WQ0013348_NOV-2023-DV-0204_20230602

June 2tt, 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
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NC Dept oi'(ywironmcfuai
1 iittalitV
Raleigh Water
JON 2 2023
Qaleigh Rebuttal ptTicr
Re: Response to NOV-2023-DV-0204
Sanitary Sewer Overflows — April 2023
Permit No. WQCS00002
Dear Mr. Vinson:
Please allow this letter to respond to the Notice of Violation & Intent to Issue Civil Penalty
document (NOV-2023-DV-0204) received on May 16th, 2023. This document contains the narrative
regarding pending violation actions of (3) Sanitary Sewer Overflow (SSO) incidents identified as Notices
of Violations reported in the month of April 2023 within the City of Raleigh Collections System 11]. This
document also provides exhibits as proof of our efforts to mitigate each sewer incident. The noticed
incidents occurred while the City operated its collection system, according to WQCS00002, dated June
611, 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 of 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 incidents, listed with the intended NOV action.
Please find below the additional information requested for the SSO incidents.
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 were caused by severe
natural conditions or exceptional incidents unless the Permittee demonstrates through properly
signed, contemporaneous operating logs or other relevant evidence that:
]a.] The S50 was caused by severe natural conditions; there were no feasible alternatives 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 system's capacity. 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 backup equipment, or should have reduced Inflow and Infiltration; or
Ita] 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 facilhies to accommodate growth or adequately controlling and preventing
Infiltration and inflow); preventative maintenance; or installation of adequate backup equipment;."
Page 1 of 12

Incident Number# 202300561 — 4/18/2023 — 1431 Gavin St, Raleigh, NC
This spill was neither willful nor intentional; it resulted from a failed 8" sewer gravity main. This
asset failure led to a sewer spill of approximately 3,500 gallons of untreated wastewater, in which
approximately 500 gallons may have reached the surface waters of Pigeon House Branch within Pigeon
House Basin. See Exhibit 1— Area of Operations
Exhibit 1- Area of
On 04/18/2023, at approximately 3:51 PM, Sewer Maintenance staff was notified of a possible sewer
spill emanating from the ground near 1431 Gavin St, Raleigh, NC. Upon arrival, it was determined that a
section of the sewer gravity main had failed (see Exhibit 2 — Damaged Section of Gravity 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 incident by 10:00 PM on the same day.
Page 2 of 12

Cdntainment and collection of this spill event consisted of employing a temporary spill containment site
downstream of the affected area (see Exhibit 3 — Temporary Containment) supported by vacuum trucks
successfully recovering over 3,000 gallons of untreated wastewater before reaching Pigeon House
Branch. This approach was intended to contain sewer flow and minimize the environmental impact on
the state's surrounding land and downstream waters.
Responding crews initiated the collection of untreated wastewater from the containment site to
reintroduce it to the collection system downstream. 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.
Due to this affected asset's location and proximity to a railroad system, a comprehensive repair plan has
been developed through Raleigh Waters Capital Improvement Project that will include utility contractors
performing the repair in coordination with the local railroad system. The project is in the design phase.
The flow has been restored and monitored routinely to ensure the flow is not obstructed.
The cost associated with the mitigation of this incident amounted to $9,508.46. The approximate cost to
the Utility to have treated 3,500 gallons of wastewater would have been $5.25. 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 for treating the greater volume of
sewage created by the spill.
The incidents leading to this spill can be considered exceptional, unintentional, temporary, and caused
by factors beyond our reasonable control. Furthermore, the 550 could not have been prevented by
exercising 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.
Page 3 of 22

A press release notification related to this incident was requested to be published in the Raleigh News'&
Observer on Wednesday, April 19th, 2023. See Exhibit 4 — Press Release.
Raleigh Water Responds to a Sanitary Sewer Spill
Cn Tuesday.April 18,2023. stapp,odmsta 3:51 FM. Raleigh WaYr star vrere
netlfad d a santary sewer pversosi a sanitary seaer maMde lowktl near 1505
Cepihl BhA., Raleigh NC. Upon arial. WRy respcMers idan ad an asth a sever
orerffm resulting from a wllapsed r viNfied day sewer kroe main. The resyontling
roes took all reasonable steps to clop and mil gris the ovaracv/a imped se soon ss
they arrivetl ire With C Imo Department of Emmonmental CLafity. DiWaon of
Water Resoulttshas been notifified of the overfly.
Rekrdh Water staff amlamd the overlbw st spprodmstWy 10:00 Fhl on the
same day. A subsequent repair to woad the kded segirent of pipe a seats plarvhed, h
e estimated that the overflow tlisdhergetl a volume cf apprmurrehly 3.5M galkrn of
ur".ted wss:ewaler. of whidh epfaodmrttly 500 sell. reached Fgaon l4o.
Bnnch Restoration krthis Raldent s o,gokhg. Thera was no obserred fish leis or
unnecessary vepetebre tlemage rssultlng fnm this sewerevenl
Raleigh Water her en p,.. eduretion and enf roemint prrynm to
prevent fha didcherge of greeds. distant, wipes. reps. Map. and other improper
mdadals Rr ft sewer system and! to seeks ehf rein ment ac5on where
epfm,nste. If these items make i1 into Me sewer system. bray may cause a
spill which can have en adverse monad on waterquelay entl endanger Mox
.Mro coma kta wooed with the esedea sres.
Water. hhmmh caste and tcki tissue are Me only llems parmsed to be
discharged into to sews system. All other Remy ads reuse damage W Me
same, system and ere not permitted.
If you. enencar stop ve sewer smells or see sewer Spills, from maMdes or
shoes. please call 91 LQg M45 to report immedistafy.
For moreatfarmaton shout how you can here prevent sanitary serrer spills.
press. resit rekisMapovAveter.
�s news release is required by NCW Ardda 21, Chapter 143.215.IC.
ry
No additional issues have been associated with this section of the collection system since the last sewer
incident. This site continues to remain an active maintenance spot pending repair.
Page 4 of 12

Incident Number # 202300703 — 4/19/2023 — 9299 Glenwood Ave., Raleigh, NC, 27617
This spill was neither willful nor intentional; it resulted from a temporary valve -controlling
bypass that malfunctioned during a routine repair operation, leading to a sanitary sewer overflow of
approximately 1,000 gallons of untreated wastewater reaching a tributary of Sycamore Creek.
On 4/19/2023, during a routine station check and maintenance, a valve controlling bypass failed to close
fully, resulting in a temporary spill that lasted approximately 5 minutes. Accumulated debris impeded
the valve gate from closing. A vacuum truck was immediately dispatched to remove the debris, allowing
the gate to close, thus restoring normal operations to resume fully. The untreated wastewater reached
an unnamed tributary of Sycamore Creek. Crews immediately assessed environmental damage but did
not find evidence of debris or potential environmental pollution. Visual inspection of the affected area
and downstream waters confirmed that no fish kill or unnecessary vegetative damage occurred. See
Exhibit 1—Affected Area
Exhibit-1—Affected Area
This event required no containment or collection effort.
Restoration of this spill event consisted of washing the land surrounding the station. Crews utilized
ample potable water to flush the affected area. This spill was contained without a significant
environmental impact on the adjacent area and its natural resources.
The cost associated with the mitigation of this event was $ 353.00. The approximate cost to the Utility to
have treated 1,000 gallons of wastewater would have been approximately $1.50. 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 for treating the greater volume of sewage created
by the spill.
No additional issues have been associated with this section of the collection system since the last sewer
event. The station continues to be assessed weekly to ensure the adequacy of operation. A press release
notification associated with this event was requested to be published in the Raleigh News & Observer on
April 20th, 2023 (see Exhibit 2 — Press Release).
Page 5 of 12

Exhibit 2 — Press Release
Raleigh Water Responds to a Sanitary Sewer Spill
on wed,.wwAaa Ig, zgz3, tl aepmammay fo:oo N.I. Rakgh vytleramt
ssw mEhC da+mdWY aewr orer5awtl PoPo C>fusnppd Awwa. RaM:gn, NC.
Uqn vnM. tYhty resWnOen iEmtRM m vttirt vmwroMlaw bwJtiry M1wn v
IOiatl vNn of pumpsbtlon?&3yufMb Creek TM reap0ra'Ig vtaEfIXkall
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lsn NcrIF Cuclinv Deparunad dFs-.voneydY W Wry. Dmipn d'Nelrflawursas.
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appdnmaldy Io-fG A0.1 m e,a zcn l ny. X u eztimWM Ntlda darllcw lacMged
v udMldap(/6VINWYIgp' DagW dlNhdhU HBzhWaler. las' an
enema MUWy wiNn SYnmcb aavir Rn6va0pn M tiva awd uagCiMa TMre
rgdprenep 9sn XJI v1.nrNpyvry sepabMda^irya ravbp M1an Mu svver
euem
• Mmadt We dischan aggressive eAeaamnaM mrosemanlpognmb
prevent tlu disclurge of Ipeaza, delis, wipes,mat, taaror M aother
anprolbr mahiials in Me sever rysMn aM m bxe eNeemen! action
wnare appropriab. Xtlwae Rama mahe ilinb Me fex2r iYzhm, IMY maY
a aplll Mlica can Noe m adveruimpM on wmol 9uaIM antl
eManger Ndu vlw cane irrte eonbcl viN UnitaflechJ areas.
Water, hunt wash, mtl tot ant 6%am are Xb only items pen uteri to Le
ntschargtl into One sewer sysMn. RII oMn mans wig reuse damage to the
amear sysbm and am not pnmitled
Xyw eapnbrce "mazire uwer smalls w son, nwtr spilliq From
manMes w Plant, plaau"II 319936 to bpwt umnclately.
For mo,i rnrion aldd My you can Itellt prevent sartibry uwer
spilt, qnu visit nlagM..govhvm..
Th rem madma,'0 awietl W l CG5 Node 21. Gµtaa 143.215.IC.
kaa
Page 6 of 12

Incident Number # 202300717 — 4/21/2023 — 8401 Glenwood Ave., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a damaged section of a 24-inch
ductile iron pipe sewer force main (see Exhibit 1— Affected Asset). The damaged section of the pipe
resulted in the sewer spill of approximately 129,000 gallons of untreated wastewater, which was
contained downstream before reaching the state's surface waters. Approximately 7,000 gallons of
untreated wastewater reached the Turkey Creek tributary during the entire mitigation operation. This
incident occurred within the Turkey Basin.
Exhibit 1—Affected Asset
On 04/21/2023 at approximately 10:49 AM, Raleigh Water Staff were notified of a sanitary sewer
overflow near 8401 Glenwood Ave., Raleigh, NC. Utility responders were immediately summoned to
respond and mitigate the overflow. The responding staff took all reasonable steps to stop and mitigate
the impact of the discharge a's soon as they arrived, gaining control of the spill event by 12:16 PM on the
same day. Utility Responders immediately established several temporary containment areas stopping
the flow from continuing to travel downstream. See Exhibit 2 - Area of Operation.
Page 7 of 12

Exhibit 2 —Area w Operation
Containment and collection of this spill incident consisted of employing a series of temporary spill
containment sites downstream of the affected area. This approach was intended to contain sewer flow
and minimize the environmental impact on the surrounding land. The untreated wastewater was
collected utilizing vacuum trucks, high -capacity tanker trucks, and small debris pumps. This combined
effort allowed responding crews to collect and reintroduce approximately 122,000 gallons of untreated
wastewater to the collection system downstream. This spill was contained without a significant
environmental impact on the adjacent area and its natural resources. See Exhibit 3 —Temporary Spill
Containment & Collection.
During the restoration phase of the operation, sewer repair crews attempted to complete a temporary
repair of the affected force main. At the same time, a comprehensive total pipe replacement project
was being developed. Responding Crews worked over 48 hrs. on the clock to maintain flow within the
Page 8 of 12

farce main and keep the untreated wastewater from reaching surface waters (see Exhibit 4 - Repair
Efforts).
Restoration for the immediately affected area consisted of utilizing several thousand gallons of potable
water to assist in washing the affected area and removing all evidence of sewer downstream of the
affected asset. Visual inspection of the affected area and downstream waters confirmed that at least
four small fish 2-3 inches in length may have been killed due to the incident.
This incident and subsequent repair costs have amounted to over $1,348,585.51. The approximate cost
to the Utility to have treated 129,000 gallons of wastewater would have been approximately $193.50.
The City saved no money from this spill. The costs for cleanup exceeded the cost of treating the volume
of sewage, had no spill occurred. Furthermore, the City still had to pay the cost of treating the greater
volume of sewage created by the spill and the cost of potable water used to mitigate the event.
This portion of the sanitary sewer collection system is a major carrier of untreated wastewater in the
northwestern portion of the service area. A pipe replacement project is underway, replacing over 2,000
linear ft. of ductile iron pipe with PVC. See Exhibit 5 —Active CIP Pipe Replacement Project.
Exhibit 5 — Active CUP Pipe Replacement Project
Page 9 of 12

A press release notification associated with this event was published in the Raleigh News & Observer on
4/22/2023 (Exhibit 6 — Press release).
Exhibit 6 — Press release
Raleigh Water Responds to a Sanitary Sewer Overflow
On Friday. April 21, 2023, at approximately 10:50 AM. Raleigh Water shelf were
notified of a sarmary sewer overflow at 8401 Glenwood Ave_ Raleigh. NC. Upon arrusl.
Ufiliy respordem identified an active sewer overflow resulting from a failed sewer force
mein located st the same address. The responding staff ere taking all reasonable steps
I stop and mitigate the overlloWs impact. The North Carolina Department of
Fsvaenrnental Duality, Division of Weser Resources, has been natfietl of tie overflow.
Raleigh Water staff are waling diligently to restore the failed sevrer face main.
The overflow was contained st sppro amately 12:10 AM on the same day It is
estimated that the overflow has discharged approxarately, 43.500 gallons of untreated
wastewater, of which approrimately MCC gallons reached Turkey Creek within Turkey
Basin. Restoration for this incident is ongoing.
• Raleigh Water has an aggressive education said enforcement program to
prevent tie discharge of amsse debris, w,pes. ragsdiapers and other improper
materials an the sewer system and to take enforcement action where
appropriate. If these items make it into the sewer system. they nay cause a
Will which can have an adverse krpsct on water quslity end endaWerthose
who came ado contact with the affected eme.
• Waterhuman waste and toilet tissue are the only items pem4ted to be
discharged onto the sewer system. All other dams will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or see sewer spilling from manholes or
pipesplease cell 91 g-9136-3245 to report immedialey.
• For more sdomation about how you can help prevent sanitary sewer spills.
please vise. refeighnc.gm water.
This news release is required by NCGS Article 21, Chapter 143.215. 1C
04*
Page 10 of 12

Sommary
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 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 preventive maintenance
program to maintain over 2,600 miles of sanitary sewer pipe and minimize the accidental release of
untreated wastewater.
Since July 2022 (Fiscal Year 2023), the Utility has maintained approximately 936.95 [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 $ 2,054,254.45 (21, approximately 14% of the Division's annual operating budget. The
133,500 gallons of untreated wastewater, identified as notice of violations in this letter, cost the Utility
approximately $1,358,428.97 to mitigate. The City's cost of sewer treatment per gallon is $.0015 [3]. At
this rate, treating the untreated wastewater spilled would cost the City $200.25. 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 incident's severity and complexity. The City continues demonstrating due diligence in
environmental performance by allocating resources to a spill incident regardless of the associated cost.
This effort is noted in the City's SSO performance rate of 1.15 total SSO rate [41 per 100 miles of pipe,
compared to the Southeastern Region of the U.S., of 7.0 spills per 100 miles of line.
[11 936.95 miles represents approximately 36%of the entire sanitary sewer collection system
121 Associated operational cost year to date for FY2023
OPERATION
LINEAR FEET
Linear Miles
COST
CCTV
413,211.20
78.25
366,545.26
Repair
1,310
0.25
932,093.69
Flushing
1,836,732.38
347.8
624,651.96
Easement
459,360.00
87
130,963.54
Easement Inspections
2,236,890.12
426.65
N/A
The total cost of Business to
Total- 4,947,503.70
Ft/ 939.95 MILES
Date is $2,054,254.45
[3] F.Y. 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 F.Y. 23 is 1.15
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,
Page 11 of 12

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 continuously develops initiatives to increase
residential and commercial customer partnerships to address grease accumulation and prevent illicit
incident discharges. The educational material and videos can be accessed through social media and the
Raleigh Water website httPs:Hraleighnc.gov/sewer-maintenance
The City continues its monetary reward or bounty program, which pays out fifty ($50) to any citizen who
observes and reports an SSO or conditions that may cause a spill incident. 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 materials that could block the flow of the sanitary sewer mains. The City also circulates
information regarding grease discharge into the sewer system and the effects of such deposits.
Whenever possible, and upon investigating the root cause of a spill incident, PUD Code Enforcement
officers develop and send registered informational letters about the spill incident 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-2023-DV-0204 issued for the month of
April 2023 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, don't hesitate to contact Matthew Vessie, Sewer Maintenance Superintendent,
t (919) 996-231 or Carlos M. Perez, ORC, Assistance Superintendent, at 919-996-5929.
'nc rely,
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]
Page 12 of 12