WQCS00002_NOV-2022-DV-0236 RSP_20221011

October 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-0236
Sanitary Sewer Overflows — July 2022
Permit No. WQCS00002
Dear Mr. Vinson:
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Raleigh Water iisle><ghRegtonal0
NC Dept of Environmental Quality
OCT If 2022
Raleigh RcSionai office
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2022-DV-0236) received on August 201h, 2022. This document contains the narrative regarding
pending violation actions of (4) Sanitary Sewer Overflow (SSO) events, reported on the month of July 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 fo feasible alternatives to the SSO, such as the use of auxiliary treatment facilities, retention of
untreated wastewater, reduction of inflow and infi tration, use of adequate backup equipment, or an increase in the capacity of the system. This pnivision 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 # 202201041— 07/04/2022 — 7703 Oak Marsh Dr., Raleigh NC
This spill was neither willful nor intentional; it resulted from a failed 6" ductile iron sewer forced main. This
asset failure led to a sewer spill of approximately 1,600 gallons of untreated wastewater remaining within the
natural topography and not reaching surface water of the state (see exhibit 1— Area of Operation).
Exhibit 1 - Area of Operation
On Monday, July 4th, 2022, at approximately 12:05 PM, Raleigh Water Utility Responders were notified of
wastewater emanating from the ground near 7703 Oak Marsh Dr., Raleigh. 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 2:05 PM.
Utility Responders were able to contain and collect the wastewater by utilizing vacuum trucks in tandem and
controlling wastewater flow from the nearest pump station. Crews were able to collect the untreated
wastewater flow in tanks preventing the wastewater from continuing downstream. The natural topography of
the surrounding land, downstream of the affected asset, served to partially contain approximately 1,600 gallons
of untreated wastewater. The ground surrounding the affected manhole absorbed a vast portion of untreated
water before it reached surface waters of the Neuse River. See Exhibit 2 -- Temporary containment. This spill was
temporarily 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, repair crews replaced the damaged section of force main (see
Exhibit 3 - Damaged Pipe and Subsequent Repair). The repair was made possible by reducing wastewater flow at
the nearby pump station. Once the force main was excavated, crews applied a 360° containment band replacing
approximately 4 ft. of ductile iron pipe. Once the repair was completed, the force main was pressurized to verify
the effectiveness of the repair, and no subsequent leaks or repair failures were noted. Crews restored the site by
backfilling the excavation with stable structural aggregates and restoring the ground surface with seed and
straw. Sewer -contaminated soil was mechanically removed and the area surrounding the pipe break was
cleaned with ample potable water to remove sewer traces from the surrounding area, and downstream
conveyance. The area was then treated with an application of lime and restored with grass seed and straw. See
Exhibit 4 — Site Restoration.
Exhibit 4 —Site Restoration
The cost associated with the mitigation of this event (including the repair efforts) amounted to $5,208.35. The
approximate cost to the Utility to have treated 1,600 gallons of wastewater would have been approximately
$2.40. The City saved no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of
sewage had no spill occurred. Furthermore, the City still had to pay the cost to treat the greater volume of
sewage created by the spill.

A press release notification 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.
See ExNbrt 5 — Press Release
Raleigh Water Responds to a Sanitary Sewer Spill
On Monday July 4.2022 at approdmatey 128 PM Raleigh Water staff
responded to a sardlary sewer overflow located M 7T03 Oak Marsh Dr RaldgiK NC
27616. The mpwnding staff look all reasonable Stops to stop and mlflgate the
ovagoWs impact as soon ea they arrived. The North t.sroflna Depamnam of
Environmental Quality, Dlvls on of Water Resources has been noded of the overflow.
Raleigh Water staff contained the overflow at approximately 3.05 PM on dte
same day It is eamated that the overflow discharged a yoke" of approAmately 1.600
gallons of unweated wastewarer The *vwkw dd not reach any surface watses of caw
state. Repair to the affecting aseat was completed on the same day along with
restoration of the affected area. No vegeladw damage or fish Idle has been observed
re4ted to tlds event
Raleigh Water has an aggmseWs education and enfarcanent program to
pmvent the discharge of grease, debris. wipes. rags. diapers and other
improper materials in the sewer system and to take salorce oven action
whom appropriate. ff dmse hams male It Into the sewer system, they may
cause a spill wh" can have an adverse Impact an watrr quality and
endanger those Who came Into contact with the affected area.
• Water, human waste, and toilet tissue are the only trams parmhtad to be
discharged Into the sewer sysissm All other hems will cause damage to the
sewer system and am not grmhted.
If you experlenor excessho sewer smalls ter sae sower spilling from
manholes or pipes, please call 91939&3245 to report knnwdletey.
For more Information about how you can help prawnt sanitary sewer
spills, please visit ~rtc.govlwster.
TM news miesee is negaied by NCGS Article 21 Chapter 143 215 1 C
Prior to this sewer event, this asset experienced ruptures which have been noted and placed in a future Capital
Project for improvement. In the last ten years this asset has been addressed as follows:
Previous SSOs
Previous Repair Activities
4/19/2021
2/13/2018
4/23/2022
11/3/2020
5/30/2021
11/23/2020
7/17/2021
4/19/2021
11/8/2021
4/23/2022
6/6/2022
5/28/2021
6/7/2022
7/17/2021
7/4/2022
11/8/2021
6/6/2022
7/4/2022
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 spot pending the completion of further Capital Improvements.
4

Incident Number # 202201195 — 07/26/2022 -- 6321 Winter Spring Dr., Wake Forest NC
This spill was neither willful nor intentional. It resulted from a broken 8" PVC pipe located 40' upstream from
sewer manhole SMH130985. This pipe failure restricted the normal flow of untreated wastewater leading to the
sewer spill of approximately 3,600 gallons of untreated wastewater reaching an unnamed tributary within Smith
Creek Basin. See Exhibit 1—Area of Operation and Damaged Section of Pipe.
Exhibit 1- Area of Operat=on and Damaged Section of Pipe
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On 07/26/2022, at approximately 10:41 AM, Raleigh Water staff responded to a sanitary sewer overflow
emanating within an unnamed tributary located near 6321 Winter Spring Dr., Wake Forest NC. The responding
staff took all reasonable steps to stop and mitigate the impact of the discharge, gaining control of the spill event
by 02:15 PM on the same day.
Containment and collection of this spill event consisted of emplacing a sewer bypass and rerouting untreated
wastewater flow from manhole SHM132959 to manhole SMH130985 thus isolating the damaged segment of the
sewer main from continuing to flow into the stream (see Exhibit 2 — Bypass Operation). This approach was
intended to contain wastewater flow and minimize the environmental impact on the surrounding land.
Responding crews also employed debris pumps at the temporary containment site to recover untreated
wastewater and any evidence of sewer debris 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, repair crews replaced the damaged section of the sewer gravity
main (see Exhibit 3 — Sewer Main Repair Effort). The repair was made possible by eliminating wastewater flow
utilizing a sewer bypass (see Exhibit 3 — Sewer by-pass). Once the sewer gravity main was excavated, crews
applied a 350° containment band replacing approximately 20 ft. of ductile iron pipe. Once the repair was
completed, the sewer main was inspected through CCTV to verify the effectiveness of the repair. CCTV
confirmed that no subsequent leaks or repair failures were noted. Crews restored the site by armoring the
creek's bank with stable structural aggregates and restoring the ground surface with seed and straw. Sewer -
contaminated soil was mechanically removed and the area surrounding the pipe break was cleaned with ample
potable water to remove sewer traces from the surrounding area, and downstream conveyance. The area was
then treated with an application of lime and restored with grass seed and straw. See Exhibit 4 — Site Restoration.
Exhibit 3 - Sewer Main Repair EHprt
0

Exhibit 4 — Site Restoration
The cost associated with the mitigation of this event (including the repair efforts) amounted to $47,208.83. The
approximate cost to the Utility to have treated 3,600 gallons of wastewater would have been approximately
$5.40. 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 within a residential area. It provides sewer collection services to
approximately 360 residences. This specific portion of the collection system has not experienced an SSO event
within the last ten years.

A press release notification was requested to be published in the Raleigh News & Observer as required by NCG5
Article 21, Chapter 143.215.1C, See Exhibit 5 — Press release.
See Exhibit 5 - Pr
Raleigh Water Responds to s Sanitary Sewer Spill
On Monday Jury 25 2022 al apprordmatep tg:e3AM, Raleigh water start
responded to a sanitary sewer spill located at 6321 VAnter Sprung Dr Wake Forest. NC.
27616 The "a was the resull or a faded sewergravity main. The responding staff look
A reasonable steps to stop and mitigate the spdrs Impad as soon as they anired The
NoM Cantina Departmenl of Envirorvnenlal QuaW Divlslon of Watar Resources has
been notified of the spill
Raleigh water start eantainad the spill at approxdmatery 2.0013M on the ume
day It is estimated that the spill discharged a volume of apprwdmatey 360Q gallons of
untreated waetewaler reaching an unnamed ItUdary within the Smith Creek Basin
Repair to the atecting asset Is underway aWQ with restoration of Me affected area No
u uwKxmary vagetatve damage or fish kill has been observed related to M event
Raleigh Water has an aggressive education and enrorcernum 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 ire affected areas.
Water, human waste, and toilet Issue are the oey items permitted to be
discharged Into the sewer system. All other items will aunt damage to the
sewer system and are not permitted.
• It you experience excesetve sewer entails or we sewer spiting from
manholes or plpee, please all 61 g-"6324b to report lownediately.
For more Informaton about how you an help prevent unitary sewer
spins, please visit: releighne.govMeter.
This news release is required by NCGS Artcb 21 Chapter 143 215.1 c
"a
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
Repair
CCTV Activities
Inspections Activities
7/23/2020
8/8/2022
9/26/2017
There have been 77 inspections completed
7/24/2020
7/27/2022
7/26/2022
between 3/15/2018 and 8/29/2022
9/15/2020
9/21/2020
8/1/2022
1. Manhole Inspections— 10
8/8/2022
2. Sewer High Priority Inspections —67
5/25/2022
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.
8

Incident Number # 202201201— 7/27/2022 — US 70-BR E., Garner, NC
This spill was neither willful nor intentional; it resulted from an obstruction in the invert impeding the normal
flow of untreated wastewater. This obstruction resulted in approximately 4,800 gallons of untreated wastewater
to reach White Oak Creek located within the White Oak Basin. See Exhibit 1— Debris in the manhole.
On 07/27/2022, at approximately 1:45 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sewer manhole near the exit ramp of US HW 70 East, Garner, NC. The responding staff took all
reasonable steps to stop and mitigate the impact of the discharge, gaining control of the spill event by 3:57 PM
on the same day.
Exhibit 1— Debris in the manhole
Crews utilized hydraulic jetting and manual tools to remove the source of the blockage from the affecting asset
thus restoring sewer flow. Upon further assessment it was observed that the cause of the blockage was a
dislodged manhole step that laid at the bottom of the manhole invert causing a disruption of normal flow. It was
also noted that although grease did not contribute to the spill, there was grease accumulated within the
confines of downstream manholes. As a precaution a temporary spill containment site was emplaced
downstream of the affected area to contain the flow of untreated wastewater and minimize the environmental
impact to the surrounding land. The manholes found to have grease accumulation were serviced with hydraulic
jetting and degreaser.
Restoration of this spill event consisted of washing the land surrounding the affected asset. Sewer debris and
solids were collected and disposed of accordingly. Crews utilized ample potable water to flush the affected area.
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 that 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 approximately $3,885.92. The approximate
cost to the Utility to have treated 4,800 gallons of wastewater would have been approximately $7.20. 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 sanitary sewer collection system services a vast commercial complex housing several food -
service establishments within the Garner Service area. A F.O.G. consultation found only two restaurants (out of
29) not in compliance and subsequently were assessed notice of violations.
There have been no additional issues associated with this section of the collection system since the last sewer
event. This site remains an active maintenance spot. A press release notification associated with this event was
requested to be published in the Raleigh News & Observer on July 28th, 2022 (see Exhibit 4 — Press Release).
Before this event, maintenance records show that sections within the collection system were assessed in the last
10 years as follows:
Flushing activities
11/12/2017
3/1/2018
11/28/2017
3/6/2018
11/30/2017
4/9/2018
12/1/2017
7/19/2022
12/2/2017
Repair inspections Activities
4/9/2018 There have been 8 Easement Inspections
completed between 8/8/2018 and 10/27/2022
1. Manhole Inspections-1
2. Sewer High Priority Inspections — 7
There have been 119 FOG assessments completed
between 8/8/2018 and 10/27/2022
10

Exhibit 4 - Press Release
Raleigh Water Responds to a Sanitary Sewer Split
On Wednesday, July 27. 2022 at approximately 145 PM. Raleigh Water staff
responded to a sanitary sewer spill located near the exit ramp on US 70 Highway E ,
Gamer The spill was the result of debris accumulation on a manhole The responding
slatrtook a0 reasonable steps to stop and mitigate the spilh -mpact as soon as they
armed The North Carolina Department of Environmental Quality Division of Water
Resources has been notified of the spill
Raleigh Water staff contained the split at approximately 3,57 PM on the same
day It is estimated that the spill discharged a volume of approximately 6,600 galons of
untreated wastewater of which roughly 4 800 gallons reached While Oak Crack iAustin
pencil within the While Oak Basin Restoration of the affected area was compleled on
Thursday July 28 No unnecessary vegetative damage or fish IN has been observed
related to Ibis event
Raleigh Water has an aggressive education and enforcement program to
prevent the discharge o1 grease, debris, wipes, rage, diapers and other
improper materials i n the server system and to take enforcement action
where appropriate. If these items make it into the sewer system, they may
cause a spill whleh can have an adverse Impact on water quality and
endanger those who come into contact with the affected areas.
Wafer, 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.
B you experience excessive sewer smalls 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 vied.• raleighnc.govhveter.
This news release is required by NCGS Article 21 Chapter 143.215 1C
11

Incident Number # 202201208 — 07/28/2022 — intersection of Major Slade Rd / Smithfield Rd, Knightdale, NC
This spill was neither willful nor intentional; it resulted from a failed 16' Polyvinyl Chloride Pipe force main. This
asset failure led to a sewer spill of approximately 4,000 gallons of untreated wastewater to spill unto the land.
Approximately 1,000gallons reached an unnamed tributary within Poplar Basin (see exhibit 1—Area of
Operation).
1- Area of Operation
On Thursday, July 281", 2022, at approximately 6:45 AM, Raleigh Water Utility Responders were notified of
wastewater emanating from the ground near the intersection of Major Slade Rd & Smithfield Rd, Knightdale, NC.
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 3:08 PM.
Utility Responders were able to contain and collect the wastewater by utilizing vacuum trucks and controlling
wastewater flow from the nearest pump station. The natural topography downstream of the affected asset, and
the excavation surrounding the affected force main served to partially contain approximately 3,000 gallons of
untreated wastewater before it reached surface waters. See Exhibit 2 —Temporary containment. This spill was
temporarily 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.
12

During the restoration phase of the operation, repair crews replaced the damaged section of force main (see
Exhibit 3 - Damaged Pipe and Subsequent Repair). The repair was made possible by reducing wastewater flow at
the nearby pump station. Once the force main was excavated, crews applied a 360' containment band replacing
approximately several feet of ductile iron pipe. Once the repair was completed, the force main was pressurized
to verify the effectiveness of the repair, and no subsequent leaks or repair failures were noted. Crews restored
the site by backfilling the excavation with stable structural aggregates and restoring the pavement to travel
conditions. Sewer contaminated soil was mechanically removed and the area surrounding the pipe break was
cleaned with ample potable water to remove sewer traces from the surrounding area, and downstream
conveyance. See Exhibit 4 — Site Restoration.
Exhibit 3 - Damaged Pipe and Subsequent Repair
13

The cost associated with the mitigation of this event (including the repair efforts) amounted to $28,809.16. The
approximate cost to the Utility to have treated 4,000 gallons of wastewater would have been approximately
$6.00. 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.
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,
See Exhibit 5 — Press Release
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There is no history of infrastructure failure with this asset prior to this sewer event. There have been no
additional issues associated with this section of the collection system since the last sewer event.
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 2022 (Fiscal Year 2023), the Utility has assessed approximately 66.58 [11 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
$ 885,577.46121, approximately .06% of the Division's annual operating budget. The 24,000 gallons of untreated
wastewater spills identified in this letter cost the Utility approximately $75,112.26. to mitigate. The City's cost of
sewer treatment per gallon is $.0015 �11. At this rate, it would have cost the City $21.00 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
0.65 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. In the previous Fiscal year 22 total performance miles assessed were 417.34 Miles at a cost of
$ 2,829,598.09,
[1166.58 miles represents 0.025%of the sanitary sewer collection system
(2) Associated operational cost year to date for FY2023
OPERATION
LINEAR FEET Unear Miles
COST
CCTV
133, 28.71 21.56
$
113,200.90
Repair
1,310 0.25
$
652,202.98
Flushing
236,390.8 44.77
$
120,173.s8
Total cost
of Business to Date
Total- 171,519.51 Ft/$6.58 MILES
$
895,577.46
[31 $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
141 The current SSO Rate for FY 23 is 0.65
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.
15

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.govZsewer-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-0236 issued for the month of July 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.
dni
Q�-
incerely,
Carlos M Perez, ORC-NC WPCSOCC # 1003875
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 raleiphnc.Gov
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