WQCS00002_NOV-2024-DV-0014_20240202

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Raleigh Water
February 211, 2024
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-2024-DV-0014
Sanitary Sewer Overflows — December 2023
Permit No. WQCS00002
Dear Mrs. Manuel:
Please allow this letter to respond to the Notice of Violation document (NOV-2024-DV-0014) dated January
09th, 2024, and received by Raleigh Water on January 17th, 2024. This document contains the narrative
regarding the pending five Notice of Violation actions of Sanitary Sewer Overflows (SSO) incidents reported in
the month of December 2023 within the City of Raleigh Collections System ill This document also provides
exhibits as proof of our efforts to mitigate the sewer incidents. The noticed incidents occurred while the City
operated its collection system, according to WQCS00002, dated June 06th, 2017. The permit includes the
language outlined in footnote one and applies to the SSOs upon which NOVs with the notice of intent (NOV-NOI)
were based. This document will establish a reasonable explanation of the actions taken to stop the spills, contain
the released untreated wastewater, collect the wastewater and reintroduce it to the collection system; and
finally, restore the possible environmental impacts brought by the release of the SSO incidents, listed with the
intended NOV-NOI action. Please find below the additional information requested for the SSO incidents.
1. "The Director may take enforcement action against the Permittee for SSOs that must be reported to the Division as
stipulated in Condition IV92). This includes SSOs that were caused by severe natural conditions or exceptional 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 550, such as the use of auxiliary treatment facilities, retention of
untreated wastewater, reduction of inflow and infiltration, use of adequate backup equipment, or an Increase in the 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.i 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 # 20230160012/02/2023 — 3731 Charleston Park DR., Raleigh, NC, 27604
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of the 8-inch gravity sewer main. This build-up led to a sewer spill of approximately 4,680 gallons of
untreated wastewater, approximately 2,680 gallons of which reached an unnamed tributary within the Neuse
Basin. (See Exhibit 1—Area of Operation)
On 12/02/2023, at approximately 10:55 PM, Raleigh Water staff responded to a customer complaint about a
sewer odor near 3731 Charleston Park, DR., Raleigh. Upon arrival, Utility Responders identified an active sanitary
sewer overflow emanating from a sanitary sewer manhole (see exhibit 2- Affected Asset-SMH312198). The
responding staff took all reasonable steps to stop and mitigate the impact of the discharge, gaining control of
the spill incident by 12:13 AM on 12/4/2023. 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 containment site
downstream of the affected asset. This approach was intended to contain wastewater flow and minimize the
environmental impact on the surrounding land. Crews successfully contained approximately 2,000 gallons of
untreated wastewater before it reached the state's surface waters, preventing further environmental pollution
(see Exhibit 3 — Containment and Collection efforts). Responding crews employed pumps at the temporary
containment site to recover flushed wastewater and any evidence of sewer completing the operation by re-
introducing the contained 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. The area around the manhole and containment area was
cleared of debris, treated with lime, and restored with grass seed and straw.

Further assessment of this incident determined that grease accumulation on the gravity main that feeds into 24-
Peyton Hall PS caused a grease blockage that led to the subsequent overflow. Code enforcement action was
initiated to send educational outreach material to approximately 358 property owners upstream of the affected
area. The requested outreach literature explains the need for customers to use the sanitary sewer collection
system properly. It also serves as an opportunity for citizens to partner with Public Utilities to protect the City's
water quality and the sewer collection infrastructure. See Exhibit 5— Code Enforcement Educational Outreach
Effort.
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The cost associated with the mitigation of this incident amounted to $ 1,809.50. The approximate cost to the
Utility to treat 4,680 gallons of wastewater would have been approximately $7.02. 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 section of the collection system is located downstream of a residential area. It provides sewer collection
services to approximately 358 properties upstream of the spill incident (see Exhibit 6 - Zone of Influence). This
specific portion of the collection system experienced a non -reportable grease -related SSO incident on 2/11/2022
in which approximately 135 gallons of untreated wastewater remained on the ground and did not reach surface
waters. The affected asset has been identified as a hot spot for recurrent maintenance at 90 to 120 days.
Eahlblt 6- Zane of Influence
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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 7 — Press release.
Eahiblt 7 - Press Release
Raleigh Water Responds to a Sanitary Sewer Overflow
Reminder. Keep All Grease Out of the System
On Sat nday Dec 2. N23 m arreodnalab 940 pm. Rdeigh Water staff were
heated of a saNlary saver odor b Me vkbey of Me 3731 Uadeslen Pad Dr Ragigh
NC Upnn uival Uaay Respondee identified an acute ewer avelbw resuiGig Item
acage m a sw'er main The raepandng staff took ad reasonable meps to stop and
MEEg utheoverflowslmpact as soon as Moy 4nWetl the NOM CamIMe OepoManl
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galons wit Mfg gallons of unseated westarvaler reacting an untamed tributary of
that Nam RNa bemn Th. tool cause was daamined to M gut.. Na veg.leffvt
damage or gtlt Idea haw been ots utd neaad to Ma event as Me name wear old
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Too news release t reaueM by NCO Mlide 21. ( ate 143 2151C
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Before this incident, maintenance records show that sections within the zone of influence of this part of the
collection system were assessed within the last ten years as follows:
Flushing activities ssos
9/13/2018 2/15/2022
1/11/2021 12/3/2023
1/13/2021
1/14/2021
1/15/2021
1/21/2021
1/22/2021
1/22/2021
CCTV Activities Repair Activities
5/14/2021 0
Inspections Activities
Manhole Inspections
11/16/2020
11/2/2022
5/8/2023
5/16/2023
6/9/2023
6/13/2023
Sewer High -
Priority Inspection
4/11/2018
11/8/2018
3/15/2019
9/10/2019
1/9/2020
1/14/2020
7/7/2020
1/5/2021
2/9/2021
8/13/2021
1/28/2022
7/21/2022
2/13/2023
10/23/2023
11/7/2023
1/9/2024
No additional issues have been associated with this section of the collection system since the last sewer
incident. This site continues to remain an active maintenance spot pending the completion of further sewer
main cleaning and CCTV assessment.

Incident Number# 20230161012/06/2023-908 Cherry Pond Ct., Wake Forest, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of the 8-inch Polyvinyl Chloride gravity sewer main. This build-up led to a sewer spill of approximately
2,530 gallons of untreated wastewater remaining within the natural topography and not reaching surface
waters. See Exhibit 1— Area of Operation.
On 12/06/2023, at approximately 6:22 PM, Raleigh Water staff responded to a sewer overflow customer
complaint near 908 Cherry Pond Ct., Wake Forest, NC. Upon arrival, Utility Responders identified an active
sanitary sewer overflow emanating from a private sanitary sewer cleanout (see exhibit 2- Affected Asset), which
resulted from a grease blockage of the downstream sewer main. The responding staff took all reasonable steps
to stop and mitigate the impact of the discharge, gaining control of the spill incident by 7:05 PM on 12/6/2023.
Crews utilized hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring
sewer flow.
Exhibit 2-Affected Ascot
Containment and collection of this spill incident consisted of removing the untreated wastewater from the
natural depression utilizing excavators and dump trucks to haul away any surface soil affected by sewer debris
accumulation. This approach was intended to contain wastewater flow and minimize the environmental impact

on the surrounding land. Crews successfully contained, collected, and removed approximately 46 cubic yards
(77,8401bs.) of untreated wastewater -saturated soil before it reached the surface waters of the state,
preventing further environmental pollution (see Exhibit 3 —Containment, Collection and Removal Efforts). This
spill was contained without a significant environmental impact on the adjacent area and its natural resources.
During the restoration phase of the operation, crews remove all traces of untreated wastewater debris from the
surrounding area. The areas around the manhole and natural containment were cleared of debris, treated with
lime, and restored with grass seed and straw. See Exhibit 4— Restoration Efforts

Exhibit 4— Restoration Efforts
Further CCTV assessment of this incident is scheduled to determine the source of the grease accumulation that
led to the subsequent overflow. A code enforcement action was initiated to send educational outreach material
to approximately 195 property owners upstream of the affected area. The requested outreach literature
explains the need for customers to use the sanitary sewer collection system properly. It also serves as an
opportunity for citizens to partner with Public Utilities to protect the City's water quality and the sewer
collection infrastructure. See Exhibit 5 — Code Enforcement Educational Outreach Effort.
Exhibit 5 —Code Enforcement Educational Outreach Effort
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The cost associated with the mitigation of this incident amounted to $ 23,396.87. The approximate cost to the
Utility to treat 2,530 gallons of wastewater would have been approximately $3.79. 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 the cost of 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 approximately 195 properties upstream of the spill incident (see Exhibit 6 - Zone of Influence). This
specific portion of the collection system experienced a non -reportable grease -related SSO incident on 2/11/2022
in which approximately 135 gallons of untreated wastewater remained on the ground and did not reach surface
waters.
Exhibit 6. Zone of Influence
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 7 — Press release.
Exhibit 7— Press Release
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Before this incident, maintenance records show that sections within the zone of influence of this part of the
collection system were assessed within the last ten years as follows:
Flushing activities
6/9/2020
6/12/2020
9/27/2021
9/28/2021
10/13/2021
10/14/2021
CCTV Activities
2/26/2020
2/27/2020
2/28/2020
3/2/2020
3/11/2020
5/5/2020
5/20/2020
12/17/2020
12/18/2020
1/5/2021
3/8/2022
3/9/2022
3/10/2022
3/16/2022
Repair Activities Inspections Activities
0 Manhole Inspection
9/6/2017
9/7/2017
No additional issues have been associated with this section of the collection system since the last sewer
incident. This site continues to remain an active maintenance spot pending the completion of further sewer
main cleaning and CCTV assessment.
fill

Incident Number # 202301625 — 12/11/2023 — 5832 Whitebud Dr., Raleigh
This spill was neither willful nor intentional; it resulted from debris accumulation (flushed wipes) blocking a
portion of an 8-in gravity sewer main. The debris accumulation led to a sewer spill of approximately 2,040
gallons of untreated wastewater, which remained on the natural topography and did not reach surface waters.
See Exhibit 1— Area of Operation.
Exhibit 1-Area of Operation
MkA
Know
On 12/11/2023, at approximately 1:31 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH101678) located near 5832 Whitebud Dr.,
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 2:23 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 completed on 12/18/2023 after hydraulic jetting was completed identified some grease
accumulation but no infrastructure deficiencies that could have influenced grease to accumulate, creating a
blockage (see Exhibit 2 — Affecting Assets with Grease Accumulation).
12

A code enforcement action was initiated to send educational outreach material to approximately 112 property
owners upstream of the affected area. The requested outreach literature explains the need for customers to use
the sanitary sewer collection system properly. It also serves as an opportunity for citizens to partner with Public
Utilities to protect the City's water quality and the sewer collection infrastructure. See Exhibit 3 — Code
Enforcement Educational Outreach Effort.
E.hiblt 3—Code Enforcement Educational Outreach Effort
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.w.oloo+ddoin.�.aY aamr i..Yn.wr.auamm•..r.,ora
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The cost associated with the mitigation of this incident amounted to $4,531.93. The approximate cost to the
Utility to treat 2,040 gallons of wastewater would have been approximately $3.06. 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 to treat the greater volume of sewage created by the spill.
13

This section of the collection system is located downstream of a residential area. It provides sewer collection
services to private properties surrounding the spill incident. Before the SSO on 12/11/2024, this specific portion
of the collection system has not experienced a grease SSO within the last ten years.
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.
— Press Release
Raleigh Water Responds to a Sanitary Sewer Overflow
Reminder. Keep All Grease Out of the System
On Monday, December I Ith, 2023. at approximately 131 PM, Raleigh Water staff
were notified of a sanftary sewer overflow at 5832 Whitebud Dr, Raleigh, NC. Upon
arrival. Utility responders identified an active sewer overflow emanating from a sewer
manhole resulting from the acarmuladon of flushed wipes. This Incident affected the
How of untreated wastewater from an 8-inch sewer gravity pipe. The responding staff
took all reasonable steps W stop and mrigate the overflows impact as soon as they
arrived The Nudh Carolina DeparMent of Emironmental Gualy, Division of Water
Resourceshas been notified of the oveMow.
Raleigh Water staff contained the overflow at approximately 223 PM on the same
day. It is estimated that the overflow discharged appoximalely 2.040 gallons of
unheated wastewater, reaching an unnamed tributary within the Big Branch Creek
basin. No vegetative damage or fish dll was observed related to this event Restoration
for this incident was completed on the same day.
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 If 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 am the only items permitted to be
discharged into the sewer system. All other Items will cause damage In the
sewer system and are not pamulted.
If you experience excessive sewer smells or sea sewer spilling from manholes
or pipes. please ®II 919-996-3245 to report immediately
For more Information about how you can help prevent sanitary sewer spills,
please visit rateighm,gavhvater.
This news release is required by NCGS Article 21. Chapter 143.215.1C.
14

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
10/17/2017
7/16/2020
7/21/2020
2/9/2021
12/11/2023
12/18/2023
12/20/2023
1/30/2024
2/1/2024
CCTV Activities
Repair Activities Easement Activities
12/20/2023
Easement Bank Easement Clearing
1/4/2024
Stabilization 4/12/2018
1/8/2024
1/11/2018
Inspections Activities
Manhole Inspection
10/9/2019
12/2/2021
11/15/2022
5/10/2023
Sewer High -Priority
Inspection
12/11/2017
1/25/2018
1/29/2018
4/20/2018
4/23/2018
1/17/2019
5/21/2019
Sewer High -Priority
Inspection
5/22/2019
11/18/2019
11/19/2019
3/17/2020
9/21/2020
2/26/2021
8/16/2021
8/18/2021
8/2/2022
8/3/2022
3/7/2023
9/15/2023
9/18/2023
1/4/2024
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 further sewer main cleaning and CCTV
assessments.
15

incident Number # 202301640-12/13/2023-8417 Sawyer Drive, 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 1,335 gallons of
untreated wastewater reaching an unnamed tributary within the Hare Snipe Basin (see exhibit 1— Area of
Operation)
On 1/13/2023, at approximately 5:08 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole (affected sewer asset SMH139284, see Exhibit 2 — Affected Asset)
located near 8417 Sawyer Drive, 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 05:49 PM on the same day. Crews utilized
hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring sewer flow.
16

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 3 — Containment and Collection Efforts.
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. See Exhibit 4 — Restoration
Efforts.
17

The cost associated with the mitigation of this incident amounted to $5,460.59. The approximate cost to the
Utility to treat 1,335 gallons of wastewater would have been approximately $2.00. 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 to treat 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. Within the last ten years, this specific portion of the
collection system has not experienced a root intrusion SSO. 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 5 — Press release.
Exhibit 5- Press Release
Raleigh Water Responds to a Sanitary Sewer Overflow
Da Wesnastlay Dec 13 2023 at aPploaimarbl:a 4 20M Raleigh water staff —"
ooaflW oil savory sewer oserflow in die vximp of the U17 S"o on Raleigh NC
Upon annul. ROR, n spandem identified w active sewer o"Idl x tesafts, fiom a
dodwga H o saver grevny man the rao'na ng self took ati reasanatle steps to
slap V f nidgata Vte o wlw a mead as saw as MI alrivaG The NoM Carolina
Depanmenl ofEmfrorarenld Duddy DMlsiondWalw 0.esowteshx been rtolilced at
IM1e weMow
RaWgh Water Mae dltrinded the overflow at appasaimdel, 5 419pm on Dec 13
2023 It is estimdetl the overflow dxhmged a volume of awaximldy 1335 stations
of wanalast waalewalor~ readis" ma HvnI," Creek basin Dan mdn-us-
... "R ndand 10 be root "n,slen No vegatativa damage a fish ten has been
obaarvad ldaod la Na event
Rakso Water has an aggras . anksonon arM etacoment Program to
went ins dx c .rge of gnaw, dells, wiles. rags, tapers and other improper
Inlah Ia the uweny9em"Io take mbrtemai actor alters
spin-m, If tM1ese R.nn, make h bdo the ae system. Ih, may cauwa
.01 "o ow have an aareng basso on syter dueay onal aradargar Chase
who care Iola contact witl Vote aflwed ..as
• want, .humanw.Us and Islet ft. are IN sty 1. pernYled to ba
ASWrged'mts Han wv.'er IMarn M ether Rents ml wee damage an IM1e
. eyNem and ..1 pgnided
ayau ezpwres exca d,no seam smdis or we saver spring trap matmks
or ppn, pilaw cad 91A9 3245 to refoon immeaet.ty
• ran mile Murmatlon about hwv you can help poet sanitary sewer salts.
0. obit releigltnsgaNwda
TNa mews rafww6ragJred by NCGSPadde 21. tl xe,1432151C

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
Inspections
Activities
2/22/2017
Manhole Inspection
Sewer High -Priority
2/23/2017
7/8/2019
Inspection
6/25/2018
7/11/2019
3/2/2020
2/22/2021
5/4/2022
4/20/2020
1/10/2024
12/22/2023
7/20/2020
12/18/2023
7/29/2020
1/11/2024
Sewer High -Priority
9/25/2020
Inspection
1/12/2021
11/2/2017
2/16/2021
11/29/2017
4/8/2021
3/19/2018
8/5/2021
3/28/2018
9/16/2021
8/23/2018
3/26/2022
8/24/2018
8/26/2022
10/16/2018
8/30/2022
2/20/2019
1/30/2023
2/25/2019
2/21/2023
3/26/2019
10/12/2023
9/16/2019
11/2/2023
2/24/2020
1/2/2024
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.
19

Incident Number # 202301774 — 12/30/2023 — 1500 Banbury Road, 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 1,100 gallons of
untreated wastewater in which approximately 800 gallons reached Southwest Prong Beaverdam Creek within
the Beaver SW Basin (see exhibit 1—Area of Operation)
On 12/30/2023, at approximately 2:46 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole near 1500 Banbury Road, 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 04:36
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.
The cost associated with the mitigation of this incident amounted to $3,455.33. The approximate cost to the
Utility to treat 1,100 gallons of wastewater would have been approximately $1.65. 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 to treat 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. Sanitary sewer assets in this area have been
routinely maintained with hydraulic jetting and will be placed 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 5 — Press release.
20

Exhibit 5 — Press Release
Raleigh Water Responds to a Sanitary Sewer Overnow
On S.n'dax. Nucdr 301h M. N1 pp MjWy 2 46 PM RAIgh MM
suP rrele nutfie]dasaMxr se:vm ueftw mar I500Our jRd. Rhr NC
III^n anlval WRry rxq+^Jmc WlxiMl on>aiva ac:m Wmlrox.mw6p XOTa
adlue revlJy hcrnrmr iembn Iln lnrLknr.Rauad awfivgr.N. Rtl
�vhn ulrn rwrgnllym �IMr>.ynnJne sbfllWMYralbwdp req
MarnW.mdilmE µry+mm�l vl trn-nrmrrM+l ry,Ny, UsINmdlValw Nreavcn.lrn
U+.. o:reAav
N+le:alr'.valn slax con+n.J P. mer'.iw al+Ppro�nwrArf 36 MpnM.�n.
a,: ,.I :..wraeJ axaw....nc. a„n„g.a,Wr.srwl,h± 10 quam d
wrw.r>aa..amr .I.rn µgourmlYr 6x s+-<r^n x... r.+aa n.
Sp.9rvrev Fmgd�a. .n G,eY Ibvegerat.<l,na3turtA le waadwnM
ruuLLdm Pt nva 0.>-JwIhrn ror tl:JndrbN x+s cangaHadmCw';am. dly
• N+1=ylr/IYn M1as an+y7a5,i.a Wiulim+nJ arlbrumam gqunb
ge.m,Ne ala,n..e=cter..,. 06d,. wrce+ ms,. Jams en]Ywr hraw.+
lair¢n tlw cwa rylurr+nJ to lal'.e arAor[amnrl xbn x�ere
aprye(nnle II are!ue arumnwleXbXn rAn:ex'er sflrn^ImWrnl1ha
a,I.rN<A N [.n n.[w.n.n.m.Imwa mr r+Nm w.hly one.m.ne.r mpar
nw Idu mrgatl xMM1 tlw .Xn,l of ,m:n
• 4'iNercNvrulr v..Np. Yra Wal Cayq prn llw Uly ll¢n6PtvmipgJ lJ h¢
d6[1rYy.deM ere FavP irWn 41 oNP R.nrt,d �uea aampa blM1a
pupm xf by pY Wm+.J
u vp, wJ.+r� ®I.+wa..w or ape �wpr.pr^e hen m.pnol..
T IPp IM. fy 91159G1i15 b wP'+rl uv5e.l,
. imnnr.iymaeA iEPNIV Ymrflr A.p P.r�taxivY w.•m Was
(lean rW n4ykr yaNla
Il —r .r .J hY NCG6M 21. Chr 1U116.IC.
I/+
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 Previous SSO
CCTV Activities
Repair
Inspections Activities
activities
Activities
4/26/2017 11/12/2020 (root intrusion)
12/21/2017
5/1/2018
Sewer High -Priority Inspection
4/11/2018 11/23/2022 (root intrusion)
11/1/2017
6/11/2018
12/29/2017
7/6/2020
4/9/2018
8/9/2018
1/2/2018
6/24/2020
12/22/2020
5/4/2018
7/6/2020
1/5/2024
8/31/2018
7/15/2020
1/9/2024
5/21/2019
7/16/2020
1/8/2024
5/21/2019
9/15/2020
3/14/2022
12/2/2019
8/1/2022
11/23/2022
3/20/2020
11/9/2022
1/9/2024
8/6/2020
11/23/2022
10/6/2020
3/26/2021
9/22/2021
1/12/2022
9/30/2022
3/8/2023
9/26/2023
1/18/2024
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.
21

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 803.9 111 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 $1,339,456.68 (21,
approximately 1% of the Division's annual operating budget. The 11,685 gallons of untreated wastewater,
identified as notice of violations in this letter, cost the Utility approximately $38,654.22 to mitigate. The City's
cost of sewer treatment per gallon is $.0015 13). At this rate, treating the untreated wastewater spilled would
cost the City $17.52. 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 to demonstrate due diligence in environmental
performance by allocating resources to a spill incident regardless of the associated cost. This effort is noted in
the City's SSO performance rate of 1.17 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.
[11 803.9 miles represents approximately 30%of the entire sanitary sewer collection system
[2) Associated operational cost year to date for FY2024
OPERATION
LINEAR FEET
Linear Miles
COST
CCTV
306,240
58
$192,796.29
Repair
1548
.29
$679,023.02
Flushing
1,272,480
241
$336,705.85
Easement
401,280
76
$130,931.52
Easement Inspection
2,263,060.8
428
N/A
The total cost of Business to Date is
Total-4,244,608.8
Ft/ 803.9 MILES
$1,339,956.68
131 F.Y. 2024 annual Divisional budget - $15,058,291
[41$.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[5) 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
0%

Environment Foundation (WEF), and the American Public Works Association (APWA) to challenge INDA and
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 to commercial and
residential users, such as wipes, fats, oil, and grease. 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://raleighnc.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-2024-DV-0014 issued for the month of December
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,
Assistance Superintendent, at 919-996-5929.
'rely,
Carlos M Perez, ORC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh, Public Utilities Department
P.O. Box 590
Raleigh, NC 27602-0590
919-996-5929 office
919-278-6020 cell
Carlos.perezcamacho@ra Ieiehnc.Gov
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