WQCS00002_NOV-2022-DV-0053 Response_20220321 (2)

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Raleigh Water Ayyqend Jeyusumomaug jo ydaq ON
March 21*, 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-0053
Sanitary Sewer Overflows — January 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-0053) received on February 25", 2022. This document contains the narrative regarding pending violation actions of (5) Sanitary Sewer Overflow (SSO) events, which occurred during the month of January 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-NOlI) 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 1V92). 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 # 202200012 — 1/3/2022 — 5217 Cedarwood Dr., Raleigh NC
This sewer spill event was the result of a severe weather event that led to an unexpected sanitary
sewage spi ll of approximately 686 gallons of untreated sewer reaching surface waters Hog Pen Branch in Big
Branch Basin. This event restricted normal sewer flow from an 8-inch gravity sewer main. This spill took place.
The weather event produced a record rainfall of 2.29 inches for January 3, 2022, affecting the Raleigh area
(NOOA, Monthly Climatological Report for Raleigh NC, see Exhibit 1 - Weather Report).
Sewer Maintenance staff was informed of the overflow on 1/3/2022 at approximately 9:37 AM. The
responding staff took all reasonable steps to monitor and mitigate the discharge's impact as soon as they arrived
until the weather event ceased at approximately 11:07 AM on the same day. Mitigation of this event was limited
since the rain event was actively ongoing. The rain assisted in defusing the sewage downstream. There was no
indication o f solids or debris in the surrounding area. Crews conducted an area assessment downstream of the
event to ensure no traces of sewage and debris associated with the spill. Crews did not find any indication of
sewage nor indications of observed fish kill related to this SSO.
The total cost of the City's response and remediation effort for this spill event was $617.28. The
approximate cost to the Utility to have treated 686 gallons of wastewater would have been approximately
$1.03. 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.
There have been no previous recorded spills for this section of the sewer system. Prior to the weather
event, the most recent record of routine maintenance in this area was conducted on 12/14/2016.
Pursuant to our Sanitary Sewer Collection System Permit, the cause of this SSO was exceptional,
unintentional, temporary, and caused by factors beyond our reasonable control. Furthermore, the SSO could not
have been prevented by the exercise of reasonable control, such as routine operations and maintenance,
adequate treatment facilities, or collection system facilities or components.
Exhibit 1 - Weather Report
Climatological Data for Raleigh Area, NC (ThreadEx) - January 2022

Date a HDD cbb Precipitation New Snow Snow Depth
Maximum Minimum Average Departure
2022-01-01 79 64 71S 29.3 a 7 0.43 0.0 0
2022-01-02 70 59 64.5 22.4 a 0 0.81 0.0 0
2022-01-03 60 3l 45.5 35 19 0) 2.29 T 0

Precipitation (inches)
Accumulated Precipitation - Raleigh Area, NC (ThreadEx)
Click and drag to zoom to a shorter time interval. green/black diamonds represent
subsequent/missing values

O

jan 2 Jan 9 Jan 16 Jan 23 jan 30
@ 2022 accumulation —= Normal —= Highest (1954) — Lowest (1890) |
ty AC Fowert

Incident Number # 202200080 — 01/07/2022 - 732 llleagnes 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" Polyvinyl Chloride pipe gravity sewer main. This build-up led to a sewer spill of approximately 210 gallons of untreated wastewater remaining within the natural topography with minor leaching into the adjacent stormwater retaining pond. (See exhibit 1 — Area of Operation)
Exhibit 1 — Area of Operation
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On 01/07/2022, at approximately 9:35 AM, Raleigh Water staff were notified conducting high priorities inspections identified a sanitary sewer overflow emanating from a manhole located near 732 Illeagnes 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 10:19 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 a stormwater containment pond (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.
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 and downstream conveyance. The areas around the
manhole were cleared of debris and washed with potable water. 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 — Site Restoration
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A follow-up CCTV assessment was conducted on 1/10/2022 to identify the root cause of the SSO. The CCTV assessment identified minor grease deposits on segments of sewer gravity mains requiring further cleaning. Additional flushing was completed on 2/8/2022 finding no grease issues within the main.
The cost associated with the mitigation of this event amounted to $1,950.57. The approximate cost to the Utility to have treated 210 gallons of wastewater would have been approximately $.31. 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 23 properties upstream of the spill event (see Exhibit 4- Zone of Influence). Within the last ten years, this portion of the collection system has not experienced a grease-related SSO event. This area has been placed on routine maintenance.
Exhibit 4- Zone of Influence

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. See exhibit 5 - Outreach Literature.
Exhibit 5 - Outreach Literature

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 ccTv Repair Inspections Activities Easement
activities Activities BOMIGEES Mainten ance Activities
11/25/2017 1/11/2022 NA 2/12/2018 8/4/2020 4/12/2017
5/23/2019 4/20/2018 11/19/2020
1/7/2022 9/7/2018 12/7/2020
2/8/2022 3/20/2019 11/19/2020
8/16/2019 1/21/2021
8/15/2019 7/15/2021
8/16/2019 9/14/2021
1/31/2020 2/7/2022
8/17/2020
There have been no additional issues associated with t his sec tion of the collection system since the las t
sewer event. This site continues to remain an active maintenance spot pending completion of further sewer
main cleaning and CCTV assessment.
Incident Number # 202200096 — 01/13/2022 — Park Glen Dr. & Raleigh Blvd., Raleigh
This spill was neither willful nor intentional; it was the result of root intrusion, which blocked a portion of a 12-in” vitrified clay pipe gravity sewer main. The root intrusion led to a sewer spill of approximately 1,950 gallons of untreated wastewater contained within the natural topography and not reaching surface waters of the state.
On 1/13/2022, at approximately 2:10 PM, Sewer Maintenance staff was notified of a sewer overflow located near the intersection of Park Glen Dr. & Raleigh Blvd., Raleigh. Upon arrival, it was discovered that untreated sewer was emanating from an adjacent manhole (SMH117520). 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 2:40 PM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage within the affecting asset thus restoring sewer flow.
Exhibit 1- Area of Operation
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This event was naturally contained within the topography of the land not requiring the assistance of pumps or implements to contain the spilled untreated wastewater. Collection consisted of manually removing sewer contaminated soil downstream of the affected asset.
During the restoration phase of the operation, crews remove sewer traces from the surrounding area and downstream conveyance. The areas around the manhole were cleared of debris and washed with potable water. The surrounding area was treated with an application of lime and restored with grass seed and straw. See Exhibit 3 — Site Restoration.
Exhibit 3 - Site Restoration

A follow-up CCTV assessment was conducted on 1/26/2022 to identify the root cause of the SSO. The
CCTV assessment identified minor root instruction between joints of segments of sewer gravity mains requiring
further cleaning. Additional flushing was requested to further mitigate the condition of the sewer main and
minimize a potential re-occurrence. See exhibit 4 — Evidence of Root Intrusion
Exhibit 4 — Evidence of Root Intrusion
RT ekeess eee Tee
Pee
Roots Medium Joint
114.2 ft.

The cost associated with the mitigation of this event amounted to $1,394.06. The approximate cost to
the Utility to have treated 1,950 gallons of wastewater would have been approximately $2.10. The City saved no
money from this spill. Its costs for cleanup exceeded the cost of treating the volume of sewage had no spill
occurred. Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the
spill.
This section of the collection system serves a residential area south of Capital Blvd., it provides sewer collection to several multi-family dwellings and single-family homes. A press release notification associated with this event was published in the Raleigh News & Observer on 01/14/2022 (Exhibit 5 — Press release).
Exhibit 5 — Press Release
Raleigh
COMMUNICATIONS DEPARTMENT
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Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday, January 13, at approximately 210 PM, Raleigh Water - Sewer Maintenance Division staff responded to a sanitary sewer spill located at Park Glen Dr and 0 N Raleigh Blvd, Raleigh NC The cause of the spill was related to roots disrupting the collection system The responding staff took all reasonable steps to stop and muitgate the impact of the spill 33 soon as they arrived. The North Carolina Department of Environmental Quality, Division of Water Resources was notified of the spi
Raleigh Water staff contained the spall at approximately 2.40 PM on the same day itis estimated that the spi discharged a volume of approximately 1,950 gallons of untreated wastewater of which all were contained by ground surface. 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, 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,
+ Ifyou experience excessive sewer smells or see sewer spilling trom
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.goviwater.
This news release is required by NCGS Article 21, Chapter 143 215. 1C
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Before this event, maintenance records show that sections of this collection system were assessed within the last 10 years as follows:
‘ a CCTV Repair Inspections Activities Flushing adtivities Activities Activities 5/25/2011 9/25/2014 8/29/2012 11/9/2020 1/11/2018 6/22/2020 8/28/2012 11/10/2014 9/18/2013 11/10/2020 1/16/2018 9/29/2020 11/6/2012 11/12/2014 12/14/2017 5/23/2018 3/3/2021 11/26/2012 5/26/2015 11/18/2020 5/25/2018 3/24/2021 3/28/2013 5/28/2015 10/15/2020 12/19/2018 6/15/2021 9/4/2013 5/29/2015 1/26/2022 12/21/2018 6/17/2021 12/6/2013 5/29/2015 4/24/2019 7/2/2021 4/22/2014 3/2/2017 11/25/2019 8/30/2021 4/25/2014 11/6/2020 12/3/2019 9/16/2021 4/25/2014 4/1/2020 12/2/2021 . 6/15/2020 3/11/2022
There have been no additional issues associated with this section of the collection system since 01/13/2022. Since 2002, this portion of the sanitary sewer collection system has not experienced a root-related SSO. This site has been added to a recurrent root management protocol.
Incident Number # 202200151 — 01/25/2022 — 621 Thistlegate Trail., Raleigh, NC
This spill was neither will ful nor intentional; it resulted from foreign debris not consistent with regular
wastewater debris such a spaper. The debris identified as the root cause of this event was found to be several
pieces of lumber (such as 2X4) which caused a partial blockage in a portion of a 12” polyvinyl chloride gravity
sewer main. The blockage led to a sewer spill of approximately 15,625 gallons of untreated wastewater reaching
a stormwater containment pond located within the Crabtree Basin.
On 01/25/2022, at approximately 9:47 AM, Raleigh Water staff were notified of a sanitary sewer
overflow emanating from a sewer manhole (SMH109628, see Exhibit 1 — Affected Asset, below). Utility
responders were immediately summoned to respond and mitigate the spill . The responding staff took all
reasonable steps to stop and mitigate the impact of the discharge as soon as they arrived, gaining control of the
spill event by 11:52 AM on the same day. Utility response crews utilized hydraulic jetting and manual removal of
the debris to eliminate the source of the blockage within the affecting asset, thus restoring sewer flow.
Exhibit 1— Affected Asset
* , ay 4 Re Affected/Asset: eo es COE}
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AF IS D e y i ‘3 a g
hy , yy BA ew og [ip CS F SGMN136794] 3
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. See Exhibit
2 —Containment and Collection Efforts, below.
10
Exhibit 2— Containment and collection efforts

During the restoration phase of the operation, crews utilized ample potable water to remove 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. See Exhibit 3 — Restoration Efforts.
Exhibit 3 —- Restoration Efforts

The cost associated with the mitigation of this event amounted to $1,732.11. The approximate cost to the Utility to have treated 15,625 gallons of wastewater would have been approximately $23.44. 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 as well as the cost of potable water used to mitigate the event.
11
A follow-up close circuit television (CCTV) assessment did not find any infrastructure issues that may
have contributed to this event. This assessment confirms that the foreign debris, lumber externally introduced
into the collection system, caused the sewer backup and the subsequent overflow. The source of the lumber
could not be identified.
This section of the collection system serves a vast commercial and residential area south of New Bern
Ave. It provides sewer collection services to over 300 properties. 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 4
— Press release).
Exhibit 4 — Press Release

Raleigh Water Responds to a Sanitary Sewer Overflow
621 Thistlegate Trail, Raleigh January 25, 2022
On Tuesday, January 25th, at approximately 9:47AM, Raleigh Water staff were
notified of a sanitary sewer overflow behind 621 Thistlegate Trl, Raleigh. Upon
arrival, Utility Responders identified an active sewer overflow resulting from de-
bris within the 12-inch 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 af Environmental Quality, Division of Water Resources has
been notified of the overflow.
Raleigh Water staff contained the overflow at approximately 11:52AM on the
same day. It is estimated that the overflow discharged a volume of approximately
15,625 gallons of untreated wastewater into a private pond. Restoration for this
avent was completed at approximately 5:33PM on the same day. No vegetative
damage or fish kill has been observed related to this event.
* Raleigh Water has an aggressive education and enforcement program to pre-
vent 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 dis-
charged 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: raleighne.gov/water.
This news release is required by NCGS Article 21, Chapter 143.215.1C.
woo000000 ‘
Publication Dates

Before this event, maintenance records show that sections of this collection system were assessed
within the last 10 years as follows:
Flushing activities CCTV Activities Repair Activities Inspections Activities Easement
Activities
11/6/2011 10/31/201 02/17/2022 4/21/2017 9/21/2015 8/7/2019 3/30/2021
7/20/2011 4/10/2017 4/12/2017 2/13/2018 1/23/2020
11/9/2011 2/28/2017 1/22/2018 7/15/2020
11/1/2012 9/6/2018 4/2/2018 12/23/2020
10/15/2013 7/9/2019 5/16/2018 2/11/2021
6/8/2012 11/26/2018 8/30/2021
4/17/2019 3/1/2022
Maintenance records show that this portion of the sanitary sewer collection system has not experienced
a debris-related SSO in the past ten years. This site has been added to recurrent maintenance efforts as this
incident was identified as an isolated event.
12
Incident Number # 202200153 — 01/26/2022 — 2804 Sylvester St., Raleigh, NC
This spill was neither willful nor intentional; it resulted from debris (such as paper and wipes) accumulation within the affecting asset (SGMN154501). The debris caused a partial blockage in a portion of an 8-inch gravity sewer main. The blockage led to a sewer spill of approximately 615 gallons of untreated wastewater reaching an unnamed tributary within the Southgate Basin.
On 01/26/2022, at approximately 8:34 AM, Raleigh Water staff were notified of a sanitary sewer overflow emanating from a sewer manhole (SMH116842, see Exhibit 1 — Affected and affecting Asset, below). 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 09:15 AM on the same day. Utility response crews utilized hydraulic jetting and manual removal of the debris to eliminate the source of the blockage within the affecting asset, thus restoring sewer flow.
Exhibit 1— Affected and Affecting Asset
S ote, - Can ae ae *
_ a res Affecting Asset eT
\
Cry
Ps CL
SMH116842

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 ample potable water to remove 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 $ 613.80. The approximate cost to the Utility to have treated 615 gallons of wastewater would have been approximately $.92. 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 as well as the cost of potable water used to mitigate the event.
A follow-up close circuit television (CCTV) assessment did not find any infrastructure issues that may have contributed to this event. The CCTV assessment recommended that this portion of the sanitary sewer collection system be placed in a recurrent maintenance program.
13
This section of the collection system serves a vast commercial and residential area west of Sanderford
Rd. It provides sewer collection services to over 250 properties. Before this event, maintenance records show
that sections of this collection system were assessed within the last 10 years as follows:
2/11/2011
10/3/2011
2/14/2012
5/8/2012
8/29/2012
10/11/2012
3/20/2013
3/28/2013
5/28/2013
9/19/2013
9/20/2013
9/23/2013
9/23/2013
9/25/2013
9/26/2013
Flushing activities
10/14/2013
10/17/2013
1/10/2014
4/30/2014
7/11/2014
7/13/2014
10/9/2014
7/10/2015
8/26/2015
9/11/2015
9/24/2015
11/30/2015
12/10/2015
1/17/2017
6/22/2017
12/11/2017
12/13/2017
12/21/2017
3/16/2018
3/19/2018
3/20/2018
3/26/2018
3/27/2018
3/28/2018
3/29/2018
4/2/2018
5/15/2018
5/31/2018
9/17/2018
4/16/2020
10/19/2020
11/4/2020
CCTV Activities
2/14/2013
7/17/2014
2/2/2017
12/28/2017
10/1/2018
10/8/2018
10/22/2018
11/4/2020
6/30/2021
7/13/2021
12/17/2021
Repair Activities Inspections Activities
1/31/2017 06/17/2022
4/17/2018 12/07/2022
6/30/2021
12/16/2021
9/15/2020
2/18/2022
Maintenance records show that this portion of the sanitary sewer collection system has experienced
three separate SSOs resulting from grease and debris accumulation as follows:
Date
6/2/2006
12/20/2006
2/3/2009
Location
Behind 1112 Savannah Dr
2904 Sylvester St
2808 Sylvester St.
SSO Duration
15 hrs.
40 min.
1 Hr.
SSO Volume (gallons) Root Cause
2700 Grease
800 Debris in line
100 Debris in line
As a result of these previous incidents, this site has been added to recurrent maintenance efforts.
14
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 19,086 gallons of untreated wastewater spill identified in this letter cost the Utility approximately $6,307.54. to mitigate. The City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $27.80 to treat the entire volume of sewer spilled. The City saved no money from these spills. The costs of mitigation well exceeded the cost of treating the volume of sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater sewage volume created by these spills. This fiscal comparison shows the City's commitment to environmental protection, sparing no cost regardless of the spill event's severity and complexity. The City continues to demonstrate due diligence in environmental performance by allocating the necessary resources to a spill event irrespective of the associated cost. This effort is noted in the City's low SSO performance rate of 1.49 total SSO rate [4] per 100 miles of pipe, compared to the Southeastern Region of the US, of 7.0 spills per 100 miles of line.
[1] 299.8 miles represents 11% of the sanitary sewer collection system
[2] Associated operational cost year to date for FY2022
OPERATION LINEAR FEET Linear Miles COST
CCTV 350,539 66.4 S$ 376,624.20
Flushing 1,226,667 232.3 $ 447,197.00
Repair 5,690 11 $ 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 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.
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
15
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, | am requesting that the NOV-2022-NOI-0053 issued for the month of
January 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. Law
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.perezcamacho @raleighnc.Gov
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