE 75 80 5 82
PRECIPITATION (IN)
YESTERDAY 2.52R 1.88 1887 0.15 2.37 T
MONTH TO DATE 3.78 1.11 2.67 0.47
SINCE JUN 1 11.35 5.00 6.35 3.09
SINCE JAN 1 27.96 22.22 5.74 24.50
DEGREE DAYS
HEATING
YESTERDAY 0 0 0 0
MONTH TO DATE 0 0 0 0
SINCE JUN 1 0 3 -3 7
SINCE JUL 1 0 0 0 0
COOLING
YESTERDAY 10
MONTH TO DATE 90
SINCE JUN 1 430
SINCE JAN 1 648
16 -6 17
121 -31 123
475 -45 470
709 -61 681
WIND (MPH)
HIGHEST WIND SPEED 22 HIGHEST WIND DIRECTION E (110)
HIGHEST GUST SPEED 31 HIGHEST GUST DIRECTION SE (130)
AVERAGE WIND SPEED 8.1
SKY COVER
POSSIBLE SUNSHINE MM
8

Incident Number # 202101564 — 07/14/2021 — 1127 Marshall St., Raleigh, NC
This spill was neither willful nor intentional; it resulted from root intrusion, which caused a pipe failure
on a 6-in" Polyvinyl Chloride gravity sewer main. The pipe failure led to a sewer spill of approximately 1,200
gallons of untreated wastewater in which 1000 gallons reached an unnamed tributary of the Neuse within the
Pigeon House Raleigh Basin.
On 07/14/2021, at approximately 10:07 AM, Sewer Maintenance staff was notified of a sewer overflow
near 1127 Marshall St., Raleigh, NC. Upon arrival, it was discovered that untreated sewer was emanating from
an adjacent manhole SMH195968, (see exhibit 5 - SSO Area of Operation). 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 10:45 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 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 no fish kill or unnecessary vegetative damage.
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 approximately 945 ft of the
downstream conveyance. The area around the manhole was cleared of debris and washed with potable water.
The site was treated with an application of lime and restored with grass seed and straw.
A follow-up CCTV assessment conducted immediately following the sewer event found a section of 6-inch
pipe was compromised with root causing the pipe to rupture. A subsequent repair took place to replace
approximately 8 ft of pipe (Exhibit 6 — Pipe Repair), restoring flow.
The cost associated with the mitigation of this event amounted to $5,307.00. The approximate cost to the
Utility to have treated 1,200 gallons of wastewater would have been approximately $1.80. 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 area south of Capital Blvd. This section of the
collection system provides sewer collection to at least 33 residential properties. A press release notification
associated with this event was published in the Raleigh News & Observer on 5/29/2021 (Exhibit 7 — Press
release). Before this event, maintenance records show that sections of this collection system were assessed as
follows:
Flushing activities
5/18/10 07/29/2015
1/29/2013 9/13/2017
1/30/2013 10/13/2017
7/24/2014 7/14/2021
7/28/2014 7/16/2021
CCTV Activities
9/6/2017
9/6/2017
9/6/2017
10/18/2017
11/21/2017
1/24/2018
7/14/2021
7/22/2021
Repair Activities
1/24/2018
1/19/2021
7/15/2021
7/28/2021
Inspection Activities
6/21/2021 12/2/2019
1/25/2018 3/19/2020
6/5/2018 10/1/2020
1/2/2019 3/2/2021
4/24/2019
9

Note
This site has been identified for future root control.
Exhibit 5 - SSO Area of Operation
10

Exhibit 6 — Pipe Repair
11

Exhibit 7 — Press Release
100,' Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
July 15, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Wednesday, July 14, 2021, at approximately 10:07 AM Raleigh Water -
Sewer Maintenance Division staff responded to a sanitary sewer spill located at 1127
Marshall St., Raleigh, NC. The cause of the spill was related to a debris blockage
disrupting the collection system. The responding staff took all reasonable steps to stop
and mitigate the impact of the spill as soon as they arrived. The North Carolina
Department of Environmental Quality, Division of Water Resources was notified of the
spill.
Raleigh Water staff contained the spill at approximately 11 00 AM on the same
day. It is estimated that the spill discharged a volume of approximately 1,000 gallons of
untreated wastewater reaching an unnamed tributary within Pigeon House Basin
Restoration for this event Is ongoing No vegetative damage or fish lull has been
observed related to 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 it into the sewer system, they may
cause a spill which can have an adverse impact on water 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 sewer system. All other items will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or see sewer spilling from
manholes or pipes, please call 919-996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer
spills, please visit: raleighnc.goviwater.
This news release is required by NCGS Article 21, Chapter 143 215.1C
12

Incident Number # 202101603 — 07/14/2021— 2601 Adcox PI., Raleigh, NC
This spill was neither willful nor intentional; it resulted from foreign debris (flushed wipes/ see exhibit —
foreign debris) not consistent with regular wastewater debris such a paper. This debris caused a partial blockage
in a portion of an 8- inch gravity sewer main. The blockage led to a sewer spill of approximately 3,500 gallons, of
which 3,000 gallons reached an unnamed tributary in Southgate Basin.
Exhibit 8— Foreign debris
On 07/20/2021, at approximately 12:19 PM, Raleigh Water staff identified a manhole spilling over.
Utility responders were immediately summoned to respond and mitigate the spill. 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 2:59 PM on the same day. Utility response 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 was intended to contain sewer flow and minimize the
environmental impact on the surrounding land. Responding crews initiated the collection of untreated
wastewaters from the containment site to re -introduced it to the collection system downstream. This spill was
contained without a significant environmental impact on the adjacent area and its natural resources. See exhibit
9 - Containment and collection efforts.
13

Exhibit 9 -- Containment and collection efforts
During the restoration phase of the operation, crews utilized ample potable water to remove evidence of
sewer 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. Visual inspection of the affected area and
downstream waters confirmed no fish kill or unnecessary vegetative damage occurred. See exhibit 10 -
Restoration efforts.
Exhibit 10 — Restoration efforts
The cost associated with the mitigation of this event amounted to $4,799.64. The approximate cost to
the Utility to have treated 3,500 gallons of wastewater would have been approximately $5.25. 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 and the cost of potable water used to mitigate the event.
A follow-up close circuit television (CCTV) assessment of approximately 1456.45 ft of sewer gravity
mains upstream and downstream of the affected asset is scheduled for root cause analysis. This assessment will
determine future maintenance requirements. This section of the collection system serves a residential area
south of Rock Quarry Rd and east of Sanderford Rd. It provides sewer collection services to approximately 237
14

properties. Before the sewer event on 07/14/2021, this section of the collection system experienced one sewer
overflow at 2410 Creech Rd on 03/27/2004. This event was isolated and not related to the subsequent event at
5501 Wade Park Blvd. A press release notification was requested to be published in the Raleigh News &
Observer as required by NCGS Article 21, Chapter 143.215.1C (see exhibit 11- Press release 2601 Adcox PI.,
Raleigh, NC). 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. Since the last sewer event, there have been no additional issues
associated with this section of the collection system.
Exhibit 11- Press release 2601 Adcox PI., Raleigh, NC
■
�Si
°�.° Raleigh
COMMUNICATIONS DEPARTMENT
July 21. 2021
For more intomralhon
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Tuesday, July 20 2021 al approximately 12'19 PM Raleigh Water . Sewer
Maintenance Division stall responded to a sanitary sewer spill located at 2601 Adcox
Place, Raleigh, NC The cause of the ape was related to a debris dockage disrupting
the collection system The responding staff took al reasonable steps to stop and
mitigate the unpact of the sp7 as soon as they arrived The North Carolina Department
of Environmental Cruelty Division of Water Resources was notified of the spill
Raleigh Water staff contained the spit at approximately 2 00 PM on the same
day. his estimated that the spell discharged a volume of approximately 4 000 gallons of
untreated wastewater of which 3 500 gallons reached an unnamed tributary within
Southgate Basin Restoration for this event is ongoing No vegetative damage or fish
loll has been observed related to this event
• Raleigh Water has en 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. t these items make it into the sewer system, they may
cause a spill which can have an adverse impact on water 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 sewer system. All other Items will cause damage to the
sewer system and are not permitted.
t you experience excessive sewer smells or see sewer spilling from
manholes or pipes, please call 919996-3245 to report immediately.
• For more Information about how you can help prevent sanitary sewer
spills, please visit raleighnc.govfwater.
This news release is required by NCGS Article 21, Chapter 143 215 IC
sad
15

Before this event, maintenance records show that sections of this collection system were assessed as
follows:
02/05/2009 - 2800 Slippery Elm Dr.
6/11/2009 - 2801 Dancer Ct.
06/11/2009 - 2812 Enka Dr.
06/15/2009 - 3009 Sanderford Rd.
06/23/2009 - 2809 Enka Dr.
06/23/2009 - 2901 Sanderford Rd.
07/07/2009 - 2813 Enka Dr.
10/28/2010 - 2709 Midway Park Ct
5/23/2011- 2820 Sourwood St
7/2/2011- 2701 Big Oak St.
7/6/2011- 1701 Fox Hollow Dr.
12/30/2011- 1705 Fox hollow Dr
10/12/2012 - 2709 Owl Tree Ct
11/9/2012 - 2708 ADCOX PL
2/27/2013 - Fox Hollow Dr
Flushing activities
3/4/2013 - 2008 Ferret Ct
3/26/2013 - 2805 Delco Ct
6/17/2013 - 2721 Big Oak St
9/15/2013 - 2701 Big oak St
9/25/2013 - 1700 Calypso Ct
10/5/2013 - 2800 Sourwood St
1/9/2014 - 2812 Ferret Ct
8/15/2014 - 2713 Midway Park Ct
1/7/2015 - 1800 Fox Hollow Dr
2/10/2015 - 2805 Creech Rd
7/23/2017 - 2514 CREECH RD
10/30/2018 - FOX HOLLOW, SOURWOOD, BIG OAK
4/3/2019 - FOXHILL, FOXTROT, FOXGATE
6/19/2020 - 2609 ADCOX PL
9/21/2020 - 2421 FOXTROT RD
7/20/2021- 2713 MIDWAY PARK CT
Inspection
12/5/11 - 2600 Big Oak St
1/4/2014 - 1718 Fox hollow Dr
4/30/2014 - 2708 Foxtail Ct
6/23/2020 - Manhole Insp - CREECH RD
Note
28 High priority Inspections from
2/28/2018 - 3/24/2021
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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 428.40 [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
3,581,811.42 [2], approximately 28% of the Division's annual operating budget. The 14,519 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $12,621.97 to mitigate.
The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $21.78 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 2.21 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] 428.40 miles represents 17% of the sanitary sewer collection system
[2] Associated operational cost year to date for FY2021
OPERATION LINEAR FEET Linear Miles COST
CCTV 387,943.05 73.47 $ 393,735.68
Flushing 1,865,983.86 353.41 $ 678,392.25
Repair 8,060.00 1.52 $ 2,509,683.49
Total - 2,261,986.91 Ft Total cost of Business to Date
428.40 MILES 3,581,811.42
[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.
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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 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-0336 issued for the month of
July, 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 [phone].
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
[e-mail]
CC: Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director - Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance
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