WQCS00002_NOV-2021-DV-0506 RSP_20220208

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Raleigh Water
February 7th , 2022
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-0506
Sanitary Sewer Overflows — November 2021
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept ofEnvirronmental Quality
'1.022s
cs
FEB 083
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-0506) received on January 24th, 2022. This document contains the narrative regarding
a pending violation actions of (3) Sanitary Sewer Overflow (SSO) events, which occurred during the month of
December 2021 within the City of Raleigh Collections System (1(. This document also provides exhibits as proof of
our efforts to mitigate each of the sewer events. 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 # 202102157 —11/12/2021— 7104 Bellweather Ct. S., Raleigh, NC
This spill was neither willful nor intentional; it resulted from an undermined ground support / stream
bank erosion, that caused a section of 8-inch vitrified clay sewer gravity main to collapse (see exhibit 1— Failed
Collapsed Pipe). Based on an open channel estimation, hydraulic modeling, and the amount of flow recovered
from a downstream containment and collection site, it was determined that the approximate volume of the spill
was 5,220 gallons. The wastewater reached approximately 2,724.90 ft. downstream of the affected asset
through an unnamed tributary of Mine Creek.
On 11/12/2021 at approximately 11:09 AM, Utility Operators identified a collapsed sewer gravity main near the
stream bank of an unnamed tributary, approximately 50 ft upstream of sewer manhole SMH139062 (see exhibit
2 — Area of Operation). The responding staff took all reasonable steps to stop and mitigate the impact of the
damage as soon as they arrived. Utility Responders placed a sewer plug in the main establishing a sewer by-pass
restoring the sewer flow at approximately 03:20 PM on the same day leading into the subsequent repair.
To correct the affected asset, Raleigh Water Repair crews restored the stream bank and replaced the damaged
section of vitrified clay pipe with 40 ft of ductile iron pipe (see exhibit 3 — Repaired Sewer Main).
Containment and collection of this spill event consisted of employing two temporary spill containment sites, one
located near the collapsed pipe and the final containment site at approximately 2,724.90 ft. downstream of the
affected area (see exhibit 2 — Area of Operation). This approach was intended to contain wastewater flow and
minimize the environmental impact onto the surrounding surface waters of the state. Responding crews
employed a pump at the temporary containment site to recover wastewater and any evidence of wastewater
completing the operation by re -introducing the wastewater into 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 affected sewer main 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.
The cost associated with the mitigation of this event amounted to $15,622.28. The approximate cost to the
Utility to have treated 5,220 gallons of wastewater would have been approximately $7.83. 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 portion of the sanitary sewer collection system serves a residential area west of Falls of the Neuse Rd.
Portions of this sewer collection system have been assessed as follows:
Flushing activities
1. 3/17/2014 - 7200 Bellweather Ct
2. 3/26/2015 - 7100 Bellweather Ct
3. 12/1/2011- 6805 Justice Dr
4. 4/19/2012 - 7100 Leveret circle
5. 3/14/2014 - 7100 Leveret Cir
CCTV Activities Repair Activities Inspections
9/28/2021 11/17/2021 1/16/2018 8/17/2020
11/28/2018 4/30/2018 10/1/2020
11/15/2021 10/10/2018 4/26/2021
3/11/2019 4/7/2021
4/1/2019 8/30/2021
4/1/2019 11/15/2021
8/7/2019 11/15/2021
1/16/2020 12/15/2020
1/14/2020 12/15/2020
4/21/2020 1/16/2020
2

A press release notification associated with this event was published in the Raleigh News & Observer on
11/13/2021 (Exhibit 4 — Press release). Since the event, no other issues have occurred with this portion of the
collection system.
Exhibit 1 - Partial Collapse
3

Exhibit 2 .• Area of Operation
4

Exhibit 4— Press Release
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
November 13, 2021
For more information
TJ Lynch, Assistant Director, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Friday, November 12th. at approximately 11:09 AM. Raleigh Water staff were
notified of a sanitary sewer overflow in the vicinity of 7104 Beltweather Ct S.. Raleigh.
Upon arrival. Utility Responders identified an active sewer overflow resulting from a
collapsed creek bank which undermined a section of an 8-inch vitrified Gay sewer
gravity main. The responding staff took all reasonable steps to stop and mitigate the
overflow's impact as soon as they arrived. The North Carolina Department of
Environmental Quality. Division of Water Resources has been notified of the overflow
Raleigh Water staff established a sewer bypass. stopping the sewer from spilling
into an adjacent creek and reestablishing sewer flow into the collection system. Utility
Responders contained the overflow at approximately 3:20 PM on the same day. It Is
estimated that the overflow discharged a volume of approximately 5,020 gallons of
untreated wastewater, reaching an unnamed tributary In Mine Creek Raleigh.
Restoration for this event is ongoing.
• 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.gov/water.
This news release is required by NCGS Artide 21. Chapter 143.215.1C.
5

Incident Number # 202102158 — 11/12/2021 — 1025 Schaub Dr., Raleigh NC
This spill was neither willful nor intentional; it resulted from road construction activity in which large
rocks (see exhibit 1- Construction Debris Found in Manhole) caused a blockage in a portion of a 12- inch cast
iron gravity sewer main. The blockage led to a sewer spill of approximately 2,880 gallons, reaching surfaces
water of Bushy Creek within Bushy Basin.
On 11/12/2021, at approximately 3:09 PM, Raleigh Water staff were notified of 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 5:30 PM on the same day. Utility Responder utilized hydraulic jetting and manual debris removal
tools to rid 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 several thousand 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 $13,551.60. The approximate cost to
the Utility to have treated 2,880 gallons of wastewater would have been approximately $4.32. 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 investigation determined that a 6 ft. diameter concrete manhole -top had been removed
during the course of road construction pushing vast amount of sediment, rocks and construction debris into the
sewer gravity main below (see exhibit 2 — Construction Debris). It was the debris accumulation that caused
wastewater flow to be disrupted.
This location remains an active construction site with restricted access to complete further CCTV
assessment. Visual assortment indicates that the sewer gravity mains continue to flow as designed.
Furthermore, the assets associated with this portion of the collection system have been added to the Hot Spot
Management Program and has been identified for recurrent assessment every 30 days. No further issues have
occurred since this SSO event.
6

Exhibit 1— Construction Debris Found in Manhole
Exhibit 2 — Construction Debris
7

Incident Number # 202102126— 11/03/2021 — 624 Edmund St., Raleigh, NC
This spill was neither willful nor intentional; it resulted a damaged section of 6-inch vitrified clay sewer
gravity main (see exhibit 1— Damaged Pipe). This damaged pipe was identified through a CCTV assessment
which confirmed that untreated wastewater was entering into a stomwater pipe. Based on flow volume,
duration and distance traveled along a stormwater conveyance, it was determined that the approximate volume
of the spill reaching surface waters of Cemetery Branch was 5 gallons.
On 11/03/2021 at approximately 1:48 PM, Utility Operators were conducting a sewer point repair to a damaged
6-inch vitrified clay sewer gravity main. During the course of the repair operation portions of the storm water
channel were being cleaned with potable water to remove any traces of untreated wastewater. As a result of
the cleaning and restoration effort untreated wastewater reached Cemetery Branch. This incident occurred as
there was no containment site established prior to commencing the cleaning of the stormwater pipe
downstream. Upon identification of the issue, crews immediately established a containment point preventing
further wastewater to reach to creek. Remaining untreated wastewater was removed from the stormwater pipe
utilizing a vacuum truck.
During the restoration phase of the operation, crews utilized ample potable water to flush and remove
wastewater debris from the affected area, including the affected stormwater pipe 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 was an isolated event resulting from an operational oversight. As a result of this event all responding crews
were counseled and retrain in sanitary sewer overflow mitigation (SSO) procedures. Crews were reminded of
the SSO mitigation protocols: Stop, Contain, Collect and Restore. These protocols ensure that every spill is to be
mitigated in a methodical process ensuring an adequate containment and collection site has been established
prior to commence flushing the affected area downstream. This effort assists in minimizing wastewater flow to
surrounding surface waters of the state.
The cost associated with the mitigation of this event amounted to $2,038.13. The approximate cost to the
Utility to have treated 5 gallons of wastewater would have been a fraction of a cent (approximately $.0075) 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 This event was mitigated with no further adverse action.
8

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 2021 (Fiscal Year 2022), the Utility has maintained approximately 240.08 [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
$ 2,185,622.02 [2], approximately 16% of the Division's annual operating budget. The 8,105 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $31,212.01. to mitigate. The City's cost of
sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $12.15 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
1.49 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] 240.08 miles represents 9% of the sanitary sewer collection system
[2] Associated operational cost year to date for FY2022
OPERATION LINEAR FEET Linear Miles COST
CCTV 92,615.01 55.42 $ 376,624.20
Flushing 70,286.27 183.77 $ 278,301.49
Repair 4,680.00 0.89 $ 1,530,696.33
Total - 1,267,581 Ft Total cost of Business to Date
240.08 MILES $ 2,185,622.02
[3] $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[4] FY21 total miles clean were 428.40 MILES at a cost of 3,581,811.42
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
9

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 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-0506 issued for the month of
November 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 Carlos M. Perez, ORC
sistance Superintendent 919-996-5929.
C
cerely,
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]
10

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 4115 6631
Return Receipt Requested
Robert Massengill, Director of Public Utilities
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
January 18, 2022
y
JAN 2 4 2022
NC Dept of Environmental Quality
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0506
Sanitary Sewer Overflows - November 2021
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Massengill:
FEB 0 8 2023
Raleigh Regional Office
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
202102157 11/12/2021 251 7104 Bellweather Ct. S Pipe Failure (Break) 5,157 5,220 Notice of Violation —
Notice of Intent
202102158 11/12/2021 141 1025 Schaub Dr. Debris in line 2,880 2,880 Notice of Violation —
Notice of Intent '
202102126 11/03/2021 023 624 Edmund St. Pipe Failure 5 5 Notice of Deficiency
North Carolina Deportment of Environmental Quality 1 DIvIslon of Water Resources
RalelghRealonalOf ice 13800 Barrett Dave 1 Ralelph.North Carolina 27609
919.79U200

-(fittu;,)
wtt() .taaok,,,2P11184114.4.

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].
Sincerely,
n9cuSIened by:
L'-
B2916E6AB32144F...for Scoiional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
Laserfiche
North Carolina Department of Environmental Quality 1 Division of Water Resources
Raleigh Regional OlDce 1 3600 Barrett Drlre I Rstelglt, North Carofna 27609
919.791A20o

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