WQCS00002_NOV-2024-DV-0238_20240621

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Raleigh Water
,SUN 2 P24
June 21", 2024
I,-.t I Regional Off! w
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-0238
Sanitary Sewer Overflows —April 2024
Permit No. WQCS00002
Dear Mrs. Manuel:
Please allow this letter to respond to the Notice of Violation document (Nov-2024-DV-0238) dated May
23rd, 2024, and received by Raleigh Water on June 7th, 2024. This document contains the narrative regarding the
pending Notice of Violation action of one Sanitary Sewer Overflow (SSO) incident reported during the month of
April 2024 within the City of Raleigh Collections System (1]- This document also provides exhibits to prove our
efforts to mitigate the sewer incident. 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 incident, listed with the intended NOV-NOI action.
Please find below the additional information requested for the SSO incident.
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 natufal conditions; there were no feasible alternatives to the 550, such as the use of auxiliary treatment facilities, retention of
untreated wastewater, reduction of inflow and infiltration, use of adequate backup equipment, or an increase in the capacity of the system. This provision is not
satisfied if, in the exercise of reasonable engineering judgment, the Permittee should have installed auxiliary or additional collections system components, wastewater
retention or treatment facilities, adequate backup equipment, or should have reduced inflow and infiltration or
[b.] The 550 was exceptional, unintenti oral, temporary, and caused by factors beyond the reasonable control of the Permittee; the 550 could not have been prevented
by the exercise of reasonable control, such as proper management, operation, and maintenance; adequate treatment or collection facilities or components (e.g.,
adequately enlarging treatment of collection facilities to accommodate growth or adequately controlling and preventing infiltration and inflow); preventative
maintenance; or installation of adequate backup equipment;"

Incident Number # 202400794 — 4/15/2024 — Chapel Hill Rd., Raleigh 11
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 24,800 gallons of untreated
wastewater in which approximately 13,700 gallons may have reached an unnamed tributary within the Richland
Basin (see exhibit 1— Area of Operation)
On 04/15/2024, at approximately 1:50 PM, a concerned citizen emailed the Stormwater Division of the City of
Raleigh, notifying of a possible sewer overflow. The email was not identified through the regular reporting
channels until the morning of 4/16/2024, prompting Raleigh Water Utility Responders to tend to the suspected
overflow immediately. Utility responders quickly arrived and observed a sanitary sewer overflow from a sanitary
sewer manhole (affected sewer asset SMH151060) near Chapel Hill 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
10:30 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. The
containment effort collected approximately 11,100 gallons of untreated wastewater on the ground before
reaching surface waters. 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.
2

The cost associated with mitigating this incident amounted to $13,285.27. The approximate cost to the Utility to
treat 3,600 gallons of wastewater would have been $37.20. 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 (see Exhibit 2- Future root control services). Within
the last ten years, this specific portion of the collection system has not experienced any SSO related to root
intrusion. Sanitary sewer assets in this area have been routinely maintained with subsequent chemical root
control treatment.
Exhibit 3- Future root control services
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 3 — Press release.
Exhibit 3 — Press release
Raleigh Water Responds to a Sanitary Sewer Overflow
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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
Easement
Inspections Activities
activities
Maintenance
Activities
Manhole Inspection
6/2/2017
1/19/2023
11/19/2021
11/25/2019
4/17/2024
5/17/2022
4/16/2024
4/30/2024
Sewer High -Priority Inspection
1/10/2018
5/8/2018
5/8/2018
5/10/2018
11/19/2018
11/30/2018
4/11/2019
11/1/2019
11/14/2019
10/31/2019
2/18/2020
2/17/2020
8/19/2020
1/6/2021
8/2/2021
8/3/2021
2/16/2022
10/31/2022
2/28/2023
9/26/2023
9/27/2023
2/12/2024
2/12/2024
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 the completion of further CCTV assessment,
sewer main cleaning, and chemical root control application.
4

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 1,349 [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 $3,617,219.08 [2[,
approximately 2% of the Division's annual operating budget.
The mitigation of the 24,800 gallons of untreated wastewater identified as notice of violations in this letter cost
the Utility approximately $13,285.27. The City's cost of sewer treatment per gallon is $.0015 [3[. At this rate,
treating the untreated wastewater spilled would cost the City $37.20. The City saved no money from these spills.
The mitigation costs 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 1.78 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] 1,349 miles represents approximately47%ofthe entire sanitary sewer collection system
[2) Associated operational cost year to date for FY2024
OPERATION
LINEAR FEET
Linear Miles
COST
OPERATION
LINEAR FEET
Linear Miles
COST
CCTV
501,600
95
$289,269.31
Repair
3,520
.66
$2,497,779.36
Flushing
2,095,395
394
$601,462.15
Easement
539,253
102
$228,708.26
Easement Inspection
3,995,104
[31 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 1.78
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
5

these fabrics, the current industry standards, and bettered ucation forth e 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 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-fiushable 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-0238 issued for April 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.
Sincerely, i
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]

DocuSign Envelope ID: 03FB9687-11A4-452E-83D0-F3E9C9FG456D
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Certified Mail # 7017 0190 0000 2486 0711
Return Receipt Reguested
May 23, 2024
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
� � � F T T �1� 1UN 07 2024 P
NC Dept of Env:ropmentai
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0238
Sanitary Sewer Overflows - April 2024
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
Raleigh Regional Offic;l
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Ray Report/s submitted by
City of Raleigh. The Division's Raleigh Regional Office concludes that the City of Raleigh violated Permit Condition I
(2) of Permit No. WQCS00002 by failing to effectively manage, maintain, and operate their collection system so
that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO constituted making an
outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1.
The Raleigh Regional Office is providing the City of Raleigh an opportunity to provide evidence and justification as
to why the City of Raleigh should not be assessed a civil penalty for the viclation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202400794 4/15/2024 1,240 Chapel Mill Rd, Raleigh, Debris in line, Grease, 24,800 13,700 Notice of Violation -
NC, 27607 Roots Intent to Assess
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
DEQ�:

DocuSign Envelope ID: 03FB9687-11A4-452E-B3Q0-F3E9C9F6456o
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Kevin Fowler with the Water Quality Section in the
Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Cc; Laserfiche
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Sincerely,
- - DocuSigned by:
Varn.t.Ssa'e, &i.ce,lnOU
62916EBAR32144F
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ