WQCS00002_NOV-2024-DV-0429 Resposne to Notice_20241104

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Raleigh Water
October 30th, 2024
NC Cc EfL..�✓i.'4i i_
Vanessa Manuel, Assistant Regional Supervisor NOV 42024
Water Quality Regional Operations Section Raa"ig]_ r e ;01.1k? `�!— ;
Raleigh Regional Office ��-�O
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Response to NOV-2024-DV-0429
Sanitary Sewer Overflows — August 2024
Permit No. WQCS00002
Dear Mrs. Manuel:
Please allow this letter to respond to the Notice of Violation document (NOV-2024-DV-0429) dated October
411, 2024, and received by Raleigh Water on October 101h, 2024. This document contains the narrative regarding
the pending Notice of Violation action of 4 Sanitary Sewer Overflow (SSO) incidents reported during August
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 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
[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;"
1

Incident Number # 202401520 — 8/8/2024 — 716 Pebblebrook Dr., Raleigh
This spill was neither willful nor intentional; it resulted from root intrusion, which blocked a portion of a 15-in
gravity sewer main. The root intrusion led to a sewer spill of approximately 2,450 gallons of untreated
wastewater reaching an unnamed tributary within the Big Branch Basin (see exhibit 1— Area of Operation). This
incident was also influenced by a rain event that produced copious amount of water that affected the normal
flow of this segment of sewer main.
On 8/8/2024, at approximately 2:41 PM, Raleigh Water staff responded to a sanitary sewer overflow emanating from a
sanitary sewer manhole (affected sewer asset SMH101282, see exhibit 2 - Affected Asset / Root intrusion) located near
7401 Sandy Creek Dr., 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 4.15 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 $8,467.46. The approximate cost to the Utility to
treat 2,450 gallons of wastewater would have been $3.67. 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
identified for routinely maintained and 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 Releas*
Raleigh Water Responds to a sanitary sewer Overflow
On Thursday, Pews: ML 2024, at awproirr iftly 2.11 PM R&W water stew
were wined of a unitary sawar ererwow at 716 PebhleWcoh D*m.. Rahigh. NC
llpan anlvef Ihity RespwWors Idsrdlwad se erslve "war averwow from s sewer
mardrefs. a�eceny the tmm , wow of ate sewer system. The rupwmkq "WI took d
reswnahk reps to rrrplpale en werwoars anrkonmaMat Input The Noreen Cw*w
Oewmw.t et Eft o Aal OUWty. DkWm d Warr Ra"aurns. has bow nW W
or ON ovamMw.
Based w a ads soseasrrnr4 R was eadmated that the overwow may have
dhr*argd appresknatnly 2,450 9dons of wWeatad wastewater of rvlAtA
apprerdrrrtlNy 2,000 gaMro nary Mew rsadrd th stmrfea oaten of a tmlhmtary wterkn
ftfy Branch Basin. TH" ervelbwsns s0rl6uted te root kthwkn M 1M dowrokeam
sepnwX of 1M sower main. No vep taew d"a or fah M was observed related to
dvls event Rnlaallm fr the kx:MPW was completed an en some day
• RaW Water has an aggressive arLoeon erM WiNcamenl program to
mat rrl dare 6W Wye oA ¢sawn dsM4wipes. raps. dapara erW seer imWoper
malarsewer♦n the sewer system and to take adorcamerA sceomr warren
appoplab. If these Rams make R kdo ate sower system' tiny mry case ■
spa whirh can have am adverse krpad *a caster wow end em4nya dwo
win come kdo cerdod *0 ate Muted waro.
Water, human waste. win WMt Issue are do only Rams pem Md to be
dechrgd kdo can sewer system. AR comer Remy we cam "Top to tM
aawr syafam wad an mewl pammi0ad.
• n you axperlsom excessive serer smell or am "ewer spON from maJnlea
or p1pu. please aR 9149W32/5 to repot knndately
• For mom Irdrmapon about how you can h* pweni steel" sewer Wit
plea+Asir -Mkigh-9W &W
This name releasele milked by NCGS Afddo 21 Chapter 143.215 1--
kWh

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:
Inspections Activities
Flushing activities
Manhole
Sewer High Priority
CCfV
Activities
Inspection
Inspection
6/6/2017
*14 manhole
*199 inspections
2/5/2019
3/5/2019
inspections
between
2/22/2020
10/8/2020
between
12/11/2017
7/16/2021
10/9/2020
12/21/2021-
10/23/2024
9/4/2024
2/21/2024
6/24/2022
10/25/2024
8/16/2024
10/28/2024
10/25/2024
10/30/2024
Chemical Root Control
7/24/2023
Easement
Maintenance
Repair Operations
Activities
4/5/2024
2/21/2022
8/15/2024
3/28/2022
10/8/2024
8/16/2024
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,
CCTV, and chemical root control applications. The "Zone of Influence" below was identified for further chemical
root control.

Incident Number # 202401939 — 8/22/2024 — 3400 Fernwood Dr, Raleigh, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of the 8" gravity sewer main. This build-up led to a sewer spill of approximately 675 gallons of
untreated wastewater reaching Hare Snipe Creek. See Exhibit 1— Area of Operation.
Exhibit 1— Area of Operatinn
UOO FemwoW Dr. Incident Map IV .� .`�.«-r+*•.•�••�+.�+
On 08/22/2024, at approximately 1:30 PM, Sewer Maintenance staff were notified of a sanitary sewer overflow
emanating from a manhole near 3400 Fernwood Dr., 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 02:17 PM on the same day. Crews utilized hydraulic jetting to remove the source of the blockage
within the affecting asset, thus restoring sewer flow. Crews also identified a partially ruptured pipe, which was
repaired accordingly (see exhibit 2 — Repair and remediation)

Containment and collection of this spill event consisted of employing a temporary spill containment site
downstream of the affected area near 4809 Rembert Rd. (see Exhibit 3 — 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 prase 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. See
restoration efforts below.
Exhibit 4 — Restoration Efforts
The cost associated with mitigating this event amounted to $16,339.01. The approximate cost to the utility to
treat 675 gallons of wastewater would have been approximately $1.01. 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 private residential area. It provides sewer
collection services to a large apartment complex upstream of the spill event (see Exhibit S—Zone of Influence). A
code enforcement action was initiated to provide the apartment management with information on the proper
use of the sanitary sewer collection system. See Exhibit 6—Information Door Hanger.
0

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Within the last ten years, this portion of the collection system has not experienced a grease -related SSO
incident. 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
5/3/2021 9/26/2024
8/23/2024
Easement Repair
Maintenance Activities
Activities Clearing
3/21/2024 8/26/2024
8/23/2024
4/30/2019
Inspection Activity
Sewer High Priority Manhole Inspection
Inspection
12/1/2017
4/11/2018
8/30/2018
3/1/2019
3/7/2019
3/8/2019
9/5/2019
9/20/2019
1/6/2020
1/15/2020
7/23/2020
8/4/2020
8/20/2020
9/8/2020
10/1/2020
1/6/2021
5/4/2021
5/6/2021
7/12/2021
8/2/2021
1/24/2022
3/21/2022
8/22/2022
9/2/2022
1/5/2023
2/8/2023
2/20/2023
2/20/2023
10/2/2023
1/16/2024
4/18/2024
7/10/2024
10/24/2024
8/1/2019
9/26/2019
8/1/2019
10/27/2019
8/1/2019
7/31/2019
9/26/2019
8/1/2019
6/9/2022
11/17/2023
12/13/2023
This section of the collection system has not experienced any additional issues since the last sewer event.
Pending the completion of further sewer main cleaning and CCTV assessment, this site will remain an active
maintenance spot.

incident Number # 202402002 — 8/25/2024 — 417 Gardner St., Raleigh, NC
This spill was neither willful nor intentional; it resulted from a collapsed section of pipe affecting the flow of
untreated wastewater of a 6'- sewer gravity main. This asset failure led to a sewer spill of approximately 300
gallons of untreated wastewater, reaching a stormwater channel. See Exhibit 1—Area of Operations
Exhibit 1—Area af0peratiu ik
On 8/25/2024, at approximately 6:04 PM, Raleigh Water - Sewer Maintenance Division staff was notified of a
sewer overflow from the ground near 417 Gardner St., Raleigh, NC. Upon arrival, crews commenced to stop the
overflow by utilizing high -velocity jetting to rid the source of the blockage. An initial assessment identified that
the source of the blockage was a pipe failure and foreign debris that was not consistent with sewer debris such
as paper. A follow-up CCTV assessment determined that the root cause of the blockage was a partially collapsed
sewer gravity main (see Exhibit 2 — Damaged Section of Gravity Main) and foreign debris (see Exhibit 3 — Foreign
Debris) appearing to be sections of a plastic container which resulted in the subsequent blockage. The
responding staff took all reasonable steps to stop and mitigate the impact of the discharge as soon as they
arrived, gaining control of the spill incident by 8:30 PM on the same day.
9

A capital Improvement Project scheduled to relocate the existing sewer gravity main will address this deficiency.
Crews removed the foreign debris, restoring the flow of untreated wastewater. The repair and relocation of the
sewer main has been scheduled as a future project.
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 the spill did not reach
any state surface waters remaining within the stormwater channel. 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 $6,479.19. The approximate cost to the
utility to treat 300 gallons of wastewater was $0.45. The City saved no money from this spill. Its costs for
cleanup and repair exceeded the cost of treating the volume of sewage had no spill occurred. Furthermore, the
City still had to pay to treat the greater volume of sewage created by the spill.
The incidents leading to this spill can be considered exceptional, unintentional, temporary, and caused by
factors beyond our reasonable control. 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.
10

Incident Number # 202402009 — 8/2/2024 — 701 Barris Rd., Wake Forest, NC
This spill was neither willful nor intentional. It resulted from a grease build-up, restricting the sewer flow within
a section of the 8" ductile iron gravity sewer main. This build-up led to a sewer spill of approximately 615,899
gallons of untreated wastewater reaching a public pond in E. Carroll Joyner Park, within Wake Forest. See Exhibit
1—Area of Operation.
Exhibit 1- Area of Operation
On 08/24/2024, at approximately 4:51 PM, Sewer Maintenance staff identified an active sanitary sewer
overflow emanating from a manhole (SMH145364 see Exhibit 2 — SSO Remediation) near the public pond at E.
Carroll Joyner Park, 701 Harris Rd., Wake Forest, 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
1:12 AM on 8/25/2024. Crews utilized hydraulic jetting to remove the source of the blockage within the
affecting asset, thus restoring sewer flow.
Exhibit 2 - SSO Remed atron
11

Containment and collection of this spill event consisted of employing a temporary spill containment site
downstream of the affected area on the downstream side of the retaining pond (near the spillway), eliminating
overflow from the pond to continue to the downstream surface waters (see Exhibit 3 — 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 pond confirmed several fish kill occurred.
Exhibit 3 —Containment and Collection Efforts
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. See
restoration efforts below. The pond was drained to remove approximately 2.5 million gallons of water and as
much sediment as possible from the bottom of the pond. A pond management contractor was hired to assist in
the remediation of the pond's conditions and re-establishing aquatic life.
The cost associated with mitigating this event amounted to $60,541.71. The approximate cost to the utility to
treat 615,899 gallons of wastewater would have been approximately $923.84. 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.
12

This section of the collection system is located downstream of a private residential area. It provides sewer
collection services to a large apartment complex upstream of the spill event (see Exhibit 5—Zone of Influence). A
code enforcement action was initiated, providing the apartment management with outreach information on
properly using the sanitary sewer collection system. A press release notification was requested to be published
in the Raleigh News & Observer as required by NCGS Article 21, Chapter 143.215.1C. Additionally, a news report
was aired in WRAL denoting the consequences caused to the public sewer infrastructure resulting from grease
residential grease accumulation. See Exhibit 6 — Press release.
Exhibit 6— Press release
Raleigh Water Responds to a Sanitary Sewer Overflow
On May August 23' 2024. at apprcnina * S 19 Pkk PANO Wpm srtll Mt*
r4tbed a a wMary sewer awAaw seer M Narrh Rd. Wake Fhest NC Upon
a —at tlepr Respe des Neniastl an uMe sewer arerpow ma"bwn 9t*ass
aea.ndaierr, aliectkq die nerrnal ier M pre u.0 0rariry maxi the nesprr Mw slat
Nee 0 reasonable brags In trt9+h Cie avrrwo erMwon"W hnpacl. 9aerbq
control of 1e areTow by 112 AM en SaMday. AWaM 24^ the NoM Cabala
Department of EmhamnentM Ou+gY {nrhken of Water lesena . hn been nodkd
M the 9"dim
the bpi some has nmf beam tlMerrrrird :Ma &MAaw nadwod dre wrlaee
waken of an unnamed b2ndary weir Nre McMand Base, ROMralon Ow Bfe naldrrt
Is ongo".
Ralegh Wafer hn an a00ras" edocabn rxisrdwcemM pmW m ke
prevara ewe Aschrps mr gnrge dmds.wpes raps dhpen aM stew Mlprepel
mabPrlMs an the aeww system cod Ion take drdatanr fd Wien whore appreplah
II IMas isms melee i iMo ire sewer eyalmrr, ireY may NYM a rya wMdr car
man an atlreree Nnpaol on cooker warm and endanpw iroea who coons Imt1
canted with see allecked uses
Water, human wash and M M rsue an it* V* his permiOW to be
dhrharged rem dre sewer syiem. N WM Nona we sense damage to me
sewer syshn and an net penrreed
If you expadeeee emsin sewn sorer r see sewer to" born mw*wk4 w
pees, please eai 919-VW3245 to sepal araM IA"
Fa mere idannahn Metal heal "au can help preesnl farm" Saw"ft.
phase VM rakethffl M* MW
The news release in npgL&M by NCf1S AAde 21 ChWW 143 715 M
as
13

Within the last ten years, this portion of the collection system has not experienced a grease -related SSO
incident. 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:
Easement
Inspection Activity
Flushing activities
CCTV activities
Maintenance
Sewer High Priority
Manhole Inspection
Activities Clearing
Inspection
5/29/2024
4/11/2019
8/26/2024
12/4/2017
10/17/2017
5/30/2024
11/15/2021
5/29/2018
1/9/2020
5/30/2024
11/16/2021
12/18/2018
12/14/2020
6/5/2024
11/22/2021
5/28/2019
8/25/2024
11/23/2021
10/2/2019
8/26/2024
11/24/2021
1/30/2020
11/29/2021
10/7/2020
3/30/2022
3/31/2022
2/25/2021
8/26/2024
3/1/2021
8/28/2024
1/14/2022
9/2/2022
2/10/2023
8/14/2023
3/7/2024
10/1/2024
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.
14

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 2,738 miles
of sanitary sewer pipe and minimize the accidental release of untreated wastewater.
Since July 2024 (Fiscal Year 2025), the Utility has maintained approximately 705 [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 $1,387,363.61 [2:.
approximately .08% of the Division's annual operating budget.
The mitigation of the 619,324 gallons of untreated wastewater identified as notice of violations in this letter cost
the Utility approximately $91,827.37. The City's cost of sewer treatment per gallon is $.0015 {3]. At this rate,
treating the untreated wastewater spilled would cost the City $929.00. 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 .59 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] 705 miles represents approximately 26%of the entire sanitary sewer collection system
[2] Associated operational cost year to date for FY2025
OPERATION
LINEAR FEET
Linear Mlles
COST
CCTV
153,120
29
$94,802.61
Repair
2,840
.s3
$914,759.84
Flushing
1,092,960
207
$269,267.61
Easement
216,480
41
$108,533.53
Easement Inspection
2,259,840
428
N/A
Total- 3,725,240 Ft / 705.5 MILES
The total cost of Business to Date is
$1,387,363.61
[3] 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.Y. 25 is 0.59
Note
In FY-2024, the Raleigh Water -Sewer Maintenance Division spent $2,735,282.91 in operations to maintain, repair, and inspect approximately 757 miles of sanitary sewer
Infrastructure.
15

Additionally, the City of Raleigh Assistant Public Utility Directors and Collections System staff have become
involved in challenging the nonwoven fabrics industry standards to better inform consumers of these products
and their detrimental effects on the collections systems. PUD staff has personally met with officers of INDA, the
leading association of the nonwoven fabrics industry based in Cary, NC, to communicate our concerns about
these fabrics, the current industry standards, and better education for the consumer. PUD has also joined forces
with other utilities nationwide through the National Association of Clean Waters Agencies (NACWA), the Water
Environment Foundation (WEF), and the American Public Works Association (APWA) to challenge INDA and
current industry standards, recognizing that they do not support compatibility in sanitary sewer 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://raleiizhnc.eov/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-0429 issued for August 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.
Sincerel
Carlos M Per RC
Assistance Superintendent, Sewer Maintenance Division
City of Raleigh, Public Utilities Department
P.O. Box 590
16

Raleigh, NC 27602-0590
919-996-5929 office
919-275-6020 cell
Carlos.perezcamacho(cpraleighnc.Gov
17

Docusign Envelope ID- 750AODC6-2A56-44EF-9601-39FBA95B3854
ROY COOPER
GOMM"
MARY PENNY KELLEY
See rcruey
RICHARD E. ROGERS, JR
Direcror
Certified Mail # 7017 0190 0000 2485 9241
Return Receipt Requested
Whit Wheeler, Assistant Director
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
NORTH CAROLINA
Environmental Quality
October 04, 2024
O U 05T U T
OCT 1 0 2124
By] .130JL,
NC Dcp� of
NOV 4 2024
'Igrt-R eglonalOffice
SUBJECT: NOTICE Of VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0429
Sanitary Sewer Overflows - August 2024
Collection System Permit No. WQCS00002
Raleigh Collection System
Wake County
Dear Mr. Wheeler:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day 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 violation(s) that are summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mina) Location Cause (Gals) (Gals) DWR Action
202401520 8/8/2024 49 716 PEBBLEBROOK Roots
DRIVE, RALEIGH
202401939 8/22/2024
47 3400 FERNWOOD Grease, Pipe Failure
DRIVE, RALEIGH (Break)
202402002 8/25/2024 146 417 GARDNER STREET, Other
RALEIGH
2,450
675
300
2,000 Notice of Violation
(Tropical Storm Debby)
675 Notice of Violation
300 Notice of Violation
D Nash CeroMut Department d EnrkanmentaLQtatfty I DtAsbn of Water Resources
Rattl9h Regbr W 0 flce I ]BOO Barrett Ortrc Rak49K North Carolina 27604
9L9.79L4200

Dacuslgn Envelope ID-;'50AODC6-2A56-44EF-9601-39FBA95B3854
Incident Start Duration
Number Date (Mies) - Location Cause
202402009 8/2/2024 31,106 701 HARRIS ROAD, Grease
WAKE FOREST
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
615,899 615,899 Notice of Violation -
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.
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].
Sincerely,
Signed by:
_ — -- —-ailn,t.SSa- _ --
82918f':A�321"4
Cc: Laserfiche
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Norlh Caro1m Oepanmentaf EnvWm lal Quality 0ivisionof Water Reswrces
Ra4191. Re9lonal003ee . ]B00 By n Drive Radel9k Nenh Cara4na 27609
a�_ 9I9.79L4200