WQCS00002_NOV-2022-DV-0289_Response Rcvd_20221107

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Raleigh Water
November 7tt', 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-0289
Sanitary Sewer Overflows — September 2022
Permit No. WQCS00002
Dear Mr. Vinson:
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Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2022-DV-0289) received on October 21", 2022. This document contains the narrative regarding
pending violation actions of (4) Sanitary Sewer Overflow (SSO) events, reported on the month of September
2022 within the City of Raleigh Collections System [II 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:
jai The 550 was caused by severe natural conditions; there were no feasible alternatives to the S50, such as the use of auxiliary treatment facilities, retention of
untreated wastewater, reduction of inflow and infiltration, use of adequate backup equipment, or an increase in the capacity of the system. This provision is not
satisfied if, in the exercise of reasonable engineering judgment, the Permittee should have installed auxiliary or additional collections system components, wastewater
retention or treatment facilities, adequate back-up equipment or should have reduced inflow and infiltration; or
[b.] The 550 was exceptional, unintentional, temporary, and caused by factors beyond the reasonable control of the Permittee; the S50 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;"
1

Incident Number # 202201459 — 9/22/2022 — 417 Raleigh Pine Dr., Raleigh
This spill was neither willful nor intentional; it resulted from foreign material introduced into the sanitary sewer
collection system not consistent with regular wastewater debris such a paper (see exhibit 1 below). This debris
caused a partial blockage in a portion of an 8-inch sewer gravity main. The blockage led to a sewer spill of
approximately 515 gallons of untreated wastewater reaching a stormwater channel that discharges into an
unnamed tributary within the Wildcat Basin.
Exhibit 1 — Foreign debris (2 pieces of 1-inch PVC pipe in various lengths)
On 09/22/2022, at approximately 8:40 AM, Raleigh Water staff identified 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 10:23 AM on the same day. Crews utilized hydraulic jetting and manual removal to retrieve 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. This approach was intended to contain sewer flow and minimize the
environmental impact on the surrounding land. Responding crews initiated the collection of untreated
wastewaters from the containment site to re -introduced it to the collection system downstream. This spill was
contained without a significant environmental impact to the adjacent area and its natural resources.
During the restoration phase of the operation, crews utilized ample potable water to remove evidence of sewer
downstream of the affected area. The area around the manhole was cleared of debris, treated with an
application of lime, and restored with grass seed and straw. Visual inspection of the affected area and
downstream waters confirmed no fish kill or unnecessary vegetative damage occurred.
The cost associated with the mitigation of this event amounted to $1,097.49. The approximate cost to the Utility
to have treated 515 gallons of wastewater would have been approximately $.77. The City saved no money from
this spill. The costs for cleanup exceeded the cost of treating the volume of sewage had no spill occurred.
Furthermore, the City still had to pay the cost to treat the greater volume of sewage created by the spill as well
as the cost of potable water used to mitigate the event.
A follow-up close circuit television (CCTV} assessment of the affected area did not identify any infrastructure
issues that may have contributed to this event. This assessment confirms that the 1-in PVC pipes caused the
sewer backup and the subsequent overflow. The source of the pipes could not be identified.
2

Before this event, maintenance records show that sections of this collection system were assessed as follows.
CCTV Repair Easement Maintenance
Flushing activities Activities Activities Inspections Activities Activities.
11/9/2018 11/9/2018 11/9/2018 5/17/2018 3/6/2018 9/16/2020 9/23/2022
11/9/2018 8/21/2018 6/15/2018 2/16/2021
7/16/2018 7/16/2018 6/14/2018 12/14/2021
11/9/2018 8/28/2018 2/4/2019 12/15/2021
11/9/2018 9/22/2022 2/5/2019 12/14/2021
7/16/2018 6/20/2019 8/19/2021
6/19/2019 3/12/2022
12/18/2019 9/23/2022
3/20/2020 9/22/2022
3/26/2020
No additional issues have been associated with this section of the collection system since the last sewer event.
The CCTV assessment, subsequent repair, and foreign material (PVC pipe) removal effort show that this spill
resulted from an isolated event which was corrected during the restoration phase of the operation. There have
been no additional issues associated with this section of the collection system since the last sewer event.
3

Incident Number # 202201475 — 9/27/2022 — 2500 Glenwood Ave., Raleigh
This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of a 6-in
gravity sewer main. The root intrusion led to a sewer spill of approximately 200 gallons of untreated wastewater
reaching Beaverdam Creek. See Exhibit 1 — Area of Operation.
Exhibit 1— Area of Operation
0n 9/27/2022, at approximately 11:45 AM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from the ground (near affected sewer asset SGMN113715) located on the grounds of CAROLINA
COUNTRY CLUB CO. located at 2500 Glenwood Ave., Raleigh. The responding staff took all reasonable steps to
stop and mitigate the impact of the discharge, gaining control of the spill event by 12:48 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 intends 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 surrounding the
affected asset was cleared of debris, treated with an application of lime, and restored with grass seed and straw.
A follow-up CCTV assessment identified that the spill resulted from root intrusion from an adjacent tree. The
root intrusion damaged the sewer main's integrity, resulting in a spill. The sewer main was repaired and restored
for service. The tree was removed from the ground to prevent further root damage. See Exhibit 2 - Root
intrusion repair efforts.
4

rvhihit 7 - Rnnt intmcinn repair nffnr+c
The cost associated with the mitigation of this event amounted to $10,986.18. The approximate cost to the
Utility to have treated 200 gallons of wastewater would have been approximately $.30. 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 of treating the greater volume of sewage created
by the spill.
Before this event, maintenance records show that sections of this collection system were assessed in February
2020. No additional issues have been associated with this section of the collection system since the last sewer
event. The CCTV assessment, subsequent repair, and tree removal effort show that this spill resulted from an
isolated event which was corrected during the restoration phase of the operation.
5

Incident Number # 202201455 — 9/20/2022 — 501 Aversboro Rd., Raleigh
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
an 8-inch vitrified clay pipe gravity sewer main section. This build-up led to a sewer spill of approximately 900
gallons of untreated wastewater reaching surface waters of Reedy Branch. See Exhibit 1— Area of Operation.
Exhibit 1- Area of Operation
On 09/20/2022, at approximately 5:30 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a private sewer deanout near 501 Aversboro Rd., 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 7:00 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 1,120 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.
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 9/22/2022 to identify the root cause of the SSO. Additional
flushing of sewer gravity mains upstream and downstream of the affected asset was completed. This asset has
been placed in the Hot Spot Management program for
6

The cost associated with the mitigation of this event amounted to $7,319.00. The approximate cost to the Utility
to have treated 900 gallons of wastewater would have been approximately $1.35. 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 of treating the greater volume of sewage created by the spill.
This section of the collection system is located downstream of a commercial 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 has not experienced a grease -related reportable SSO in the past ten years. 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
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
allows citizens to partner with Public Utilities to protect the City's water quality and sewer collection
infrastructure.
7

Before this event, maintenance records show that sections within the zone of influence of this collection system
were assessed within the last ten years as follows:
Flushing activities
9/5/2017
9/5/2017
11/4/2017
11/7/2017
11/28/2017
11/29/2017
11/30/2017
12/2/2017
12/5/2017
12/19/2017
12/20/2017
2/12/2019
3/1/2019
11/26/2019
6/9/2020
1/28/2022
2/1/2022
3/7/2022
9/23/2022
11/4/2022
Chemical Root
Control
7/6/2022
7/7/2022
7/14/2022
CCTV
Activities
12/22/2016
12/14/2017
8/10/2018
11/27/2019
12/18/2019
3/3/2020
3/17/2020
3/7/2022
7/29/2022
9/7/2022
9/21/2022
10/14/2022
Repair
Activities
8/10/2018
2/25/2020
2/7/2022
7/25/2022
7/27/2022
10/12/2022
Easement
Maintenance
Activities
5/6/2022
6/19/2018
Inspections Activities
• 63 manholes Inspections since
06/24/2020
• 218 High priority Inspections
since 1/10/2018
No additional issues have been 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.
8

Incident Number # 202201447 — 9/20/2022 — 3210 Yonkers Rd., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a pipe failure resulting from possible erosion caused
by rapidly 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 483 gallons of untreated wastewater reaching
Marsh 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 2 gallons per minute.
Exhibit 1—Failed Pipe
Exhibit 2—Area of Operation
On 9/20/2022, at approximately 7:40 AM, Raleigh Water staff conducting a high -priority inspection on an aerial
sewer gravity main, identified liquid flowing into Marsh Creek. The responding Easement Inspector immediately
requested Utility Response to assess the extent of the pipe damage. 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 11:10 AM on the same day.
See Exhibit 3 — Repaired pipe.
9

Exhibit 3 —Repaired pipe
Containment and collection of this spill event consisted of employing a temporary spill containment site near
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 and re -introduced it to the downstream collection system. This spill was contained without a significant
environmental impact on the adjacent area and its natural resources. See exhibit 4 - Containment and Collection
Efforts.
Exhibit 4 — Containment and Collection 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 5 — Repair and
restoration efforts).
10

A follow-up CCTV investigation (conducted after the 550 mitigation and repair efforts) found no further
evidence of infrastructure deficiencies. Visual inspection of the affected area and downstream waters confirmed
that no fish kill or unnecessary vegetative damage occurred. Additional sewer main rehabilitation work has been
coordinated with Utility contractors to assess further repair needs of this sewer main.
The cost to date associated with the mitigation of this event amounted to $5,588.11. The approximate cost to
the Utility to have treated 483 gallons of untreated wastewater would have been approximately $.72. 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 of treating the greater volume of sewage
created by the spill and the cost of potable water used to mitigate the event.
This asset is under Capital Improvement Project pending rehabilitation work and CCTV assessment completion.
No further issues have occurred since this SSO event.
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 focus on continual improvement, the prevention of pollution, and increased
environmental performance efficiency. This endeavor is 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 that aims 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 103.84 [3[ 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
$ 1,148,708.67 [21, approximately .08% [3) of the Division's annual operating budget. The 2,098 gallons of
untreated wastewater spills identified in this letter cost the Utility approximately $24,990.78 to mitigate. The
City's cost of sewer treatment per gallon is $.0015 [41. At this rate, it would have cost the City $3.14 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 for
treating 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 S50 performance rate of
0.65 total S50 rate [s[ per 100 miles of pipe, compared to the Southeastern Region of the U.S., 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 ONEAR FEET linear Mlles COST
CCTV 133, 18.71 2156 $ 113,200.90
Repair 1,310 0.25 $ 652,202.98
Flushing 236,390.8_ _ 44.77 _ $ 120,17358
Total - 371,519.51Ft/ 66.58 MILES
[31 FY 2023 annual Divisional Budget -$14,657,701
Total cost of Business to Date
$ 885,577.46
[4] $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[5] The current 5S0 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
12

. •
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 free 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:/Jraleighnc.gov/sewer-maintenance
The City continues its monetary reward program or bounty program, which pays out fifty ($50) dollars to any
citizen who observes and reports an SSO or conditions that may cause a spill. 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 daily. 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-0289 issued for the month of
September 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 get in touch with Matthew Vessie, Sewer Maintenance Superintendent, [phone], or Carlos M.
Perez, ORC.
(—Assistance Superintendent 919-996-5929.
� r�
Sincerely,
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
Ca rlos.perezca machoPraleighnc.Gov
13

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS. JR.
Director
Certified Mail # 7020 3160 0000 4109 0423
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
October 10, 2022
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2022-DV-0289
Sanitary Sewer Overflows - September 2022
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
NC Dept of Environmental Quality
NOV 7 2022
Raleigh Regional Office
The self -reported Sanitary Sewer Overflow (5S0) 5-Day Report submitted by City of Raleigh indicates violations of
permit conditions stipulated in the subject permit and North Carolina G.S. 143-215.1. Violations include failing to
effectively manage, maintain, and operate the subject collection system so that there is no SSO to the land or
surface waters and making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a
permit is required.
Specific incident(s) cited in the subject report include the following:
Incident Start Duration
Number Date (Mins) Location
Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
202201447 9/20/2022 210 3210 Yonkers Rd, Pipe Failure (Break) 483 483 Notice of Violation
Raleigh, NC, 27604
202201455 9/20/2022 90 501 Aversboro Rd, Grease 900 900 Notice of Violation
Garner, NC, 27529
202201459 9/22/2022 103 417 Raleigh Pine drive Debris in line
515 515 Notice of Violation
North Carolina Depanmenr of Environmental Quality I Division of water Resources
Raklgh Regional °ri a 13800 barren Drive I Raleigh. North Carolina 27609
9i9.791.4200

Incident Start Duration
Number Date (Mins) Location
Cause
Total
Vol
(Gals)
Total Vol
Surface
Water
(Gals) DWR Action
202201475 9/27/2022 63 2500 Glenwood Ave, Roots
Raleigh, NC, 27608
200 200 Notice of Violation
Remedial actions, if not already implemented, should be taken to correct the above noncompliance.
a written response to this Notice of Violation. Your response is to be received by the regional office
business days following receipt of this violation. Please include any additional documentation about
.in the response:' The submittal will be considered in determining whether the Division will assess a
the cited violations:
Please submit
within 15
this incident(s)
civil penalty for
If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Regional Office - WQS File
Laserfiche
DQ5
v �nyPy.
North Carolina Department of Environmental Quality I DMslon of Water Resources
RalelghRegbrel Office 13600 Barren Drive I Raleigh North Carolina 27609
919.7924200