WQCS00002_NOV2022-DV-0109 Response_20220804

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Raleigh Water

August 4th, 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-0109
Sanitary Sewer Overflows – March 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-0109) received on May 4th, 2021. This document contains the
narrative regarding a pending violation action of (5) Sanitary Sewer Overflow (SSO) events, which
occurred during the month of March 2022 within the City of Raleigh Collections System [1]. This
document also provides exhibits as proof of our efforts to mitigate the sewer event. 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 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 single SSO event.

1. “The Director may take enforcement action against the Permittee for SSOs that must be reported to the Division as stipulated in Condition IV92). This includes
SSOs that 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 backup 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;”
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Incident Number # 202200334 – 03/07/2022 – Intersection of W. Young St. and Granit Falls Blvd.,
Rolesville, NC
This spill was neither willful nor intentional; this incident was the result of directional drilling by
a private contractor boring under W. Young St., Rolesville, NC. The bore-through caused interruption to
sewer flow in a portion of a 2” sewer force main. The bore-through resulted in the sewer spill of
approximately 6,450 gallons of untreated wastewater in which approximately 3,450 gallons reached
surface waters of an unnamed tributary within the Smith Creek basin. Approximately 3,000 were
contained within the natural topography preventing further spreading downstream. This event occurred
within Smith Creek N. Raleigh. See
Exhibit 1 – Area of Operation

On 03/7/2022, at approximately 3:00 PM, Raleigh Water staff was notified of a bore-through and a
subsequent sewer spill affecting the immediate area of the directional drilling. 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 7:30 PM on the same day. Crews utilized vacuum trucks to remove the
sewer while repairs to the damaged force main were being completed. See Exhibit 2 – Repair Efforts
Exhibit 2 – Repair Efforts

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Containment and collection of this spill event consisted of throttling down the sewer pressure at the
upstream pump station while operators employed vacuum trucks to contain the flow within the
temporary excavation thus minimizing 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. See Exhibit 3 – Containment and Collection Efforts.

Exhibit 3 – Containment and Collection Efforts

Cleanup consisted of removing and disposing of sewer debris from the excavation. The area around the
bore-through pipe 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.
Raleigh Water Repair Crews were able to repair the damaged section of forced main restoring
operations at the lift station. Raleigh Water Code Enforcement group was summoned to assess the
damage and to assign the associated cost of the incident against the contractor. The total cost of the
City's response and remediation effort for this spill event was $5,814.22
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
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.

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Exhibit 4 – Press Release

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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 greatly 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 2600 miles of sanitary sewer pipe and minimize
the accidental release of untreated wastewater.

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 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
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in the proper use of the sanitary sewers to prevent 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-0109 issued for the
month of March 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 (919) 996-
2312 or John Kiviniemi, Assistant Raleigh Water Director, at [phone]

Sincerely,

Carlos M Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh, Public Utilities Department
P.O. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
[e-mail]