WQCS00002_NOV-2023-DV-0421_20240124

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Raleigh Water
January 24tb, 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-2023-DV-0421
Sanitary Sewer Overflows — November 2023
Permit No. WQCS00002
Dear Mrs. Manuel:
NC Dept of Enviror;ne2tzl Qa„ity
JAN 2 4 2024
lblf igh Regient':1'
Please allow this letter to respond to the Notice of Violation document (NOV-2023-DV-0421) received on
January 31d, 2024. This document contains the narrative regarding the pending Notice of Violation action of (1)
Sanitary Sewer Overflow (SSO) event, reported on the month of November 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
6th, 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 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:
fa.] The SSO was caused by severe natural conditions; there were no feasible alternatives 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 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
Ib.) The SSO was exceptional, unintentional, temporary, and caused by factors beyond the reasonable control of the Permittee; the SSO 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 # 202301511 - 11/3/2023 — 2245 Garner Rd., Raleigh
This spill was neither willful nor intentional; it resulted from a debris blockage within the sewer main attributed
to flued wipes accumulation, which restricted the flow of untreated wastewater from an 8" sewer gravity main.
This debris blockage led to a sewer spill of approximately 550 gallons of untreated wastewater, in which
approximately 50 gallons reached an unnamed tributary within Rochester Basin. See Exhibit 1—Area of
Operations
On 11/03/2023, at approximately 11:38 AM, Raleigh Water- Sewer Maintenance Division staff was notified of a
sewer overflow emanating from multiple manholes near 2245 Garner 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 flushed wipes. A follow-up
CCTV assessment, completed on 11/9/2023, determined that the root cause of the blockage was a damaged
section of a 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 12:33 PM on the same day.
Note
A subsequent repair work order was requested to correct the deficiency.

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. 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
Exhibit 3— Containment and Collection
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 —Sewer Main Repair). Sewer flow
was restored following the repair operation.

Exhibit 3 —Sewer Main Repair
During the restoration phase of the operation, crews utilized ample potable water to flush the affected site 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.
The cost associated with the mitigation of this incident amounted to $7,189.80. The approximate cost to the
Utility to treat 550 gallons of wastewater was $.84. 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. No additional issues have been associated with this section of the
collection system since the last sewer incident.

r 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 Sewer Maintenance 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 560 gallons of untreated wastewater, identified
as notice of violation in this letter, cost the Utility approximately $7,189.80 to mitigate. The City's cost of sewer
treatment per gallon is $.0015 [31• At this rate, treating the untreated wastewater spilled would cost the City
$.84. 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 to treat 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 0.02 total SSO rate [41 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 Mlles
COST
CCN 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
(4) $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[51 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

current industry standards, recognizing that they do not support compatibility in sanitary sewer collection4
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: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-0421 issued for the month of November
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,
ORC, Assistance Superintendent, at 919-996-5929.
Sincerely,
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
[e-mail]