WQCS00002_Compliance Evaluation Inspection_20230922

DocuSign Envelope ID: OB9EA9C5-F7B6-4772-9B32-29358FF541BD
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. John Kiviniemi
Assistant Director of Raleigh Water
City of Raleigh
P.O. Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
September 22, 2023
Subject: Compliance Evaluation Inspection
City of Raleigh Sewer Collection System
Collection System Permit No: WQCS00002
Wake County
Dear Mr. Kiviniemi:
On June 30,2023, Cheng Zhang and Kevin Fowler of the Raleigh Regional (RRO) Office Division of
Water Resources conducted a Compliance Evaluation Inspection of the subject facility. The assistance
and cooperation of you, Mr. Matt Vessie, the Utilities Manager, Mr. Carlos Perez, the Operator in
Responsible Charge (ORC), and many other members of your staff during the inspection, were very
helpful and appreciated. A checklist of items is enclosed with this letter. During the inspection the
following items were noted:
1.) The City's collection system is classified as a Class 4 collection system. It has approximately 2,468
miles of gravity sewer mains, 134 miles of force main, 517 simplex pump stations that discharge to a
pressure sewer and serve a single building, 4 simplex pump stations serve more than one building,
and 123 duplex pump stations. Mr. Carlos Perez is the Operator in Responsible Charge (ORC) and
Mr. Jeffrey Bognar, Mr. David Collins, Mr. David Jackson, Mr. Manuel Lopez, and Mr. Chris
Worthy are the backup ORCs.
2.) The City has a GIS based collection system map which has all items required by the permit.
3.) The City has adopted a Sewer Use Ordinance and established inter -local agreement with Town of
Clayton in Johnston County.
4.) The City has developed and implemented a Capital Improvement Plan (CIP) for the sewer system,
which includes all components required by the permit. Current CIP covers a ten-year period (2021 to
2030). The CIP covers sewer interceptor upgrades, sewer main replacement under Asset
Management Plan (AMP), pump station upgrades, and miscellaneous sewer improvement.
5.) The system has 123 duplex pump stations, all stations were equipped with SCADA. Major pump
stations are inspected daily, others weekly. Five pump stations were visited during the inspection. It
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ 919.791.4200
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DocuSign Envelope ID: OB9EA9C5-F7B6-4772-9B32-29358FF541BD
was noted that the visual/audible alarms at Pump Station #53 were not functioning at the time
of inspection.
6.) The City has developed and implemented a Fats Oils and Grease (FOG) program. Grease
traps/interceptors at restaurants are inspected by the City's Fat/Oil/Grease Program inspectors. It
was noted that distribution/mailing of FOG educational material has not been conducted and
documented in the past several years, due to the City's information vetting policy. 15A NCAC
02T .0108 (b) requires at least semiannual distribution of FOG educational material targeted
at both residential and nonresidential users. It was noted that FOG educational material and
water/wastewater reports are posted on the City's website and available to consumers. The City has
implemented an aggressive educational outreach initiative that addresses illicit discharges such as
wipes, fats, oil, and grease to commercial and residential users. The City developed a complimentary
property managers resource kit for residential users that provides best practice resources for
establishing a property -specific awareness program. The City continues its monetary reward or
bounty program to promote pollution prevention, 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. The City 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. With consideration of these initiatives the City has taken, distribution of
FOG educational material can be reduced to annually.
7.) The City has developed and implemented a spill response action plan; the plan was updated in June
2023 and found adequate.
8.) A review of records and logbooks indicate the following:
a) Records are maintained adequately for sewer line maintenance, cleaning, high priority line
inspection, and right of way maintenance. All maintenance and inspection records are kept in
Cityworks program. The City is behind the schedule in sewer easement maintenance due to
the Covid pandemic, has developed a strategy by classifying sewer easements into four
categories and acting accordingly to ensure easement is accessible should a spill happens.
b) 174 Sanitary Sewer Overflows (SSOs) were discovered or reported since the last inspection.
Required SSO reports, press releases, and public notices were available for review.
9.) The City has designated over eleven thousand high riority/aerial lines; these lines are inspected semi-
annually. Two siphon boxes were observed during the inspection, which were in good condition, the
right-of-way to these lines was well maintained.
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
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DocuSign Envelope ID: OB9EA9C5-F7B6-4772-9B32-29358FF541BD
Please respond in writing to RRO within 30 days of receipt of this letter regarding Items 5 and
6. If you have any questions regarding the attached report or any of the findings, please contact Cheng
Zhang at: [phone] (or email: Cheng [e-mail]. og_v).
Sincerely,
DocuSigned by:
-e. haKAxt
B2916E6A632144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Attachments: Compliance Inspection Report
Cc: Laserfiche
Matt Vessie, City of Raleigh (Electronic copy only)
Carlos Perez, City of Raleigh (Electronic copy only
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
nnpn .mo EnWromm�nfal nual

DocuSign Envelope ID: 77395B63-F578-426C-A70E-F79E1FAC8F91
Compliance Inspection Report
Permit: WQCS00002 Effective: 02/01/16 Expiration: 01/31/24 Owner: City of Raleigh
SOC: Effective: Expiration: Facility: Raleigh Collection System
County: Wake PO Box 590
Region: Raleigh
Raleigh NC 276020590
Contact Person: John Kiviniemi Title: Phone: [phone]
Directions to Facility:
System Classifications: CS4,
Primary ORC: Carlos Manuel Perez
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: 1003875 Phone:[phone]
NC0030759
City of Raleigh - Smith Creek Resource Recovery Facility
NC0079316
City of Raleigh - Little Creek Resource Recovery Facility
WQCS00094
Town of Zebulon - Zebulon Collection System
WQ0002708
City of Raleigh - Wrenn Road WWTF
NC0029033
City of Raleigh - Neuse River Resource Recovery Facility
WQCS00063
Town of Knightdale - Knightdale Collection System
WQCS00308
Town of Wendell - Wendell Collection System
Inspection Date: 06/30/2023 Entry Time 09:OOAM Exit Time: 02:30PM
Primary Inspector: Cheng Zhang Docusignedby: Phone: [phone]
Secondary Inspectors):
D6171508E1EC41 F...
Kevin Fowler DocuSigned by:
E
t
Reason for Inspection: Routine 1�lIiL Fewer Inspection Type: Collection System Inspect Non Sampling
F04A5B95DCE14CC...
Permit Inspection Type: Collection system management and operation
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Miscellaneous Questions
Capital Improvement Plan
Inspections
Lines
(See attachment summary)
General
Map
Spill Response Plan
Manholes
Sewer & FOG Ordinances
Reporting Requirements
Spills
Pump Stations
Page 1 of 7

DocuSign Envelope ID: 77395B63-F578-426C-A70E-F79E1FAC8F91
Permit: WQCS00002 Owner - Facility: City of Raleigh
Inspection Date: 06/30/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Current permit will expire on January 31, 2023. Renewal application received by the Division on August 3, 2023.
The City has a Sewer Use Ordinance. The City has implemented a grease trap/interceptor inspection program,and taken
enforcement actions against violators. Distribution of grease/sewer educational material has not conducted and documented
since the last inspection due to the City's Information Vetting Policy.
The City has developed and implemented a Capital Improvement Plan covering a period from 2024 through 2028.
The Spill Response Action Plan was adequate.
The City maintains a GIS based sewer system map that has all required elements.
All inspections (pump stations, manholes, high priority lines), maintenance (right-of-way/easements, gravity line cleaning),
and repair are documented digitally as work orders.
The City reported 174 SSOs since 2019, SSO reports and required press releases/public notices were available for review.
Annual wastewater performance reports have been submitted to the Division and available to all customers (posted on the
City's website).
Five pump stations and two siphon boxed were visited during the inspection. It was noted that visual and audible alarms at
Pump Station #54 were not functioning.
Page 2 of 7

DocuSign Envelope ID: 77395B63-F578-426C-A70E-F79E1FAC8F91
Permit: WQCS00002 Owner - Facility: City of Raleigh
Inspection Date: 06/30/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade? 0 ❑ ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis? 0 ❑ ❑ ❑
# What is that frequency? weekly
# Are there any issues being addressed currently or any in the planning stages?
0
❑ ❑ ❑
Is there a specific pump failure plan available for all pump stations?
0
❑ ❑ ❑
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
0
❑ ❑ ❑
Are new/significantly upgraded pump stations equipped with anti -corrosion materials?
0
❑ ❑ ❑
Does the permittee have a copy of their permit?
0
❑ ❑ ❑
# Is permit expiring within the next 6 months?
0
❑ ❑ ❑
If Yes, has the Permittee applied for renewal?
0
❑ ❑ ❑
Comment: Current permit will expire on January 31, 2023. Renewal application received by
the Division on
August 3, 2023.
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
0
❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced?
0
❑ ❑ ❑
Is there a Grease Control Program that legally requires grease control devices?
0
❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance?
30 days
Is Grease Control Program enforced via periodic inspections/records review? 0 ❑ ❑ ❑
Is action taken against violators? 0 ❑ ❑ ❑
# Have satellite systems adopted an equivalent or more stringent ordinance? 0 ❑ ❑ ❑
Is grease/sewer education program documented with req'd customer distribution? ❑ 0 ❑ ❑
# Are other types of education tools used like websites, booths, special meetings, etc? 0 ❑ ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
Grease/sewer educational material posted on the City's website.
Comment: Distribution of grease/sewer educational material was not conducted and documented due to
the City's Information Vetting Policy.
Capital Improvement Plan Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted? ❑ ❑ ❑
Is it designated for wastewater only or does it have a dedicated section? ❑ ❑ ❑
Does CIP cover three to five year period of earmarked improvements? ❑ ❑ ❑
Does CIP include description of project area? ❑ ❑ ❑
Does CIP include description of existing facilities? ❑ ❑ ❑
Does CIP include known deficiencies? ❑ ❑ ❑
Does CIP include forecasted future needs? 0 ❑ ❑ ❑
Comment:
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DocuSign Envelope ID: 77395B63-F578-426C-A70E-F79E1FAC8F91
Permit: WQCS00002 Owner - Facility: City of Raleigh
Inspection Date: 06/30/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Map
Yes No NA NE
Is there a overall sewer system map?
0
❑ ❑ ❑
Does the map include:
Pipe Type (GS/FM)
0
❑ ❑ ❑
Pipe sizes
0
❑ ❑ ❑
Pipe materials (PVC, DIP, etc)
0
❑ ❑ ❑
Pipe location
0
❑ ❑ ❑
Flow direction
0
❑ ❑ ❑
Approximate pipe age
0
❑ ❑ ❑
Pump station ID, location and capacity
0
❑ ❑ ❑
# Force main air release valve location & type
0
❑ ❑ ❑
# Location of satellite connections
❑
❑ 0 ❑
Is the map being updated for changes/additions within 1 year of activation?
0
❑ ❑ ❑
Reporting Requirements Yes No NA NE
# Have there been any sewer spills in the past 3 years? ❑ ❑ ❑
If Yes, were they reported to the Division if meeting the reportable criteria? ❑ ❑ ❑
If applicable, is there documentation of press releases and public notices issued? ❑ ❑ ❑
Is an Annual Wastewater Performance Report being filed with the Division, if required? ❑ ❑ ❑
Is the report being made available to all its sewer customers? ❑ ❑ ❑
# How is it being made available? posted on the
City's website
Comment:
Inspections
Yes No NA NE
Are adequate maintenance records maintained?
❑ ❑ ❑
Are pump stations being inspected at the required frequency?
❑ ❑ ❑
# Is at least one complete functionality test conducted weekly per pump station?
❑ ❑ ❑
Is there a system or plan in place to observe the entire system annually?
❑ ❑ ❑
Is the annual inspection documented?
❑ ❑ ❑
# Does the system have any high -priority lines/locations?
❑ ❑ ❑
Are inspections of HPL documented at least every 6 months?
❑ ❑ ❑
Are new lines being added to the HPL list when found or created?
❑ ❑ ❑
Comment:
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available? 0 ❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑
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DocuSign Envelope ID: 77395B63-F578-426C-A70E-F79E1FAC8F91
Permit: WQCS00002 Owner - Facility: City of Raleigh
Inspection Date: 06/30/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Does the plan include:
24-hour contact numbers ❑ ❑ ❑
Response time ❑ ❑ ❑
Equipment list and spare parts inventory ❑ ❑ ❑
Access to cleaning equipment ❑ ❑ ❑
Access to construction crews, contractors, and/or engineers ❑ ❑ ❑
Source of emergency funds ❑ ❑ ❑
Site sanitation and cleanup materials ❑ ❑ ❑
Post-overflow/spill assessment ❑ ❑ ❑
Does the Permittee appear to respond within 2 hours of first knowledge of a spill? 0 ❑ ❑ ❑
Comment:
$pills Yes No NA NE
Is system free of known points of bypass? ❑ ❑ ❑
If No, describe type of bypass and location
Are all spills or sewer related issues/complaints documented? ❑ ❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ ❑ ❑
# If Yes, is there a corrective action plan? ❑ ❑ 0 ❑
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Two siphon boxes at Walnut Creek Outfall
Are right-of-ways/easements maintained for full width for access by staff/equipment? ❑ ❑ ❑
If No, give details on temporary access:
Is maintenance documented? ❑ ❑ ❑
Are gravity sewer cleaning records available? ❑ ❑ ❑
Has at least 10% of lines older than 5 yrs been cleaned annually? ❑ ❑ ❑
Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑
Comment:
Manholes
Yes No NA NE
Please list the Manholes Inspected:
Manhole outside Pump Station #51
Manhole outside Pump Station #54
Are manholes accessible?
❑ ❑ ❑
# Are manhole covers/vents above grade?
❑ ❑ ❑
Are manholes free of visible signs of overflow?
❑ ❑ ❑
Are manholes free of sinkholes and depressions?
❑ ❑ ❑
Are manhole covers present?
❑ ❑ ❑
Page 5 of 7

DocuSign Envelope ID: 77395B63-F578-426C-A70E-F79E1FAC8F91
Permit: WQCS00002 Owner - Facility: City of Raleigh
Inspection Date: 06/30/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
# Are manholes properly seated?
0
❑ ❑ ❑
# Are manholes in good condition?
0
❑ ❑ ❑
# Are inverts in good condition?
0
❑ ❑ ❑
Is flow unrestricted in manholes?
0
❑ ❑ ❑
Are manholes free of excessive amounts of grease?
0
❑ ❑ ❑
Are manholes free of excessive roots?
0
❑ ❑ ❑
Are manholes free of excessive sand?
0
❑ ❑ ❑
Are manhole vents screened?
0
❑ ❑ ❑
Are vents free of submergence?
0
❑ ❑ ❑
Are manholes free of bypass structures or pipes?
0
❑ ❑ ❑
Comment:
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Pump Station #123, #51, #53, #54, #41 (Walnut Creek)
# Number of duplex or larger pump stations in system
123
# Number of vacuum stations in system
0
# Number of simplex pump stations in system
517
# Number of simplex pump stations in system serving more than one building
4
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?
127
# A simple one-way telemetry/communication system (auto -dialer) installed?
4
For pump stations inspected:
Are they secure with restricted access?
0
❑ ❑ ❑
Were they free of by-pass structures/pipes?
0
❑ ❑ ❑
Were wet wells free of excessive grease/debris?
0
❑ ❑ ❑
# Do they all have telemetry installed?
0
❑ ❑ ❑
Is the communication system functional?
0
❑ ❑ ❑
Is a 24-hour notification sign posted ?
0
❑ ❑ ❑
Does the sign include
Owner Name?
0
❑ ❑ ❑
Pump station identifier?
0
❑ ❑ ❑
# Address?
0
❑ ❑ ❑
Instructions for notification?
0
❑ ❑ ❑
24-hour emergency contact numbers?
0
❑ ❑ ❑
Are audio and visual alarms present?
0
❑ ❑ ❑
Are audio and visual alarms operable?
❑
0 ❑ ❑
Page 6 of 7

DocuSign Envelope ID: 77395B63-F578-426C-A70E-F79E1FAC8F91
Permit: WQCS00002 Owner - Facility: City of Raleigh
Inspection Date: 06/30/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# Is there a backup generator or bypass pump connected? 0 ❑ ❑ ❑
If tested during inspection, did it function properly? ❑ ❑ ❑
Is the back-up system tested at least bi-annually under normal operating conditions? 0 ❑ ❑ ❑
# Does it have a dedicated connection for a portable generator? ❑ ❑ 0 ❑
# Is the owner relying on portable units in the event of a power outage? ❑ ❑ 0 ❑
# If Yes, is there a distribution plan? ❑ ❑ 0 ❑
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
# Does Permittee have the approved percentage of replacement simplex pumps? 0 ❑ ❑ ❑
Is recordkeeping of pump station inspection and maintenance program adequate? 0 ❑ ❑ ❑
Do pump station logs include at a minimum:
Inside and outside cleaning and debris removal? 0 ❑ ❑ ❑
Inspecting and exercising all valves? 0 ❑ ❑ ❑
Inspecting and lubricating pumps and other equipment? 0 ❑ ❑ ❑
Inspecting alarms, telemetry and auxiliary equipment? 0 ❑ ❑ ❑
Comment: Visual and audible alarms at Pump Station #54 were not functioning at the time of inspection.
Page 7 of 7