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HomeMy WebLinkAboutWQCS00002_NOV-2024-DV-00082_20240328�\ `00 0/� INIM Raleigh Water March 26, 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-00082 Sanitary Sewer Overflows —January 2024 Permit No. WQCS00002 Dear Mrs. Manuel: Please allow this letter to respond to the Notice of Violation document (NOV-2024-DV-0082) dated February 13th, 2024, and received by Raleigh Water on February 26'1, 2024. This document contains the narrative regarding the pending four Notice of Violation actions of Sanitary Sewer Overflows (SSO) incidents reported in the month of January 2024 within the City of Raleigh Collections System I'l 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 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.] 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# 202400236 — 1/10/2024 — 4905 North Hills Drive, Raleigh This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of a 10-in Vitrified -Clay Pipe gravity sewer main. The root intrusion led to a sewer spill of approximately 1,450 gallons of untreated wastewater reaching a stormwater channel within the Mine Basin (see exhibit 1— Area of Operation) On 1/10/2024, at approximately 8:05 AM, Raleigh Water staff responded to a sanitary sewer overflow emanating from a sanitary sewer manhole (affected sewer asset SMH116395, see Exhibit 2 —Area of Operations) located near 4905 North Hills 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 09:03 AM 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 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. The cost associated with the mitigation of this incident amounted to $3,154.37. The approximate cost to the Utility to treat 1,450 gallons of wastewater would have been approximately $2.17. 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 On Wednesday Jamey 10. 2024, al approsnnalely 8.05 am. Raleigh Water slut were mnaed at a senile, sewer overflow in the uidnity at 4905 Notts Rills D, Rekigh NC. upon ertivel. LUty Responders Idenbfled an amve sewer overflew ..A, home bind.' In to sewer main nomotrausehaabeendeterannedtabe mob and rags The rapondng staff loaM all reasonaWa steps to stop and mdyefe the ovedbx's impad as soon as me, arrived The Nml Cemfina Depemnent of Emtonmenld tTleay, Dh+ion of Water Reaourta ha been mt8ed of the overflow Raleigh Water staff dimmated dre overtax at apposiwteb 905 am on Jameary 10. 2024. Na aed ann thw the ovedbw lone Creak a dealt No of etdfi manna 1650 rah. deeeled watewalar reacting Alone Creak beet,. No vegeltire Oamega or etas km has been obaeme rellnd to this Want. palest Water has an aggressive education and anbrcemere program m p akent Me disdind a of grease. dears. vied, rage. Gapers and of brprope malalal'w the sewer system andtotake enforcement adbn s .. appropriate Ilethesehemmakenklothes splm,theymaycausea spa wbbA oa have an aMene Impadon wane WAp and endanger these who dome Into coned wlM the aaeded mea. Water, human wade, and toilet Issue are to only items p mraed on be 6sdarged Into the sewer sydem. All other items We cause damage to the .b cyder, and to Mt pemalent N you expand a excessive fewer areas or see same sprang from maMdes w press, please call 919-908-3245 to raped mmeaelety. Far more Infi montlon about how you can held boron nt eaMe, save spio pease vkll: rWWghnc.g Mads,. Ras dews notes Is requests by NCGS Addle 21. Groper 10215.IC. wx 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 Chemical Root Control Inspections Activities CCTV Activities Easement Maintenance Repair Operations Activities 2/17/2017 1/20/2023 Easement Sewer High 5/1/2017 5/8/2017 9/19/2019 12/28/2016 1/19/2023 Inspection Priority 8/19/2019 2/3/2022 8/25/2022 3/1/2017 4/18/2023 Inspection 8/28/2019 9/6/2022 1/24/2024 3/16/2017 5/1/2023 11/6/2017 2/26/2020 4/11/2023 1/25/2024 9/10/2018 6/1/2023 11/7/2017 7/26/2023 9/11/2019 3/28/2018 7/26/2023 12/27/2019 Manhole 4/9/2018 1/31/2020 Inspection 8/23/2018 2/27/2020 11/9/2020 11/2/2018 2/10/2020 12/17/2020 2/8/2019 2/10/2022 1/4/2021 4/1/2019 10/7/2022 5/4/2021 4/11/2019 1/10/2024 1/5/2022 4/12/2019 3/28/2022 4/15/2019 11/18/2022 7/17/2019 2/8/2024 8/5/2019 1/15/2020 9/17/2020 9/18/2020 3/24/2021 4/8/2021 7/27/2021 8/26/2021 11/2/2021 2/22/2022 2/23/2022 2/23/2022 8/31/2022 9/14/2022 9/15/2022 1/9/2023 2/14/2023 7/7/2023 7/20/2023 1/3/2024 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. 4 Incident Number# 202400280-03/13/2024-4801 Blue Bird Court, 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 252 gallons of untreated wastewater in which approximately 126 gallons reached a stormwater catch basin within Simmons Basin (see exhibit 1—Area of Operation). On 12/30/2023, at approximately 2:46 PM, Raleigh Water staff responded to a sewage overflow from a sanitary sewer manhole near 4801 Blue Bird Court, 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 mitigating this incident amounted to $9,012.59. The approximate cost to the Utility to treat 252 gallons of wastewater would have been approximately $.37. 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. Before this incident, maintenance records show that sections within the zone of influence (see exhibit 2 — Zone of Influence) were assessed within the last ten years as follows: Flushing CCTV Repair Inspections Contractor Chemical Root Easement Maintenance activities Activities Activities Activities Control Initial Treatment Activities 5/13/2017 1/14/2020 5/16/2019 2/9/2018 1/7/2023 5/23/2019 11/18/2019 3/8/2021 5/17/2019 3/21/2018 7/11/2019 12/10/2019 12/13/2021 5/17/2019 6/4/2018 7/19/2021 12/13/2019 12/14/2021 12/4/2023 11/21/2018 12/5/2023 1/10/2020 12/1/2023 1/26/2024 2/6/2019 1/29/2024 6/30/2020 12/4/2023 1/31/2024 2/19/2019 2/29/2024 7/13/2021 12/6/2023 2/1/2024 6/24/2019 9/3/2021 12/20/2023 2/20/2024 12/19/2019 12/13/2021 1/14/2024 3/21/2024 4/6/2020 11/30/2023 1/25/2024 8/12/2020 12/1/2023 1/26/2024 10/26/2020 12/4/2023 2/1/2024 2/8/2021 12/5/2023 2/5/2024 2/17/2021 1/13/2024 3/11/2024 4/20/2021 1/14/2024 3/15/2024 4/21/2021 1/22/2024 3/18/2024 5/10/2021 1/24/2024 5/12/2021 1/25/2024 5/25/2021 1/31/2024 6/28/2021 10/11/2021 3/15/2022 10/26/2022 4/12/2023 10/10/2023 Exhibit 2-2one of Infl.. 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 # 202400326 — 1/19/2024 — 7301 Grist Mill Road, Raleigh This spill was neither willful nor intentional; it resulted from debris blocking a portion of an 8-in Vitrified -Clay Pipe gravity sewer main. The root intrusion led to a sewer spill of approximately 1,500 gallons of untreated wastewater reaching a stormwater channel within Perry Basin (see exhibit 1—Area of Operation). On 01/19/2024, at approximately 8:33 AM, Raleigh Water staff responded to a sanitary sewer overflow emanating from a sanitary sewer manhole near 7301 Grist Mill 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 09:45 AM 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 Efforts. VI Cv}, Fir 'i4 1 / Y u 11 �� • t ry i The'cost associated with the mitigation of this incident amounted to $2,438.37. The approximate cost to the Utility to treat 1,500 gallons of wastewater would have been approximately $2.25. 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. Our maintenance records show that within the last ten years, this portion of the collection system experienced an unrelated SSO on 1/22/2020, resulting from grease accumulation. 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 On Friday, January 191h, 2024. at approximately 8 33 AM, Raleigh Water stag were notified of a sanitary sewer overflow near 7301 Grist Mill Rd., Raleigh, NC. Upon arrival, Utility responders identified an active sewer overflow emanating from a sewer manhole resulting from debris in the gravity main. 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 stag contained the overflow at approximately 9-45 AM on the same day. It is esfimated that he overflow discharged approximately 1,500 gallons of untreated wastewater, which reacted a storm drain and ultimately Perry Creek No vegetative damage or fish kill 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 it into the sewer system, they may cause a spill which can have an adverse Impact on water quality and endanger those who come into comae with the affected areas. • Water, human waste. and toilet tissue are the only Rena permitted to be discharged Into the sewer system. All other hems will cause damage to the sewer system and are not permitted, • If you experience excessive sewer smells or we 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: releighncgovAvater. This news release is required by NCGS Article 21, Chapter 143 215.1C kM# Before this incident, maintenance records show that sections within the zone of influence (see Exhibit 4 — Zone of Influence) of this collection system were assessed within the last ten years as follows: Flushing Inspections Activities CCTV Activities activities Manhole Inspection Sewer High Priority Inspection 3/4/2019 8/10/2017 8/9/2019 11/29/2017 10/7/2019 10/25/2021 10/30/2020 1/12/2018 8/15/2019 11/30/2017 10/10/2019 3/3/2022 6/16/2021 3/1/2019 6/15/2021 12/7/2017 1/2/2020 3/30/2022 1/10/2022 8/9/2019 6/10/2022 12/12/2017 1/28/2020 9/7/2022 5/24/2023 11/17/2020 6/13/2022 3/21/2018 4/23/2020 9/15/2022 11/16/2023 11/18/2020 12/29/2022 4/16/2018 7/29/2020 2/24/2023 11/28/2023 11/19/2020 4/11/2023 10/25/2018 8/27/2020 3/28/2023 1/19/2024 11/23/2020 4/14/2023 11/30/2018 2/8/2021 3/29/2023 1/19/2024 4/27/2023 2/14/2019 2/10/2021 10/9/2023 6/16/2023 3/11/2019 4/6/2021 10/10/2023 Chemical Root 6/20/2023 7/12/2021 2/27/2024 Control 3/1/2024 1/11/2023 Exhibit 5-Zone of Influence Repair Operations 11/2/2023 11/1/2023 No additional sewer issues have been associated with this section of the collection system since the last sewer incident. This site remains an active maintenance spot pending further sewer main cleaning and CTV assessment. 10 Incident Number # 202400013-1/2/2024 - 6209 River Jasmine Lane, Raleigh This spill was neither willful nor intentional; it resulted from a small separation of an 8-inch ductile iron pipe sewer aerial gravity main. This asset failure led to a sewer spill of approximately 143 gallons of untreated wastewater, reaching an unnamed tributary within the Neuse Basin. See Exhibit 1—Area of Operations On 1/2/2024, at approximately 8:58 AM, a Raleigh Water - Sewer Maintenance Division staff was conducting an easement inspection when he identified sewer emanating from a sewer aerial gravity main near 6209 River Jasmine Lane, Raleigh, NC. Upon arrival, crews commenced to stop the overflow by placing a containment site while repair efforts were under way minimizing the potential for continued sewer overflow to downstream surface water. No sewer blockage was attributed to this incident. See Exhibit 2 — Damaged Section of 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 11:21 AM on the same day. 11 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 the failed pipe with ductile iron, 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. Exhibit 3 — Completed Repair 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 although the spill reached state surface waters, the immediate containment allowed the overflow to remain within the initial stormwater conveyance. 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 $11,164.98. The approximate cost to the utility to treat 143 gallons of wastewater would have been $.21. This 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. 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 1252 [i] 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 $2,913,456.22 [2], approximately 2%of the Division's annual operating budget. The 3,345 gallons of untreated wastewater, identified as notice of violations in this letter, cost the Utility approximately $25,770.31 to mitigate. The City's cost of sewer treatment per gallon is $.0015 131. At this rate, treating the untreated wastewater spilled would cost the City $ 5.01. 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 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 1.47 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. [111252 miles represents approximately 47%of the entire sanitary sewer collection system [2] Associated operational cost year to date for FY2024 OPERATION LINEAR FEET Linear Miles COST CCTV 449,010 85 $270,804.27 Repair 2280 .43 $2,065,862.65 Flushing 1,683,537 319 $450,633.70 Easement 480,949 91 $126,155.60 Easement Inspection 3,995,104 757 N/A The total cost of Business to Date is Total. 6,610,980 Ft / 1252 MILES $2,913,456.22 13] 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. [5] The current SSO Rate for F.V. 24 is 1.47 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 13 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: httos://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-0082 issued for the month of January 2024 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, ORC, Assistance Superintendent, at 919-996-5929. SincerQIY, /ell6Y Carlosez, 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 @ralei¢hnc.Gov 14