WQCS00002_NOV-2024-DV-0190_20240513

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Raleigh Water
May 13", 2024 1,WAY _.
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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-0190
Sanitary Sewer Overflows —March 2024
Permit No. WQCS00002
Dear Mrs. Manuel:
Please allow this letter to respond to the Notice of Violation document (NOV-2024-m-o19o) dated March
131h,2024, 2024, and received by Raleigh Water on April 19th, 2024. This document contains the narrative
regarding the pending two Notice of Violation actions of Sanitary Sewer Overflows (SSO) incidents reported
during the month of March 2024 within the City of Raleigh Collections System [ll 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-NO] 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 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
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 # 202400597— 3/7/2024— 7049 Jeffreys Creek Ln., Raleigh
This spill was neither willful nor intentional; it resulted from the introduction of foreign material not consistent
with regular wastewater debris, such as toilet paper (see Exhibit 1—Introduced Foreign Material). This debris
caused a blockage in a portion of an 8" polyvinyl chloride gravity sewer main, which also damaged an elevated
sewer manhole. The blockage led to a sewer spill of approximately 6,059 gallons of untreated wastewater
reaching the surface waters of Perry Creek within the Perry Basin.
Exhibit 1—Introduced Foreign Material
Note —the pictures below contain foam material (suspected seat cushion) found as the root cause of the overflow.
On 03/07/2024, at approximately 11:13 AM, Raleigh Water staff responded to a sanitary sewer overflow
emanating from a damaged elevated sewer manhole near 7049 Jeffreys Creek Ln., Raleigh, NC (see Exhibit 2—
Damaged Elevated Sewer Manhole). The responding staff took all reasonable steps to stop and mitigate the
discharge's impact, gaining control of the spill incident by 12:06 PM on the same day.

Containment and collection of this spill incident consisted of employing a temporary spill containment site
downstream of the affected area, restricting sewer flow to downstream surface waters. This approach was
intended to contain wastewater flow and minimize the environmental impact on the surrounding land.
Responding crews employed 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.
During the restoration phase of the operation, crews repaired the damaged manhole and removed
approximately 35 cubic yards of sewer -contaminated soil from the area surrounding the spill. The area around
the spill was cleared of debris and treated with lime. Approximately 29 loads of wood chips (approximately 435
cubic yards) were spread through the area to assist in the restoration. See Exhibit 3—Restoration Efforts.
The cost associated with mitigating this incident amounted to $40,343.48. The approximate cost to the Utility to
treat 6,059 gallons of wastewater would have been approximately $9.10. 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 4 — Press Release.
Exhiba 4 — Press Release
Raleigh Water Responds to a Sanitary Sewer Overtlow
During an easement inspection on Thursday March 7th, 2024, at approximately
11:13 AM, Raleigh Water staff identified a sanitary sewer overflow near 7049 Jeffrey
Creek Ln Raleigh, NC. This incident affected the flow of untreated wastewater from an
8-inch PVC sewer gravity main. The responding staff took all reasonable steps to stop
and mitigate the overflow's 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 12:06 PM on the
same day. It is estimated that the overflow discharged approximately 6059 gallons of
untreated wastewater, of which an undetermined amount may have reached Perry
Creek within Nauss Basin. No vegetative damage or fish kill was observed related to
this event. Restoration for the incident Is ongoing.
• 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 contact with the affected areas.
• Water, human waste, and toilet tissue are the only items permitted to be
discharged into the sewer system. All other items will cause damage to the
sewer system and are not per rihed.
• 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: raleighnc.govAvater.
This news release is required by NCGS Article 21, Chapter 143.215.1 C.
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A code enforcement action was initiated through the Raleigh Water Code Enforcement Office. Outreach
information literature was requested to be sent to approximately 500 residents upstream of the affected area.
The literature explains the need for customers to use the sanitary sewer collection system properly and allows
citizens to partner with Public Utilities to protect the City's water quality and sewer collection infrastructure. See
Exhibit 5—Outreach Information.
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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 # 202400598 — 3/7/2024 —1401 Wendell Boulevard, Wendell
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of the 8" Polyvinyl Chloride pipe gravity sewer main. This build-up led to a sewer spill of
approximately 1,440 gallons of untreated wastewater, in which approximately 440 gallons may have reached an
unnamed tributary within Buffalo Lowe Basin. See Exhibit 1—Area of Operation.
On 3/7/2024, at approximately 7:19 AM, Sewer Maintenance staff were notified of a sanitary sewer overflow
emanating from a manhole near 1401 Wendell Blvd., Raleigh, NC. The responding staff arrived shortly after and
commenced taking all reasonable steps to stop and mitigate the impact of the discharge, gaining control of the
spill event by 8:12 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 event consisted of employing a temporary spill containment site
downstream of the affected area near Buffalo Creek (see Exhibit 2 —Containment and Collection Efforts). 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 re -introducing 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 removed sewer -contaminated soil from the affected area
of the downstream conveyance using mechanical ground removal. The areas around the manhole were cleared
of debris, washed with potable water, treated with lime, and finally restored with grass seed and straw.
A follow-up CCTV assessment was conducted on 3/13/2024 to identify the root cause of the SSO. The CCTV
assessment is ongoing and pending further sewer main cleaning.
The cost associated with mitigating this event amounted to $3,471.47. The approximate cost to the utility to
treat 1,440 gallons of wastewater would have been approximately $2.16. 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 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 approximately 262 properties upstream of the spill event (see Exhibit 3—Zone of Influence). Within
the last ten years, this portion of the collection system has experienced debris -related SSO events on
O1/23/2019 (incident # 201900199) and 12/1/2021 (incident #202102208). As a result of these incidents, several
assets have been placed on a recurrent maintenance service interval of 30 days.

A press release notification associated with this event was requested on 3/8/2024 (see exhibit 4 -Press Release).
Raleigh Water Responds to a Sanitary Sewer Overflow
On Thursday, March TIh, 2024, at approximates, 7:19 AM, Raleigh Water staff
ere missend of a asides,.ever overflow near 1401 Wended Mod, Wendel, NC. Upon
anal, Utility Responders IdentIfied an scone sewer overflow emanating Mom a server,
sewer manhole. This Wtltlent affected the flow of i nbeatnd wastewaterhr m an Burch
PVC sewer gravity main. The responding staff took all reasonable steps to stop and
mitpate she overety''s impact as soon as May armed. Tito Nar Carolina Department
of Em emrmental Chad, Division of Water Reswmes, has Ecen notified of Me
overflor
Raleigh Water staff contained the oveMow at approximi lety 8.12 A14 on Me
same day. II he esftated Nat Me wer0ow discharoed appronmatety 1,4409aflons of
untreated waslwiater, of which appro smately 400 gai may have reared Bulletin
Creek worse Buffalo Basin. No vegeeane damage or0sh U was observed related to
this went Resleration for this incident was completed! on Me same day.
people Water has an aggressive concedes and enforcement program W
prevent Me discharge of grease, debris, wipes, rags diapers and othervnpmpar
material h the sewer system and to lake enforcement action where appropdae.
If Mesa hems make h he re sewer system, May may cause a sine which can
have an adverse knpacl or water puffery and endanger M. who mme into
corned wish Me affected arena
Water, human waste, and lineal tisslw are Me any, hems pennihed to ce
discharged into the sewer system. Ad poor hens we cause damage to the
sewer rystem and are not permiffed
If you expeeer..,c, Ne scam ImeM or see sewer s,wi from manhples or
pipes, pease ca1919-99 45 to report mmin iaey
• Formers Nleniaher aMOnl how spin end hdp forwent sandary sewer ones
please m4 raleighoc.gwlwaer.
This nee release is repined by NCOS oracle 21, Chapter 143215.1C.
Before this event, 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
CCTV activities
6/20/2018
12/20/2021
5/2/2017
1/23/2019
1/3/2022
1/9/2018
12/16/2021
4/22/2022
1/10/2018
12/20/2021
7/21/2022
1/19/2018
1/3/2022
11/9/2022
1/23/2018
2/2/2022
2/14/2023
8/1/2018
3/3/2017
6/26/2023
8/2/2018
5/25/2017
10/25/2023
1/9/2019
1/23/2018
11/7/2023
1/8/2019
12/16/2021
11/14/2023
12/16/2021
11/17/2023
8/22/2023
8/23/2023
3/13/2024
Inspection
Activity
Manhole
Sewer High Priority
Inspection
Inspection
5/10/2022
11/17/2017
3/26/2020
5/19/2022
2/12/2018
10/13/2020
3/21/2018
3/16/2021
5/24/2018
3/17/2021
1/23/2019
10/14/2021
1/28/2019
10/22/2021
4/4/2019
2/25/2022
5/13/2019
9/30/2022
6/12/2019
10/4/2022
6/18/2019
3/29/2023
12/11/2019
9/1/2023
3/25/2020
9/6/2023
3/21/2024

Since the last sewer event, this section of the collection system has not experienced any additional issues. This
site will remain an active maintenance spot pending the completion of further sewer main cleaning and CCTV
assessment.

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 1,252 [1] miles of gravity sewer mains
by flushing with hydraulic jetting, conducting CCTV assessments, and performing repair operations, easement
maintenance, and inspections. The fiscal year-to-date cost of these operations amounts to $2,913,456.22 [2],
approximately 2%of the Division's annual operating budget. The 7,499 gallons of untreated wastewater,
identified as notice of violations in this letter, cost the Utility approximately $43,814.95 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 $11.24. 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.
[1] 1252 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
CCN 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- 6,610,880 Ft / 1252 MILES
$2,913,456.22
[3] F.Y. 2024 annual Divisional budget - $25,058,291
[4] $.0015 is based on the annual water treatment operating cost compounded by the total treated effluent.
[5] The current 550 Rate for F.Y. 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
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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-0190 issued for the month of March
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.
'ncerely, _ _
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 ODraleighnc.Gov
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