WQCS00002_NOV-2022-DV-0139 Rsp_20220601

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Raleigh Water NC DION ofEn*onmental Quality
JUN 1 2022
June 1", 2022 Raleigh Regional office
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-0139
Sanitary Sewer Overflows-April 2022
Permit No. WQCS00002
Dear Mr.Vinson:
Please allow this letter to serve as a response to the Notice of Violation & Intent to Issue Civil
Penalty document (NOV-2022-DV-0139) received on May 171h, 2022.This document contains the
narrative regarding pending violation actions of(2) Sanitary Sewer Overflow(SSO)events, reported on
the month of April 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 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:
Ia.]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;"

Incident Number#202200609—4/17/2022—5500 Crossfield Dr., Raleigh
This spill was neither willful nor intentional, it was the result of root intrusion, which blocked a
portion of an 8-in gravity sewer main.The root intrusion led to a sewer spill of approximately 2,925
gallons of untreated wastewater in which roughly 1,500 gallons reached a nearby storm drain in the
Sycamore Creek Basin (see exhibit 1—Area of Operation)
Exhibit 1—Area of Operation
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On 04/17/2022, at approximately 3:32 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH148013) located near 5500
Crossfield Dr., Raleigh NC.The responding staff took all reasonable steps to stop and mitigate the impact
of the discharge,gaining control of the spill event by 5:29 PM on the same day. Crews utilized hydraulic
jetting to remove the source of the blockage within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
approximately 360 ft downstream of the affected area restricting sewer flow on the stormwater
channel.This approach was intended to contain wastewater flow and minimize the environmental
impact on the surrounding land. Responding crews employed pumps at the temporary containment site
to recover flushed wastewater and any evidence of sewer completing the operation by re-introducing
the wastewater to the collection system. This spill was contained without a significant environmental
impact on the adjacent area and its natural resources. Visual inspection of the affected area and
downstream waters confirmed no fish kill or unnecessary vegetative damage.
During the restoration phase of the operation, crews utilized ample potable water to flush the affected
area and remove sewer traces from the surrounding area and downstream conveyance.The area
around the manhole was cleared of debris, treated with an application of lime, and restored with grass
seed and straw. See Exhibit 2—Site Restoration.

Exhibit 2—Site Restoration
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A CCTV assessment identified a buried manhole as the root cause of the event (see Exhibit 3—Affected
Asset with Root Intrusion). Subsequently the manhole was exposed, raised to surface, and rid of root.
The CCTV assessment did not identify any other deficiencies requiring further maintenance.
Affected Asset with Root Intrusion
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The cost associated with the mitigation of this event amounted to$5,293.48. The approximate cost to
the Utility to have treated 2,925 gallons of wastewater would have been approximately$4.38. Raleigh
Water saved no money from this spill. Its costs for cleanup exceeded the cost of treating the volume of
sewage had no spill occurred. Furthermore, Raleigh Water still had to pay the cost to treat the greater
volume of sewage created by the spill.
This section of the collection system is located downstream of a residential area. It provides sewer
collection services to over 100 properties surrounding the spill event (see Exhibit 3-Zone of Influence).
Within the last ten years, this specific portion of the collection system has not experienced a root
related SSO event. This area has been placed on routine maintenance for root control.

Exhibit 3-Zone of Influence
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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. 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.
Exhibit 4—Press release
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COMMUNICATIONS DEPARTMENT
For mort,information
Matitti-P Vessie,Sewer Maintenance Manager,Raleigh Water,SM96-3245
Raleigh Water Responds to a Sanitary Sewer Spill
On Sunday,April 17,2022,at approbmately 3.32 PM.Raleigh Water-Sewer
Maintenance Division staff responded to a sanitary sewer spill located at 5500
Crosafield Way,Raleigh,NC Upon arrival,Utility responders identified an active
sewer spill
The responding staff took an reasonable steps to stop and mitigate the
impact of the spill as soon as they arrived The North Carolina Department of
Environmental Quality,Division of Water Resources was notified of the spill.
Raleigh Water staff removed the blockage source and contained the spill at
approximalely 5 29 PM on the same day II is estimated that the spill discharged a
volume of approximately/2,925 gallons of untreated wastewater of which approximately
1,500 gallons reached a nearby slorm drain in the Sycamore Creek basin.Restoration
for this event has been completed No vegetative damage or fish kin has been 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 permifted 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.govhxaler.
This news release is required by NCGS Article 21,Chapter 143,215,1C
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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 10 years as follows:
Easement Repair Inspections Activities
Flushing activities CCTV Easement
Maintenance Activities
Activities
3/9/2017 11/30/2017 9/14/2017 2/2/2018 9/27/2017 313 sewer asset
3/10/2017 12/1/2017 10/2/2017 8/9/2018 inspections since 2018
4/4/2017 12/5/2017 10/11/201 6/22/2020
5/16/2017 12/7/2017 10/17/201
6/15/2017 12/11/2017 11/30/201
6/16/2017 2/23/2018 3/17/2018
6/20/2017 4/21/2022 3/1/2020
8/14/2017 3/8/2021
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.

Incident Number#202200675—4/22/2022—3019 Forestville Rd. Raleigh
This spill was neither willful nor intentional, it resulted from a failed 8" ductile iron sewer forced
main. This asset failure led to a sewer spill of approximately 3,000 gallons of untreated wastewater not
remaining within the natural topography and not reaching surface waters of Neuse Basin.
On 04/22/2022, at approximately 02:49 PM, Sewer Maintenance staff was notified of a sewer spill
emanating from the ground, near 3019 Forestville Rd. Upon arrival, it was determined that a section of
forced main had failed (see Exhibit 1—Damaged Section of Force Main).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 06:30 PM on the same day. Exhibit 1—Damaged section of Force Main
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Containment, collection, cleanup, restoration, and repair of this spill event consisted of employing a
vacuum truck to minimize the flow of untreated water downstream and isolating the site for the repair
to be completed. Sewer repair crews, in coordination with pump station mechanics, reduced the flow
until the damaged section of pipe was repaired (see Exhibit 2—Completed Repair). Normal sewer flow
was restored at approximately 11:45 PM on the same day.
Exhibit 2—Completed Repair
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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 that no fish kill or
unnecessary vegetative damage occurred.
Crews utilized ample water, during the restoration phase of the operation, to flush the surrounding
affected area.The site of the sewer run-off was treated with an application of lime and restored with
grass seed and straw.
The cost associated with the mitigation of this event amounted to $8,766.25.The approximate cost to
the Utility to have treated 3,000 gallons of wastewater would have been approximately$4.50. 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 to treat the greater
volume of sewage created by the spill.
The events leading to this spill can be considered 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. This asset has been identified for additional
assessment and a possible capital improvement project for replacement.
A press release notification related to this event was requested to be published in the Raleigh News&
Observer on April 22, 2022.There have been no further sewer events associated with this location.
Raleigh
NEWS RELEASE
Raleigh Water Responds to a Sanitary Sewer Spill
On Friday April 22,2022,at approximately 2 49 PM,Raleigh Water-Sewer
Maintenance Division staff responded to a Bandar/sewer spill located at 3019
Forestville Road,Rolesville,NC Upon arrival,Utility responders identified an active
sewer spill.The responding staff took all reasonable steps to stop and mitigate the
impact of the spill as soon as they arrived.The North Carolina Department of
Environmental Quality,Division of Water Resources was notified of the spill
Raleigh Water staff removed the blockage source and contained the spill d
approximately 6 30 PM completing the necessary repair of the damaged section of pipe
at approximately 10:00 PM.It is estimated that the spill discharged a volume of
app_imalely 3.000 gallons of unheated wastewater which remained an the natural
topography not reaching surface waters of the State.This Incident occurred within the
Neuse Basin No vegetative damage or fish kill has been observed related to this
rent
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 permtted.
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:raleighne.govnxater.
This news release is required by NCGS Article 21,Chapter 143.215AC.

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 5,925 gallons of
untreated wastewater spill identified in this letter cost the Utility approximately$14,059.73. to mitigate.
The City's cost of sewer treatment per gallon is$.0015 [3]. At this rate, it would have cost the City$8.88
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.
[11299.8 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 1.1 $ 1,826,277.64
Total- 1,582,896 Ft Total cost of Business to Date
299.8 MILES $ 2,640,575.97
[3]$.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[4]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 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 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-DV-0139 issued for the month of
April 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(919) 996-
2312, or Carlos M. Perez, ORC, Assistance Superintendent 919-996-5929.
S.i.ncerely,
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
[e-mail]