Commentary The playground area of Atlanta Memorial Park taped off after it was contaminated with sewage during an earlier flood incident.

Published on February 15th, 2016 |

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3 thoughts for solving sewage in Peachtree Creek, Memorial Park

Editor’s Note: In an earlier post, BuckheadView issued a challenge to Mayor Kasim Reed and his Department of Watershed Management to provide the residents of Buckhead and Atlanta a workable plan and commitment to fix the constant sewage contamination of Peachtree Creek and Atlanta Memorial Park in south Buckhead.

BuckheadView promised to provide thoughtful ideas for solutions to the problem from three sources by today, Feb. 15, prior to a meeting of the Atlanta City Council at which a resolution is scheduled to be voted on which would require the Department of Watershed Management to present Council with short- and long-term solutions within 90 days.

BuckheadView believes the city should provide a plan and commitment to Atlanta residents before they go to the polls on March 1 and are asked to vote on an extension of the 1 percent special added tax to support capital improvement projects of Watershed Management.

BuckheadView recognizes that the three solutions provided below are lengthy, but hopes our readers will consider the significance of this public health issue and read each thoroughly. The credentials for each author are at the bottom of their submission.

John Schaffner, owner/editor

 

Stop sewage overflows residents see & can’t see

By Justin Wiedeman, CPA, PE

Justin Wiedeman

Justin Wiedeman

The combined sewer system discharges to the separated sewer system that ultimately traverses Bobby Jones (Golf Course) and Memorial Park. A relief sewer (deep tunnel) was completed in 2008 with insufficient storage capacity to eliminate the combined sewer overflows or meet the regulatory criteria.

Combined sewer overflows continue by design. This is particularly of concern when Memorial Park is flooding which often occurs during significant rainfall events.

The combined sewer overflows upstream of Memorial Park are effectively out of sight. The discharges to Tanyard and Clear Creeks, which are tributaries of Peachtree Creek, dwarf the sewer overflows residents see spewing from manholes.

Based on a rather simple analysis, I’d recommend the following two major components of a capital program to solve the chronic overflow problems in the Proctor Creek Basin and Peachtree Creek Basin with further engineering analysis and review required:

A. Construct a Peachtree Creek sewer relief tunnel
Based on a simple analysis of the city of Atlanta’s Watershed Management Department (“Watershed Department”) submittals to USEPA/GAEPD, an additional 125 million gallons of storage CSOwould eliminate sewage overflows. This includes the separated trunk sewer system as well as the combined sewer system for Peachtree Creek. This could be accomplished based on the construction of an additional deep tunnel system with modifications to the wastewater and dedicated combined sewer overflow treatment facilities.

B. Separate Proctor Creek Basin combined sewers and reallocate storage
If the Proctor Creek Basin storm water runoff “pipe” was separated from the sanitary sewage “pipe” then combined sewer overflow tunnel storage could be reallocated to the Peachtree Creek tributaries. Certainly parks and greenways could be a big part of the plan as well.

This could reduce combined sewer overflow storage for the Peachtree Creek basin to approximately 100 million gallons.

While I’ve provided a rather simple analysis of data submitted to USEPA/GAEPD by Watershed Management, an independent and thorough engineering analysis may determine that additional storage volumes are required. Additionally, hydraulic conditions, operations, maintenance or other issues may warrant examining alternatives similar to the Chicago TARP (Tunnel and Reservoir Plan) which includes tunnels, retrofitting of existing quarries for storage, surface storage or some combination thereof.

Summary analysis of combined sewer overflows to Peachtree Creek tributaries
The reports submitted by Watershed Management to USEPA/GAEPD have odd data “quirks”. Given the data inconsistencies, my confidence level in the data is relatively low and a thorough and independent engineering analysis is highly recommended.

The following table provides a summary analysis of combined sewer overflow discharges to Peachtree Creek tributaries upstream of Memorial Park over the past five years based on data reported by Watershed Management.

Wiedeman chrt 1

While rainfall is the primary influence on combined sewer overflows, review of the data indicates the operable storage capacity of the existing CSO Storage Tunnel may be impaired. This could be a result of significant sediment and debris now contained within the deep tunnel system.

The analysis summarized in the table above indicates an additional 125 million gallons of storage would be adequate to capture the combined sewer overflow from all but the most extreme flooding events. As a point of reference, the existing CSO Tunnel provides approximately 250 million gallons of storage.

Summary analysis of combined sewer overflows to Peachtree Creek tributaries based on Proctor Creek storage reallocation

The following table provides a simple analysis (pro forma) of the impact of reallocating Proctor Creek Basin combined sewer overflow storage based on data submitted by Watershed Management to USEPA/GAEPD for the past five years.

Wiedeman chart 2

Based on reallocation of Proctor Creek storage, complete capture of Peachtree Creek tributary overflows would be provided with an additional 100 million gallons of storage.

The RM Clayton site is heavily utilized. It includes tunnel shafts, tunnel pumping stations, wastewater treatment facility unit processes and appurtenances as well as dedicated combined sewer overflow treatment facilities.

Any improvements to the conveyance system which increase the capture rate of sewage from the separated sewers or the combined sewers will require modifications to the treatment facilities.

(Justin Wiedeman is a Certified Public Accountant (CPA) and a Registered Professional Engineer (PE) with specialized background and experience in forensic accounting and engineering with water and sewer utilities, construction and real estate development matters. He was engaged by the city of Atlanta in 2003 to review Atlanta’s combined sewer overflow (CSO) program and for other matters. He has provided expert testimony in litigation involving Atlanta’s sewer programs on behalf of plaintiffs.)

A view inside the Nancy Creek Tunnel.

A view inside the Nancy Creek Tunnel.

 

The fix: build a Peachtree Creek tunnel

By City Councilwoman Mary Norwood

In 2000, the city had planned to build a sewage storage tank next to the Top Hat Soccer fields at the Intersection of Northside Drive and Broadland Road, a few blocks north of West Paces Ferry Road. The community was concerned that it would not work and that it would be nuisance to the neighborhood.

Atlanta City Councilwoman Mary Norwood

Atlanta City Councilwoman Mary Norwood

At that point, a grassroots organization called “CLEAN” hired an engineering firm to analyze the issue and come up with a long-term solution.

That solution was the Nancy Creek Tunnel which enabled the Nancy Creek basin to evolve from having been one of the most polluted in Atlanta to one of the cleanest. This solution was more expensive, but it was the RIGHT solution.

The project was completed in 2005 with DeKalb and Fulton County providing reimbursements for their fair share of the cost.

Today, just south of the Nancy Creek basin is the Peachtree Creek basin. There is simply too much sewage in the system.

In 2014, the Department of Watershed Management built the Peachtree Creek Capacity Relief Project (referred to as Liddell) to store 10 million gallons of sewage during periods of high rainfall, but as your neighbors in Memorial Park will tell you, this has not eliminated the sewage-filled stormwater which floods their park, their children’s playground, their golf course, and their own yards.

Here’s what’s happened in the past four years at the four CSO Control Facilities: Tanyard Creek CSO, Clear Creek CSO, Proctor Creek CSO, and Intrenchment Creek CSO:
2012: 19 sewage-filled stormwater floods
2013: 31 sewage-filled stormwater floods
2014: 34 sewage-filled stormwater floods
2015: 46 sewage-filled stormwater floods

How is this happening? Upstream, the city releases combined sewer overflow discharges which impact Memorial Park. The frequency of these discharges has grown dramatically over the past

This graphic shows the route of the Nancy Creek Tunnel.

This graphic shows the route of the Nancy Creek Tunnel.

several years!

To fix this, we must build a Peachtree Creek Tunnel. Just as we did with the Nancy Creek Tunnel, DeKalb County would pay their fair share of the cost. A Peachtree Creek Tunnel would provide substantial deep storage and conveyance for portions of DeKalb County, South Buckhead and Midtown.

Similar to the Nancy Creek Tunnel, it would be in granite and lined with concrete where appropriate. If we do this, it will be expensive, but it if it is done properly it will fix the sewage-filled stormwater floods in and around Memorial Park and the Bobby Jones Golf Course.

Sewage should be in tunnels 300 feet beneath us in our granite–not in our yards, our parks, and our city streets!

My resolution asks that the Department of Watershed Management design the solution because they have all of the data, but at the very least, I need (and our citizens need) a REALLY GOOD SOLID explanation of what will work, since their most recent solution (Liddell) has not.

As I have said, I don’t care if the city calls these pollutants “overflows”, “spills”, or “discharges”, what is happening downstream of our city’s CSO Facilities (Combined Sewer Overflow Facilities) is

a public health hazard.

Pollution warning sign downstream on Tanyard Creek from the CSO facility.

Pollution warning sign downstream on Tanyard Creek from the CSO facility.

For the layperson, a CSO Facility does NOT clean up the sewage. That happens at the Chattahoochee River at the RM Clayton Treatment Plant. CSO Facilities throw some chlorine on it and run it through a screen: that’s it! There is a LOT of bad stuff that is then sent into our city’s neighborhoods, parks and streets.

Sewage is in every neighborhood that is near our CSO’s. We have four CSO locations and our neighbors near ALL of them deserve a better quality of life. We are Atlanta, and if we are truly to be a World Class City, we cannot have third-world infrastructure.

Mayor Reed, your predecessor cleaned up the Chattahoochee River. I, and citizens across our City are asking you to clean up our city’s creeks, parks, and neighborhoods.

Your Administration is asking Atlantans to authorize an extension of the one-cent sales tax which will generate another $750 million. My request–and I think it’s the request of all Atlantans–is if you’re going to ask us to continue to fund Water & Sewer projects, then please FIX it… REALLY FIX IT.

(Post 2 At-Large Atlanta City Councilwoman Mary Norwood was a leader in the CLEAN citizen movement of 2000 that led to the building of the Nancy Creek Tunnel. She presently has legislation before City Council to force the administration to come up with short- and long-term fixes for the sewage problems in the Peachtree Creek basin.)

 

Let’s stop repeating the past

By Robert Schreiber, Citizen monitor of Atlanta water/sewer operations

Atlanta’s downstream neighbors on the Chattahoochee are benefiting from its investment to upgrade its sewer system. But many of Atlanta’s own residents do not receive similar benefits.

Robert Schreiber

Robert Schreiber

Undeniable endangerment of public health and property is occurring along a Buckhead segment of Peachtree Creek. Polluted waters are backing-up and contaminating private properties, a public park, and a golf course. Other creeks in Atlanta are also impaired.

Many factors contribute to Peachtree Creek’s problems, some of which are beyond the control of Atlanta’s City Council. But water-sewer rate payers and the Council do have control over some of the factors. Any solution for Peachtree Creek must pass four simple tests before it is worthy of consideration.
• Will lawful permits be obtained?
• Will lawful water quality monitoring occur and be made available to the public?
• Will there be lawful compliance and enforcement?
• Does the solution comply with both of the city’s two consent decrees?

Three examples will help illustrate the importance of the four tests.

Example 1: In the early 2000’s Atlanta proposed constructing the West Area Storage Tunnel (WAST) and a new Combined Sewer Overflow Treatment Plant (CSO-TP). The WAST was designed to terminate on the R.M. Clayton property at the convergence of Peachtree Creek and the Chattahoochee River. And the CSO-TP would be built on the same parcel.

Letters between Atlanta’s Department of Watershed Management (DWM) and Georgia’s Environmental Protection Division (EPD) show that the DWM sought to discharge treated CSO

Aerial photo shows the unpermited discharge outlet at the RM Clayton facility into Peachtree Creek.

Aerial photo shows the unpermited discharge outlet at the RM Clayton facility into Peachtree Creek.

wastewater to Peachtree Creek.

The EPD denied the request, in part, because of concern that during heavy rain, the Chattahoochee River could rise more than Peachtree Creek thereby causing a backwater (reverse flow up the creek). And this backwater condition could occur while the CSO-TP was discharging.

One of the CSO Consent Decree Objectives is, “eliminating all unpermitted discharges from the Combined Sewer System”. But this objective and the denied request from EPD did not stop the DWM. Instead, it constructed a new CSO-TP discharge into Peachtree Creek without a lawful permit.

A year ago, the EPD, Mayor Kasim Reed, Commissioner JoAnn Macrina, City Attorney Cathy Hampton, and many others were notified about the new unpermitted outfall. The EPD’s response indicated that discharging wastewater from the CSO-TP to Peachtree Creek is prohibited and any discharge would be considered unpermitted.

As of today, discharges occur infrequently and they do not count as one of the city’s permissible overflows. There is no mention of these events in the Quarterly Reports which are the official record of the CSO Consent Decree.

Example 2: The 2005 permit for the West Area CSO system identied specific locations where water quality sampling was to occur. However, documents submitted by DWM to EPD in 2012 indicate that sampling data often came from locations other than the ones in the permit.

In the 2015 permit, EPD required that the 2012 documents be updated by November 19, 2015. But only after an inquiry was sent to Mr. Jud Turner, Director of EPD, did it become known that

Aerial photo shows part of the city of Atlanta's R. M. Clayton Water Reclamation Center on Peachtree Creek at the Chattahoochee River in northwest Atlanta.

Aerial photo shows part of the city of Atlanta’s R. M. Clayton Water Reclamation Center on Peachtree Creek at the Chattahoochee River in northwest Atlanta.

Atlanta had not submitted the updates in a timely manner. The new documents have yet to be approved by the EPD and a request for clarification of the sampling information has already been submitted to the EPD.

Example 3: Atlanta operates five sewer tunnels. Wastewater, often combined with stormwater, is sent through deep dropshafts to fill the excavated tunnels. Atlanta never applied for permits which are required before constructing the dropshafts and neither EPD nor EPA required that the permits be obtained.

Now, none of the dropshafts have lawful permits which are required by Georgia and federal regulations. And without the permits, there is no lawful monitoring well program for public review which ensures that public health and aquifers are protected.

Details of Atlanta’s failure to obtain permits for the dropshafts, along with similar events in other municipalities have been submitted to the Commission for Environmental Cooperation (CEC, Canada, the United States, and Mexico). The submission alleges that the EPA has established a nationwide pattern of failing to enforce the regulations which require permits for the dropshafts and monitoring well programs.

Prior to the CEC submission, the EPA always issued erroneous responses to the allegations without having any accountability. EPA’s response to the CEC is due by April 15, 2016.“The submission, “Municipal Wastewater Drop Shafts” can be viewed on the CEC website.“

The three examples are just some of many. There are more which, when considered collectively, contribute to nothing less than a scandalous sewer program which ratepayers are financing.

Protecting public health requires solutions which comply with environmental laws and enforcement programs which ensure compliance. Let’s stop repeating the past.

(From March 2001-December 2004, Robert Schreiber was involved in leadership positions of the public participation process associated with the court-ordered consent decrees through Atlanta’s Neighborhood Planning Unit process and the Atlanta Planning Advisory Board process. He regularly monitors the program. Schreiber is a former chairman of NPU-N, former president of the Atlanta Planning Advisory Board and is an active member of NOCRAP (Newly Organized Citizens Requesting Aquifer Protection). He resides in Buckhead.)

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