WQCS00002_NOV-2022-DV-0330_Response Rvcd_20221213

NC Dept of Environmental Quality
DEC 1 3 2022
Raleigh Reg] ona! Office
Raleigh Water
December 13th, 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-0330
Sanitary Sewer Overflows — October 2022
Permit No. WQCS00002
Dear Mr. Vinson:
NC Dept of Environmental Quality
DEC 13 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-0330) received on November 22"d, 2022. This document contains the narrative
regarding pending violation actions of (1) Sanitary Sewer Overflow (SSO) events, reported on the month of
October 2022 within the City of Raleigh Collections System [1]. This document also provides exhibits as proof of
our efforts to mitigate each of the sewer events. The noticed events occurred while the City operated its
collection system, according to WQCS00002, dated June 6th, 2017. The permit includes the language outlined in
footnote 1 and applies to the SSOs upon which NOVs with the notice of intent (NOV-NOI) were based. This
document will establish a reasonable explanation of the actions taken to stop the spills; contain the released
untreated wastewater; collect the wastewater and reintroduce it to the collection system; and finally, restore
the possible environmental impacts brought by the release of the SSO events, listed with the intended NOV-NOI
action. Please find below, the additional information requested for the SSO events.
1. "The Director may take enforcement action against the Permittee for SSOs that must be reported to the
Division as stipulated in Condition IV92). This includes SSOs that was caused by severe natural conditions
or exceptional events unless the Permittee demonstrates through properly signed, contemporaneous
operating logs, or other relevant evidence that:
[a.] The SSO was caused by severe natural conditions; there were 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
retention or treatment facilities, adequate back-up equipment or should have reduced inflow and infiltration; or
[b.] The SSO was exceptional, unintentional, temporary, and caused by factors beyond the reasonable control of the Permittee; the 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 # 202201630 —10/25/2022 —1705 Tryon Park Dr., Raleigh
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of an 8-inch Polyvinyl Chloride Pipe gravity sewer main (see exhibit 1— Grease accumulation). This
build-up led to a sewer spill of approximately 2,150 gallons of untreated wastewater, in which approximately
1,050 gallons reached an unnamed tributary within Southgate Basin. See Exhibit 2 — Area of Operation.
Exhibit 1—Grease Accumulation
Exhibit 2 — Area of Operation
On 10/25/2022, at approximately 12:45 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sewer manhole (SMH150154) located approximately 320 ft north of 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 4:20 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 1,000 ft downstream of the affected asset (see exhibit 3 — Containment 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.
Exhibit 3 — Containment Efforts
2

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. See Exhibit 4 —
Restoration Efforts.
Exhibit 4 - Containment Efforts
A follow-up CCTV assessment was conducted on 11/1/2022 to identify the root cause of the SSO. The
assessment found no infrastructure deficiencies that may have been attributed to the grease accumulation and
subsequent spill. Additional flushing of sewer gravity mains upstream and downstream of the affected asset
was completed.
The cost associated with the mitigation of this event amounted to $8,270.96. The approximate cost to the Utility
to have treated 2,150 gallons of wastewater would have been approximately $3.22. 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 residential area. It provides sewer collection
services to several properties upstream of the spill event (see Exhibit 5- 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.
Exhibit 5- Zone of Influence
3

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.
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 6 — Press Release.
k®/
1.00,.: Raleigh
NEWS RELEASE
COMMUNICATIONS DEPARTMENT
October 26, 2022
For more intoi 1ra6on:
John Kivinienii, Awh<fant Director, Raleigh Water, 919 9963245
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep All Grease Out of the Shared Sanitary
Sewer System
On Tuesday, October 25. 2022. at approximately 12:45 pm, Raleigh Water staff
were notified of a sander/ sewer spill in the vicinity of 1705 Tryon Park Or., Gamer
NC. The sander/ sewer spill was the result of grease within the sanitary sewer system
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 removed the blockage source and contained the spill at
approximately 4 20 pm on the same day It is estimated that the spill discharged a
volume of approximately 2,150 gallons of unheated wastewater of which 1.150
gallons reached a stonmvater channel within the Southgate Basin. Restoration of the
affected area is ongoing. No unnecessary vegetative damage or fish kill was observed
related to this event
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge o1 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.govlwater.
This news release is required by NCGS Article 21, Chapter 143 215.1C
4

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 Chemical CCTV Repair Inspections Activities
Root Control Activities Activities
02/13/18 05/29/18 07/07/22 03/16/18 08/03/16 Easement Inspections - 11
02/16/18 09/25/18 03/14/18 10/26/22 Manhole lnspections — 15
02/20/18 09/26/18 03/14/18 Sewer High Priority Inspections — 35
02/28/18 09/27/18 11/01/22
03/04/18 10/01/18
04/19/18 10/26/22
05/14/18 10/31/22
05/14/18 11/01/22
05/25/18 11/04/22
05/25/18
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.
5

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 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 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 [1j 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 [2], approximately .08% [3] of the Division's annual operating budget. The 2,150 gallons of
untreated wastewater spills identified in this letter cost the Utility approximately $8,270.96to mitigate. The
City's cost of sewer treatment per gallon is $.0015 [41. At this rate, it would have cost the City $3.22 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 SSO performance rate of
0.65 total SSO rate [5] 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 LINEAR FEET Linear Miles COST
CCTV 133, 18.71 21.56 $ 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
$ 885,577.46
Total - 371,519.51 Ft / 66.58 MILES
[3] FY 2023 annual Divisional Budget - $14,657,701
[4] $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[5] The current SSO Rate for FY 23 is 0.65
Additionally, the City of Raleigh Assistant Public Utility Directors and Collections System staff have become
involved in challenging the nonwoven fabrics industry standards to better inform consumers of these products
and their detrimental effects on the collections systems. PUD staff has personally met with officers of INDA, the
leading association of the nonwoven fabrics industry based in Cary, NC, to communicate our concerns about
these fabrics, the current industry standards, and better education for the consumer. PUD has also joined forces
with other utilities nationwide through the National Association of Clean Waters Agencies (NACWA), the Water
Environment Foundation (WEF), and the American Public Works Association (APWA) to challenge INDA and
current industry standards, recognizing that they do not support compatibility in sanitary sewer collections
systems nationally. These agencies work collectively to challenge the testing protocols, assessment guidelines,
and consumer education and labeling of these non -dispersible.
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
6

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://raleighnc.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-0330 issued for the month of October
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.
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
[e-mail]
7

ROY COOPER
Guy ernoi
ELIZABETH S. BISER
si�n+�ru•v
RICHARD E. ROGERS. JR.
Director
Certified Mail # 7020 3160 0000 4109 0638
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
' 1; , 3 r s: NOV 2 2 2 .
NORTH CAROLINA
Environmental Quality
November 14, 2022
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2022-DV-0330
Sanitary Sewer Overflows - October 2022
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
The self -reported Sanitary Sewer Overflow (SSO) 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
202201630 10/25/2022 215 1705 Tryon Park Dr, Debris in line, Grease
Raleigh, NC, 27610
2,150 1,050 Notice of Violation
Remedial actions, if not already implemented, should be taken to correct the above noncompliance. Please submit
a written response to this Notice of Violation. Your response is to be received by the regional office within 15
business days following receipt of this violation. Please include any additional documentation about this incident(s)
in the response. The submittal will be considered in determining whether the Division will assess a civil penalty for
the cited violations.
Nortli Carolina Department nl Envlronmrnl al Quality Or, hvm nl Wmer Reso uses
Ralel9h 11,4110.41 Cif fice •1&)O Bartell Drivr I RaICI)Ma Myth Carolina /.il,04
018.7MA?00

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.
Cc: Regional Office - WQS File
Laserfiche
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Nut•11 Carolina fcparlmcnl nl Enrirnnmental lrtallly I Dh num nl Watt., Rrsnatrer
Raleigh Rryknal Of fire .WOO &vielf INlve Raleigh. Ve-th Carolina dd.0a
vl9.i�l 4200