WQCS00002_NOV-2021-DV-0279_20210812

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Raleigh Water
August 11th, 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-0279
Sanitary Sewer Overflows— May 2021
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept of Environmental Quality
AUG 12 Lid
Raleigh Regional Office
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2021 DV 0279) received on July 28', 2021. This document contains the narratives regarding a
pending violation actions of (4) Sanitary Sewer Overflow (SSO) events, which occurred during the month of May
2021 within the City of Raleigh Collections System Ili. 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 550 events.
1. "The D:rrr for 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 un'ess 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 alternat+ves to the 5S0, 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 r aparity of the system. This provision is not satisfied if, in the
exercise of reasonable engineering judgment, the Permittee should have instal'ed auxi:iary or additional collections system components, wastewater retention or treatment
facilities, adequate back-up equipment or should have reduced inf ow and infiltration; t:r
[b.l The SSO was exceptional, unintentional, temporary and : aused by factors beyond the reasonab'e control of the Permittee; the SSD 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 control mg and preventing infiltration and inflow); preventative maintenance; or
installation of adequate back-up equipment;"
1

Incident Number # 202101344 — 05/20/2021— 5536 Neuse View Dr., Raleigh, NC (Neuse River Pump Station
52)
This spill was neither willful nor intentional; it resulted from a loss of utility power and pump #2 tripping
the main breaker to the station. When the generator activated, the automatic transfer switch (ATS) could not
send power back to the pumps without a mechanic to reset the correct breakers. Signage is present at the
station with the proper steps for transferring power. At the time, SCADA alarms were present for Loss of Utility
Power, RTU Status: Inactive, and generator Running. The responsible plant operator on duty responds to these
alarms and makes a phone call to the on call mechanic in time to save an overflow. The failure affected flow and
surcharged a 54-inch Reinforced Concrete Pipe (RCP) gravity sewer main upstream of the station and resulted in
approximately 1,400 gallons of untreated wastewater spilling directly to the ground and did not reach surface
waters.
On 5/20/2021, at approximately 3:53 am, Raleigh Water staff were alerted via flow meter alarm
notification that manhole SMH108009, directly upstream of Neuse River Pump Station, was surcharged above
the elevation of the manhole. Neuse River Operations was contacted immediately, and an on call mechanic was
sent to the site. Upon arrival, the mechanic reset the correct breakers, activated the pumps, and returned the
station to normal operation.
Restoration of this spill event consisted of washing the land surrounding a manhole that surcharged.
Although no utility operator or bystander witnessed this incident, the only evidence was a 20 ft by 35 ft puddle
of clear sewer surrounding a manhole. The flow remained within the natural topography with no indication of
sewer reaching surface waters. No traces of solids were present. Crews utilized ample potable water to flush,
clear, and collect any evidence of sewer for proper disposal. Crews completed the restoration by applying lime
seed and straw. This spill was mitigated without a significant environmental impact on the adjacent area and its
natural resources.
There is no history of previous sewer spills associated with this section of the sanitary sewer collection
system. Before this event, maintenance records show that this station was last serviced and inspected on
5/13/21. Since the sewer event, there have been no other issues associated with this section of the collection
system. This site remains an active maintenance spot as specified by the collections system permit.
2

Incident Number # 202101350 — 5/24/2021— 3800 Hillsborough St., Raleigh
This spill was neither willful nor intentional; it was the result of root intrusion, which blocked a portion of
an 8-in" gravity sewer main. The root intrusion led to a sewer spill of approximately 1,500 gallons of untreated
wastewater not reaching surface waters of the state.
On 5/24/2021, at approximately 7:25 AM, Sewer Maintenance staff was notified of a sewer overflow
located at 3800 Hillsborough St., Raleigh. Upon arrival, it was discovered that untreated sewer was emanating
from an adjacent manhole (SMH142431). 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 9:12 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, collection, cleanup, and restoration of this spill event consisted of employing a temporary
sewer containment site downstream from the 5S0 location to stop the flow of sewer into the stream (see
Exhibit 1- SSO Area of Operation, p4). Crews used pumps at the temporary containment site to recover the
remaining sewer into a downstream sewer manhole. The area around the manhole was cleared of debris,
treated with an application of lime, and restored with grass seed and straw. During the restoration phase of the
operation, crews utilized water from adjacent hydrants to defuse and flush the affected area.
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.
The cost associated with the mitigation of this event amounted to $1,426.00. The approximate cost to
the Utility to have treated 1,500 gallons of wastewater would have been approximately $2.25. 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 near Meredith College. This system
provides sewer collection to several multi -dwelling properties. A press release notification associated with this
event was published in the Raleigh News & Observer on 5/27/2021 (Exhibit 2 — Press release, p5)
Before this event, maintenance records show that sections of this collection system were assessed as
follows:
Flushing activities CCTV Activities Inspection activities
1/27/2004 7/7/2021 2/13/2018 3/16/2020
7/28/2009 7/12/2021 4/27/2018 8/5/2020
2/10/2020 1/18/2019 8/27/2020
6/14/2021 1/22/2019 8/28/2020
5/1/2019 9/2/2020
5/2/2019 9/22/2020
5/9/2019 9/29/2020
11/6/2019 2/17/2021
3/5/2020 2/18/2021
3/11/2020 2/22/2021
3/13/2020
3

The latest maintenance/inspection assessment for this site was conducted on 6/14/2021 in which several
segments of main were flushed. There have been no additional issues associated with this section of the
collection system since the last sewer event. This site has been added to the Hot Spot Management Program for
root management with a recommended maintenance interval of every 6 months.
Exhibit 1- SSO Area of Operation
4

Exhibit 2 Press Release
•
Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
May 27, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Monday, May 24. 2021, at approximately 7:34 AM. Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spfil located at 3800
Hillsborough Street, Raleigh, NC 27616. The cause of the spill was related to root
Intrusion into the sewer gravity main The responding staff look an reasonable steps to
stop and mitigate the impact of the spill as soon as they arrived The North Carolina
Department of Environmental Duality, Division of Water Resources was notified of the
spill.
Raleigh Water- Sewer Maintenance Division staff. stopped the spill al
approximately 9.12 AM on the same day It is estimated that the spin discharged
approximately 1,500 gallons of untreated wastewater, with none reaching surface
waters. Restoration associated with this event was completed on the same day. 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: ralelghnc.gov/water.
This news release is required by NCOS Article 21, Chapter 143 215.1C.
Wit
5

Incident Number # 202101351— 05/24/2021— 5000 Windy Dr, Raleigh, NC
This spill was neither willful nor intentional. It resulted from grease accumulation, restricting the sewer
flow within an 8" gravity sewer main. This accumulation led to a sewer spill of approximately 14,000 gallons of
untreated wastewater, reaching an unnamed tributary within the Marsh Basin (see exhibit 1— SSO Area of
Operation, p7)
On 05/24/2021, at approximately 10:24 AM, Sewer Maintenance staff was notified of a sewer spill
emanating from a manhole near 5000 Windy Hill Dr., Raleigh, NC. The responding staff arrived shortly after and
commenced taking all reasonable steps to stop and mitigate the impact of the discharge, gaining control of the
spill event by 12:31 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 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 4,031 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. The restoration was
completed on 5/28.
A follow-up CCTV assessment was conducted immediately following the sewer event and did not find any
evidence of infrastructure deficiency leading to grease accumulation. Further sewer cleaning has been
scheduled.
The cost associated with the mitigation of this event amounted to $ $16,109.11. The approximate cost to the
Utility to have treated 14,000 gallons of wastewater would have been approximately $21.00. The City saved no
money from this spill. Its costs for cleanup exceeded the cost of treating the volume of sewage had no spill
occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the
spill.
This section of the collection system provides sewer collection services over 100 properties near the spill
event (see exhibit 2- Zone of Influence, p8). Before the event on May 24th, this portion of the collection system
experienced the following SSOs: 10/2/2000 5128-A Windy Hill Dr.; 3/20/2006 5155 Windy Hill Dr.; 2/2/2008
5031 Windy Hill Dr.; and 12/26/2013 5128-A Windy Hill Dr. Due to these events, this area has been identified as
an area for repeated maintenance.
A press release notification associated with this event was requested on 05/28/2021 (see exhibit 3 —
Press Release, p---9). 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 (see Exhibit 4 — Code Enforcement Letter, p10)
6

Before this event, maintenance records show that sections within the zone of influence (see exhibit 2 —
Zone of Influence, p of this collection system were assessed as follows:
Flushing activities
10/2/2000
3/20/2006
2/2/2008
12/26/2013
2/9/2012
2/14/2012
2/15/2012
2/15/2012
3/29/2012
3/30/2012
4/4/2012
CCTV activities Inspections
3/21/2014 6/27/2018 12/8/2017
4/29/2014 5/16/2017 2/6/2018
6/4/2014 1/13/2021 2/8/2018
6/10/2014 10/8/2020 2/9/2018
7/24/2014 5/27/2021 3/22/2018
4/17/2015 5/25/2021 5/10/2018
10/5/2020 5/28/2021 5/14/2018
1/25/2021 5/16/2018
1/28/2021 Repairs Activities 8/9/2018
2/15/2021 5/9/2017 8/13/2018
5/25/2021 7/20/2017 8/20/2018
7/29/2021 7/25/2017 8/21/2018
6/28/2018 10/19/2018
11/23/2020 3/15/2019
12/14/2020 3/18/2019
3/19/2019
10/3/2019
(manholes and High
10/4/2019
10/8/2019
10/10/2019
10/11/2019
10/14/2019
10/15/2019
10/17/2019
10/31/2019
11/1/2019
1/10/2020
1/21/2020
2/24/2020
2/25/2020
4/27/2020
6/1/2020
7/27/2020
Priority assets)
7/29/2020
7/30/2020
8/13/2020
8/24/2020
9/3/2020
11/13/2020
11/24/2020
12/7/2020
12/9/2020
12/15/2020
1/27/2021
1/28/2021
2/11/2021
3/15/2021
8/2/2021
8/3/2021
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.
Exhibit 1- SSO Area of Operation
Exhibit 2
Zone of Influence
/

8

Exhibit 3 Press Release
Raleigh
NEWS RELEASE
COMMUNICATIONS DEPAR.TM1NT
May 25, 2021
Far more. nWrmai0n.
TJ Lynch. Assistant Dlrectai, Raleigh Wafer, 919-995-3245
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep Grease Out of the Shared Sanitary
Sewer System
On Monday, May 24 2021, at approximately 10 09 AM. Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 5000 Windy
Hill Drive, Raleigh, MC 27616. The cause of the spill was related to grease found in
the sewer gravity main 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 Duality Division of Water Resources was notified of the spa!
Raleigh Water - Sewer Maintenance Division staff stopped the spill at
approximately 12.31 PM on the same day, I1 is estimated that the spill discharged
approximately 12,500 gallons of untreated wastewater reaching surface waters of
Marsh Creek Basin Restoration associated with this event is on-gomg There has not
been any vegetative damage or fish loll associated with this event
Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debris, wipes, raga, 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 919-996321510 report immediately.
For more information about how you can help prevent sanitary sewer
spills, please visit: raleighnc.govhrrater.
This news release is required by NCGS Article 21 Chapter 143.215.14;
9

Exhibit 4 Code Enforcement Letter
•
jtaleigh
Pr Sanitary Sewer Overflow in your neighborhood
Dear Raleigh malty Customer
The City of Raleigh recently experienced a sanitary sewer overflow in your area. The overflow was
caused by improperly disposing of materiels into the City of Raleigh sanitary sewer system such as
per, papa grease or rags. Yon can help prevad these events from occurring by following simple
practices lined below. This will help the City protect water quality, maintain our sanitary sewer system
and keep the sewage in the pipe.
DO NOT pour mare. fats end ens from a.atdge down the drain.
DO NOT a. the toilet as a svak.baekat. (oo disposable/ •Awhebl.• wlpse p.pes
tewds, debelL diaper or baby wipes, co: dams tampons or other personal
hygiene predacte).
nee the sewer system or the kitchen .ink 414141411110 dispose of food lamps.
collect cooking oils and gnaw in a cattails and dispose din the g
plan food scraps in waste basket 1n a prb.p bag along with disposal of
other solid wake or start 4 compost pile.
DO NOT
PLEASE
PLEASE
Prevention can save you a1QX! property owners ere responsible for keeping their sewer service line
dean, sanitary, and continually functioning from their lame to the sewer main. This also includes
service her connections in easements. Most back-ups are due to blockages that occur in the sen'ke line
and the homeowner or customer would typically have to calla plumber You can avoid these
preventable plumber bills by properly disposing of waste'
To report a sewer back-up that is overflowing from a City manhole, please cell the Public Utilities
operatnrss MIsfan at 919-996a71! at any tiro, 24 lours a day, 7 days a week
For more Information on the proper use of your sanitary sewer system, please contact the Public
Utilities Deputising at the number above or find us on the web at wwwsaideluw.gov. With your help
and with the Public Utilities Department preventive matt1esunwe and fats, oils and grease programs,
most sewer overflows can be avoided.
Please help us prevent needless damage to property and the environment
Thank you.
PUSI c Lti:a:IcS M4_RI140C • i4.4,r•4RfE C.TIrE • 4 t7C 13• P. . .t,rsezo •11C 2T401
•AU,*•FGi C, . 55� 660• R.L.C.e«,• C 2772
10

Incident Number # 202101366 — 05/29/2021 — 1837 Snow Wind, Raleigh, NC
This spill was neither willful nor intentional; it was the result of root intrusion, which caused a pipe failure
on an 8 in" Ductile Iron gravity sewer main. The pipe failure led to a sewer spill of approximately 4,230 gallons
of untreated wastewater reached an unnamed tributary of the Neuse within the Mine Basin.
On 5/29/2021, at approximately 2:01 PM, Sewer Maintenance staff was notified of a sewer overflow
located near 1837 Snow Wind, Raleigh, NC. Upon arrival, it was discovered that untreated sewer was emanating
from an adjacent manhole (SMH117290). 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 04:24 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, collection, cleanup, and restoration of this spill event consisted of employing a temporary
sewer containment site downstream from the 550 location to stop the flow of sewer into the stream (see
Exhibit 1 - S50 Area of Operation, p12). Crews used pumps at the temporary containment site to recover the
remaining sewer into a downstream sewer manhole. The area around the manhole was cleared of debris,
treated with an application of lime, and restored with grass seed and straw. During the restoration phase of the
operation, crews utilized water from adjacent hydrants to defuse and flush the affected area.
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.
The cost associated with the mitigation of this event amounted to $3,850.65. The approximate cost to
the Utility to have treated 4,230 gallons of wastewater would have been approximately $6.34. 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 west of Creedmoor Rd. This system
provides sewer collection to several properties. A press release notification associated with this event was
published in the Raleigh News & Observer on 5/29/2021 (Exhibit 2 — Press release, p13)
Before this event, maintenance records show that sections of this collection system were assessed as
follows:
Flushing activities CCTV Activities Easement Activities Inspection Activities
7/25/2011 9/5/2014 5/30/2021 6/2/2021 6/2/2021
7/26/11 4/15/2015 7/9/2021 7/9/2021
7/27/2011 4/6/2015 10/9/2017
7/28/2011 12/8/2015 7/16/2019
9/30/2012 4/18/2017 6/29/2021
4/17/2014 5/3/2019
7/22/2014 5/6/2019
7/23/2014 5/29/2021
9/4/2014
11

This site has been scheduled for easement clearing in order to improve access and minimize future root
intrusion as well as a point repair to address sewer main issues.
Exhibit 1 - SSO Area of Operation
12

Exhibit 2 — Press Release
Raleigh
RFLEASE
c.CltrC071.1DNS si:€FrifiTL`crf
40.ar f 2(12 t
Fur rtnro Irrime,Yton;
VIM
I 1 l fnc- A�SJ.lar4 nrc{rn-r, RciAll N'..#er. 3I9
Raleigh Water Responds to a Sanitary Sewer Spill
On Satu'day idayr 29. 21121 at appreaEcmdl ZO1FM, Halals Water slag
reworded to a santary smear averdas ballad an a sanitary smear aasemard bchnd
1E3? snow Wind D!, Raleigh, NC 71615 iha avallow was a resat of root lMrus`on
Into an B' pollr.tmr1 chloride sewer main Raspondl*►g staff lack al reasenabe slaps to
step and mngale iha nyedloyis mpacl as soon as only amend iha KErin Cara{11a
De:ciaimant of Errdrenmenlal of Wader Roounces has been nal fled al
Iry overarm
idol fn Water staff slot/pod and cnnfal`►ed the endow ac apt:rmtmalcy
4.24FM Iha same day 11 Is coIfl Bed Ma a+rafiaN dyer argod a volume of
apprmimalnlI 4,320 galansal JMsealod xasiawa1cr Ihal maenad an unnamed
trt>t.tary of the Meuse with n Iha Mhe Basra iha rrxdalnmani sJlc Nil refrain
aperatarol through the night with rt .Cullom Mints farctaslad to to completed by
410OFM an May 30, 2,021 No tibQalairra damage crash Ill has teen otxerred rallied
to this inch:lent
• Ratak Water has an aggressive eduaalfoo and errroroement program to
primary' Die dlcaharrge of grease, debris, stink rags, diapers end other
Improper materiels In bee moor tsytstam and to tatta °ar amentaathin
whore approprlata. fr theca dims make It Into the sewer system. May may
amuse a WO vrh1W1i Dan hew an adverse Miami oa wabr quality lard
endanger thine who name lab ambient with' the Warded areas_
• Water, human waste, and toilet lissom are the only Items permitted la be
dsaharged lists ilia saws( system. All abler Items vita OSUMI damage to the
sewer system and are not permitted.
• If you experience eaaerrrlva rawer walla or see sower spilling from
manholes or plpee. please *all W1t-BBB- 24S to report hnmeWatoly.
• For more Information about haw you oan help pmvant sanitary sewer
splits, please visit relelg ino.govlwainr_
R►3 flaws raicasa Is req reed by. fiCa5 Antic 21 Charms *43 219 1 C
NOM
13

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 11] miles of gravity
sewer mains by flushing with hydraulic jetting, conducting CCTV assessments, and performing repair operations,
easement maintenance, and inspections. The fiscal year-to-date cost of these operations amounts to
3,581,811.42 [2], approximately 28% of the Division's annual operating budget. The 21,130 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $21,385.76 to mitigate.
The City's cost of sewer treatment per gallon is $.0015 13]. At this rate, it would have cost the City $31.70 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.
(11428.40 miles represents 17% of the sanitary sewer collection system
12] Associated operational cast 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
Repa r 8,060.00 1.52 $ 2,509,683.49
Total - 2,261,984.91 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.
14

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 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 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-0279 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 [phone].
1 ,
'ncerely,
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
15

i

ROY COOPER
Governor
JOHN NICHOLSON
Interim Secrenuy
S. DANIEL SMITH
LVrecfor
Certified Mail # 7020 3160 0000 2219 5017
Return Receipt Requested
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental' Quollty
June 14, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0279
Sanitary Sewer Overflows - May 2021
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 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
202101344 5/20/2021 112 5536 Neuse View Drive Pump station 1,400 Notice of Violation
equipment failure
202101350 5/24/2021 107 3800 Hillsborough Roots 1,500 Notice of Violation
Street
202101351 5/24/2021 198 5000 Windy Hills Drive Grease
14,000 14,000 Notice of Violation —
Notice of Intent
Not [It Caro!ina Oeparlmcm of Cmlronmemal ' .L J Ly I OtNsion of staler Rrsour; rs
Raleigh RecilnwlOfnee 1 100 tlarr,It Orxc l Ralefoh North Carolina '4,0)
91 )3 )IA200

Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202101366 5/29/2021 143 1837 Snow Wind Drive Pipe Failure (Break), 4,230 4,230 Notice of Violation -
Roots 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 Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at mitch.hayes©ncdenr.gov.
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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