WQCS00002_NOV-2024-DV-0161_20240422

0 '
0 '/00
\ 10
�10
Raleigh Water
April 22"d, 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-0161
Sanitary Sewer Overflows— February 2024
Permit No. WQCS00002
Dear Mrs. Manuel:
APR 2 2 2024
Please allow this letter to respond to the Notice of Violation document (NOV-2024-DV-0161) dated March
13th,2024, 2024, and received by Raleigh Water on March 19", 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 February 2024 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 SSO 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
lb.] 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 # 202400415—1/10/2024 — 5536 Neuse View Dr., Raleigh
This spill was neither willful nor intentional; it resulted from an unidentified ATV traffic (see Exhibit 1 below)
near the damaged air release valve (ARV). This damage did not affect the normal flow of untreated wastewater
within the temporary bypass pipe. The unidentified ATV traffic that damaged the ARV led to a sewer spill of
approximately 1,500 gallons of untreated wastewater in which approximately 200 gallons may have reached
surface waters of the Neuse River.
Exhibit 1—ATV Transit
Note —the picture below was provided by a neighbor who witnessed the Incident. The AN rider has not been identified.
On 02/04/2024, at approximately 5:59 PM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a damaged air release valve located near 5536 Neuse View Dr., Raleigh, NC. where an active
interceptor improvement project is currently underway. The responding staff took all reasonable steps to stop
and mitigate the impact of the discharge, gaining control of the spill incident by 06:51 PM on the same day.
Crews replaced the damaged ARV restoring sewer flow. See Exhibit 2 —ARV Repair Effort, below.
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 vacuum pumps to recover stagnant 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 remove approximately 26 cubic yards of sewer
contaminated soil from the area surrounding the damaged ARV. The area around the damaged ARV was cleared
of debris, and treated with lime. See Exhibit 4 — Restoration Efforts.
Exhibit 4—Re oratian Efforts
The cost associated with the mitigation of this incident amounted to $2,980.94. The approximate cost to the
Utility to treat 1,500 gallons of wastewater would have been approximately $6.72. 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.

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 Sunday, February 4th, 2023, at approximately 4:39 PM, Raleigh Water staff were
notified of a sanitary sewer overflow near 5536 Neuse View Dr.. Raleigh, NC. Upon
arrival, utility responders identified an active sewer overflow, from a damaged ah-
release valve that resulted from vandalism to a 24inch sewer by-pass project.
This incident affected the flow of untreated wastewater from a 244nch high -density
polyethylene (HOPE) sewer gravity main. The responding staff took all reasonable
steps to slop 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 contained the overflow at approximately 6:51 PM on the same day.
It is estimated that the overflow discharged approximately 1,500 gallons of untreated
wastewater, of which approximately 200 gallons may have reached the Neuse River.
No vegetative damage or fish kill was observed related to this event Restoration for
this incident is ongoing.
• Raleigh Water has an aggressive education and enforcement program to
prevent the discharge of grease, debris, wipes, rags, Gapers and other Improper
materials in the sewer system and to take enforcement action where
appropriate. If these hems make R 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 Hems permitted to be
discharged into the sewer system. All 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 919-996-3245 to report immediately.
• For more information about how you can help prevent sanitary sewer spills,
please visit: raleighncgovAvater.
This news release is required by NCGS Adde 21, Chapter 143.215.1C.
NH#
Since the last sewer incident, no additional sewer issues have been associated with this section of the collection
system. An official police report was initiated following the notification of the damage. (see Exhibit 6— Police
Report, below)

Exhibit 6-Police Report
..I. WLICQ DB . Ox../IRCWM "..
Page: 1
Minis) - Cf.486IP1CAT101i: UCVR QAW/T..R .
MH . QPAT: GV@. R0:
fill Other/Oeeuge to P Periy Iv:lmrl 008 03/06/3e i7:16
02 e30 ...0066J[
iC(.'ATIOX OR CR[r0[: TYPQ oP PR0lIIs:
82 ANDURDB Min DR
OP➢RR68 MYW OATS OF OPPBN68: RRS OF OPPQR68: OPP[C80.'6 nnW
COOQ tO:
6D8 lO SUN 02104/16 TO 02/04/24 16:11 TO 19:00 M[LLO
.161
REPORT® BY: RAM 6Rx: A08: AODOI66:
A0.4IP. L Wym Anmot Q P 15 5500 RQO6Q VIER DR
•COOPS• __. Q-MISR .-.Mn L-LOST D-DMAORO xionkW
P-POURD PROPRIIY
CDDR: ((IY: OQSCYIP[IOQ OP PROnkn:
VAIDB:
1.D t 6RRADR PIP&
VAIAQ DAMADRD: VRLOB RQWV&RED:
TMAL VALVE b10LER:
WI Vxm (LRST. P[RS[. MI): RAC&: &RM! AGE: AD➢RR66:
V-CITY oP RAL&IOH C[TY OP MLeIOR RALBt®t. tlC
P8RSW16)ARAHBT®: RACE: 60Q8�ADRt�:0�D0PRLe01 ADO0.Pv'S:
CHARDQ:
`IJ nFOED CM
ROYWQA i1011101Q
RAIA NPOW DETAM"ABIr
�y
W i I
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 # 202400480 — 02/16/2024 — 1527 Tryon Rd., Raleigh
This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of an 8-in
gravity sewer main. The root intrusion led to a sewer spill of approximately 475 gallons of untreated wastewater
reaching a stormwater containment pond connected to an unnamed tributary within Walnut Basin (see exhibit 1
—Area of Operation).
On 2/16/2024, at approximately 1:01 PM, Raleigh Water staff responded to a sewage overflow from a sanitary
sewer manhole near 1527 Tryon Rd., Raleigh, NC. The responding staff took all reasonable steps to stop and
mitigate the impact of the discharge, gaining control of the spill incident by 02:37 PM on the same day. Crews
utilized hydraulic jetting to remove the source of the blockage within the affecting asset, thus restoring sewer
flow.
The containment and collection of this spill incident were executed with precision and efficiency. A temporary
spill containment site was strategically placed downstream of the affected area, effectively restricting sewer
flow to downstream surface waters. This approach successfully contained wastewater flow and minimized the
environmental impact on the surrounding land. Responding crews skillfully 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.
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 $3,749.16. The approximate cost to the Utility to
treat 475 gallons of wastewater would have been approximately $.71. 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 Contractor Chemical Root
activities Activities Control Initial Treatment
2/22/2018 4/8/2024 8/4/2022
3/13/2018
3/14/2018
4/23/2018
10/30/2018
6/3/2022
7/8/2022
11/16/2022
4/16/2023
7/31/2023
2/16/2024
2/19/2024
3/21/2024
Eehlblt 2—Zone of Influence
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 # 202400520 — 2/22/2024 — 401 Virginia Water Drive, Rolesville, NC
This spill was neither willful nor intentional; it resulted from a failed sewer bypass operation conducted by a
utility contractor, which affected the flow of an 8-in gravity sewer main. The bypass failure was caused by a
pump running out of fuel, causing the flow of untreated wastewater to overflow the manhole. This pump failure
led to approximately 500 gallons of untreated wastewater overflowing, of which approximately 250 gallons
reached an unnamed tributary within Harrys Creek Basin (see exhibit 1—Area of Operation).
On 2/22/2024, at approximately 1:26 PM, Raleigh Water staff promptly responded to a sanitary sewer overflow
emanating from a sanitary sewer manhole. The responding staff, demonstrating their commitment to public
safety, took all necessary steps to stop and mitigate the impact of the discharge, gaining control of the spill
incident by 2:09 PM on the same day. The utility Contractor restored the bypass pumps, stopping the overflow
and thus restoring sewer flow.
The containment and collection of this spill incident were executed with precision and efficiency. A temporary
spill containment site was strategically placed downstream of the affected area, effectively restricting sewer
flow to downstream surface waters. This approach successfully contained wastewater flow and minimized the
environmental impact on the surrounding land. Responding crews skillfully 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.

Exhibit 2—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 and treated with lime.
The cost associated with mitigating this incident amounted to $2,013.11. The approximate cost to the Utility to
treat 500 gallons of wastewater would have been approximately $0.75. 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.
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. No additional issues have been associated with this section of the collection system
since the last sewer incident. The contractor was issued a violation notice as a result of this event.

Incident Number # 202400555 - 2/29/2024 - 900 Lorimer Road, Raleigh
This spill was neither willful nor intentional; it resulted from road construction activity in which large rocks and
other related construction material caused a blockage in a portion of an 8-inch ductile iron pipe gravity sewer
main (see exhibit 1- Construction Debris Found in Manhole). The blockage led to a sewer spill of approximately
750 gallons, and approximately 600 gallons of untreated wastewater reached an unnamed tributary within the
Bushy Basin.
Exhibit 1-Construction Debris Found In Manhole
On 02/29/2024, at approximately 12:15 PM, Raleigh Water staff were notified of a manhole spilling over. Utility
responders were immediately summoned to respond and mitigate the spill. 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 event by 01:30 PM on the same day. Utility Responder contained the overflow utilizing a vacuum system to
maintain the flow below overflow levels. Responders also utilized hydraulic jetting and manual debris removal
tools to rid the source of the blockage within the affecting asset, thus restoring sewer flow.
Containment and collection of this spill event consisted of employing a temporary spill containment site
downstream of the affected area. This approach was intended to contain sewer flow and minimize the
environmental impact on the surrounding land. Responding crews initiated the collection of untreated
wastewater from the containment site to re -introduce it to the collection system downstream. This spill was
contained without a significant environmental impact on the adjacent area and its natural resources. See Exhibit
2 —Containment Efforts)
10

Exhibit 2 — Containment Efforts
During the restoration phase of the operation, Utility contractors manually removed several pieces of debris
from the sewer main to restore flow. See Exhibit 3 — Manual Debris Removal. Crews also utilized several
thousand gallons of potable water to assist in washing the creek and remove all evidence of sewer downstream
of the affected area. The area around the manhole was cleared of debris, treated with lime, and restored with
grass seed and straw. Visual inspection of the affected area and downstream waters confirmed that no fish kill
or unnecessary vegetative damage occurred.
Exhibit 3—Manual Debris Removal
The cost associated with mitigating this event amounted to $3,400.56. The approximate cost to the utility to
treat 750 gallons of wastewater would have been $1.12. The City saved no money from this spill. The costs for
cleanup exceeded the cost of treating the volume of sewage, and no spill occurred. Furthermore, the City still
had to pay the cost of treating the greater volume of sewage created by the spill and the cost of potable water
used to mitigate the event.
This location remains an active construction site with restricted access to complete further CCTV assessment.
Visual assortment indicates that the sewer gravity mains continue to flow as designed. Furthermore, the assets
associated with this portion of the collection system have been added to the Hot Spot Management Program
and have been identified for recurrent assessment every 30 days. No further issues have occurred since this SSO
event. Raleigh Water held the road contractor with the burden of the total sewer restoration and debris removal
cost.
11

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 [7] 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 [21,
approximately 2% of the Division's annual operating budget. The 3,225 gallons of untreated wastewater,
identified as notice of violations in this letter, cost the Utility approximately $12,143.77 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 $ 4.83. 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 141 per 100 miles of pipe, compared to the Southeastern
Region of the U.S., of 7.0 spills per 100 miles of line.
[1] 1252 miles represents approximately 47% of the entire sanitary sewer callection system
[21 Associated operational cost year to date for FY2024
OPERATION LI NEAR FEET
Linear Miles
COST
CCTV 449,010
85
$270,804.27
Repair 2280
.43
$2,065,862.65
Rushing 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- 6,610,880 Ft / 1252 MILES
$2,913,456.22
131 F.V. 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 550 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
111Va

'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-0161 issued for the month of February
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 [phone] or Carlos M. Perez,
ORC, Assistance Superintendent, at 919-996-5929.
'ncerel1y
os 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 Ieighnc.Gov
13