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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. 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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. 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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