WQCS00002_NOV-2022-DV-0088 RSP_20220425

/ NC Dept ofEnviromul imbd Quality
%)0//
1111111 APR 25 2022
Raleigh Water RaWA ftland OTm
April 251h, 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-2022-DV-0088
Sanitary Sewer Overflows — February 2022
Permit No. WQCS00002
Dear Mr. Vinson:
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2022-DV-0088) received on April 61h, 2022. This document contains the narrative regarding
pending violation actions of (3) Sanitary Sewer Overflow (SSO) events, reported on the month of February 2022
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 events occurred while the City operated its collection system,
according to WQCS00002, dated June 6th, 2017. The permit includes the language outlined in footnote 1 and
applies to the SSOs upon which NOVs with the notice of intent (NOV-NOI) were based. This document will
establish a reasonable explanation of the actions taken to stop the spills; contain the released untreated
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 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;"

Incident Number # 2022000292 — 2/28/2022 — Intersection of Flamingo Lane and Crispin Court., Raleigh NC
This spill was neither willful nor intentional, It resulted from a grease build-up, restricting the sewer flow
within a section of a 12-inch ductile iron pipe gravity sewer main. This build-up led to a sewer spill of
approximately 1,660 gallons of untreated wastewater in which roughly 1,060 gallons reached an unnamed
tributary in the Crabtree Basin (see exhibit 1— Area of Operation)
On 02/20/2022, at approximately 7:12 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitarysewer manhole (SMH117876) located near the intersection of Flamingo Ln. and
Crispin Ct., Raleigh NC. The responding staff took all reasonable steps to stop and mitigate the impact of the
discharge, gaining control of the spill event by 8:35 PM on the same day. Crews utilized hydraulic jetting to
remove the source of the blockage within the affecting asset, thus restoring sewer flow.
Note
The time entered in RlMs was erroneously label as 7-12 AM ristead -d 7 12 PM. The Iota duration of th s event was 83 minutes
Incident Started Dt 02/20/2022 Time F.12 al II Incident End Dt 02/2012022 Time: 08:35_pm
(mmAd-yyyy) (hh:mm AMlPMj mm -yyyy (hh:mm AWPM)
Estimated Volume of the SM 1.880 galions Estimated Duration (Round to nearest hour) 13.23 hours
Containment and collection of this spill event consisted of employing a temporary spill containment site
approximately 500 ft downstream of the affected area restricting sewer flow on the unnamed tributary (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

During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and
remove sewer traces from the surrounding area and downstream conveyance. The area around the manhole
was cleared of debris, treated with an application of lime, and restored with grass seed and straw. See Exhibit 3
— Site Restoration.
Exhibit 3 Ste Restoration
A follow-up CCTV assessment was conducted on 2/28/2022 to identify the root cause of the SSO. The CCTV
assessment did not identify a major grease deposit requiring further cleaning. Additional flushing was completed
on 2/28/2022 finding no grease issues within the main.
3

The cost associated with the mitigation of this event amounted to $2,356.63. The approximate cost to the Utility
to have treated 1,660 gallons of wastewater would have been approximately $2.49. 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 several mobile homes upstream of the spill event (see Exhibit 4- Zone of Influence). Sections of this
collection system are identified as a private system outside the jurisdiction of maintenance from Raleigh Water.
Within the last ten years, this specific portion of the collection system has not experienced a grease related SSO
event. This area has been placed on routine maintenance.
Outreach information literature was requested to be sent to the immediate -affected area. The requested
outreach literature explains 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.
H

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
5/31/2011
10/9/2012
11/6/2014
6/1/2011
10/26/2012
11/13/201
6/3/2011
10/26/2012
11/14/201
6/4/2011
10/31/2012
3/18/2015
6/7/2011
11/1/2012
7/29/2015
6/27/2011
11/6/2012
12/25/2015
7/8/2011
6/30/2013
02/02/2017
3/16/2012
7/5/2013
07/30/2010
3/19/2012
7/8/2013
07/25/2019
5/4/2012
11/3/2014
08/01/2019
5/9/2012
11/3/2014
08/05/2019
10/2/2012
11/4/2014
08/06/2019
10/3/2012
11/5/2014
CCTV Activities Repair Activities Inspections Activities
3/18/2015 02/24/17 Since February 2018
09/18/18 there have been over
235 high priority and
manhole inspection
conducted
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 # 2022000246 — 2/20/2022 — 2408 Renfrow 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-inch polyvinyl chloride (PVC) pipe gravity sewer main. This build-up led to a sewer spill of
approximately 6,000 gallons of untreated wastewater remaining on the ground and not reaching the surface
waters of the state. (See exhibit 1 — Area of Operation)
On 02/28/2022, at approximately 1:30 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (SMH109917) located near 2408 Renfrow Rd., Raleigh NC. The
responding staff took all reasonable steps to stop and mitigate the impact of the discharge, gaining control of
the spill event by 2:30 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 vacuum truck to recover stagnant
wastewater that remained in the natural topography (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 and
remove sewer traces from the surrounding area. The area around the manhole and containment area was
cleared of debris, treated with an application of lime, and restored with grass seed and straw. See Exhibit 3 —
Site Restoration.
A follow-up CCTV assessment was conducted on 3/28/2022 to identify the root cause of the SSO. The CCTV
assessment identified partial root intrusion and grease accumulation requiring further cleaning. Additional
flushing was completed on 3/2/2022.
The cost associated with the mitigation of this event amounted to $8,117.73. The approximate cost to the Utility
to have treated 6,000 gallons of wastewater would have been approximately $9.00. 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 several properties upstream of the spill event (see Exhibit 4- Zone of Influence). this specific portion
of the collection system has not experienced a grease related SSO event within the last ten years. This area has
been placed under routine maintenance.

Exhib t 4 Zone of nfluence
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 5 — Press release. Outreach information literature was requested to
be sent to the immediate -affected area. The requested outreach literature explains 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.
Raleigh Water Responds to a Sanitary Sewer Spill
tie Mayday. February +at at appadmany 130 N,e R~ Water"were
ooseed of a saabry sewer Mr0 or In the ycr ity of 2400 Romany Rash. Mao NC
Upon aftel. stow 1dea00ed an acute rawer oversew reeve" ham a tesed mista le
Baal wIYN dhruplM samal sewer ease from an O�Ith sewer 0ravey man T> e
re+ouk" staatook an Mumabie staps to dop and ndegam dle oversews bnpact as
soon as they a11inid The Nat Canisnr Oapardnerd d Envear.." Qu W, Onmen
d Water Reaaerces has been noeAed of ero 7nir0ow
Raleigh WAN 21aR removed are blockage wwce Vol wmahM Ins Overflow at
app oxi matey 5 51 p m m be cams day It Is aaEma W that be oversew dndraMed a
wbmte of appesmafe S 8.0 M nations of Unhealed mmimak, lemanarp within the
eateral topMaphy and not reaching surface nom of a. slate Realtratlen fas n
wnt aearpoGrp ylwe vru 1a observed ten lee n or.recassaly vegelatke damaoe
Jesse flan One Bawer everd
Raleigh Water has an a00vesalva odueauon and enforcement program to
Prevent the dleaharee of greens. debris, whose, rags. diapers son! other
improper materials In the wryer system and to lake enforeerneot wb n
setero appropriate. d these hems rtihe it into the senior eyftem, they my
Mae a *Oin *men ten haw an adeeme beped on water quality and
ondanper dkw who gams itch eentee! edt in, oReclsd sreaa.
• Water. human waste, and toilet dssoe M the only hems permitted to be
diwhsrged into the enrer system. As ollner Ilenw wig uses Oarrnspr to era
savior system and are not permitted.
N you experience excessive savior smells or we sewer *piping ham
manholes or pipes, please "it 911e-e110-3tie5 to nine" innledlohy
• For mom Inlenmatlen about how you ten help prevent sanitary swery
spies, please visit: mlelghlM-00 vi 111K.
This nowt ral ass is wAa sd M NCgS AM* %* Chapter 143 115 IC
we
8

Incident Number # 202200432 — 2/14/2022 —1202 New Bethel Church Rd., Garner, NC
This spill was neither willful nor intentional; this incident was the result of a failed sewer force main by-
pass pipe fitting. The by-pass was constructed to by-pass an existing 30" Ductile Iron Pipe sewer force main. The
failed by-pass resulted in the sewer spill of approximately 63,000 gallons of untreated wastewater reaching
Mahler's Creek within Lower Swift Basin. This project was under the jurisdiction of the North Carolina
Department of Transportation (NCDOT). The scope of this project included the relocation of a force main as part
of DOT road bridge construction. NCDOT contractors installed and operated the sewer bypass under the
specifications of sewer infrastructure design. Onsite representatives of NCDOT assumed the responsibility for
the failed bypass and the reporting requirements of the incident through the Regional Department of
Environmental Quality — Division of Water Resources. This effort was coordinated between Raleigh Water
Representatives and NCDOT Division-5 on -site engineer. NCDOT reported the spill event through NCDOT
Division-5 environmental office respectively.
On 02/14/2022, at approximately 07:30 AM, a utility contractor working on behalf of NCDOT, notified Raleigh
Water staff of a sewer overflow involving a failed sewer by-pass on a force main near 1202 New Bethel Church
Rd., NC. Raleigh Water staff assisted DOT in responding to mitigate the impact of the discharge immediately
upon arrival, gaining control of the spill event by 11:30 AM on the same day.
Containment and collection of this spill event consisted of throttling down wastewater flow and volume at the
upstream pump station to minimize sewer flow at the affected site. Wastewater flow was rerouted and
simultaneously collected into vacuum trucks to minimize the environmental impact on the surrounding
land. Through this effort responding crews were able to collect roughly 7,000 gallons of untreated wastewater
before it reached surface waters.
Cleanup consisted of removing and disposing of sewer debris from the excavation. The area around the
damaged by-pass was cleared and decontaminated with the application of lime, grass seed, and straw. This spill
was contained without a significant environmental impact on the adjacent area and its natural resources. There
was no observed fish kill associated with this SSO nor unnecessary damage to area vegetation.
The Utility contractor working on behalf of the NCDOT was able to repair and replace the damaged section of
the force main restoring the sewer bypass operations.
The total cost of the City's assistance in responding to the remediation effort for this spill event was $5,991.86.
The approximate cost to the Utility to have treated 63,000 gallons of untreated wastewater would have been
approximately $94.50. The City saved no money from this spill. The costs for cleanup and repair 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 volume of sewage created by the spill as well as the cost of potable water used to mitigate the
event.
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 NCDOT construction project.
10

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
8/20/2013
2/28/2022
8/5/2013
3/ 1/2022
3/9/2017
3/2/2022
8/1/2017
3/3/2022
3/2/2022
Repair Activities Inspections Activities
3/21/2022 Easement Inspection
10/14/2019
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.

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 299.8 [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
$ 2,640,575.97 [2], approximately 20% of the Division's annual operating budget. The 70,660 gallons of
untreated wastewater spill identified in this letter cost the Utility approximately $16,4466.22. to mitigate. The
City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $105.99 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.
(11299.8 miles represents 11% of the sarrtary sewer collection system
[2] Associated operational cost year to date for FY2022
OPERATION LINEAR FEET Linear Mites COST
CCTV 350,539 66.4 S 376,624.20
Flushing 1,226,667 232.3 $ 447,197.00
Repair 5,690 1.1 $ 1,826,277,64
Total • 1,582.896 Ft Total cost of Business to Date
299.8 MILES $ 2,640,575.97
[3] $.0015 is based on the annual water treatment operating cost compounded by the total treated effluem
J41 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 have 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 property
managers resource kit that provides best practice resources for establishing a property -specific awareness
11

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:Hraleighnc.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-2022-NOI-0088 issued for the month of February
2022 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.
04, 5j r
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
Carlos. oerezcamacho raleiybnc.Gov
12