WQCS00002_NOV-2023-DV-0389_20231228

0
�0 NC Dept ofEnv ronmental Quality
C7 :? 8 2023
Raleigh Water
Raleigh Regional Office
December 262h, 2023
Vanessa Manuel, Assistant 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-0389
Sanitary Sewer Overflows —October 2023
Permit No. WQCS00002
Dear Mrs. Manuel:
Please allow this letter to respond to the Notice of Violation document (NOV-2023-DV-0389) received on
December 4th, 2023. This document contains the narrative regarding the pending Notice of Violation action of
(3) Sanitary Sewer Overflows (SSO) event, reported on the month of October 2023, within the City of Raleigh
Collections System al 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-NO] 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 ahematives to the SSO, such as the use of auxiliary treatment facilities, retention of
untreated wastewater, reduction of inflow and infiltration, use of adequate backup equipment, or an increase in the opacity 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.] The ss0 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 # 202301428-10/6/2023 - 737 Hunting Ridge Rd., Raleigh
This spill was neither willful nor intentional; it resulted from a collapsed section of pipe affecting the flow of
untreated wastewater of an 8" sewer gravity main. This asset failure led to a sewer spill of
approximately 690 gallons of untreated wastewater, reaching a stormwater channel. See Exhibit 1— Area of
Operations
Exhibit 1—Area of Operations
On 10/06/2023, at approximately 11:34 AM, Raleigh Water - Sewer Maintenance Division staff was notified of a
sewer overflow emanating from a sewer manhole near 737 Hunting Ridge Rd., Raleigh, NC. Upon arrival, crews
commenced to stop the overflow by utilizing high -velocity jetting to rid the source of the blockage. An initial
assessment identified that the source of the blockage was due to the accumulation of grease and rags. A follow-
up CCTV assessment determined that the root cause of the blockage was the collapsed crown of an 8-inch
vitrified clay pipe sewer gravity main (see Exhibit 2 — Damaged Section of Gravity Main). Pipe material debris
caused the rags and grease to accumulate, resulting in the subsequent blockage. 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 12:20 PM on the same day.
FA

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.
Repairing the damaged sewer gravity main involved excavating the affected area and exposing the collapsed
pipe. Crews replaced the damaged section of clay pipe with PVC, restoring the flow of untreated wastewater.
The repair was performed without disrupting sewer services (see Exhibit 3 — Completed Repair). 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 remaining within the stormwater channel. Crews utilized ample water during the
restoration phase of the operation to flush the surrounding affected area.
The cost associated with the mitigation of this incident amounted to $9,693.52. The approximate cost to the
utility to treat 690 gallons of wastewater was $1.03. 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 to treat 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. No additional issues have been associated with this section of the collection
system since the last sewer incident.

Incident Number # 202301447—10/12/2023 —1900 Main Campus Dr. Raleigh, NC
This spill was neither willful nor intentional; it resulted from a damaged section of an 8" steel sewer gravity main
pipe, which did not affect the normal flow of untreated wastewater. This asset failure led to a sewer spill of
approximately 1,380 gallons of untreated wastewater, reaching Walnut Creek (see Exhibit 1—Area of
Operations).
On 10/12/2023, at approximately 7:45 AM, while performing a high -priority inspection of the same asset, a
Raleigh Water- Sewer Maintenance Division Easement Inspector identified untreated wastewater discharging
from a crack on the side of the pipe into the creek near 1900 Main Campus Rd., Raleigh, NC (see exhibit 2 —
Damaged Section of Gravity Main). Repair crews were immediately contacted to repair and correct the damaged
section of pipe. Upon arrival, crews commenced to contain and repair the pipe. 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 12:21 PM on the same day.
Exhibit 2 —Damaged Section of Gravity Main

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 (see
exhibit 3 — Containment and collection site). 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.
Exhibit 3 - Containment and Collection Site.
Repairing the damaged sewer gravity main consisted of replacing several feet of pipe. Crews replaced the
damaged section pipe with a permanent joint, restoring the flow of untreated wastewater. The repair was
performed without disrupting sewer services (see Exhibit 3 — Completed Repair). Sewer flow was restored on
the same day.
The cost associated with the mitigation of this incident amounted to $7,892.02. The approximate cost to the
utility to treat 1,380 gallons of wastewater was $2.07. 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 to treat the greater volume of sewage created by the spill.
A press release notification associated with this event was requested to be published in the Raleigh News &
Observer on October 12th, 2023 (see exhibit 4 — Press Release).

Exhibit 2- Press Release
Raleigh Water Responds to a Sanitary Sewer Overflow
On Thursday, October 12. at approximately 7:45 am, Raleigh Water staff were
notified of a sanitary sewer overflow in the vicinity of 1900 Main Campus Dr. Raleigh
NC. Upon arrival. LMIRy Responders Identified an active sewer overflow rewli ng from
an asset failure. The responding stag took all reasonable steps to stop and mitigate the
overflows Impact as soon as they anived. The North Carolina Department of
Environmental Quality, Division of Water Resources has been notified of the overflow.
Raleigh Water stag eliminated the overflow at approximately 12:21 pm on the
same day. It is estimated that the ovediow discharged a volume of approximately 1380
gallons of untreated wastewater which did reach Walnut Creek. A point repair was
made to repair the damaged pipe and restoration for this event has been
completed. No vegetative damage or fish kill has been observed related to this event
as the waste water did not reach surface water.
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debris, wipes, rags, diapers and other Improper
materials in the sewer system and to take enforcement action where
appropriate. If these hems make i1 into the sewer system, they may cause a
spill which can have an adverse impact an water quality and endanger those
who come into contact with the affected areas.
• Water, human waste, and toilet tissue are the only items permitted to be
discharged Into the sewer system. Ail other Items will cause damage to the
sewer system and are not permitted.
• If you experience excessive serer smells or see sewer spilling from manholes
or pipes, please call 919-996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer spills,
please visit. rateighnc.govhvater
This news release is required by NCGS Article 21, Chapter 143.215.1C.
The incident 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. Furthermore, this incident was identified as part of Raleigh Water's High Priority
Inspection Program. A previous inspection conducted on 8/23/2023 showed no deficiencies in this asset.
No additional issues have been associated with this section of the collection system since the last sewer
incident.

Incident Number # 202301484 — 10/23/2023 —1903 Alexander Rd., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a damaged section of a 6-inch vitrified clay pipe
sewer gravity main pipe, affecting the normal flow of untreated wastewater. This asset failure led to a sewer
spill of approximately 1,500 gallons of untreated wastewater, reaching a stormwater channel within the
Crabtree Basin. See Exhibit 1— Area of Operations.
On 10/23/2023, at approximately 9:48 AM, Raleigh Water - Sewer Maintenance Division staff were notified of a
sewer odor near 1903 Alexander Road, Raleigh. Upon close assessment, it was identified that untreated
wastewater was flowing through an adjacent stormwater pipe. A CCTV assessment identified a standing
manhole leached untreated wastewater through its walls, reaching a broken stormwater pipe below.
Utility Responders were immediately contacted. 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 10:48 AM on
the same day.
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 (see
exhibit 2 —Containment and collection site). 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.

Exhibit 2—Containment and Collection Site.
Further CCTV assessment identified other deficiencies in this section of the collection system. A Capital
improvement project has been requested to correct the noted deficiencies. While the project is designed, assets
within this portion of the collection system have been placed in hot spot management for recurrent
maintenance.
The cost associated with the mitigation of this incident amounted to $9,526.77. The approximate cost to the
utility to treat 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 to treat the greater volume of sewage created by the spill.
A press release notification associated with this event was requested to be published in the Raleigh News &
Observer on October 23rd, 2023 (see exhibit 3 — Press Release).

Exhibit 3 - Press Release
Raleigh Water Responds to a Sanitary Sewer Overflow
On Monday, October 23rd, at approximately 9:48AM, Raleigh Water staff were
notified of a sanitary sewer overflow in the vicinity of the 1903 Alexander Rd. Raleigh,
NC. Upon arrival, utility responders identified an active sewer overflow resulting from
an asset failure In sewer gravity main 147451. The responding staff took all reasonable
steps to stop and mitigate the overfloWs impact as soon as they arrived. The North
Carolina Department of Environmental Quality, Division of Water Resources has been
notified of the overflow.
Raleigh Water staff stopped the overflow at approximately 10ABAM on the same
day. It is estimated that the overflow discharged a volume of approximately 1,500
gallons of untreated wastewater which did reach Oxford Branch within the Crabtree
Creek basin via a storm drain channel. Crews used hydraulic flushing to remove the
blockage from the sewer main. CCTV work has been conducted to identify the issues
within the sewer gravity main and repair work orders have been initiated. No
vegetative damage or fish kill has been observed related to this event.
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debris, wipes, rags, diapers and other improper
materials in the sewer system and to take enforcement action where
appropriate. If these items make fl into the sewer system, they may cause a
spill which can have an adverse impact on water quality and endanger those
who come into contact with the affected areas.
• Water, human waste, and toilet tissue are the only items permitted to be
discharged into the sewer system. Al other items will cause damage to the
sewer system and are not permitted.
• If you experience excessive sewer smells or see sewer spilling from manholes
or pipes, please call 919996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer spills,
please visit: raleighnc.govAvater,
This news release is required by NCGS Article 21, Chapter 143.215.1C.
frpp
The incident 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. Furthermore, this incident was identified as part of Raleigh Water's High Priority
Inspection Program.
No additional issues have been associated with this section of the collection system since the last sewer
incident.

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 [,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 $290,055.31 [21,
approximately 1% of the Division's annual operating budget. The 3,570 gallons of untreated wastewater,
identified as notice of violations in this letter, cost the Utility approximately 27,112.31 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 $5.35. 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 141 per 100 miles of pipe, compared to the Southeastern
Region of the U.S., of 7.0 spills per 100 miles of line.
11] 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
ccfv 23.2
$84,642.00
$122,847
Repair 2667
0.5
$64,133.34
Flushing S40838.4
102.4
$111,176.2-5
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
[31 F.Y. 2024 annual Divisional budget - $15,058,291
1415.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
15] The current SSO Rate for F.Y. 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
10

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-0389 issued for the month of October
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 [phone] or Carlos M. Perez,
RC, Assistance Superint ent, at 919-996-5929.
cer ly,
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.oerezcamacho @raleiehnc.Gov
11

Doc6Sign Envelope ID: B9620OF7-9377-4BBE-9390-3DOAB9C65A52
ROY COOPER
Gc nun
ELIZABETH S. BISER
RICHARD E. ROGERS. JR.
00.1Wl
Certified Mail # 7020 3160 0000 4115 0417
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
....r . NCDeptofEnvironlnental
Quality
DEC 2 8 2023
r;oa r c,•..aorr,:, Raleigh Regional
Fnvironmenra(QualirY Office
November 07, 2023
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2023-DV-0389
Sanitary Sewer Overflows - October 2023
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
The self -reported Sanitary Sewer Overflow (SSO) 5-Day Report submitted by City of Raleigh indicates violations of
permit conditions stipulated in the subject permit and North Carolina G.S. 143-215.1. Violations include failing to
effectively manage, maintain, and operate the subject collection system so that there is no SSO to the land or
surface waters and making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a
permit is required.
Specific incident(s) cited in the subject report include the following:
Total Vol
Total
Surface
Incident
Start
Duration
Vol
Water
Number
Date
(Mina)
Location
Cause
(Gals)
(Gals)
DWR Action
202301428
10/6/2023
46
737 HUNTING RIDGE
Pipe Failure (Break)
690
690
Notice of Violation
ROAD, RALEIGH,
27615
202301447
10/12/2023
276
1900 Main Campus
Pipe Failure (Break)
1,380
1,380
Notice of Violation
202301484
10/23/2023
60
1903 ALEXANDER
Pipe Failure (Break)
1,500
1,500
Notice of Violation
ROAD, RALEIGH,
27608

DocuSign Envelope ID: B9B200F7-9377-4BBE-9390-3DOAB9C65A52
Remedial actions, if not already implemented, should be taken to correct the above noncompliance. Please submit
a written response to this Notice of Violation. Your response is to be received by the regional office within 15
business days following receipt of this violation. Please include any additional documentation about this incident(s)
in the response. The submittal will be considered in determining whether the Division will assess a civil penalty for
the cited violations.
If you have any questions, please do not hesitate to contact Kevin Fowler with the Water Quality Section in the
Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Cc: Laserfische
Sincerely,
CDoceslgneA by:
�/aut Sia'e. katn. d
B281fiEBAB32144F...
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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