WQCS00002_NOV-2022-DV-0022 RSP_20220303

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Raleigh Water
March 3rd, 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
101.1
Re: Response to NOV-2021-DV-0022
Sanitary Sewer Overflows — December 2021
Permit No. WQCS00002
Dear Mr. Vinson:
f�nviront'I`e1tal Q°a1�ty
NC Dept oVAR ?i TM
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2021-DV-0022) received on February 2nd, 2022. This document contains the narrative
regarding pending violation actions of (5) 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, restore the possible
environmental impacts brought by the release of the SSO events, listed with the intended NOV-NOI action.
Please find below, the additional information requested for the 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 was 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 backup 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 S50 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 # 202102208 — 12/1/2021— 1401 Wendell Blvd., Raleigh, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow
within a section of 8" Polyvinyl Chloride pipe gravity sewer main. This build-up led to a sewer spill of
approximately 2,160 gallons of untreated wastewater of which 1,450 gallons reached an unnamed tributary
within Buffalo Lowe Basin. (See exhibit 1— Area of Operation)
Exhibit 1— Area of Operation
On 12/01/2021, at approximately 8:15 AM, Sewer Maintenance staff conducting high priorities
inspections identified a sanitary sewer overflow emanating from a manhole located near 1401 Wendell Blvd.,
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 9:45 AM on the same day. Crews
utilized hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring sewer
flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
downstream of the affected area near Buffalo Creek (see exhibit 2 — Containment and Collection Efforts). 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 site 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.
2

Exhibit z—Containment and Collection Efforts
During the restoration phase of the operation, crews utilized mechanical ground removal of sewer
contaminated soil from the affected area of the downstream conveyance. The areas around the manhole were
cleared of debris, washed with potable water, treated with an application of lime, and finally restored with grass
seed and straw. See Exhibit 3—Site Restoration.
Exhibit 3—Site Restoration
Afollow-up CCTV assessment was conducted on1 1toidentUytherootcauseoftheSSO.The
CCTV assessment is ongoing pending further sewer main cleaning.

The cost associated with the mitigation of this event amounted to $ 3,128.19. The approximate cost to
the Utility to have treated 2,160 gallons of wastewater would have been approximately $3.24. 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 downstream of a residential area. It provides sewer
collection services to approximately 262 properties upstream of the spill event (see Exhibit 4- Zone of Influence).
Within the last ten years, this portion of the collection system experienced a debris -related SSO event on
01/23/2019 (incident # 201900199). As a result of these incidents, several assets have been placed on a
recurrent maintenance service interval of 30 days.
Exhibit 4- Zone of Influence
A press release notification associated with this event was requested on 12/01/2021 (see exhibit 5 -Press
Release). 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.
4

Exhibit 5 -Press Release
'�►:` Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
[hemming 1, 2021
For mare information'
Tit Lynch, Assrslani Director. Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
Keep Grease Out of the Drain
On Wednesday. December 1, at approximately 8 15 AM Raleigh Water - Sewer
Maintenance Dmsion staff responded to a sanitary sewer spill located at 1401 Wendell
Blvd, Wendell, NC The cause of the spill was related to accumulated grease
disrupting the collection system. The responding staff took all reasonable steps to stop
and mitigate the Impact of the spit as soon as they arrived The North Carolina
Department of Environmental Chatty Division of Water Resources was notified of the
spl
Raleigh Water staff contained the spit at approximately 9 45 AM on the same
day It is estimated that the spit discharged a volume of approximately 2 160 gallons of
untreated wastewater of which 1.450 gallons reached Buffalo Creek in the Buffalo
Basin 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
endanger those who come into contact with the affected areas.
• Water, human waste, end 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 releighnc.govfwater.
This news release Is required by NCGS Article 21, Chapter 143 215 1C
tries
Before this event, maintenance records show that sections within the zone of influence of this collection
system were assessed within the last 10 years as follows:
Flushing Repair Inspections
activities CCTV activities
6/20/2018 5/2/2017 8/2/2018 1/14/2019 2/12/2018 12/11/2019
1/23/2019 1/9/2018 1/9/2019 3/21/2018 12/11/2019
12/16/2021 1/10/2018 1/8/2019 5/24/2018 12/11/2019
12/20/2021 1/19/2018 12/16/2021 1/23/2019 3/26/2020
1/3/2022 1/23/2018 4/4/2019 10/13/2020
2/2/2022 8/1/2018 6/12/2019 3/17/2021
6/12/2019 10/14/2021
6/18/2019
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.
5

Incident Number # 202102258— 12/12/2021 — 612 Carolina Ave., 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 2,775
gallons of untreated wastewater in which approximately 2,000 gallons reached surface waters of Simmons
Branch. (See exhibit 1 — Area of Operation)
Exhibit 1— Area of Operation
On 12/12/2021, at approximately 12:05 PM, Sewer Maintenance staff was notified of a sewer overflow
located at 612 Carolina Ave., Raleigh. Upon arrival, it was discovered that untreated sewer was emanating from
an adjacent manhole SMH113635 (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 1:56 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 a temporary spill containment site
downstream of the affected area near 1001 Ravenwood Dr. north 1-440 and downstream of a dry retaining pond
bed (see exhibit 2 — Containment and Collection Efforts). 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 site 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.
6

Exhibit 2 — Containment and Collection Efforts
During the restoration phase of the operation, crews utilized ample potable water to flush the affected
area of the downstream conveyance. The areas around the manhole were cleared of debris, washed with
potable water, treated with an application of lime, and finally restored with grass seed and straw.
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 $5,044.77. The approximate cost to
the Utility to have treated 2,775 gallons of wastewater would have been approximately $4.16. 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. A press release notification associated with this event was requested on 12/12/2021 (see exhibit 3 -Press
Release).
7

Exhibit 3 -Press Release
Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
December 13, 2021
For more information
Matthew P Vessre. Sewer Maintenance Manager, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Sunday, December 12, at approximately 12 05 PM, Raleigh Water - Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 612 Carolina
Avenue, Raleigh, NC The cause of the spill Is currently under investigation 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 Quaity Division
of Water Resources was notified of the spill
Raleigh Water staff contained the spill at approximately 1 56 PM on the same
day It is estimated that the spill discharged a volume of approximately 2 775 gallons of
untreated wastewaterof which, 2,000 gallons reached surface waters within Simmons
Branch 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
endanger those who come Into contact with the effected 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: rsleighnc.govhvater.
This news release is required by NCGS Article 21, Chapter 143 215 1C
In*
This section of the collection system provides sewer collection services to a residential and commercial
area south of Western Blvd. Within the last ten years, this portion of the collection system has only experienced
a root -related SSO. As a result of this SSO, several assets have been placed on a recurrent maintenance service
interval and identified for future chemical root control application.
The latest maintenance/inspection assessment for this site was conducted on 12/14/2021 in which a
pipe joint was found to be separated allowing root to infiltrate. Consequently, several follow-up repair work
orders have been established to correct the noted deficiencies. There have been no additional issues associated
with this section of the collection system since the last sewer event.
8

Before this event, maintenance records show that sections within the zone of influence (see exhibit 6 —
Zone of Influence) of this collection system were assessed within the last 10 years as follows:
Flushing activities
6/16/2010
6/29/2010
1/15/2011
3/8/2012
3/10/2013
4/8/2013
5/22/2013
5/23/2013
6/3/2013
6/28/2013
9/3/2014
9/10/2014
6/5/2015
5/12/2015
10/1/2019
1/14/2020
5/27/2021
3/8/2021
12/14/2021
Exhibit 6— Zone of Influence
CCTV Activities
6/17/2010
10/1/2019
2/17/2021
12/13/2021
12/13/2021
12/13/2021
12/13/2021
12/14/2021
Repair Activities
5/14/2019
5/16/2019
Easement Activities Inspection activities
10/31/2017 2/9/2018 8/12/2020
12/11/2017 3/21/2018 10/26/2020
4/3/2019 6/4/2018 2/8/2021
4/18/2019 11/21/2018 2/17/2021
2/17/2021 2/6/2019 4/20/2021
2/19/2019 4/21/2021
6/24/2019 5/12/2021
12/19/2019 6/28/2021
4/6/2020 10/11/2021
9

Incident Number # 202102314 —12/28/2021— 2110 Blackwolf Run Ln., Raleigh, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow
within a section of 8" Polyvinyl Chloride pipe gravity sewer main. This build-up led to a sewer spill of
approximately 1,500 gallons of untreated wastewater reaching an unnamed tributary within Neuse Basin. (See
Exhibit 1— Area of Operation)
Exhibit 1—Area of Operation
On 12/28/2021, at approximately 3:18 PM, Raleigh Water Staff was notified of a sanitary sewer overflow
emanating from a manhole located near 2110 Blackwolf Run Ln., 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 04:18 PM on the same day. Crews utilized hydraulic jetting to remove the
source of the blockage within the affecting asset, thus restoring sewer flow (see Exhibit 2 — Hydraulic jetting
cleaning).
Exhibit 2 — Hydraulic jetting cleaning
YrjAVi
a.1KX5rty-
10

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 wastewater flow and minimize the
environmental impact on the surrounding land. Responding crews employed pumps at the temporary
containment site 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 removed sewer contaminated soil from the
affected area. The areas around the manhole were cleared of debris, washed with potable water, treated with
an application of lime, and finally restored with grass seed and straw.
A follow-up CCTV assessment was conducted on 12/30/2021 to identify the root cause of the SSO. The
CCTV assessment recommended that further maintenance of an outside sewer drop is required (see Exhibit 3 —
CCTV Assessment /grease accumulation). The assessment also identified a moderate pipe sag (see Exhibit 4 —
Moderate sag) that possibly contributed to the accumulation of grease. A subsequent repair work order has
been established for correction. This asset will be placed on a recurrent service rotation.
Exhibit 3 — CCTV Assessment /grease accumulation
Exhibit 4— Moderate Sae
The cost associated with the mitigation of this event amounted to $2,620.21. The approximate cost to
the Utility to have treated 1,525 gallons of wastewater would have been approximately $2.28. 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 downstream of a residential area. It provides sewer
collection services to approximately 793 properties upstream of the spill event (see Exhibit 5- Zone of Influence).
Within the last ten years, this portion of the collection system has not experienced a grease -related SSO.
11

Exhibit 5- Zone of Influence
A press release notification associated with this event was requested on 12/28/2021 (see exhibit 6 -Press
Release). 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.
Exhibit 6 -Press Release
Raleigh
NEWS RELEASE
COL'.Al)r11CA1 ION; [)E.P:J1T MErit
Uer+.so-r 9 2311
F n mare elersakw
ra.gnew P. Vick. ^seer 1ncknvrra Man:., Anklet. Wan, 919 9W,l:n•.
Raleigh Water Responds to a Sanitary Sewer Spill
Keep Grease Out of the Drain
On Toacay December28 at approximately 319 Pal Raleigh Water Serer
Maintenance DFasion atatf responded to a sanitary farm spa located at 2110 stack
Wen Run Lane, Raleigh NC The cone at the spa was related to acanmWtN imam
d e Odeg the waMen system The rewaxing sou took at reasonable deeps to atop
arid reegate 91e impact tied s.0 as aeon as they arrived. TM North Camel
Department et Environmental fealty Dhlotor of Water Resources was neared tithe
api
Meth Warm see metered me ape a epeeoalmale y d 11PM on the won ea..
e N eftlmated that the ape discharged a Mane et appmmMm/ 1 500 gallon of
untreated waatawatm reading Neuse River hash Reebratan for des event was
completed by 530 PM er the same day No vegetative damage w fah all has been
observed related to Sm eveeL
Raleigh Water has an atoressire education and enforcement moment to
prevent the discharge of pease, delete, wipes, raps, diapers and other
improper materials to the Neer system and ter Mka enforcement action
where appropriate It these items make It Into the seer system, they may
cane a spat width can have en adveree Impact on enter quality and
endanger gorse who come Into contact web the affected areas.
Water, human waste, and toilet tissue are the only Menu permitted to be
diachmped Into the seer system. An other items wnl cause damage toga
mew system and are not permitted.
R you experience excessive seer smells or see sewer Wiling from
manholes or pipes, please can 9119963246 to report immediately.
Fe. more toeoemmbn about how you can help prevent sanitary weer
spies, please shell nNkhttageeMaler.
This news release N rebuked by NCOS Alone 21 Chapel 143 2151C
twi
1.2

Before this event, maintenance records show that sections within the zone of influence of this collection
system were assessed within the last 10 years as follows:
Flushing activities CCN activities Repair Inspections
8/22/2012 8/18/2017 8/22/2012 1/15/2020 2/8/2017
10/8/2012 8/15/2019 3/2/2018 1/24/2020
10/9/2012 8/21/2019 9/11/2018 1/27/2020
10/10/2012 8/27/2019 11/8/2019 2/4/2020
10/15/2012 8/29/2019 11/19/2019 2/13/2020
10/16/2012 9/4/2019 11/20/2019 2/14/2020
10/18/2012 9/5/2019 11/27/2019 2/18/2020
12/26/2012 9/9/2019 12/4/2019 2/19/2020
1/7/2013 9/11/2019 12/19/2019 3/4/2020
9/5/2013 9/16/2019 1/6/2020 8/6/2020
9/17/2013 9/19/2019 1/7/2020 8/12/2020
9/18/2013 9/24/2019 1/8/2020 8/13/2020
5/2/2014 11/26/2019 1/9/2020 8/18/2020
5/3/2014 12/16/2019
5/4/2014 3/4/2020
5/12/2014 3/4/2020
5/13/2014 11/19/2020
5/13/2014 12/8/2020
6/9/2014
Easement Clearing
9/29/2017
3/6/2018 1/8/2021
3/9/2018 1/8/2021
4/13/2018 1/11/2021
4/16/2018 1/11/2021
4/17/2018 1/14/2021
11/6/2018 5/3/2021
11/9/2018 7/6/2021
11/9/2018 8/5/2021
11/15/2018 8/5/2021
3/5/2019 8/5/2021
3/6/2019 8/5/2021
3/7/2019 8/5/2021
3/11/2019 8/5/2021
7/26/2019 8/5/2021
7/29/2019 8/5/2021
8/7/2019 8/5/2021
8/13/2019 8/13/2021
2/18/2020 10/21/2021
2/19/2020 1/4/2022
7/17/2020 2/5/2022
1/5/2021
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, repair, and final CCTV assessment.
13

Incident Number # 202102268 —12/14/2021— 3307 Quail Hollow Dr., Raleigh, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow
within a section of 811 Polyvinyl Chloride pipe gravity sewer main. This build-up led to a sewer spill of
approximately 900 gallons of untreated wastewater of which 100 gallons reached Big Branch. (See exhibit 1—
Area of Operation)
Exhibit 1— Area of Operation
3307 Quail Hollow Dr SSO INCIDENT MAP
VaaMaar
55 110 220ft wew nuke eeaydtreooeCae old P14411
. 1 . 1 nomcome wee.r..s,_Ne.
1 YNh•100 Pec danNOT maw, Ns own a v
�d mcwn.trtr eat them% a....p-p-....
On 12/14/2021, at approximately 12:53 PM, Sewer Maintenance staff conducting high priorities
inspections identified a sanitary sewer overflow emanating from a manhole located near 3307 Quail Hollow 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 1:30 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 a temporary spill containment site
downstream of the affected area (see Exhibit 2 — Containment and collection efforts). 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 site 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.
14

Exhibit 2—Containment and collection efforts
During the restoration phase of the operation, crews utilized mechanical ground removal of sewer
contaminated soil from the affected area of the downstream conveyance. The areas around the manhole were
cleared of debris, washed with potable water, treated with an application of lime, and finally restored with grass
seed and straw. See Exhibit 3 — Site Restoration.
Exhibit 3— Site Restoration
15

A follow-up CCTV assessment was conducted on 12/17/2021 to identify the root cause of the SSO. The
CCTV assessment determined that the root cause of this incident was attributed to root intrusion at a joint
within the affecting asset located 160.8' downstream from SMH113635. This joint is possibly separated allowing
for the root intrusion to occur. See Exhibit 4 — Separated joint.
Exhibit 4 — Separated Joint
The cost associated with the mitigation of this event amounted to $8,522.95. The approximate cost to the
Utility to have treated 900 gallons of wastewater would have been approximately $1.35. 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 downstream of a residential area. It provides sewer
collection services to a multi -family dwelling. Outreach information literature was 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.
The last recorded SSO experienced in this portion of the collection system was recorded on 11/22.2006
due to heavy rain. This site has been added to recurrent maintenance interval program. Before this event,
maintenance records show that sections within the zone of influence of this collection system were assessed
within the last 10 years as follows:
Flushing activities CCTV activities Repair Activities Inspections
12/11/2012 5/11/2018 3/10/2015 12/30/2021 1/30/2018 9/11/2020
3/21/2013 5/14/2018 3/16/2015 1/31/2018 3/2/2021
10/20/2013 5/14/2018 12/17/2021 4/30/2018 3/15/2021
10/28/2013 4/4/2019 Easement Maintenance 1/18/2019 8/17/2021
4/3/2014 4/4/2019 Activities 5/9/2019 12/14/2021
3/11/2015 4/4/2019 5/12/2017 11/12/2019 12/17/2021
3/15/2015 12/14/2021 12/11/2018 11/13/2019 12/29/2021
10/18/2015 2/28/2020 1/12/2022
8/5/2020 3/1/2022
16

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.
Incident Number # 202102313 —12/28/2021— 3201 Friar Tuck Rd., Raleigh, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow
within a section of 8" Vitrified Clay pipe gravity sewer main. This build-up led to a sewer spill of approximately
250 gallons of untreated wastewater reaching a stormwater channel. (See exhibit 1—Area of Operation)
Exhibit 1— Area of Operation
On 12/28/2021, at approximately 12:22 PM, Sewer Maintenance staff was notified of a sanitary sewer
overflow emanating from a manhole located near 3201 Friar Tuck Rd., 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 1:12 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 a temporary spill containment site
downstream of the affected area (see Exhibit 2 — Containment and collection efforts). 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 site 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.
17

Exhibit 2 — Containment and collection efforts
During the restoration phase of the operation, crews utilized ample potable water to clear and flush the
areas around the manhole and downstream conveyance of the stormwater system and creek.
A follow-up CCTV assessment was conducted on 12/30/2021 to identify the root cause of the SSO. The
CCTV assessment determined that the root cause of this incident was attributed to a broken pipe (See Exhibit 3
— Broken Pipe. A subsequent trenches repair was conducted to immediately correct the issue.
Exhibit 3 — Broken Pipe
USMH: SMH113208
DSMH: SMH105100
M G O
Miscellaneous General Observation
153.5 ft.
The cost associated with the mitigation of this event amounted to $692.66. The approximate cost to the
Utility to have treated 900 gallons of wastewater would have been approximately $.37. 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.
18

This section of the collection system is located downstream of a residential area. It provides sewer
collection services to approximately 55 properties upstream of the spill event (see Exhibit 4- Zone of Influence).
Outreach information literature was 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.
Exhibit 4- Zone of Influence
19

Within the last ten years, this portion of the collection system has not experienced a grease -related SSO.
Before this event, maintenance records show that sections within the zone of influence of this collection system
were assessed within the last 10 years as follows:
Flushing activities CCTV activities
10/9/2012 10/29/2014 10/16/2015
10/21/2013 10/19/2015 4/7/2014
12/17/2013 12/12/2015 11/5/2014
1/27/2014 12/18/2015 1/6/2022
3/27/2014 7/1/2019
3/28/2014 7/2/2019
7/12/2019
Repair Activities
2/28/2022
Easement Maintenance
Activities
2/6/2018
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.
20

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 7,585 gallons of untreated
wastewater spill identified in this letter cost the Utility approximately $20,008.59. to mitigate. The City's cost of
sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $11.37 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
systems nationally. These agencies work collectively to challenge the testing protocols, assessment guidelines,
and consumer education and labeling of these non -dispersible.
21

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-0022 issued for the month of
December 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
Assistance Superintendent 919-996-5929.
A_
nc rely,
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
Carlos.perezcamachoc raleighnc.Gov
22

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7020 3160 0000 4115 6839
Return Receipt Requested
Whit Wheeler, Assistant Public Utilities Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
January 24, 2022
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2022-DV-0022
Sanitary Sewer Overflows - December 2021
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
FEB 0 2 2022
By mot.:- -
NC Dept of Environmental Qualit,
Raleigh Regional Office
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by City of Raleigh indicates violations of
permit conditions stipulated in the subject permit and North Carolina G.S. 143-215.1. Violations include failing to
effectively manage, maintain, and operate the subject collection system so that there is no SSO to the land or
surface waters and making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a
permit is required.
Specific incidents cited in the subject report include the following:
Incident Start Duration
Number Date (Mins) Location
Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
202102208 12/1/2021 90 1401 Wendell Blvd Grease
2,160 1,450 Notice of Violation
202102258 12/12/2021 111 612 Carolina Ave. Debris in line 2,775 2,000 Notice of Violation
202102314 12/28/2021 60 2110 Blackwolf Run Grease
Lane
1,500 1,500 Notice of Violation
202102268 12/14/2021 37 3307 Quail Hollow Dr. Debris in line
900 100 Notice of Deficiency
202102313 12/28/2021 50 320 Friar Tuck Rd. Grease
Lane
250 250 Notice of Deficiency
North Carolina Department of Environmental Qltallty I Division of Wier Resource,
Raleigh Regional Office 13800 Barrett Drive I Raletelt North Carolina 27609
919.791A200

Remedial actions, if not already implemented, should be taken to correct the above noncompliance. Please submit
a written response to this Notice of Violation. Your response is to be received by the regional office within 15
business days following receipt of this violation. Please include any additional documentation about this incident(s)
in the response. The submittal will be considered in determining whether the Division will assess a civil penalty for
the cited violations.
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: Regional Office - WQS File
Laserflche
Sincerely,
‘,..,,,J,t_ r 4-----e
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
,:a..f9$))
North Carotins Department of Environmental Quality I !Rolston of Water Resources
Raleigh Regional Offke I JB00 Barrett Drive I Raleigh Nonh Carolina 27609
919.7914200