WQCS00002_NOV-2022-DV-0273 Response Received 20221014_20221014

1111 )
10
Raleigh Water
October 14th, 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-0273
Sanitary Sewer Overflows — August 2022
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept of Environmental Quality
OCT 1 4 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-0273) received on September 28th, 2022. This document contains the narrative
regarding pending violation actions of (5) Sanitary Sewer Overflow (SSO) events, reported on the month of
August 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 550 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:
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
retent'Ion or treatment facilities, adequate back-up equipment or should have reduced inflow and infiltration; or
[b.I The 550 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 le.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"
1

Incident Number # 202201249 — 8/04/2022 — 5500 Crossfield Dr., Raleigh
This spill was neither willful nor intentional, it was the result of root intrusion, which blocked a portion of an 8-in
gravity sewer main. The root intrusion led to a sewer spill of approximately 1,575 gallons of untreated
wastewater in which roughly 975 gallons reached a nearby storm drain in the Sycamore Creek Basin (see Exhibit
1— Area of Operation)
Exhibit 1— Area of Operation
AffectingA set
',:.SGMN 160689
On 08/04/2022, at approximately 5:48 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH110644) located near 5500 Crossfield Dr.,
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 07:33 PM on the same day. Crews utilized hydraulic jetting to remove the
source of the blockage within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
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. See Exhibit 2
— Site Restoration.
2

Exhibit 2 — Site Restoration
A follow up CCTV assessment did not identify any infrastructure deficiencies that would indicate root intrusion
through a gap , crack or opening. Subsequently the sewer main was further cleaned to remove potential root
intrusion. The CCTV assessment did not identify any other deficiencies requiring further maintenance.
The cost associated with the mitigation of this event amounted to $1,203.92. The approximate cost to the Utility
to have treated 1,575 gallons of wastewater would have been approximately $2.36. 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 100 properties surrounding the spill event (see Exhibit 3- Zone of Influence). This area has been
placed on routine maintenance for chemical root control.
Exhibit 3- Zone of influence
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.
3

Exhibit 4 - Press release
Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
August 5. 2022
Fa more information
Matthew P. Vessie, Sewer Maintenance Manager, Raleigh Water, 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Thursday. August 4. 2022 at approximately 5 48 PM_ Raleigh Water staff
responded to a sanitary sewer spill located at 5500 Cressfseld Way Raleigh. NC- The
responding staff took all reasonable steps to stop and mitigate the spills Impact as
soon as they arrived_ The North Carolina Department of Environmental Quality
Division of Water Resources has been notified of the spill
Raleigh Water staff contained the spill at approximately 7 33 PM on the same
day It is estimated that the spill discharged a volume of approximately 1.575 gallons of
untreated wastewater in which approximately 975 gallons reached a nearby storm drain
in the Sycamore Creek basin Restoration for this event has been completed There
was no observed fish kill or unnecessary vegetative damage resulting 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, 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.
• 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: raleighnc.govfwater.
This news release is required by NCGS Article 21 _ Chapter 143 215 1 C
#bW
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
3/9/2017 11/30/2017
3/10/2017 12/1/2017
4/4/2017 12/5/2017
5/16/2017 12/7/2017
6/15/2017 12/11/2017
6/16/2017 2/23/2018
6/20/2017 4/21/2022
8/14/2017 08/5/2022
9/14/2017
10/2/2017
10/11/201
10/17/201
11/30/201
3/17/2018
3/1/2020
3/8/2021
08/17/2022
Easement
Maintenance
Activities
2/2/2018
8/9/2018
6/22/2020
Repair Activities Inspections Activities
9/27/2017
313 sewer asset
inspections since 2018
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, CCTV assessment, and chemical root control application.
4

Incident Number # 202201270 — 8/8/2022 — 3101 Compatible Way, Raleigh, NC
This spill was neither willful nor intentional; it resulted from a private land -clearing activity in which sections of
the manhole top were mechanically dislodged causing damage to the manhole cover. A broken section of the
manhole cover was found inside the sewer manhole which created a blockage that disrupted normal
wastewater flow within a portion of an 8-inch Polyvinyl Chloride gravity sewer main (see Exhibit 1— Broken
manhole cover). The blockage led to a sewer spill of approximately 3,200 gallons of untreated wastewater in
which approximately 3,000 gallons reached a stormwater channel never reaching surface waters. Approximately
200 gallons remain on the ground. The spill flow was contained within the stormwater channel at approximately
1100 ft. before it reached an unnamed tributary of Walnut Basin. See Exhibit 2 - Area of Operation.
Exhibit 1- Broken manhole cover
Exhibit 2 - Area of Operation
On 08/08/2022, at approximately 2:32 PM, Raleigh Water staff were notified of a manhole spilling over. 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 4:40 PM on the same day. Utility Responders utilized hydraulic jetting and manual debris removal
tools to rid the source of the blockage within the affecting asset, thus restoring sewer flow. See Exhibit 3 — Spill
Mitigation Efforts.
5

Exhibit 3 - Spill Mitigation Efforts.
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
wastewater 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 several thousand gallons of potable water to assist
in washing the creek and remove all 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.
Repair crews repaired and replaced the damaged section of the manhole with a new ring and cover (see Exhibit
4 — Repair and restoration efforts).
Exhibit 4 - Repair and restoration efforts
6

A follow-up CCTV investigation (conducted after the SSO mitigation and repair efforts) did not find any further
evidence of infrastructure deficiencies that would have influenced the SSO. The broken manhole cover was
identified as the root cause of this SSO. Additionally, the CCTV investigation identified a buried manhole
downstream of the spill site. As a result of this finding, Crews were able to raise the manhole to adequate
engineering specifications (see Exhibit 5 — Manhole Raising Efforts). Visual inspection of the affected area and
downstream waters confirmed no fish kill or unnecessary vegetative damage occurred.
Exhibit 5 - Manhole Raising Efforts
The cost associated with the mitigation of this event amounted to $7,437.88. The approximate cost to the Utility
to have treated 3,200 gallons of untreated wastewater would have been approximately $4.80. 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 and the cost of potable water used to mitigate the event.
This section of the collection system is located downstream of a residential area. It provides sewer collection
services to a multiunit residential complex (see Exhibit 6- Zone of Influence). The last recorded SSO for this
section of the Collection system was attributed to grease accumulation on 06/26/2019 (incident number
201901112).
Exhibit 3- Zone of Influence
7

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 7 — Press release.
Exhibit 7 — Press release
Raleigh
NEWS RELEAS
COMMUNICATIONS DEPARTMENT
August 6 2022
Fre more mlormabon
Matthew P Vessie. Sewer Maintenance Manager, Raleigh Wafer, 919-996-3245
Opp '44
Raleigh Water Responds to a Sanitary Sewer Spill
On Monday. August B_022 at approximately 232 PM Raleigh Water staff were
notified of a sanitary sewer overflow In the vicinity of 3101 Compatible Way
Raleigh NC Upon amval Uhld7 responders identrlied an active sewer overlay/ The
responding staff look all reasonable steps la stop and mitigate the overflow I impact se
soon as they arrived The North Carolina Department or Environmental Ovally Division
of Water Resources has been notified al the overflow
Raleigh Water staff removed the blockage source and contained the overflow at
approximately 4 40pm on the same day R Is estimated that the overflow discharged a
volume of approximately 3.200 gallons of untreated wastewater el which approximately
3.000 gallons reaching a nearby storm drain in me Walnut Creek basso Restoralicn ter
this event is currently shill in process There was no observed fish kill or unnecessary
vegetative damage resulting from this sewer event
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge o1 grease. debris, wipes. rags. diapers and other
improper materials rn 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. Alt other items wilt 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 419.996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer
spills. please visit: raleighnc.gov+watar.
This news release is required by NCGS Article 21, Chapter 143 2 i 5 IC
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 Repair Activities Inspections Activities
4/2/2018 8/9/2022 8/9/2022 2/28/2018 6/24/2022
4/18/2018 4/17/2018 1/19/2021
4/19/2018 8/20/2018 1/15/2021
5/9/2018 2/28/2019 11/24/2021
4/11/2019 7/30/2019 2/4/2022
6/26/2019 2/20/2020 9/6/2022
8/9/2022 8/13/2020
8

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 further sewer main cleaning, CCTV
assessment, and chemical root control application. Furthermore, the assets associated with this portion of the
collection system have been added to the Hot Spot Management Program and have been identified for
recurrent assessment every 30 days. No further issues have occurred since this SSO event.
Finally, we consider this SSO was exceptional, unintentional, temporary, and caused by factors beyond the
reasonable control of Raleigh Water. 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; preventative maintenance; or installation of adequate back-up equipment.
9

Incident Number # 202201271— 8/9/2022 — 4609 Oak Park Rd., Raleigh NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of 8-inch polyvinyl chloride (PVC) pipe gravity sewer main. This build-up led to a sewer spill of
approximately 6,000 gallons of untreated wastewater remaining on the ground and not reaching the surface
waters of the state. (See Exhibit 1— Area of Operation)
Exhibit 1- Area of Operation
CnintaZneni and [ oII i a 4ni
On 08/09/2022, at approximately 2:07 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (5MH125400) located near 4609 Oak Park Rd., Raleigh NC. The
responding staff took all reasonable steps to stop and mitigate the impact of the discharge, gaining control of
the spill event by 3:10 PM on the same day. Crews utilized hydraulic jetting to remove the source of the
blockage within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary containment site at
approximately 3,300 ft downstream of the affected asset. 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.
10

During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and
remove sewer traces from the surrounding area. The area around the manhole and containment area was
cleared of debris, treated with an application of lime, and restored with grass seed and straw.
A follow-up CCTV assessment was conducted on 08/10/2022 to identify the root cause of the SSO. Additional
flushing of sewer gravity mains upstream and downstream of the affected asset was completed on 09/08/2022.
This hydraulic flushing did not identify any major issues with the main.
The cost associated with the mitigation of this event amounted to $7,023.05. The approximate cost to the Utility
to have treated 3,151 gallons of wastewater would have been approximately $4.72. The City saved no money
from this spill. Its costs for cleanup exceeded the cost of treating the volume of sewage had no spill occurred.
Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the spill.
This section of the collection system is located downstream of a residential area. It provides sewer collection
services to several properties upstream of the spill event (see Exhibit 2- Zone of Influence). This specific portion
of the collection system experienced a grease -related SSO event on 09/15/2019 (incident # 201901533). This
area has been placed under routine maintenance and several assets have been placed in the Hot Spot
Management Program for continued maintenance and assessment.
Exhibit 2- Zone of Influence
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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 3 — 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.
Esrhihit 3 — Press Release
Raleigh
NEWS RELEASE
COMe4UNICA f IONS DEPARWEINT
A94oml 10, 2022
For more mammalian'
dahn lOyirmarta. Assistant Dustin. rla k idh Wales_ 919-996-3245
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep AU Grease and Rags Out of the Shared
Sanitary Sewer System
On Tuesday. August 9 2022 at appwOvimateiy 2 OTpm Ratergh 'Water staff were
no -Shed of a saititay sewer spat in du ncindy or 4609 Oak Perk Rd.,
Raleigh NC Curry reepcnders Iderltihetl an active sever spill resulting from grease
and rags wtlte, the sandary sewer system The responding slam took al reason**
steps to slap and mitigate the spirts impact as soon as they armed. The Node Carole.
Department of Envuonmenlal Cuaiiy Dimon ol'Naler Resources sae been mobbed of
the spol
Raleigh Water stall removed the blockage source and conlamed the spilt at
approximalelk 3 10pm on Nee same day It is estknaled that the spi11 discharged a
volume or approximately 3 150 gallons al untreated wastewater Ip With 300 gaaors
did not reach surtaco waters doe lc ground conveyance Restoration for me event a
slit ongoing There was no observed fish kia or unnecessary vegetative damage
reaumng from this shiver event
Raleigh Water has an aggressive education end enforcement program to
prevent the discharge al grease, debris, wipes, raga, diapers and other
improper materials in the sewer system and to late enforcement action
where appropriate. N these items make it veto the sewer system. they may
cerise a .pill which can have an adverse impact on water quality and
endanger those who come veto contact with the affected areas_
Water human waste. and toilet tissue are the only item. permitted to he
discharged into the Sewer system. A11 other items will cause damage to the
sewer system and are not herniated.
If you experience excessive sewer smells or see sewer sealing from
manholes or pipes. please cell 919-996-3245 to report imniemately.
For more mlormation about how you can help prevent sanitary sewer
spins, please visiti raleighnc goveweter,
This news release is recurred bd r4C vS Article 21 Chapter 143 215 1C
agar
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 Easement Inspections Activities
Flushing activities CCTV Activities Maintenance
Activities
Activities
8/10/2022 8/2/2019 8/10/2022 11/8/2017 11/29/2017 Since July 2018 there has been:
10/19/2021 8/1/2019 3/19/2020 11/7/2017 8/3/2021 9 -Manhole lnspections
7/7/2020 7/24/2019 11/14/2019 8/16/2017 58- High Priority lnspections
5/27/2020 7/23/2019 10/31/2019 6/14/2017
10/15/2019 4/11/2017 9/23/2019 10/19/2017
10/9/2019 2/15/2017 9/19/2019 10/15/2018
9/17/2019 12/14/2017
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 the completion of further sewer main
cleaning and CCTV assessment.
12

•
Incident Number # 2022001326 — 8/20/2022 — 3809 Mid Lakes Dr., Raleigh NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of a 12-inch ductile iron pipe gravity sewer main. This build-up led to a sewer spill of approximately
1,920 gallons of untreated wastewater in which roughly 920 gallons reached a private stormwater pond in the
Crabtree Basin (see exhibit 1— Area of Operation). This Stormwater pond is not considered a source of drinking
water.
Exhibit 1—Area of Operation
On 08/20/2022, at approximately 7:10 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (SMH117876) located near the intersection of Flamingo Ln. and
Crispin Ct., Raleigh NC. The responding staff took all reasonable steps to stop and mitigate the impact of the
discharge, gaining control of the spill event by 8:46 PM on the same day. Crews utilized hydraulic jetting to
remove the source of the blockage within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
approximately downstream of the affected area restricting sewer flow onto the conveyance. This approach was
intended to contain wastewater flow and minimize the environmental impact on the surrounding land.
Responding crews employed vacuum trucks to recover 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, crews utilized ample potable water to flush the affected area and
remove sewer traces from the surrounding area and downstream conveyance. The area around the manhole
was cleared of debris, treated with an application of lime, and restored with grass seed and straw. See Exhibit 2
— Site Restoration.
13

A follow-up CCTV assessment was conducted on 09/1/2022 to identify the root cause of the SSO. The CCTV
Additional CCTV assessment and subsequent maintenance is scheduled.
The cost associated with the mitigation of this event amounted to $3,873.44. The approximate cost to the Utility
to have treated 1,660 gallons of wastewater would have been approximately $2.88. 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 3 — 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.
14

•
Exhibit 3—Press Release
vs ` Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
August 22, 2022
for more .donation.
John Knov ire. Ao.raWn1 °vector. Raleigh Water. 919.996-924S
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep All Grease Out of the Shared Sanitary
Sewer System
On Saturday. August 20 2022 al apwoxanalely 2 10 om Raleigh Wale, star
were routed of a sanitary sewer spill in the vsc.rny of 3809 Mid Lakes Ce..
Raleigh NC Liti0t responder iderterbed an active sewer spiN resulting from grease
vathin the sanitary sewer system The respooWnq slab look all reasonable Steps to slop
and mrpgate the Splits impact as soon AS they arrived The North Carolina Department
of Environmental puaI0y Umyen of Water Resources has teen nwhfied of the spat
Raleigh W aler staff removed the blockage SOUI05 and contained the spill at
approximately 5 45 pm on the same dab It is estimated that the soil abcharged a
✓ olume of approximately 1,920 gallons o1 unhealed wastewater in whim 920
g allons reached a slarmwaler contentment pond not designated as a drinking water
source This event occurred wahin the Crabtree Basin Reslorahcr ul the affected area
is ongoing No unnecessary vegetative damage er fish krs was observed related to this
evenl
Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease. debits. wipes, rags. diapers and other
improper materials in the sewer system end to take enforcement ath0n
where appropriate. It 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 wM the affected areas.
• Water, human waste, and toilet tissue are the only Items permitted to be
discharged into the Sewer system. All other 11ems will cause damage l0 the
sewer system and are not permitted.
11 you experience excessive sewer smells or see sewer spilling horn
manholes or pipes. please call 919-99e-51951n report immediately.
• For more Information ad0ut how you can help prevent sanitary sewer
spills, please visit raleighnc.govwater.
This news release .s requeed oy NCGS Annie 21. Chapter 143 213 ' C
apt
This section of the collection system is located downstream of a residential area. 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. 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
3/22/2014 6/28/2015
8/18/2014 10/18/2015
1/5/2015 08/20/2022
4/19/201
CCTV Activities
2020-01-29 10:30 AM
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.
15

Incident Number # 202201373 — 8/30/2022— 6498 Ray Rd., 3101 Compatible Way, Raleigh, NC
This spill was neither willful nor intentional; it resulted from a pipe failure resulting from possible erosion caused
by rapid moving sand sedimentation within the creek bed. This sedimentation may have been attributed to
wearing at the bottom of the gravity sewer main creating a small orifice at the bottom of an 8-inch Ductile Iron
gravity sewer main. This pipe failure did not cause any disruption to normal wastewater flow (see Exhibit 1 —
Failed pipe). The pipe failure led to a sewer spill of approximately 371 gallons of untreated wastewater reaching
Hare Snipe Creek. See Exhibit 2 - Area of Operation. Based on the size of the orifice it was estimated that the
spilled flow into the creek was approximately less than 1 gallon per minute.
Exhibit 1—Failed Pipe
Exhibit 2—Area of Operation
On 08/30/2022, at approximately 10:15 AM, Raleigh Water staff conducting a high -priority inspection on an
aerial sewer gravity main, identified liquid flowing into Hare Snipe Creek. The responding Easement Inspector
immediately requested a CCTV assessment to verify whether the liquid flow was untreated wastewater or
groundwater. CCTV Crews confirmed that the liquid flowing in the creek was untreated wastewater emanating
from the bottom of the sewer gravity pipe. Repair Crews immediately formulated a plan to correct and repair
the failed pipe. 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 4:26 PM on the same day.
16

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
wastewater 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.
Exhibit 3 - Spill Mitigation Efforts.
During the restoration phase of the operation, crews utilized ample potable water to assist in washing the creek
and remove all evidence of sewer downstream of the affected area. The area around the failed pipe was cleared
of debris, treated with an application of lime, and restored with grass seed and straw. Repair crews repaired and
replaced the damaged section of the pipe according to engineering specifications. See Exhibit 4— Repair and
restoration efforts).
Exhibit 4 - Repair and restoration efforts
17

A follow-up CCTV investigation (conducted after the SSO mitigation and repair efforts) did not find any further
evidence of infrastructure deficiencies. 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 $7,437.88. The approximate cost to the Utility
to have treated 3,200 gallons of untreated wastewater would have been approximately $4.80. 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,ithe City still had to pay the cost to treat the greater volume of sewage created by the
spill and the cost of potable water used to mitigate the event.
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 Repair Activities Inspections Activities
10/15/2018 9/2/2022 10/26/2017 Since July 2018 there has been:
10/15/2018 8/30/2022 10/26/2017 6 -Manhole Inspections
3/12/2019 8/30/2022 59- High Priority Inspections
8/30/2022 9/1/2022 2- Easement Inspection
9/8/2022
10/10/2022
There have been no additional issues associated with this section of the collection system since the last sewer
event. No further issues have occurred since this SSO event.
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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 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
$ 885,577.46 [2], approximately .06% of the Division's annual operating budget. The 10,216 gallons of untreated
wastewater spills identified in this letter cost the Utility approximately $25,662.58. to mitigate. The City's cost of
sewer treatment per gallon is 5.0015131. At this rate, it would have cost the City $15.26 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 550 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.
[1] 66.58 miles represents 0.025% of the sanitary sewer collection system
[2] Associated operational cost year to date for FY2023
OPERATION LINEAR FEET Linear Mlles COST
_ CCN 133, IBJI _ 21.58 - _ _ $ 113,200.90
Repair 1,310 _ 0.25 $ 652,202.98
Flushing 236,390.8 _ 44.77 _ $ 120,173.58
Total cost of Business to Date
Total- 371,519.51 Ft/ 66.58 MILES
$ 885,577.46
[3] $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[4] The current S50 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.
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
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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, I am requesting that the NOV-2022-NOI-0273 issued for the month of August
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.
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@ raleighnc.Gov
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