WQCS00002_NOV-2021-DV-0454 RSP_20211116

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Raleigh Water
November 15th, 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-0454
Sanitary Sewer Overflows — August 2021
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept of Environmental Quality
NOV 16 LuL
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-0454) received on November 1st, 2021. This document contains the narrative
regarding pending violation actions of (2) Sanitary Sewer Overflow (SSO) events, which occurred during the
month of September 2021 within the City of Raleigh Collections System [1]. This document also provides exhibits
as proof of our efforts to mitigate each 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 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 # 202101925 — 09/16/2021 — 1510 Graduate Ln., Raleigh, NC
This spill was neither willful nor intentional; it resulted from foreign debris (flushed wipes) 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 2,550 gallons, reaching an
unnamed tributary in Bushy Basin.
On 9/16/21, at approximately 9:45 AM, 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 11:10 AM 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.
During the restoration phase of the operation, crews utilized approximately 115,500 gallons of potable
water to assist in washing the creek and remove all 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.
The cost associated with the mitigation of this event amounted to $41,873.28 (this amount includes the
cost to repair the offset gravity main). The approximate cost to the Utility to have treated 2,550 gallons of
wastewater would have been approximately $3.82. 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 conducted on 09/29/2021 determined that the
cause of the debris accumulation was the result of an offset joint within the gravity main. A follow up repair
operation was scheduled and completed on 10/04/2021 (See Exhibit 1— Repair).
Exhibit 1— Repair
2

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 1- Press Release). Since the last sewer event, there have
been no additional issues associated with this section of the collection system.
Exhibit 2- Press Release
•
Raleigh
NEWS RELEASE
QOIAIAUNC:ATIONS EEPARTMENT
September 17. 2Y21
Far more Infort nn:
Ti Lynch Assistant Oreclef, Raetgh Wader, a 10. E.-3245
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep All Wipes Out of the Shared Sanitary
Sewer System
On Thursday September 16 2021, at assrDdmatery 0:45 AM, Sateen Water •
Sewer ►tarlenanee Envision staff responded to a sentare sewer spit ccaled al 1610
Oruduala Lane, Raleigh. NO. The ca.rse cf the SD II Was Waled to Dished wipes
!prod In the sewer grave./ main The respentIN stall look ail reasonable steps Io s10D
and rrillgitc the Impart & Mosprlas soon as they err ved The Uo1rl Carc4ra
Department al Endmnmenlal Oual ty, Ordain al Wale- Ra».rees was nettled el the
spit
Raleigh Water • Serer Maintenance D v sten slari stopped tic sp I r al
oppreslmatatr 11:10 AM ontne same day h s estimated that trio spit discharged
approdmatatt 2,SS0 galens al amraoted wastewater. reach,na surface waters of Busty
Sash Restoration assccaled with Ih6 sewar sail were coma clod an Ilia sane day
• Ralalotl Water has an aggressive education and ertdomament program to
prevent the dlsoharpe of grease, debris, wipes. rags, diapers and other
Improper materials :n the serer system and In take enitsroant»nt colon
where appsoprMte. ti theca Rama make 11 into the sewer truism. they may
pause a split Wtloh pen have an adverse Impart on water quality and
endanger those who oonte Into oontaot with eta oriented auras.
Water. human waste. and ballot tissue aro the only (tams permitted to bs
discharged brio the Bawer system. All othar Rams eSi cause damage to the
sewer system and aro not permitted.
B you experience exoessIne sower wails or sea sewer spilling from
manholes or pipes. picas* aa71 91169B11$246 to report enmedlataly.
• For more Inlornrotion about now you pan help prevent sanitary sewer
sprits. pleas* visit: ,nIOtenno.paWe ater.
Ths nays release ks regj rod N Allele 21 Choate 43 21 S +.
a�x
3

Incident Number # 202101973 — 09/23/2021— 917 Willow Run South Dr., Raleigh
This spill was neither willful nor intentional; it was the result of root intrusion, which blocked a portion of
an 8-in" vitrify clay pipe gravity sewer main. The root intrusion led to a sewer spill of approximately 1,000
gallons of untreated wastewater reaching surface waters of the state.
On 9/23/2021, at approximately 12:54 PM, Sewer Maintenance staff was notified of a sewer overflow
located at 917 Willow Run South Dr., Raleigh. Upon arrival, it was discovered that untreated sewer was
emanating from an adjacent manhole (SMH116241, see exhibit 1- 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 1:25 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 SSO location to stop the flow of sewer into the stream 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 $1,687.62. The approximate cost to
the Utility to have treated 1,000 gallons of wastewater would have been approximately $1.50. 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 Falls of the Neuse Rd. This system
provides sewer collection to several residential properties. A press release notification associated with this event
was published in the Raleigh News & Observer on 9/24/2021 (Exhibit 2 — Press release)
Maintenance records show that sections of this collection system were assessed as follows:
Flushing activities CCTV Activities Inspection activities
3/26/2015 9/28/2021 12/7/2017 8/7/2019
4/19/2012 12/21/2017 1/14/2020
3/10/2014 1/16/2018 1/16/2020
3/14/2014 3/22/2018 4/21/2020
1/22/2019 4/30/2018 8/17/2020
10/1/2019 5/2/2018 10/1/2020
10/2/2019 9/27/2018 12/15/2020
10/9/2018 2/25/2021
10/10/2018 4/7/2021
10/25/2018 4/26/2021
3/11/2019 7/19/2021
4/1/2019 8/26/2021
8/30/2021
4

The latest maintenance/inspection assessment for this site was conducted on 9/28/2021 in which several
segments of main were CCTV to identify the event's root cause (see exhibit 3-SSO Investigation Report). 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
Affected Asset
SMH116241
! Containment and Collection Site
5

Exhibit 2 — Press Release
•%;' Raleigh
NFWrkiS RELEASE
COMMUNICATIONS DEPARTMENT
September 24, 2021
For more information:
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, September 23, 2021, at approximately 12 54 PM. Raleigh Water -
Sewer Maintenance Division staff responded to a sanitary sewer spill located at 917
Willow Run South Drive, Raleigh, NC. The cause of the spill was related to root
intrusion 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 215 PM 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 Mine Creek Basin
Restoration for this event was completed on the same day. 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
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
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 3,550 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $ 43,560.9 to mitigate. The City's cost of
sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $5.33 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.
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
7

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-0454 issued for the month of
September 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].
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

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 2219 3228
Return Receipt Requested
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
October 22, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0454
Sanitary Sewer Overflows - September 2021
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
I1.3y
1-ENCtffinif -f-Liii)
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
202101925 9/16/2021 85 1510 Graduate Ln, Debris in line 2,550 2,550 Notice of Violation -
Raleigh Notice of Intent
202101973 9/23/2021 31 917 Willow Run South Roots
Drive
1,000 1,000 Notice of Violation
North Carolina Deportment of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800Barrett Drive I Raleigh North Carolina27609
9I9.79U200

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 [e-mail].
f-r2.
Cc: Raleigh Regional Office - WQS File
Laserfiche
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
..1.1W)k
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh. North Carolina 27609
919.79L4200