WQCS00002_NOV-2022-DV-0193 Response_20220811

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Raleigh Water
August 11th, 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-0193
Sanitary Sewer Overflows — May 2022
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept et Environmental Quality
AUG 1 1 2022
Raleigh Regional Office
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil
Penalty document (NOV-2022-DV-0193) received on July 20t", 2022. This document contains the
narrative regarding pending violation actions of (2) Sanitary Sewer Overflow (SSO) events, reported on
the month of May 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 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:
la.] 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
+ystem components, wastewater retention or treatment facilities, adequate back-up equipment .r should have reduced inflow and infiltration; or
[b.] The 550 was exceptional, unintentional, temporary, and caused by factors beyond the reasonable control of the Permittee; the 550 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 collects n facilities to at.ommndate growth or adequately controlling and preventing
infiltration and inflow); preventative maintenance; or installation of adequate back-up equipment;"
Page 1 of 11

Incident Number # 202200705 — 05/04/2022 — 208 Blanchard St., Raleigh
This spill was neither willful nor intentional, it was the result of grease accumulation, which
blocked a portion of a 6-inch vitrified clay pipe gravity sewer main. The grease accumulation led to a
sewer spill of approximately 1,200 gallons of untreated wastewater reaching a nearby stormwater
channel within the Wildcat Basin. The wastewater was contained within the stormwater ditch and did
not reach Wildcat Bran€h. See exhibit 1 Area of Operation
ixhih t 1 •• Area of Operation
r 7
On 05/04/2022, at approximately 10:56 AM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset 5MH120251 1) located near 208
Blanchard St., 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 11:56 AM on the same day. Crews utilized hydraulic
jetting to remove the source of the blockage within the affecting asset 2, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
approximately 570 ft downstream of the affected area restricting sewer flow on the stormwater
channel. 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 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.
1 Affected Asset Structure within the collection system that allowed the release of untreated wastewater into the environment. typically a sewer manhole
2. Affecting Asset: Structure within the collection system that housed a blockage which resultrd in an SSO typically a sewer gravity main
Page 2 of 11

A CCTV assessment did not identify any infrastructure deficiencies that may have contributed to the
grease accumulation. No further maintenance or follow-up service was recommended. See Exhibit 2 —
CCTV Assessment
Exhibit 2 — CCTV As+essment
USMH: SMH120251
DSMH: SMH152173
The cost associated with the mitigation of this event amounted to $713.83. The approximate cost to the
Utility to have treated 1,200 gallons of wastewater would have been approximately $1.80. Raleigh
Water saved no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of
sewage had no spill occurred. Furthermore, Raleigh Water 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 over 88 properties surrounding the spill event (see Exhibit 3- Zone of Influence 3).
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.
Exhibit 3 Zcne of nfluence
3. Zone of Influence: Area upstream frcm an 5S0 that contains homes cr businesses whose discharge of wastewater may have contributed to the
creation of a system blockage Ident.fying this area is critical to analyi ng potent al sources of illicit discharges such as grease or rags that generate
blockages, as well as determ ning where educatrona+ materials can be distributed post -incident to educate residents regarding the groper use of the
col ection system.
Page 3 of 11

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. 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.
Exh.bit 4 Press release
Raleigh
NEWS RELF A e
COMMUNICATIONS DEPARTMENT
May 4, 2022
For more information
Matthew P. Vessie, Sewer Maintenance Manager, Raleigh Water. 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Wednesday. May 4 2022 at approximately 10:56 AM, Raleigh Water staff
were notified of a sanitary sewer overflow in the vicinlly of 208 Blanchard St.,
Raleigh NC Upon arrival, Utility responders identified an active sewer overflowing
resulting from grease within the 8-inch sewer main The responding staff took al
reasonable steps 10 stop and mitigate the overflow's impact as soon as they arrived
The North Carolina Department of Environmental Quality, Division of Water Resources
has been notified of the overflow
Raleigh Water staff removed the blockage source and contained the overflow at
approximately 11 56 AM on the same day it is estimated that the overflow discharged a
volume of approximately 1,200 gallons of untreated wastewater in which all 1 200
gallons was collected before reaching surface waters Restoration for this event has
been completed There was no observed fish NCI or unnecessary vegetative damage
resuttirg from this sewer 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. ff these items make it into the sewer system, they may
cause a spill which can have art adverse impact on water quality and
endanger those who come into contact with the affected areas.
• Water, human waste, and toilet tissue are the only items permitted to be
discharged into the sewer system. All other items will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or sea sewer spilling from
menhoks or pipes, please call 919-996-324510 report immediately.
• For mom Information about how you can help prevent sanitary sewer
spills, please visit: raleighnc.govlwater.
This news release is required by NCGS Article 21. Chapter 143.215 1C
Page 4 of 11

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:
Repair Inspections Activities
Flushing activities CCTV Activities {Manhole Inspection
Activities
Sewer High Priority Inspection)
3/22/2012 10/16/2014 3/27/2012 9/24/2018 12/15/2021 3/23/2020
3/27/2012 12/22/2015 10/16/2014 3/6/2017 3/5/2018 11/5/2020
3/29/2012 1/29/2018 2/20/2017 1/30/2018 6/13/2018 9/10/2020
8/1/2013 9/25/2018 1/30/2018 3/28/2019 6/13/2018 2/16/2021
8/2/2013 9/26/2018 10/8/2018 8/22/2018 1/31/2019 8/20/2021
10/8/2013 10/8/2018 10/9/2018 6/20/2019 3/14/2022
10/21/2013 10/10/2018 10/10/2018 6/19/2019 8/1/2022
9/10/2014 10/10/2018 12/17/2019
10/18/2018
8/22/2019
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.
Page 5 of 11

Incident Number # 202200737 — 05/09/2022 —1530 S. Gleneagle Dr. Garner
This spill was neither willful nor intentional, it resulted from a failed 12-inch reinforced concrete
pipe gravity sewer main. This asset failure led to a sewer spill of approximately 9,550 gallons of
untreated wastewater reaching surface waters of Buck Branch, within the Benson Basin.
On 5/9/2022, at approximately 09:24 PM, Raleigh Water staff was notified of a sewer spill emanating
from the ground, near 1530 5. Gleneagle Dr., Garner. Upon arrival, crews proceeded to break the
blockage but encountered a large amount of silt and sand, indicative of a possible main break. Crews
also identified a sinkhole on the easement aligned with the sewer main. Due to these observations, it
was determined that the sewer spill was attributed to a possible pipe collapse. See Exhibit 1— Damaged
Section of Gravity Main
Exhibit 1— Damaged Section of Gravity Hain
A CCTV assessment was utilized to attempt to confirm the condition of the sewer main and to determine
the scope of repair needed. This assessment focused on the affecting asset, SGMN128887, which is
located on a sanitary sewer easement in Garner that runs through a residential area. This outfall
originates near the US Hwy 70 and Yeargan Rd intersection and captures primarily residential flow, with
some commercial input as well. Commercial users include two food service establishments and one
public school. The CCTV confirmed that repair would be required and that due to the pipe diameter and
its wastewater flow the work would be referred to the Raleigh Water Capital Improvements Division for
contractor support. The responding staff took all reasonable steps to stop and mitigate the impact of the
discharge as soon as they arrived. The asset was placed on bypass to eliminate the overflow, containing
the spill event by 12:35 AM the following morning. See Exhibit 2 —Temporary Sewer by-pass.
Collection efforts of this spill event consisted of employing a temporary spill containment site
downstream of the affected area restricting sewer flow on the creek. 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.
Page 6of11

Exhibitz-Temp=*Sewer by- pass
During the restoration phase of the operation, crews removed the contaminated soil from the affected
area to include the downstream conveyance. The surrounding area was then treated with an application
of lime and properly restored with grass seed and straw. Once the bypass was established crews
proceeded to clean the adjacent creek removing sewer traces from the downstream conveyance.
Repair efforts toaddress this sewer main were relinquished toalicensed utility contractor. Contractors
successfully replaced approximately 360 ft of concrete pipe with 12-inch PVC. See Exhibit 3 —Scope of
Repair Effort.
Exhibit 3 —Scope of Repair Effort
Page 7 of 11

The cost associated with the mitigation of this event amounted to $182,075.75. The approximate cost to ,
the Utility to have treated 9,550 gallons of wastewater would have been approximately $14.32. The City
saved no money from this spill. Its costs for cleanup and repair 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.
The events leading to this spill can be considered exceptional, unintentional, temporary, and caused by
factors beyond our reasonable control. Furthermore, the 550 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.
A press release notification related to this event was requested to be published in the Raleigh News &
Observer on May loth, 2022. There have been no further sewer events associated with this location.
Exhibit 4 — Press release
Raleigh
NEWS RELEASE
COMMUNICA1lONS DEPARTMENT
May 10 2022
For more mlormation
Matthew A Vessie Sewer Maintenance Manager Rale.gh Water. 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Monday May 9 2022 at approximately 924 PM Raleigh Water staff were
notified of a sanitary sewer overflow in the vicinity of 1530 S Gleneagle Dr
Gamer NC Upon arrival. Uthty Responders Identified an acute sewer overflow
resuf Uig from asset Wm* within the 12.inch main The responding staff took an
reasonable steps to stop and mitigate the overflow's impact as soon as they arrived
The North Carolina oepadment of Environmental Quaity, Division of Water Resources
has been notified of the overflow
Raleigh Water staff worked to remove the blockage source and determined it to
be asset failure The overflow was stopped at approximately 12 35AM on Tuesday May
10 2022 It is estimated that the overflow discharged a volume of approximately
9 550 gallons of untreated waste water reached surface waters within the Swill Creek
River Basin Restoration for this event Is currenily a ongoing operation There was no
observed fish MI or unnecessary vegetative damage resulting horn this sewer event
Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debris, wipes, rags, diapers end other
improper materials in the sewer system and to take enforcement action
where appropriate. 1f 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 ere not permitted.
• If you experience excessive sewer smells or see sewer 'pilling from
manholes or pipes, please call 919-996 324510 report immediately.
• Far more information about how you can help prevent sanitary sewer
spills, please vi'It: ralelghnc.govlweter.
This news release is required by NCGS Article 21 Chapter 143 215.1C
albs
Page 8 of 11

, 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
Easement Inspections Activities
Activities (Manhole Inspection
Sewer High Priority Inspection)
5/19/2022 6/29/2020 5/13/2022 1/11/2018 10/11/2019
12/8/2017 6/3/2022 6/9/2022 1/12/2018 1/6/2020
12/8/2017 5/10/2022 6/15/2022 1/16/2018 1/22/2020
12/8/2017 5/19/2022 4/3/2018 4/20/2020
9/18/2017 7/6/2022 4/10/2018 6/3/2020
12/8/2017 12/11/2020 10/18/2018 7/17/2020
7/6/2022 4/12/2019 7/20/2020
10/31/2019 7/13/2020
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.
Page 9 of 11

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 150 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.
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 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.
Page 10 of 11

On behalf of the City of Raleigh, I am requesting that the NOV-2022-DV-0193 issued for the month of
May 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-
312, or Carlos M. Perez, ORC, Assistance Superintendent 919-996-5929.
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.perezcamachoPraleighnc.Gov
Page 11 of 11

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