HomeMy WebLinkAboutWQCS00002_NOV-2023-DV-0342_20231003 (2)�` `F/0
110
1111111111"
Raleigh Water
October 2"d, 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-2023-DV- 0342
Sanitary Sewer Overflows —August 2023
Permit No. WQCS00002
Dear Mr. Vinson:
Please allow this letter to respond to the Notice of Violation document (NOV-2023-DV-0342) received on
September 18, 2023. This document contains the narrative regarding the pending Notice of Violation action of
(4) Sanitary Sewer Overflows (SSO) event, reported on the month of August 2023, within the City of Raleigh
Collections System Ill• This document also provides exhibits as proof of our efforts to mitigate the sewer events.
The noticed events occurred while the City operated its collection system, according to WQCS00002, dated June
6, 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 were 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 550 was caused by severe natural conditions; there were no feasible alternatives to the S50, 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 backup equipment, or should have reduced inflow and infiltration or
(b.j The 550 was exceptional, unintentional, temporary, and caused by factors beyond the reasonable control of the Permittee; the 550 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 backup equipment;"
Incident Number # 202301200 — 8/16/2023 —1115 Temple St., Raleigh
This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of an 8-in
Vitrified -Clay Pipe gravity sewer main. The root intrusion led to a sewer spill of approximately 3,600 gallons of
untreated wastewater reaching an unnamed tributary within the Mine Basin (see exhibit 1—Area of Operation)
On 08/16/2023, at approximately 5:57 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH113461) located near 1115 Temple St.,
Raleigh, NC. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge,
gaining control of the spill incident by 09:40 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 incident consisted of employing a temporary spill containment site
downstream of the affected area, restricting sewer flow to downstream surface waters. 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.
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 lime, and restored with grass seed and straw.
A CCTV assessment identified root intrusion as the incident's root cause (see Exhibit 2 — Affecting Assets with
Root Intrusion).
Exhibit 2 -
The cost associated with the mitigation of this incident amounted to $6,799.82. The approximate cost to the
Utility to have treated 3,600 gallons of wastewater would have been approximately $5.40. 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 for 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 residences surrounding the spill incident (see Exhibit 3- Future root control services). Within
the last ten years, this specific portion of the collection system experienced a non -reportable SSO related to root
intrusion in which approximately 495 gallons of untreated wastewater spilled onto the ground. The SSO was
mitigated with hydraulic jetting and mechanical root cutters. Sanitary sewer assets in this area have been
routinely maintained with subsequent chemical root control treatment.
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.
Exhibit 4— Press release
Raleigh Water Responds to a Sanitary Sewer /9vernow
OnN'mn...,,aWuH I6. M21tl;pnaenablY 53a PM, R.a WMar Ya9
wxi xiMJ a. w:Lry,wwr B+erw: C 1I15 T—A st nMNgn. vc. 11p n
mnl UuM ngmJfla WanCrea a+sarve amw m'v5awmurpng Ncm rw!
Xbagn. Tlo inuOmX Wlut':bJ Nu!Iowol ul4sMo-1 roawivl icn� an }rrGr V 4A.v
CI%fMp 9"My.'tlpJ.TM IHp'Ndn94b111Wk eJ try Wnide HN4 b Hry fM
dMgiq M evflMMt IMW it fevr is NtylrtnE. TN YaM Cvtlm, n;vmv.
a enulrnm..bl wMM omiw p xaw Nas+vs. wu +uMe] Mx owmr..
Rpypl Wdbf 40111 Snbbrp na hadbn dl dOT �nNM Y Ba0 iM p1 Ni
trio JaY. 2b.. W Cq 9q OMt(gx Ji,Mu�9ec aepJamMary J0.N 9all>+s u'
tealM'u9NawHO.liidu'UM U. WmOm
rn b]Mb prguN,
W'clgP Waln Nam uri n.. ebrw, ntnbd.s po}anrtl
Grc:emM 6fM•aq,algn,se. Jeers, wryer ray. Obpm am ]nv mpmp<r
maepbla nM,ew.rtmm,a tl ba nrbwmam aam nNMe
aGGmr01e, I(IMa bma Tab J mp Ilru mnx�a'i Ham IMY m01 Ouef a
i wN[Ir ar Mc n eMr3C rPaC an rvekr cu ty aW Otlm9M J'Ox
.M] C!M /rC RFlbM wM MaMcte] via
waw. +l*m wa0. an tl�C. Jet'.X arc Se mM Jm's pmnmJro w
nb ub iawu a»'am M c'sw tlu3 wi Gw V W M
u.YGr4»im'wd m1 permltJ
It IVYi4NwMf Baauve aswe-ti0A4aof SmM WAN ft nm,nMYnp
G�Pfi. Orifti OJ 9•eAH3J3<5 •a rppl immeJmOy
Fv maa�MruNmaew:nwrpu un Mp xevem aaulaMimer ePin
PpeteVM etlfr9Meq]YM'We/
Trv, rrcw[stlnfe b le}aW %NCGS Mtlm 31. Jrfpty 1432151C
iA
Before this incident, 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
1/26/2017
12/31/2019
12/10/2019
1/2/2020
12/11/2019
6/8/2022
12/19/2019
9/12/2023
12/23/2019
9/29/2023
CcTv
Easement
Activities
Maintenance
Activities
2/3/2017
7/25/2023
2/2/2017
7/25/2023
8/16/2023
Inspections Activities
12/15/2017
10/28/2020
5/29/2018
5/4/2021
6/6/2018
8/26/2021
10/1/2018
3/3/2022
3/13/2019
9/13/2022
3/14/2019
9/13/2022
8/6/2019
2/22/2023
1/15/2020
2/27/2023
10/16/2020
7/20/2023
Since the last sewer incident, no additional sewer issues have been associated with this section of the collection
system. This site remains an active maintenance spot pending the completion of further sewer main cleaning
and chemical root control application.
Incident Number # 202301204 — 8/22/2023— 2609 Spring Forest Rd., Raleigh
This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of an
8-in ductile iron pipe -gravity sewer main. The root intrusion led to a sewer spill of approximately 1,750 gallons of
untreated wastewater reaching an unnamed tributary within the Mine Basin (see exhibit 1—Area of Operation)
On 08/22/2023, at approximately 12:34 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH156784) located near 2609 Spring Forest
Rd., Raleigh, NC. The responding staff took all reasonable steps to stop and mitigate the impact of the discharge,
gaining control of the spill incident by 01:30 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 incident consisted of employing a temporary spill containment site
downstream of the affected area, restricting sewer flow to downstream surface waters. 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. See Exhibit 2 —Containment and Collection.
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 lime, and restored with grass seed and straw.
A CCTV assessment identified root intrusion as the incident's root cause (see Exhibit 3 — Affecting Assets with
Root Intrusion).
The cost associated with the mitigation of this incident amounted to $8,488.14. The approximate cost to the
Utility to have treated 1,750 gallons of wastewater would have been approximately $2.62. 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 for treating the greater volume of sewage created by the
spill.
This section of the collection system is located downstream of a commercial area. It provides sewer collection
services to several establishments surrounding the spill incident. This specific portion of the collection system
has not experienced an SSO within the last ten years. Sanitary sewer assets in this area have been routinely
maintained for subsequent chemical root control treatment.
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.
Exhibit 4— Press release
Raleigh Water Responds to a Sanitary Sewer Overflow
Un-ueadey. August 22. at ap,sOc Mildly 12.3 PM, Pa',ea9 Water son
ware dos9 la sanldery a nni, pvNgow near 2609 Sp ins Forest Rd. Walsh NC.
Upon solved, Utaly ResparN63 idamle an adore sewer oelew rauifng hama
bkcAsed of seism lne newer tsars,, main Tne re.01.0took al eaet�e,de
atepsm amp scot mlgab tle, anR�-w'e Impact as seen n Ihe, amnec Tba hl"
C msra Dep.meat a C. vkc .,Wl oueM towalon of W os Rasoumex, One teen
named ul and twernow.
Raie9h Waer MR conlamed he owtftw at approximately 1 N PM M de,
same, day. ll N eagae,tad Uu11M ondlow dpcherge l a wlunla Of ainnexerna ly 17W
galore of u musside wastewater, s h 0 did read) a aharn dmin am unmYely reacsed
an rmimao lnd.I.vy in vOunr Cmak Raemrepon b, INs.rem nes Ewen completed
Nam rglaNhve dismiss or 5sh NY related Of in. mm raw been postal as Inw
WaeteWaM cod not onto suda:w wou,
R,Nil W.O., Mean.g ,enn. sae aduceWn and anloeamsnt program to
,overt IN discharge, at pens, debda, wipec ngs, dNpen aM What
Improper matedats In the sawn system and m Mks snfoesmem action when
appmpriam. "Ih.a. Imm. make d Into It. sower s,In., they may ca... a
.pill which cmr have an elvers Impaq an net t llry and endanger" we
who cane Into contest wth the ."sled ama.
Water, human waste. and RORM ths.. are We only items permllted to be
dh thargad Ime tlw saws fyslem. MI twiner Item. will .... damage to the
s.wsr snnm and,re not wnnlRed.
tlyou extu ddncd...I. saws, amNls or no.tamer spilllie from
manholes or plpan, pl.. tall 919-996424610 mpod immediately.
For mtq Inlormatlon clout haw you can help preen sanitary fewer spills,
pleas. NYh La1pMc.govwaur.
ThN rewn elease n; requmdl d, NCCS Article 21. C40W 143211
Before this incident, 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
CCTV Activities Repair Activities
Inspections Activities
2/8/2018
4/13/2021
5/2/2017
9/24/2021 10/11/2018
10/31/2019
2/15/2018
5/18/2021
5/5/2017
8/15/2023
11/4/2019
3/9/2018
6/24/2021
3/8/2018
8/28/2023
11/17/2022
7/31/2018
9/10/2021
7/31/2018
8/28/2023
6/17/2022
2/24/2021
8/15/2023
4/9/2021
5/12/2023
3/2/2021
8/22/2023
7/12/2021
Since the last sewer incident, no additional sewer issues have been associated with this section of the collection
system. This site remains an active maintenance spot pending the completion of further sewer main cleaning
CCTV assessment and chemical root control application.
Incident Number# 202301218-8/24/2023-701 Van Buren Road., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a collapsed 8" sewer gravity main resulting from a
void created by a collapsed underground stormwater pipe. This asset failure led to a sewer spill of approximately
1,500 gallons of untreated wastewater, which remained within the natural topography and did not reach surface
waters. See Exhibit 1—Area of Operations
On 08/24/2023, at approximately 2:11 PM, Sewer Maintenance staff was notified of a sewer odor near 701 Van
Buren Road. Raleigh, NC. Upon arrival, it was determined that a section of the gravity main had failed (see
Exhibit 2 — Damaged Section of Gravity Main). The pipe collapse directly resulted from a collapsed stormwater
pipe that eroded the surrounding ground, creating a void that undermined the sewer 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 7:15 PM on the same day.
Containment, collection, cleanup, restoration, and repair of this spill incident consisted of employing a vacuum
truck to minimize the flow of untreated water downstream and isolating the site for the repair to be completed.
Repair crews repaired the damaged section of the sewer pipe and stormwater pipe accordingly (see Exhibit 3 —
Completed Repair). Normal sewer flow was restored on the same day.
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 the spill did not reach
any surface waters of the state.
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 incident amounted to $5,681.07. The approximate cost to the
Utility to have treated 1,500 gallons of wastewater would have been approximately $2.25. 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 SSO 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.
A press release notification related to this incident was requested to be published in the Raleigh News &
Observer on August 28 and August 28, 2023. There have been no further sewer incidents associated with this
location. See Exhibit 4 — Press Release
No additional issues have been associated with this section of the collection system since the last sewer
incident.
Raleigh Weld Responds to a Snnital SewerOverflow
asY:eri.aepnv.IznpnruxenwanwWmiemwaefYarve«w ap'NPm,.w✓.
l ssndo P.1 RNxp:IC llpMaML,1l+Nnpmba.JFYtlnslnss'wr .xspvMLMpepn puT
:rTFenMpfYbp aMrtfpOMni WLInYtlnnMatlefFpbfbefeEm09amgeYpwa
'.ptlnfemnFFsniw611:s IbM CVYr:aOfnrtnFYb:namnm OdO. Mf:m:x WyarRNw,e:
13.psn100MdAs ow:lPr
ain Pab%Y eMMIGMeremfvnapppmnxlrl}1JYTpn Mp:u1]B N}}n.sn9maJPYOr
CvxlNYieNblu—I CIlo-1 CVO ' m Me Pe, iwunxYxnib nmasMn
.'eMap�aa>!}avwnl':wph-0Naryb MCMl:aaa IM Vmi4 RIiMYTMPc Pnl nasnFl:cngeia?
:I.rt9lIMn:IvmaeaTt:nelpen Man MsevrtNnWMONNt •w:tl nPa run viler JO:eM.SWauaX:
• RJe:L'nP✓e:.La y: ppe:.srecOtt:Aun anJ.,m 'w9p:apamlppPxlPp ps.;. Wp•aap, Yo'::r:
Mpes ;In Paien YAO—.11 rovnYnub a1n".. .Ybmnpbbn e:dmnlYSMvns.
uPpp•Ns ieasMm.mFsf�Ta Mimnal[YT.':b ma�cYnsas[i wl+Nan nNMPs.
npwe+wn a+e, pnaemnzxmof..np.pT..p+on .Yen
• �wxx. naTimm�,ew+pnn.wfmnexw.smfpxr-awNi.aaw�ew.mae.[aF...anr
oP.. wme niwsf mnbwumeeWxsnmmrbYenaw=tlea
eaw sapFf:a.vxin.axM e'.xua.e.iewx.e.FR banmaMtlno�p:nf.pNNib:plpgW Jzf
p:.wn.nm.YYx+
• iw mon WwmlmappNlwnryu MnOppmeRsaWlfeeenMlApensNse Nllgl:n: geNa•
I l:snMamiN:snpN.iF11CG9gi0s 21. Cnxwr li]ti51C
10
Incident Number # 202302220 — 8/27/2023 — 5042 Tryon Road., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a large quantity of debris that entered the wet well,
affecting the pump cycle and wastewater flow capacity.
On the night of 8/27/2023 at approximately 11:10 PM, Raleigh Water's SCADA (supervisory control and data
acquisition system) received a high wet well alarm from pump station # 44-Silver Lake, located at 5044 Tryon Rd.
Responding crews arrived on -site at approximately 11:30 PM on the same day and found that both pumps had
tripped an overloaded breaker. 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 2:10 AM on 08/28/2023.
To mitigate the incident, responding crews utilized a vacuum truck to keep the flow of untreated wastewater
below spill levels and within the wet wells of the station. Crews removed both pumps and cleared massive
amounts of debris and rags from their impellers and wet wells. This incident also caused a blockage in the
receiving force main that had to be removed before the pump station was returned to normal operation.
To dislodge the debris, Crews attempted to throttle the flow back and forth until the stoppage was successfully
dislodged, minimizing the continued release of untreated wastewater.
Restoration of this spill event consisted of washing the land surrounding the station. Sewer debris and solids
were collected and disposed of accordingly. 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.
Visual inspection of the affected area and downstream waters confirmed that no fish kill or unnecessary
vegetative damage occurred.
This event resulted in the approximate loss of 1,900 gallons of untreated wastewater reaching an unnamed
tributary to Swift Creek (Yates Mill Pond). See Exhibit 1- Area of Operation.
Exhibivl — Area of Operation
11
The cost associated with the mitigation of this event was $1,176.29. The approximate cost to the Utility to have
treated 1,900 gallons of wastewater would have been approximately $2.85. 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.
This pump station services a vast residential and commercial area within the Tryon Rd corridor. There has been
no history of asset failures associated with this Sewer Network Structure. Before this event, maintenance
records show that this station was serviced as follows:
Work Order #
Activity
Date completed
Findings
1025777
PU Suction Lift P.S. Check
2023-08-1412:41 PM
No findings
1028529
PU Suction Lift P.S. Check
2023-08-2109:28 AM
No findings
1031734
PU Suction Lift P.S. Check
2023-08-29 08:02 AM
No findings
1039414
PU Suction Lift P.S. Check
2023-09-06 09:11 AM
No findings
1040085
PU Suction Lift P.S. Check
2023-09-13 12:13 PM
No findings
1046628
PU Suction Lift P.S. Check
2023-09-19 07:59 AM
No findings
1048162
PU Suction Lift P.S. Check
2023-09-27 10:00 AM
No findings
No additional issues have been associated with this section of the collection system since the last sewer event.
The station continues to be assessed to ensure no other malfunctions occur. A press release notification
associated with this event was requested to be published in the Raleigh News & Observer on August 28, 2023
(see exhibit 2 — Press Release).
Exhibit 2- Press Release
Raleigh Water Responds to a Sanitary Sewer Overflow
On Sander , August 2). 1241M Raleigh Waat staff were notified of a marMary
oveaaw In Me vicialty of 5044 Tryon Rd Rakr h NC Upon arrival. Utility
Responders Identified an aclFm sewer wedbw resaMig from Wrap maMixSm rMNn
a pump nNcn The responang staff Mood ell mewneGe steps to amp and rdvtlg.de Ma
c,. A. s impact as soon as dry surreal The NonM Camara Department, of
Emmunmemal Crash, Divorce of Water Resources has been nodded of the ovedaw.
Raleigh Water staff contaMed Me oveRmw at apatoAmatel, 2:10 am on AuMnal
28.ID23 It te eamended Ned Me aaeMow Mere a volume of ppmdmamly 1999
paeans of uMealatl wesnwtlerwtiN 6tl moo,a storm Marvin and uMmelaly reatwd
a. nnamed friend, a Padm frary to Creak M) Resddan far this... at he.
Even wmplelM No vegetable damage or doh MY heat hen oM.nad mooted to Nis
event as Me waste evalx ad mend mutters wain
Ratalgh Water has an axamotv9 maxamon and cork.., drusam do
pr.vent the di.chage of grease. Makes MM rags. Gaper. and oMe, Mpmpen
mandate In Me street Madam and to take enforcement sodden Mtxe
appropriate If Mete cams make aid. the sew.r.pmm, they may a tus. a
plot which urn have an adverse Impact an wane muss, a" endanger moved, mare.. am, conlaM mate Me spread! anem
Water. human want@, and ham distant am Me only Item prnmeea toE.
c a.lased We Me arms, system AA other hems me came damge to Me
ewer system and are net penned.
If you eperience excessiv r server sereda as, see sever stands from naMob
ortpes. Oeaseral19139 32451crapdimm 9ately
For sae Morm.lcn stand how You can help provent sanlNry sewn spit,.
tape vWt uAighnc ymManr.
This tan rate..¢ c raMided Ey NCW ANcla 21. Chats 143215.1C
F
12
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 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 2,644 miles
of sanitary sewer pipe and minimize the accidental release of untreated wastewater.
Since July 2023 (Fiscal Year 2024), the Utility has maintained approximately 503.4 [11 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 $290,055.31 [21,
approximately 1% of the Division's annual operating budget. The 8,750 gallons of untreated wastewater,
identified as notice of violations in this letter, cost the Utility approximately $22,145.32 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 $13.12. 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 0.02 total SSO rate (4) per 100 miles of pipe, compared to the Southeastern
Region of the U.S., of 7.0 spills per 100 miles of line.
[1] 503.4 miles represents approximately 19%of the entire sanitary sewer collection system
[2] Associated operational cost year to date for FY2024
OPERATION
LINEAR FEET
Linear Miles
COST
ccry
23.2
$84,642.00
$122,847
Repair
2667
0.5
$64,133.34
Flushing
540838.4
102.4
$111,176.25
Easement
171027
32.3
$30,103.72
Easement Inspection
1821520
345
$0.00
The total cost of Business to Date Is
Total- 2,658,899 Ft / 503.4 MILES
$290,055.31
131 F.Y. 2024 annual Divisional budget - $15,058,291
[41 S.0015 Is based on the annual water treatment operating cog compounded by the total treated effluent.
[51 The current 550 Rate for F.V. 24 is 0.02
Note
In FY-2023, the Raleigh Water -Sewer Maintenance Division spent $2,054,254.45 In operations to maintain, repair, and inspect approximately 939.95 miles of
sanitary sewer Infrastructure.
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
13
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 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 prevention message 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 educational outreach 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-0342 issued for the month of August
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, at (919) 996-2312 or Carlos M. Perez,
RC, Assistance SSu�perintendent, at 919-996-5929.
`an
0' V b
mcerely,
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
Carlos. oerezca macho @ ra Ieiehnc.Gov
14