WQCS00002_DV-2022-0126 case file_20221121

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7020 3160 0000 4115 0011
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
November 21, 2022
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(1)
and Collection System Permit No. WQCS00002
City of Raleigh
Raleigh Collection System
Case No. DV-2022-0126
Wake County
Dear Mr. Wheeler:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $536.57 ($500.00 civil penalty +
$36.57 enforcement costs) against City of Raleigh.
This assessment is based upon the following facts: a review has been conducted of the Sanitary Sewer Overflow (SSO)
5-Day Report submitted by City of Raleigh. This review has shown the subject facility to be in violation of the requirements
found in Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1). The violation(s) that occurred are
summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that City of Raleigh violated the terms, conditions or
requirements of Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(I) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
North Carolina Department of Environmental Q alley I Division of Water Resources
RaIHph Re tonal Office 13d00 Barrett Drive i &MO, North Car6Rna 27609
919.7914200

Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, I, Scott
Vinson, Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against City of
Raleigh:
$500.00 For 1 of the 3 violations of Collection System Permit No. WQCS00002 and G.S. 143-215.1(a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
$500.00 TOTAL CIVIL PENALTY
$36.57 Enforcement Costs
$536.57 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
The duration and gravity of the violation;
The effect on ground or surface water quantity or quality or on air quality;
The cost of rectifying the damage;
The amount of money saved by noncompliance;
Whether the violation was committed willfully or intentionally;
The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143 B-282.1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty (30) days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
AND
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center, Raleigh
Raleigh, NC 27699-1628

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document, you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 5:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS §150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
6714 Mail Service Center
Raleigh, NC 27699 6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
160I Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact Mitchell Hayes with the Division of Water Resources staff of the Raleigh
Regional Office at [phone] or via email at [e-mail].
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Raleigh Regional Office - Enforcement File
Laserfiche

Case Number: DV-2022-0126
Assessed Party: City of Raleigh
Permit No.: WQCS00002
JUSTIFICATION FOR REMISSION REQUEST
County: Wake
Amount Assessed: $536.57
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF WAKE
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
City of Raleigh
Raleigh Collection System
PERMIT NO. WQCS00002
)
)
)
)
)
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
)
) CASE NO. DV-2022-0126
Having been assessed civil penalties totaling $536.57 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated November 21, 2022, the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the day of , 20
SIGNATURE
ADDRESS
TELEPHONE

ATTACHMENT A
City of Raleigh
CASE NUMBER: DV-2022-0126
PERMIT NO: WQCS00002
FACILITY: Raleigh Collection System
Other Violations
INCIDENT VIOLATION
NUMBER DATE VIOLATION TYPE
REGION: Raleigh
COUNTY: Wake
VIOLATION DESCRIPTION
TOTAL VOLUME PENALTY
(GALLONS) AMOUNT
202200096 1/13/2022 CSO/SSO(Sewer Overflow) Discharge without valid permit 1,950
202200151 1/25/2022 CSO/SSO(Sewer Overflow) Discharge without valid permit
202200153 1/26/2022 CSO/SSO(Sewer Overflow) Discharge without valid permit
15,625
615
$0.00
$500.00
$0.00

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Raleigh
Facility Name: Raleigh Collection System
Permit Number: WQCS00002
County: Wake
Case Number: DV-2022-0126
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
A total volume of 15,625 gallons flowed from a manhole due to debris in the line. All of the volume flowed to an UT to the
Neuse River a class B; NSW in the Neuse River Basin. Increased nutrients and pathogens to surface waters.
2) The duration and gravity of the violation;
The SSO started on 01.25.2022 at 09:47 am and ended the same day at 11:52 am.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on surface water quality included increased nutrients and pathogens 4 4,1cAN ec..,. Cwwta.
vall4) The cost of rectifying the damage; 1; i U �`' S
The cost of rectifying the SSO is $ I,732.11.
5) The amount of money saved by noncompliance;
The cost to treat 15,625 gallons of sewage is approximately $15.24
6) Whether the violation was committed willfully or intentionally;
It does not appear that the violation was committed willfully or intentionally.
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority;
There have been 9 violations within the past 12 months.
8) The cost to the State of the enforcement procedures.
$36.57
))--21 ,,22
Date
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

r

Permit Enforcement History Details by Owner
E
0 5
61 co E ro
• a. a.
N
0
0
N r
A
177.4 m
To c
r 03 0
City of Raleigh
O
Fla
d
C
C O 0
W 0 x
Remission
0 2
7 m
rre cc
44
0
c
c
co
as
45
0
0)
0
0
z
O
a
O
49
O
0
u)
m
N
ti
69
2/28/08 $3,750.00
DV-2008-001'
0
N
0)
z
0
0
0
0
O
61
co
1113
49
6/22/10 $1,500.00
DV-2010-006,
$0.00 No 3/1/12
ti
Ifl
64
1/12/12 $2,500.00
DV-2012-000
0
z
0
O
49
0
0
0
0
O
a
O
CO
113
0
0
z
0
O
49
0
09
O
3
0
0
N
47,
DV-2015-002•
0
z
O
0
co
N
49
a
0
69
M
O
a
7/18/16 $3,250.00
DV-2016-006:
z
0
0
CD
CM
49
5/22/17 $2,500.00
DV-2017-002:
0
0
z
0
O
O
co
co
co
CV
DV-2017-003:
a
z
0
0
49
co
M
0
49
co
co
10/9/17 $5,000.00
DV-2017-0061
co
a
0
z
0
0
O
49
1/29/18 $2,500.00
DV-2018-000!
0
z
0
O
49
2/21/18 $0.00
DV-2018-0031
0
z
O
0
0
49
7/11/18 $500.00
DV-2018-0051
za z° za
co o co
0) 0) 0)
CV P N
co to
co u) o ti
t0 N
49 49
CD
49
10/29/18$500.00
DV-2018-0061
DV-2019-0031
CD
C7
N
M
69
7/8/19 $3,400.00
0)
0
z°
0
0
0
49
CD
C)
N
CO
69
49
Cr)
N
CO
49
10/1/19 $3,750.00
DV-2019-013:

0
z
O
O
44
DV-2020-002!
O
z
O
O
O
4,
0
0
N
a
8/7/20 $4,250.00
DV-2020-008:
O
z
O
0
49
0
co
N
69,
O
69)
69
8/22/20 $250.00
O
0
0
lC)
9/4/20 $2,500.00
DV-2020-010
O
z
O
O
69
0
iri
69,
<V
0
1<)
49
10/2/20 $2,000.00
DV-2020-0114
o
0
z
O
O
4,
3/22/21 $3,500.00
DV-2021-003,
O
z
3/22/21 $2,000.00
DV-2021-004r
M
<<00
O
z
0
2
IAA
<0
69
5/11/21 $500.00
DV-2021-007
$0.00 No 8/2/21
h
11)
<r)
69
6/14/21 $1,000.00
DV-2021-009,
O
z
0
O
49
it)
<0
C9
49
7/23/21 $1,500.00
DV-2021-012:
N
O
0
z
O
O
409
)
<0
89
10/5/21 $750.00
DV-2021-015:
0
z
S
2
69
10/18/21$750.00
DV-2021-016
0
z
8
0
69
to.
<0
N)
69
12/9/21 $250.00
DV-2021-0181
0
z
8
0
ti
IA
<0
1/26/22 $250.00
DV 2022-000:
O
z
O
O
49
COtri
co
N
69
L)
<0
CO
69
Q
0
10
N
49
N
0)
DV-2022-002'
N
CO
ts-
<0
O
4'
4/13/22 $150.00
DV-2022-003
1-
0
z
O
O
69
000
N
69
1)
<0
0)
6/16/22 $250.00
DV-2022-005
lr)
<O
69
10126/22$500.00
DV 2022-012
Total Balance Due : $9,859.19
00
c0
Ci
co
<0
<0
69
u?
C
O
E
td
n.
O
_ H
O
69
ti
to
a
3
6
E
m
Total Enforcement Cost $1,410.68
Total Penalty Amount: $64,300
A
Total Cases:
Sum of Total Case Penalties: $65,710.68

ROY COOPER
Governor
ELJZABETH S. BISER
Seam!),
S. DANIEL SMITH
Certified Mali # 7020 3160 0000 4109 5220
Radler Receipt R nested
Whit Wheeler, Assistant Public Utilities Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH
Quality
February 14, 2022
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2022-DV-0053
Sanitary Sewer Overflows - January 2022
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S.143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as
bo why the City of Raleigh should not be assessed a civil penalty for the violation(s) that are summarized below:
Total Vol
Total Surface
IInddent Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202200012 1/3/2022 90 5217 Cedarwood Dr. Severe Natural Conditions 686 686 Notice of Deficiency
202200080 1/7/2022 35 732 IUeagnes Road Grease
210 0 Notice of Deficiency
202200096 1/13/2022 38 Park Glen X Raleigh Blvd Roots
1,950 0 Notce of Violation
202200151 1/25/2022 125 621 Thistlegate Trail Debris In One 15,625 15,625 Notice of Violation —
Notice of Intent
Nardi Carobs Dq.nioeerl drnrrm.nebEWay I d nd War InCIUes
Raldillitegkeplatript I MOO NEnMDen I Xs*"North arolr>7i0�

Inddent Start Duration
Number Date (Mins) Location Cause
202200153 1/26/2022 41 2804 Sylvester St. Debris in line
Total
Vol
(Gab)
Total Vol
Surface
Water
(Gals) DWR Action
615 615 Notice of Violation
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or falls to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at mitch.hayes©ncdenr.gov.
Sincerely,
74/1;71
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
Laserfiche
NorthdrelnaDrylwimentelintinnsratalarby 01110enelWaterRasowees
Iaeph WOilb• 131Oow,.uonw IaksetNcethar* ViO$

Water Resources
ENVIRONMENTAL DUALITY
June 6, 2017
Mr. Matthew P. Vessie, Sewer Maintenance Superintendent
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
Subject: Permit No. WQCS00002
City of Raleigh
Raleigh Collection System
Wake County
Dear Mr. Vessie:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
In accordance with your application received May 19, 2015 and Settlement Agreement (16 EHR 00538 and
16EHR 00843), we are forwarding herewith Permit No. WQCS00002, dated June 6, 2017, to the City of Raleigh
for the operation and maintenance of the subject wastewater collection system.
This permit shall be effective from June 6, 2017 until January 31, 2024 and shall be subject to the conditions
and limitations specified herein. It is your responsibility to thoroughly review this permit. Please pay particular
attention to the monitoring and reporting requirements in this permit and any special conditions.
For purposes of permitting, the collection system is considered to be any existing or newly Installed system
extension up to the wastewater treatment facility property or point of connection with a separately owned
sewer system. The collection system is considered all gravity lines, pump stations, force mains, low pressure
sewer systems, STEP systems, vacuum systems, etc. and associated piping, valves and appurtenances that
help to collect, manage and transport wastewater to a wastewater treatment plant under the Permittee's
ownership or maintained and operated by the Permittee through a perpetual legal agreement. Satellite
systems are systems tributary to the Permittee's collection system but those collection systems are not owned
or maintained by the Permittee. The system description provided on Page 1 of this permit is meant to provide
a general idea about the size of the system and may not be all inclusive of the collection system at the time of
permit issuance or afterward.
A discharge of wastewater to the environment from the Permittee's wastewater collection system prior to
reaching the wastewater treatment facilities is referred to herein as a Sanitary Sewer Overflow (SSA). The
evaluation of enforcement options after an SSO will be determined considering all relevant information
available or requested of the Permittee. Compliance with all conditions of the permit as well as all statutes
and regulations pertaining to the wastewater collection system must be maintained or appropriate
enforcement actions may be taken as noted in Condition VI(2).
Stoic of North Carolina I Environmental Quality
1617 Mail Savior Caw Raleigh. Nonlr Carolina 27699.1617
919-707.9000

Raleigh Collection System
June 6, 2017
A reportable SSO is an SSO greater than 1,000 gallons to the ground or an SSO of any amount that reaches
surface water (including through ditches, storm drains, etc.). Reporting requirements induding the required
verbal report and written report to the appropriate regional office are referenced in Condition IV(2). Form
CS-SSO can be downloaded from the SSO Reporting area at: ltto://aortal.ncdenr.or8/web/wa/swo/os/cs/sso
A notive of deficiency (NOD), notice of violation (NOV), chril penalty, and/or a moratorium on the addition of
waste to the system may be issued if adequate Justification for an SSO Is NOT submitted to the regional office.
In order to submit a daim for justification of an SSO, you must use Part II of form CS-SSO with additional
documentation as necessary. DWR staff will review the justification claim and determine if enforcement
action Is appropriate. Please be advised that the information needed to justify a spill is very comprehensive.
if any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to
request an adjudicatory hearing upon written request within thirty days following the receipt of this permit.
This request must be in the form of a written petition, conforming to Chapter 1508 of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC
27699-6714. Unless such demands are made. this permit shall be final and binding.
If you have questions regarding compliance, contact the appropriate regional office. If you need additional
information concerning this permit, please contact Steve Lewis at [phone].
Sincerely,
for 5. Jay Zimmerman, P.G.
Director, Division of Water Resources
by Deborah Gore, Supervisor
Pretreatment, Emergency Response, Collection System Unit (PERCS)
enclosure: Permit No. WQCS00002
cc: Raleigh Regional Office, Water Quality Regional Operations
Water Resources Central Files — WQCS00002
Maureen Kinney, NC Operators Certification Program (electronic)
PERCS Files (electronic)

0110 0
00
Raleigh Water
March 21st, 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-0053
Sanitary Sewer Overflows —January 2022
Permit No. WQCS00002
Dear Mr. Vinson:
Altreto Muam'pu33o vbcr am
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2022-DV-0053) received on February 25th, 2022. This document contains the narrative
regarding pending violation actions of (5) Sanitary Sewer Overflow (550) events, which occurred during the
month of January 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-N01) 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.J The SSO was caused by severe natural conditions; there were no feasible akernatives to the 550, 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.J 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;"
1

Incident Number # 202200012—1/3/2022 — 5217 Cedarwood Dr., Raleigh NC
This sewer spill event was the result of a severe weather event that led to an unexpected sanitary
sewage spill of approximately 686 gallons of untreated sewer reaching surface waters Hog Pen Branch in Big
Branch Basin. This event restricted normal sewer flow from an 8-inch gravity sewer main. This spill took place.
The weather event produced a record rainfall of 2.29 inches for January 3rd, 2022, affecting the Raleigh area
(NOOA, Monthly Climatological Report for Raleigh NC, see Exhibit 1— Weather Report).
Sewer Maintenance staff was informed of the overflow on 1/3/2022 at approximately 9:37 AM. The
responding staff took all reasonable steps to monitor and mitigate the discharge's impact as soon as they arrived
until the weather event ceased at approximately 11:07 AM on the same day. Mitigation of this event was limited
since the rain event was actively ongoing. The rain assisted in defusing the sewage downstream. There was no
indication of solids or debris in the surrounding area. Crews conducted an area assessment downstream of the
event to ensure no traces of sewage and debris associated with the spill. Crews did not find any indication of
sewage nor indications of observed fish kill related to this SSO.
The total cost of the City's response and remediation effort for this spill event was $617.28. The
approximate cost to the Utility to have treated 686 gallons of wastewater would have been approximately
$1.03. 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.
There have been no previous recorded spills for this section of the sewer system. Prior to the weather
event, the most recent record of routine maintenance in this area was conducted on 12/14/2016.
Pursuant to our Sanitary Sewer Collection System Permit, the cause of this SSO was exceptional,
unintentional, temporary, and caused by factors beyond our reasonable control. Furthermore, the SSO could not
have been prevented by the exercise of reasonable control, such as routine operations and maintenance,
adequate treatment facilities, or collection system facilities or components.
Exhibit 1- Weather Report
1
Date
2022-01-01
Climatological Data for Raleigh Area, NC (FhreadEx) - January 1022
Temperature
Maximum
Minimum
T4
2022.01-02 70
1 2022•01 0 60—
64
59
31
Average
715
64 5
455
Departure
293
224
3.5
rAccumulated Preclpitallon - Raleigh Area. NC (Threadt4
.nil dna la Man 51 a.en.w u . ..1..... opal. Mil immoral* Marti.
lir Naomi mini§ Mara
aa.: MP
* 1e11
r..
111.1.1 M#r
t Mrw.l —memos* —la.au IMe.
imD
CDD
7
0
19
Precipitance
iicw Spew
Saow Depth
0.43
0.0
0
0.81.
2.29
0.0
0
0
2

Incident Number # 202200080 — 01/07/2022 — 732 Illeagnes 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" Polyvinyl Chloride pipe gravity sewer main. This build-up led to a sewer spill of
approximately 210 gallons of untreated wastewater remaining within the natural topography with minor
leaching into the adjacent stormwater retaining pond. (See exhibit 1— Area of Operation)
Exhibit 1- Area of Operation q_
, •' i n* ', i. Lam.' . , 4
t744,5. :11p.
• VI T
On 01/07/2022, at approximately 9:35 AM, Raleigh Water staff were notified conducting high priorities
inspections identified a sanitary sewer overflow emanating from a manhole located near 732 Illeagnes Rd.,
Raleigh, NC. The responding staff arrived shortly after and commenced taking all reasonable steps to stop and
mitigate the impact of the discharge, gaining control of the spill event by 10:19 AM 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 near a stormwater containment pond (see exhibit 2 — Containment and
Collection Efforts). 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.
3

'EN hihit 2 — Containment and Collection Efforts
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 areas around the
manhole were cleared of debris and washed with potable water. The area around the manhole was cleared of
debris, treated with an application of lime, and restored with grass seed and straw. See Exhibit 3 —Site
Restoration.
k xhlb t 3 Site Restoration
4

A follow-up CCTV assessment was conducted on 1/10/2022 to identify the root cause of the SSO. The
CCTV assessment identified minor grease deposits on segments of sewer gravity mains requiring further
cleaning. Additional flushing was completed on 2/8/2022 finding no grease issues within the main.
The cost associated with the mitigation of this event amounted to $1,950.57. The approximate cost to
the Utility to have treated 210 gallons of wastewater would have been approximately $.31. 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 approximately 23 properties upstream of the spill event (see Exhibit 4- Zone of Influence).
Within the last ten years, this portion of the collection system has not experienced a grease -related SSO event.
This area has been placed on routine maintenance.
Exhibit 4- Zone of Influence
./...."-----j
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. See exhibit S - Outreach Literature.
5

Exhibit 5 - Outreach literature
PUBLIC u'f ILIr s
Tte C4 of!aloe,.eco Ua had• sa.+txv',-•tr..'
n w+woo TM owtl.wwn tamed by m.INW.
y.at*rd0el.•5.mp.prM as 9* . a.Jr
..ens e•a. t ,.tem Taatan do some wr WW1'. 'IV
Mat W1 help thees prowl ore.* qu+slT arq m.•':
P..r.r., e+ti'+T stow srs,..n
aONOT pour yw•r, fats modals hemto.ilni down
lho Ink
DOMI' met sbin M a.w.Wiet. Poo alp•••*• i.
n..koh. WyA moor *mole. espore of Welwp•.,
tend«K t+Mpoos MbeT pweaH Mrp.99p. Wr$ )
CO mar w. Oho wow aletM.s ilia r•rooms I. w•
. f Ieelamspa
MIAI! wlw cookie Ms•nit••io N • Wrta9Wl.at
Ikon* of Y.TMyi.p
P LUM plow hod impel, was w M•i1M• w gwbqo
lay for appeal Ili 'odd ■•it% w .ewi •arp.rt pi.
%SI s.,xe.lvt4 upt a= to..s..enntM •rl+tSIV the
4v S. YntMy »wV mpn 9Mm t1. prowt. 4r•+
1.1.a>'1rk4 lal rhlaht.ftafg. of L.1.F WNW .rvra
w.tea„ Iteu'wt ryst d n.Ta teaas.a'.I.h'+J
'MO" 5lMrbw A.A. P own flow pl.a..[F J•. P.A.',
' 01.-.MarwNw• L.vhnnatarf 996-I AS For Ina.
nfvnut4n r tFy proxy. or. J r99
'tcer'A Pomp eefN i•'+IMv,.batmswMI,
4gn
lMte eber• Mgg.stu.,{ CM help save 5a. RrrK/ .hl
P rotect lht to ronme,4
Thans K„ P.m ,p, WO
`i
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:
CCTV Repair Inspections Activities Easement
Flushing Activkies Maintenance
activities Activities Activities
11/25/2017 1/11/2022 NA 2/12/2018 8/4/2020 4/12/2017
5/23/2019 4/20/2018 11/19/2020
1/7/2022 9/7/2018 12/7/2020
2/8/2022 3/20/2019 11/19/2020
8/16/2019 1/21/2021
8/15/2019 7/15/2021
8/16/2019 9/14/2021
1/31/2020 2/7/2022
8/17/2020
There have been no additional issues associated with this section of the collection system since the last
sewer event. This site continues to remain an active maintenance spot pending completion of further sewer
main cleaning and CCTV assessment.
6

Incident Number # 202200096 — 01/13/2022 — Park Glen Dr. & Raleigh Blvd., Raleigh
This spill was neither willful nor intentional; it was the result of root intrusion, which blocked a portion of
a 12-in" vitrified clay pipe gravity sewer main. The root intrusion led to a sewer spill•of approximately 1,950
gallons of untreated wastewater contained within the natural topography and not reaching surface waters of
the state.
On 1/13/2022, at approximately 2:10 PM, Sewer Maintenance staff was notified of a sewer overflow
located near the intersection of Park Glen Dr. & Raleigh Blvd., Raleigh. Upon arrival, it was discovered that
untreated sewer was emanating from an adjacent manhole (SMI1117520). See exhibit 1- Area of Operation. 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 2:40 PM on the same day. Crews utilized hydraulic jetting to remove
the source of the blockage within the affecting asset thus restoring sewer flow.
Exhibit 1- Area of Operation
This event was naturally contained within the topography of the land not requiring the assistance of
pumps or implements to contain the spilled untreated wastewater. Collection consisted of manually removing
sewer contaminated soil downstream of the affected asset.
During the restoration phase of the operation, crews remove sewer traces from the surrounding area
and downstream conveyance. The areas around the manhole were cleared of debris and washed with potable
water. The surrounding area was treated with an application of lime and restored with grass seed and straw. See
Exhibit 3 — Site Restoration.
7

Exhibit 3 — Site Restoration
A follow-up CCTV assessment was conducted on 1/26/2022 to identify the root cause of the SSO. The
CCTV assessment identified minor root instruction between joints of segments of sewer gravity mains requiring
further cleaning. Additional flushing was requested to further mitigate the condition of the sewer main and
minimize a potential re -occurrence. See exhibit 4 — Evidence of Root intrusion
Exhibit 4 — Evidence of Root Intrusion
USMH: SMH117520
EISMH: SMH151684
The cost associated with the mitigation of this event amounted to $1,394.06. The approximate cost to
the Utility to have treated 1,950 gallons of wastewater would have been approximately $2.10. 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.
8

This section of the collection system serves a residential area south of Capital Blvd., it provides sewer
collection to several multi -family dwellings and single-family homes. A press release notification associated with
this event was published in the Raleigh News & Observer on 01/14/2022 (Exhibit 5 — Press release).
EMI* 5— Press Release
i
Raleigh OP
NEWS RELEASE
001.P.P..P1101.1 Cn PM1M.i r
a-.im I. Mr
.. —
11.11.n. P Yew., Sew. Mmorm.r.pummtv Pow ..rn 1r. M412•S
Raleigh Water Responds so a Wharf feller Spill
lbThumb, e011Mr111. r area.*} le Pr. quer Wow Sere
ra.r..n 11•Men .e ague✓ r a Ma/rr MOM wryer at Pat OM d
PPP lr 01.01. to 2141.y.1.0 rM Uwe•104. nalWW r ..r u.C.1
r.rrl.l hfl.n The Nfa.11.1. OM lob alMMMWe yaps r /re Fay
rwa.18w. ew.elyee eN M fM•MM+need re Uri Gunn eeparr.l
1......11.11112.10.7 O.Fa .l Yee. erla.Me.ar.rM per /M
e.001 wr.r.at00.me M 1.14 r agre..yp!M PIP r 1. .amp
Oar am abobb let M IMP 01th.5M a rar.r aarprr.rl, 1..10 aem et
erlalM walrwrea. Mob al.wa lama Mows mew nrre.ep
$ eww angry 10 MOM*.O...1.. re NMI rw...vW Wahl le
M rMa
• Ryer. Mar rrrr ape/r adrrab. mei eMurerM puree
pupa ea fe[...w neap., rlarllnre. u.f wer.r
lerum. Ire We en re erne gleans Ire lelear *Naar
are..eeleprr. ttee. ass Fare 11I.b ere rer erer*.eer near
ten . a nee WO. MI Mp M MIrelb Faaay Pr lbw bump
1Me to See. ell eau Mr Mery ea MedearM►
• Man. MAP 10e11.1M ton e11r Y. M ear emu ee.eer le M
rrrergw _NM Mee 1 11•1.. Moab bap M lad r.yp bM
awl gar..** en mobil
• 11rr..y.l..e.um.. MwleaW pup Meal Miya9r�
er SI $n rpti r ale uM 01e410,20.0b nun e.ebeerr.
. ro..Mn We MOW aaalewl'M ereleeee alaewrlrrN.r Maw
MOIL *WM, MID ralereerserner.
Ike — erne w RUM a. rrAl Yrr. 71 cMll. 1112101C
ar
Before this event, maintenance records show that sections of this collection system were assessed
within the last 10 years as follows:
Flushing activities CCTV Repair Inspections Activities
Activities Activities
5/25/2011 9/25/2014 8/29/2012 11/9/2020 1/11/2018 6/22/2020
8/28/2012 11/10/2014 9/18/2013 11/10/2020 1/16/2018 9/29/2020
11/6/2012 11/12/2014 12/14/2017 5/23/2018 3/3/2021
11/26/2012 5/26/2015 11/18/2020 5/25/2018 3/24/2021
3/28/2013 5/28/2015 10/15/2020 12/19/2018 6/15/2021
9/4/2013 5/29/2015 1/26/2022 12/21/2018 6/17/2021
12/6/2013 5/29/2015 4/24/2019 7/2/2021
4/22/2014 3/2/2017 11/25/2019 8/30/2021
4/25/2014 11/6/2020 12/3/2019 9/16/2021
4/25/2014 4/1/2020 12/2/2021
6/15/2020 3/11/2022
There have been no additional issues associated with this section of the collection system since
01/13/2022. Since 2002, this portion of the sanitary sewer collection system has not experienced a root -related
SSO. This site has been added to a recurrent root management protocol.
9

Incident Number # 202200151— 01/25/2022 — 621 Thistlegate Trail., Raleigh, NC
This spill was neither willful nor intentional; it resulted from foreign debris not consistent with regular
wastewater debris such a spaper. The debris identified as the root cause of this event was found to be several
pieces of lumber (such as 2X4) which caused a partial blockage in a portion of a 12" polyvinyl chloride gravity
sewer main. The blockage led to a sewer spill of approximately 15,625 gallons of untreated wastewater reaching
a stormwater containment pond located within the Crabtree Basin.
On 01/25/2022, at approximately 9:47 AM, Raleigh Water staff were notified of a sanitary sewer
overflow emanating from a sewer manhole (SMH109628, see Exhibit 1— Affected Asset, below). 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 11:52 AM on the same day. Utility response crews utilized hydraulic jetting and manual removal of
the debris to eliminate the source of the blockage within the affecting asset, thus restoring sewer flow.
Exhibit 1— Affected Asset
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 on the adjacent area and its natural resources. See Exhibit
2 —Containment and Collection Efforts, below.
10

Exhibit 2— Containment and collection efforts
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, See Exhibit 3 —
Restoration Efforts.
Exhibit 3 — Restoration Efforts
The cost associated with the mitigation of this event amounted to $1,732.11. The approximate cost to
the Utility to have treated 15,625 gallons of wastewater would have been approximately $23.44. 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.
11

A follow-up close circuit television (CCTV) assessment did not find any infrastructure issues that may
have contributed to this event. This assessment confirms that the foreign debris, lumber externally introduced
into the collection system, caused the sewer backup and the subsequent overflow. The source of the lumber
could not be identified.
This section of the collection system serves a vast commercial and residential area south of New Bern
Ave. It provides sewer collection services to over 300 properties. 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).
Exhlblt 4 — Press Release
Raleigh Water Responds to a tannery Sewer Overflow
�2+ Thellegate Trail Raleigh
January 25. 2027
On Tuesday. January 25t+. at apprmuolnlely 9:47AM. Raleigh Water stall were
notified el a sanders, sewer modem beheld 621 Thislogals Trt. Raleigh Ups+
smut. Utility Responders rder0ilird an acli+e sewer overflew resulting from de-
bns wen Tie 12•Inch man The responding stall bait at reasgnabb steps
to atop end mitigate the overlbw's Impact as aoui as they roared. The North
Caroline Department d Environmental Quality. Dwebn ol Weer Resources has
WWI needed of to overflow.
Raleigh Water Mal contained to oeernow nt apprsxmolely 1152AM on Ow
same day. t le estimated del the overflow discharged avolme ol approximately
15.625 gallons of unteated wastewater into a private pond Restore/Jon for this
marinas completed at sopioaludely 633PM on the same day No vegalatve
damage or rah kW has been observed related Io bb event
• Flae1Oh Water has an aggressaw euucabon all enthralment program to pre-
vent to discharge el grease. debris. wipes. rags diapers and other improper
materials it the sewer system and 10 tahe enlrnowmed action whore appropriate
t them items make 0 Into the Bearer system, they may cause a sp01, which can
have an schema impact on wafer Quality end endanger those who came Into
COMM with the elected areal,
• Water. human wage. and toilet tissue are the only name IXO10 trd to be dis-
charged Into the !ewer sveem. Al other items will cause damage b to sewer
system and are not permitted.
• t you experience escee7Ne WNW ants or see sewer Wang from manhobs
hY pees. please call 919496.3245 to report mnediataly
• For more blonneban about have you can holp prevent sanitary sewer spOls,
Plea") vise releighnc gw/water.
Tub news release is required by NCGS Article 21. Chapter 143215.1C
W00000000
Publication Oates
Before this event, maintenance records show that sections of this collection system were assessed
within the last 10 years as follows:
Repair Activities Inspections Activities Easement
Flushing activities CCry Activities Activities
11/6/2011 10/31/201 02/17/2022 4/21/2017 9/21/2015 8/7/2019 3/30/2021
7/20/2011 4/10/2017 4/12/2017 2/13/2018 1/23/2020
11/9/2011 2/28/2017 1/22/2018 7/15/2020
11/1/2012 9/6/2018 4/2/2018 12/23/2020
10/15/2013 7/9/2019 5/16/2018 2/11/2021
6/8/2012 11/26/2018 8/30/2021
4/17/2019 3/1/2022
Maintenance records show that this portion of the sanitary sewer collection system has not experienced
a debris -related SSO in the past ten years. This site has been added to recurrent maintenance efforts as this
incident was identified as an isolated event.
12

Incident Number # 202200153 — 01/26/2022 — 2804 Sylvester St., Raleigh, NC
This spill was neither willful nor intentional; it resulted from debris (such as paper and wipes)
accumulation within the affecting asset (SGMN154501). The debris caused a partial blockage in a portion of an
8-inch gravity sewer main. The blockage led to a sewer spill of approximately 615 gallons of untreated
wastewater reaching an unnamed tributary within the Southgate Basin.
On 01/26/2022, at approximately 8:34 AM, Raleigh Water staff were notified of a sanitary sewer
overflow emanating from a sewer manhole (SMH116842, see Exhibit 1-- Affected and affecting Asset, below).
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 09:15 AM on the same day. Utility response crews utilized hydraulic jetting and manual removal of
the debris to eliminate the source of the blockage within the affecting asset, thus restoring sewer flow.
Exhibit 1- Affected and Affecting Asset
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 on 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 $ 613.80. The approximate cost to the
Utility to have treated 615 gallons of wastewater would have been approximately $.92. 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 did not find any infrastructure issues that may
have contributed to this event. The CCTV assessment recommended that this portion of the sanitary sewer
collection system be placed in a recurrent maintenance program.
13

This section of the collection system serves a vast commercial and residential area west of Sanderford
Rd. It provides sewer collection services to over 250 properties. Before this event, maintenance records show
that sections of this collection system were assessed within the last 10 years as follows:
2/11/2011
10/3/2011
2/14/2012
5/8/2012
8/29/2012
10/11/2012
3/20/2013
3/28/2013
5/28/2013
9/19/2013
9/20/2013
9/23/2013
9/23/2013
9/25/2013
9/26/2013
Flushing activities
10/14/2013
10/17/2013
1/10/2014
4/30/2014
7/11/2014
7/13/2014
10/9/2014
7/10/2015
8/26/2015
9/11/2015
9/24/2015
11/30/2015
12/10/2015
1/17/2017
6/22/2017
12/11/2017
12/13/2017
12/21/2017
3/16/2018
3/19/2018
3/20/2018
3/26/2018
3/27/2018
3/28/2018
3/29/2018
4/2/2018
5/15/2018
5/31/2018
9/17/2018
4/16/2020
10/19/2020
11/4/2020
CCTV Activities
2/14/2013
7/17/2014
2/2/2017
12/28/2017
10/1/2018
10/8/2018
10/22/2018
11/4/2020
6/30/2021
7/13/2021
12/17/2021
Repair Activities
1/31/2017
4/17/2018
6/30/2021
12/16/2021
9/15/2020
2/18/2022
Inspections Activities
06/17/2022
12/07/2022
Maintenance records show that this portion of the sanitary sewer collection system has experienced
three separate SSOs resulting from grease and debris accumulation as follows:
Date
6/2/2006
12/20/2006
2/3/2009
Location
Behind 1112 Savannah Dr
2904 Sylvester St
2808 Sylvester St.
SSO Duration
15 hrs.
40 min.
1 Hr.
SSO Volume (gallons)
2700
800
100
Root Cause
Grease
Debris in line
Debris in Tine
As a result of these previous incidents, this site has been added to recurrent maintenance efforts.
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 2021 (Fiscal Year 2022), the Utility has maintained approximately 299.8 [1] 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
$ 2,640,575.97 [2], approximately 20% of the Division's annual operating budget. The 19,086 gallons of
untreated wastewater spill identified in this letter cost the Utility approximately $6,307.54. to mitigate. The
City's cost of sewer treatment per gallon is $.0015 [3]. At this rate, it would have cost the City $27.80 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
1.49 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.
[11 299.8 miles represents 11% of the sanitary sewer collection system
[2) Associated operational cost year to date for FY2022
OPERATION LINEAR FEET Linear Miles COST
CCTV 350,539 66.4 $ 376,624.20
Flushing 1,226,667 232.3 $ 447,197.00
Repair 5,690 11 $ 1,826,277.64
Total - 1,582,896 Ft Total cost of 8uslness to Date
299.8 MILES $ 2,640,575.97
[31$.0015 Is based on the annual water treatment operating cost compounded by the total treated effluent.
(41 FY21 total miles clean were 428.40 MILES at a cost of 3,581,811.42
Additionally, the City of Raleigh Assistant Public Utility Directors and Collections System staff has
become involved in challenging the nonwoven fabrics industry standards to better inform consumers of these
products and their detrimental effects on the collections systems. PUD staff has personally met with officers of
INDA, the leading association of the nonwoven fabrics industry based in Cary, NC, to communicate our concerns
about these fabrics, the current industry standards, and better education for the consumer. PUD has also joined
forces with other utilities nationwide through the National Association of Clean Waters Agencies (NACWA), the
Water Environment Foundation (WEF), and the American Public Works Association (APWA) to challenge INDA
and current industry standards, recognizing that they do not support compatibility in sanitary sewer collections
systems nationally. These agencies work collectively to challenge the testing protocols, assessment guidelines,
and consumer education and labeling of these non -dispersible.
Raleigh Water has an aggressive educational outreach initiative to address illicit discharges such as
wipes, fats, oil, and grease to commercial and residential users. Raleigh Water has developed a complimentary
property managers resource kit that provides best practice resources for establishing a property -specific
15

awareness program. Each kit contains brochures and complimentary gadgets to help residents manage grease
and fat collection and disposal. The resource kit also features a multimedia flash drive with videos and
reproducible educational material that property managers can use to educate tenants to reduce the risk of
sewer backups caused by the introduction of solids through their residential piping. Each kit costs Raleigh water
approximately $85.00 to produce and is provided free of charge to the property management. Raleigh Water is
continuously developing initiatives to increase residential and commercial customer partnerships to address
grease accumulation and prevent illicit discharges. The educational material and videos can be accessed through
social media and the Raleigh Water website https://raleighnc.gov/sewer-maintenance
The City continues its monetary reward program or bounty program, which pays out fifty ($50) dollars to
any citizen that observes and reports an SSO or conditions that may cause a spill event. This program has been
advertised via printed material, a television advertisement campaign, and graphic design "wraps" on Sewer
Maintenance vehicles. These graphics on our vehicles function as mobile billboards spreading our message of
prevention and offering contact information throughout the service area each day. This program was developed
hoping that citizens and customers would become more aware of the signs of an emerging system problem
causing the SSO occurrence and become proactive in helping the City prevent these occurrences. Additionally,
all customers are notified via their water and sewer utility bills not to discharge improper materials into the
sanitary sewer mains. The City also circulates information regarding the discharge of grease into the sewer
system and the effects of such deposits. Whenever possible, and upon investigating the root cause of a spill
event, PUD Code Enforcement officers develop and send registered informational letters about the spill event to
the customer base serviced by the line where the SSO has occurred. This is done to educate our customers on
the proper use of sanitary sewers to prevent the disposal of non-flushable items and items harmful to the
continuous operation of the collections system.
On behalf of the City of Raleigh, I am requesting that the NOV-2022-NOI-0053 issued for the month of
January 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.
Siriisece'Iy,
Carlos M Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh, Public Utilities Department
P.O. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
Carlos,rezcamachoraleighnc.Gov
16