WQCS00002_NOV-2021-DV-0426 RSP_20211101

140
00
Raleigh Water
November 15t, 2021
Mr. Scott Vinson
Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Response to NOV-2021-DV-0426
Sanitary Sewer Overflows —August 2021
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept ofEnvironmental Quality
NOV 01 201
Raleigh Regional °face
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2021-DV-0426) received on October 18th, 2021. This document contains the narrative regarding
a pending violation actions of (1) Sanitary Sewer Overflow (SSO) event, which occurred during the month of
August 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 event occurred while the City operated its collection
system, according to WQCS00002, dated June 6th, 2017. The permit includes the language outlined in footnote
1 and applies to the SSOs upon which NOVs with the notice of intent (NOV-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 event, listed with the intended NOV-NOI action. Please
find below, the additional information requested for the SSO event.
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 a 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 # 202101684 — 08/04/2021— 5101 Glenwood Ave., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a partially collapsed sewer manhole wall.
Although no active SSO was witnessed during the discovery of the partial manhole collapse, the presence of
paper debris was indicative of a previous sewer spill. Based on hydraulic modeling and the amount of flow
recovered from Hare Snipe Creek, it was determined that the approximate volume of the spill was 6,300 gallons.
On 08/04/2021, at approximately 11:00 AM, a Utility Inspector identified sewer debris at the base of
sewer manhole SMH118791 (see exhibit 1- Partial collapse). A close inspection identified that an approximately
two -foot section of the wall had collapsed, leading to a subsequent sewer overflow through the opening and
onto the creek below. The responding staff took all reasonable steps to stop and mitigate the impact of the
damage as soon as they arrived, restoring the manhole at approximately 2:30 PM on the same day. Repair crews
were able to patch the collapsed portion of the wall with hydraulic cement, restoring the sewer flow within the
manhole walls (see exhibit 2 — Repaired manhole).
Containment and collection of this spill event consisted of employing a temporary spill containment
within the affected area (see Exhibit 3 — Restoration and Containment). This approach was intended to contain
wastewater flow and minimize the environmental impact on the surrounding surface waters of the state.
Responding crews employed a pump at the temporary containment site to recover wastewater and any
evidence of sewer completing the operation by re -introducing the wastewater to the collection system. During
the restoration phase of the operation, crews utilized ample potable water to flush and remove wastewater
debris from the affected area, including the manhole and the creek. 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.
This manhole damage may have been attributed to a previous wet weather event. The accumulated
rainfall reached 2.52 inches of precipitation recorded for July 8th 2021. This sewer asset has no history of
weather -related issues. See Exhibit 4 — Weather Report.
The cost associated with the mitigation of this event amounted to $1,612.61. The approximate cost to
the Utility to have treated 6,300 gallons of wastewater would have been approximately $9.45. 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 30-inch reinforced concrete pipe serves as a major interceptor pipe for the Crabtree Creek corridor.
It has been identified as a high -priority asset, which requires to be inspected regularly as per the Sanitary Sewer
Collections system permit. Previous inspections did not show any structural issues or concerns. Before this
event, maintenance records show that sections of this collection system were inspected as follows:
3/12/2019 — No infrastructure deficiencies noted
9/24/2019 — No infrastructure deficiencies noted
2/27/2020 — No infrastructure deficiencies noted
8/11/2020 — No infrastructure deficiencies noted
8/4/2020 — No infrastructure deficiencies noted
9/8/2020 — No infrastructure deficiencies noted
1/7/2021— No infrastructure deficiencies noted
NOTE: This section of main is scheduled to be abandoned as part of the Crabtree PH3 CIP project currently in
design.
2

A press release notification associated with this event was published in the Raleigh News & Observer on
08/05/2021 (Exhibit 5 — Press release).
Exhibit 1— Partial Collapse
3

Exhibit 2 — Repaired manhole
Exhibit 3 — Restoration and Containment
4

Exhibit 4- Weather Report
Almanac for Raleigh Area, NC (ThreadEs)
July 8, 2021
Daily Data
Observed
Normal
Record Highest Record Lowest
Max Temperature
79
91
105 in 2012
72 in 1950
Min Temperature
71
70
78 in 1986
53 in 1979
Avg Temperature
75.0
80.5
90.5 in 2012
65.5 in 1892
Temptation
ES
NE
2.52 m 2021
0.00 in 201:•
Snowfall
0.0
0.0
0.0 in 2021
0.0 in 2021
Snow Depth
0
-
0 in 2021
0 in 2021
HDD (base 65)
0
0
0 in 2021
0 in 2021
CDD (base 65)
10
16
26 in 2012
1 in 1892
Month -to -Date Summar•
Observed
Normal
Record Highest
Record Lowest
Avg Max Temperature
85.6
90.7
100.9 in 2012
75.6 in 1892
Avg Min Temperature
66.4
69.7
73.8 in 1902
57.1 in 1979
Avg Temperature
76.0
80.2
87.0 in 2012
68.6 in 1892
Total Precipitation
3.78
1.11
4.88 in 1931
0.00 in 1988
Total Snowfall
0.0
0.0
Tin 1954
0.0 in 2021
Max Snow Depth
0
-
0 in 2021
0 in 2021
Total HDD (base 65)
0
0
6 in 1892
0 in 2021
Total CDD (base 65)
90
122
178 in 2012
37 in 1892
Year -to -Date Summary
Observed
Normal
Record Highest
Record Lowest
J
Avg Max Temperature
68.7
69.5
72.5 in 2012
63.8 in 1895
Avg Min Temperature
46.9
47.5
51.1 in 1890
41.7 in 1970
Avg Temperature
57.8
58.5
61.4 in 2017
53.7 in 1970
Total Precipitation
27.96
22.22
34.67 in 1936
12.90 in 1986
Total Snowfall (since July 1)
0.0
0.0
Tin 1954
0.0 in 2021
Max Snow Depth (since July 1)
0
-
0 in 2021
0 in 2021
Total HDD (since July 1)
0
0
6 in 1892
0 in 2021
Total CDD (since Jan 1)
648
710
930 in 2010
311 in 1972
Period of Record:
• Max Temperature : 1887-01-01 to 2021-10-31
• Min Temperature : 1887-01-01 to 2021-10-31
• Precipitation : 1887-01-01 to 2021-10-31
• Snowfall : 1887-01-01 to 2021-10-31
• Snow Depth : 1944-05-18 to 2021-10-31
5

fxhib,t 5 Press Release
•
0400#Ralei g h
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
August 5, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Wednesday, August 4, 2021, at approximately 11.00 AM, Raleigh Water -
Sewer Maintenance Division staff responded to a sanitary sewer spill located at 5101
Glenwood Avenue, Raleigh, NC The cause of the spill was the result of a damaged
connection pipe. The responding staff took all reasonable steps to stop and mitigate the
impact of the spill as soon as they arrived The North Carofna Department of
Environmental Quality, Division of Water Resources was notified of the spill.
Raleigh Water staff contained the spill at approximately 2 30 PM on the same
day. It is estimated that the spill discharged a volume of approximately 6,300 gallons of
untreated wastewater reaching Hare Snipe Creek. Restoration for this event Is ongoing.
No vegetative damage or fish kill 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
erfdanger 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
6

Summary
The Sewer Maintenance Division of Raleigh Water strives to develop initiatives that improve operational
reliability to meet customer expectations and meet or exceed the Water Quality Collection System permit
requirements. Our operations are focused on continual improvement, the prevention of pollution, and increased
environmental performance efficiency. This endeavor is 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 2,566 miles of sanitary sewer pipe and minimize the accidental release of untreated
wastewater.
Since July 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 6,300 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $1612.61 to mitigate.
The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $9.45 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 ' Y0
CCTV 387,943.05 73.47 $ 393,735.68 -0
f
Flushing 1,865,983.86 353.41 $ 678,392.25 �/^�
Repair 8,060.00 1.52 $ 2,509,683.49 �`'^
O
Total - 2,261,986.91 Ft Total cost of Business to Date O�/ *Ij�e
428.40 MILES 3,581,811.42 ��fldr� O, A Ufa'
[3] $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent. �4140
Pet, f��j
[4] .24% attributed to dry weather SSOs e4410 !✓
"Oc
Additionally, the City of Raleigh Assistant Public Utility Directors and Collections System staf
become involved in challenging the nonwoven fabrics industry standards to better inform consumers oese
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.
7

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-0426 issued for the month of
August, 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
leigh Water Director, at [phone].
Sincerely,.
Carlos M Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh, Public Utilities Department
P.O. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
[e-mail]
CC: Robert Massengill, Raleigh Water Director
T. J. Lynch, Assistant Raleigh Water Director Wastewater
Matthew P Vessie, Superintendent Sewer Maintenance
8

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 2219 3112
Return Receipt Requested
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
October 05, 2021
011', 1 i
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OCT 18 I
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SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0426
Sanitary Sewer Overflows - August 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
202101684 8/4/2021 220 5101 Glenwood Avenue Pipe Failure (Break) 6,300 6,300 Notice of Violation
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.
North Caroline Department of Environmental Quality I Division *Water Resources
Raleigh Regional °fnce 13800Barrett Drive I RakI9h.NorthCarolina 27609
919.79L4200

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 [e-mail].
Cc: Raleigh Regional Office - WQS File
Laserfiche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality 1 Division of Water Resources
Raleigh Regional Office 3800 Barrett Drive 1 Raleigh North Carolina 27609
919.791.4200