WQCS00002_NOV-2021-DV-0318_20210810

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Raleigh Water
August 10th1 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-0318
Sanitary Sewer Overflows —June 2021
Permit No. WQCS00002
Dear Mr. Vinson:
IVA
Please allow this letter to serve as a response to the Notice of Violation &Intent to Issue Civil Penalty
document (NOV-2021-DV-0318) received on July 27th, 2021. This document contains the narratives regarding a
pending violation actions of (2) Sanitary Sewer Overflow (SSO) events, which occurred during the month of July
2021 within the City of Raleigh Collections System [1]. 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-1\101) 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-N01 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 # 202101463 — 06/28/2021— 0 Harris Rd, Raleigh, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow
within an 8" Vitrified Clay pipe gravity sewer main section. This build-up led to a sewer spill of approximately
7,880 gallons of untreated wastewater, reaching an unnamed tributary within the Richland Wake Forest Basin.
(See exhibit 1— SSO Area of Operation, p.4)
On 06/28/2021I at approximately 5:15 PM, Sewer Maintenance staff was noed of a sewer spill
emanating from a manhole located near 0 Harris Rd, Wake Forest. 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 11:47 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 the downstream conveyance. The
areas around the manhole were cleared of debris and washed with potable water. The area around the manhole
was cleared of debris, treated with an application of lime, and restored with grass seed and straw.
A follow-up CCTV assessment was conducted on 07/14/2021 to identify the root cause of grease
accumulation. The CCTV assessment is ongoing pending further sewer main cleaning.
The cost associated with the mitigation of this event amounted to $ $5,536.68. The approximate cost to
the Utility to have treated 7,880 gallons of wastewater would have been approximately $11.82. The City saved
no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of sewage had no spill
occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the
spill.
This section of the collection system is located in a residential area. It provides sewer collection services
to over 430 properties upstream of the spill event (see Exhibit 2- Zone of Influence, p4). Before the event on
June 28th, this portion of the collection system experience two separate SSO events: 2/13/2010 Harris Rd
Easement SSO, Asset I.D. SGMN116109 and 7/11/2005 201 Harris Rd. SSO, Asset I.D. SGMN108589.
A press release noiiiicacion associated with this eveni was requested on 6/29/2021 (see exhibit 3 -Press
release, p.5). 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.
2

Before this event, maintenance records show that sections within the zone of influence [21 of this
collection system were assessed as follows:
Flushing
activities
3/27/2017
4/10/2017
7/19/2017
7/25/2017
8/15/2018
8/16/2018
8/17/2018
8/20/2018
8/22/2018
8/24/2018
8/28/2018
8/30/2018
9/12/2018
5/15/2019
9/23/2019
1/6/2021
CCN activities
3/21/2017 12/1/2017
3/28/2017 1/16/2018
3/29/2017 1/19/2018
4/4/2017 1/24/2018
4/13/2017 7/19/2019
4/19/2017 7/26/2019
4/25/2017 4/13/2021
5/10/2017 4/14/2021
5/11/2017 4/28/2021
5/23/2017 7/1/2021
7/10/2017
Repair
2/9/2021
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.
2. Zone of influence — residential or commercial area upstream of the affected asset that may have influenced the sewer event. This area is selected based on continuous
sanitary sewer collection connection towards the affecting asset. Selection of this area is critical for sewer events involving grease accumulation that may result in a
subsequent enforcement action.
3

Exhibit 1- SW Area of Operation
Exhibit 2—Zone of Influence
II

Exhibit 3 - Press Release
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep Grease Out of the Shared Sanitary Sewer
System
On Monday. June 28, 2021, at approximately 5:13 PA9, Raleigh Water - £ewer
hlairtenanoe Division staff responded to a sanitary sewer spill bcated at 0 Hams
Road, Wake Forest, NC. 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 Ouslity, Division of Water Resources was notified of the spill.
Raleigh Water - Sewer Maintenance Division staff, stopped the spill at
approximateh/ 11:47 P141 on the same day. It is estimated that the spill discharged
approximatety 7,880 gallons of untreated wastewater, reaching surface waters of
Richland Creek within Richland Basin Restoration associated with this event was
completed on Tuesday. June 29. There has not been any vegetative damage or fish n'i
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 vrhich 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.gov/water.
This news release is required by NCGS Article 21. Chapter 143 215 1 C
E�
5

Incident Number # 202101469 — 06/29/2021— 6601 Times Dr, Raleigh, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow
within an 8" gravity sewer main section. This build-up led to a sewer spill of approximately 2,800 gallons of
untreated wastewater, reaching an unnamed tributary within the Perry Basin (See exhibit 1— SSO Area of
Operation, p8)
On 06/29/2021I at approximatelyPM, Sewer Maintenance staff was noed of a sewer spill
emanating from a manhole near 6601 Times 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 5:44 PM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage
within the affecting asset, thus .restoring sewer flow,
Containment and collection of this spill event consisted of employing two temporary spill containment
sites downstream of the affected area. This approach was intended to contain wastewater flow and minimize
the environmental impact on the surrounding land. Responding crews employed pumps at the temporary
containment sites to recover flushed wastewater and any evidence of sewer completing the operation by re-
introducing the wastewater to the collection system. This spill was contained without a significant
environmental impact on the adjacent area and its natural resources. Visual inspection of the affected area and
downstream waters confirmed that no fish kill or unnecessary vegetative damage occurred.
During the restoration phase of the operation, crews utilized ample potable water to flush the affected
area and remove sewer traces from the area surrounding the manhole and the downstream conveyance. The
areas around the manhole were cleared of debris and washed with potable water. The area around the manhole
was cleared of debris, treated with an application of lime, and restored with grass seed and straw.
A follow-up CCTV assessment was conducted immediately following the sewer event of 06/29 to identify
the root cause of grease accumulation. The CCTV assessment is ongoing, pending further sewer main cleaning.
The cost associated with the mitigation of this event amounted to $10,074.11. The approximate cost to
the Utty to have treated 2,800 gallons of wastewater would have been approximately $4.20. 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 to approximately 228 properties
upstream of the spill event. Two hundred two of these properties are serviced by a private sewer system in
which Raleigh Water has no jurisdiction of maintenance or treatment of grease accumulation in their private
sewer collection system (see Exhibit 3- Zone of Influence, p9). Before the event on June 29th, this portion of the
collection system experienced three separate SSO evenis: 12/11/06 (6531 Meridien Dr); 2/9/05 (easement off
5541 Meridien Dr.); and 1/8/2003 (easement behind 6541 Meridien Dr). This site has been identified as an area
for repeated maintenance.
A press release notification associated with this event was requested on 6/29/2021 (see exhibit 2, 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.
0

Before this event, maintenance records show that sections within the zone of influence "I of this
collection system were assessed as follows:
Flushing
activities
3/25/2011
12/14/2012
3/15/2013
6/14/2013
9/13/2013
12/6/2013
3/14/2014
5/28/2014
8/14/2014
11/30/2014
1/15/2015
4/10/2015
7/2/2015
10/28/2017
11/2/2017
11/5/2017
4/30/2019
5/1/2019
5/2/2019
6/5/2020
6/8/2020
6/10/2020
8/17/2020
6/16/2021
6/23/2021
7/6/2021
7/13/2021
7/26/2021
CCN activities
12/1/2017
1/16/2018
1/19/2018
1/24/2018
7/19/2019
7/26/2019
4/13/2021
4/14/2021
4/28/2021
7/1/2021
7/2/2021
7/7/2021
7/9/2021
7/13/2021
7/23/2021
Easement Clearing
6/21/2021
Inspections
12/13/2017
12/14/2017
4/23/2018
12/21/2018
2/25/2019
7/29/2019
7/30/2019
10/17/2019
3/31(2020
10/1/2020
2021
6/21/2021
7/29/2021
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
1 "- r 0*
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M

Exhibit 2 — Press Release
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep Grease Out of the Shared Sanitary
Sewer System
On Tuesday, June 29, 2021, at approximately 3:46 PF,1 Raleigh Water .Sewer
6laintenance Division staff responded to a sanitary sewer spill located at 6601 Times
Drive, Raleigh, NC. The cause of the spill was related to grease found in the sev;er
gravity main. The responding staff took all reasonable steps to stop and mitigate the
mpact 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 staff, slopped the spill at
approximately 5:45 PfA on the same day. If is estimated that the spill discharged
approximately 2800 gallons of untreated wastewater, reaching surface waters v;ithin
Perry Basin Restoration associated with this event is ongoing There has not been any
vegetalive 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, raps, 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.gov±water.
This nevas release is required by NCGS Article 21, Chapter 143 215AC
Exhibit 3 -Zone of Influence
0

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
315811811842 [2], approximately 28% of the Division's annual operating budget. The 10,680 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $15,610.79 to mitigate.
The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $16.02 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
428.40 MILES
Total cost of Business to Date
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.
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
Wei

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,
A 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 [phone].
incerely,
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
11

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