WQCS00002_NOV-2022-dv-0348_Response Rvcd_20221230

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Raleigh Water
January 3RD, 2023
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-0348
Sanitary Sewer Overflows — November 2022
Permit No. WQCS00002
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Dear Mr. Vinson:
NC Dept of Environmental Quality
DEC 30 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-0348) received on December 20th, 2022. This document contains the narrative
regarding pending violation actions of (1) Sanitary Sewer Overflow (SSO) events reported in the month of
November 2022 within the City of Raleigh Collections System [1]. This document also provides exhibits as proof
of our efforts to mitigate each sewer event. The events occurred while the City operated its collection system,
according to WQCS00002, dated June 6th, 2017. The permit includes the language outlined in footnote one 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:
[al 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 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;"
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Incident Number # 202201731 — 11/23/2022 —1414 Banbury Rd., Raleigh
This spill was neither willful nor intentional. It resulted from a water main break upstream of the affected sewer
asset at the intersection of Wade Avenue and Banbury Rd. (see exhibit 1-Water main break). As a result of the
water main break, large amounts of treated water reached the nearby sanitary sewer collection through the
underlying pavement. The quantity of water treated exceeded the collection's pipe capacity overwhelming an 8-
inch Ductile Iron pipe downstream. The large amount of treated water that entered the sanitary sewer
collection system sent copious amounts of silt and debris into the downstream sewer gravity main, causing
several manholes to discharge. This surge of water subsequently caused a sewer spill of approximately 4,725
gallons of untreated wastewater, in which about 4,000 gallons reached an unnamed tributary within Beaver
Southwest Basin. See Exhibit 2 — Area of Operation.
Exhibit 1— Water Main Break
Exhibit 2—Area of Operation 1- 2
On 11/23/2022, at approximately 7:45 AM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from multiple manholes along the 1400 block of Banbury Rd. (SMH162976, SMH 162977, SMH
161457) Raleigh, NC. The responding staff took all reasonable steps to stop and mitigate the impact of the
discharge, gaining control of the spill event by 08:48 AM on the same day. Crews utilized hydraulic jetting to
remove silt, sand, and gravel that accumulated within the sewer gravity main downstream of the water main
break, thus restoring sewer flow. Water Repair crews were able to shut a bypass valve isolating the water main
and shutting the treated water flow downstream.
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Containment and collection of this spill event consisted of employing various temporary containment sites
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 reintroducing 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
During the restoration phase of the operation, crews utilized ample potable water to flush the affected area and
remove all traces of untreated wastewater debris and silt from the surrounding area. The area around the
affected manholes and containment area was cleared of debris, treated with the application of lime, and
restored accordingly. See Exhibit 4 — Restoration Efforts.
Exhibit 4— Restoration Efforts
A follow-up CCTV assessment was conducted on 11/23/2022 to identify the root cause of the SSO. The
assessment found no infrastructure deficiencies that may have been attributed to the overflow. Additional
flushing of sewer gravity mains upstream and downstream of the affected asset was completed to remove any
remaining silt and grit from the gravity sewer main.
The cost of mitigating this event, including the cost associated with the water main repair efforts, amounted to
$14,105.51. The approximate cost to the Utility to have treated 4,725 gallons of wastewater would have been
approximately $7.08. The City saved no money from this spill. Its costs for cleanup and repair 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.
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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. This specific portion of the collection system
experience a non -reportable SSO on 11/20/2022 (1500 Banbury Rd, Raleigh) related to a rain event resulting in a
capacity issue. This area has been placed under routine maintenance.
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.
Raleigh Water Responds to a Sanitary Sewer Spill
REMINDER: Keep All Grease Out of the Shared Sanitary
Sewer System
On Wednesday, November 23, 2022, at approximately 7:45 am, Raleigh Water
staff were notified of a sanitary sewer spill in the vicinity of 1416 Banbury Rd, Raleigh
NC. The sanitary sewer spill was the result of roots accumulation within the sanitary
sewer system. The responding staff took all reasonable steps to slop and mitigate the
spill 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 8.48 am on the same day It is estimated that the spill discharged a
volume of approximately 4,725 gallons of untreated wastewater of which 4,000
gallons reached the Southwest Prong 6eaverdam Creek. Restoration of the affected
area has been completed. 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 of grease, debris, wipes, rags, diapers and other
improper materials in the sewer system and to take enforcement action
where appropriate. If these items make it into the sewer system, they may
cause a spill which can have an adverse impact on water quality and
endanger those who come into contact with the affected areas.
Water, human waste, and toilet tissue are the only items permitted to be
discharged into the sewer system. All other items will cause damage to the
sewer system and are not permitted.
If you experience excessive sewer smelts or see sewer spilling from
manholes or pipes, please call 919-996-3245 to report immediately.
For more information about how you can help prevent sanitary sewer
spills, please visit: raleighnc.govfwater.
This news release is required by NCGS Article 21, Chapter 143 215.IC
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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
2/7/2017
6/22/2017
7/16/2020
7/23/2020
7/30/2020
9/15/2020
CCTV
Activities
11/23/202
2/9/2017
3/9/2017
4/19/2018
8/5/2020
9/8/2020
9/8/2020
3/14/2022
Repair
Activities
8/27/2020
1/31/2020
8/9/2018
Inspections Activities
Sewer High Priority Inspection
12/29/2017
5/4/2018
8/31/2018
5/21/2019
Valve Inspection
8/9/2021
8/10/2021
8/11/2021
5/4/2022
11/14/2022
11/16/2022
Other Raleigh Water Activities
System Pressure Advisory
12/9/2020
11/28/2022
Valve Inspection (ELM)
1/2/2018
Water Main Repair
8/9/2017
1/1/2018
12/6/2020
12/7/2020
1/14/2022
11/23/2022
Water System Valve Box Adjustment
9/29/2022
Water System Valve DPR
2/8/2019
Water System Valve Repair
3/13/2019
Since the last sewer event, no additional issues have been associated with this section of the collection system.
Upon final investigation, it was determined that the SSO was directly related to the water main break as the
treated water entered the sanitary sewer collection system under the pavement and through the manhole's
brick walls. CCTV assessment did not find any other evidence of infrastructure failure.
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Summary
The Sewer Maintenance Division of Raleigh Water strives to develop initiatives that improve operational
reliability to meet customer expectations and meet or exceed the Water Quality Collection System permit
requirements. Our operations 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 (The fiscal Year 2023), the Utility has assessed approximately 103.84 [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
$ 1,148,708.67 [2], approximately .08% [3] of the Division's annual operating budget. The 4,721 gallons of
untreated wastewater spills identified in this letter cost the Utility approximately $14,105.51 to mitigate. The
City's cost of sewer treatment per gallon is $.0015 [4]. At this rate, it would have cost the City $7.08 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
Total - 371,519.51 Ft / 66.58 MILES
$ 885,577.46
[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
program. Each kit contains brochures and complimentary gadgets to help residents manage grease and fat
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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-0348 issued for November 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
perintendent 919-996-5929.
Cot-,\
rely,
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]
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