Published on February 22nd, 2016 |1
‘Off-Line’ CSO plant in July caused 100M gal. sewer overflows
For several of these CSO events, Watershed Management reported materially significant violations of the permit, including exceeding fecal coliform standards and failure to sample.
This information was included in the city’s Department of Watershed Management 2015 Third Quarterly Report submitted in October to the U.S. Environmental Protection Agency (EPA) and Georgia Environmental Protection Division (EPD). The report is required by the two regulatory agencies.
“A sewage treatment plant being taken out of service is a highly unusual occurrence,” BuckheadView was told by Buckhead resident Justin Wiedeman, CPA, PE, a professional engineer who served on the Nancy Creek Tunnel Technical Advisory Committee.
Wiedeman was an owner for 15 years of Wiedeman & Singleton engineering firm, which was founded in Atlanta in 1906 and worked on many water and sewer systems in the U.S. and internationally. The firm was “consulting engineer” for Atlanta’s drinking water system for more than a half century. Justin Wiedeman worked for the firm for almost 30 years.
“In my 20-years of professional consulting engineering work in this field I’m not aware of another instance except in the case of force majeure (i.e. natural disasters).” Wiedeman told BuckhedView. “I’m not aware of a hurricane, tornado, earthquake or other natural disaster to hit Atlanta in that time frame”, meaning last summer.
“Sewage treatment facilities are designed to operate 24 hours a day given that the demands on the system are continuous,” Wiedeman added. “Sewer systems don’t just shut down and take a
Wiedeman explained that treatment facilities incorporate redundancy and reliability measures, generally dictated by environmental rules and regulations, “such that continuous maintenance and repairs can be made while facilities continue to operate and protect the environment.”
He said the operating permit requires continuous operation. The NPDES Permit (GA0038644) issued by the State of Georgia, which was applicable at the time the combined sewer overflow treatment plant went “off-line”, states (excerpt):
“…the permittee shall operate the CSO WQCF at maximum treatable flow once capacity at the POTW is reached and storage in the collection system is maximized in order to reduce the magnitude, frequency and duration of CSO discharges from the CSO control facilities.”
There is no indication from the correspondence made available on the Watershed Department’s website that an enforcement action was taken by the State Georgia. Further, there is no explanation as to why the facility, which cost an estimated $55 million in 2008 dollars and was completed that year, was not operational for the month of July.
So why was the West Area CSO treatment plant down for the month of July 2015?
Possibly members of the city’s Utilities Committee should ask that question, and others, of DWM Commissioner Jo Ann Macrina and her staff at their meeting Tuesday at 9:30 a.m. in City Council Conference Room 1 at Atlanta City Hall.
The management of DWM have promised to return to the Utilities Committee on Tuesday with short- and long-term plans for dealing with health problems of sewage pollution in Tanyard and Peachtree creeks during and following heavy rainfalls that lead to raw sewage (feces) being deposited in Atlanta Memorial Park and its playground area, as well as sewage spewing from manholes throughout that area of south Buckhead.
Another of BuckheadView’s resources, Robert Schreiber, did point out that DWM’s 2015 Third Quarterly Report to EPD did provide
a possible partial explanation as to why the West CSO Treatment Plant was off-line for the month of July.
(Schreiber, while not a professional engineer, has closely followed the permitting, operations and consent decree violations and activities of DWM for some 15 years and has had constant correspondences with the EPD and EPA over that period of time.)
The suggested reason in the Quarterly Report was that “maintenance was being performed by divers in the pumping shaft of the West Area Storage Tunnel” and that maintenance work may have been authorized by City Council legislation.
An excerpt from page 9 of the 2015 Third Quarterly Report states: “In accordance with the NPDES permit, DWM obtained approval from the Georgia Environment Protection Division for a temporary bypass of the West Area Water Quality Control Facility (WQCF) and to treat combined sewer flows at the Clear Creek, Tanyard Creek and North Avenue CSCFs prior to having the West Area WQCF online.”
The excerpt from page 9 continues: “At the time the discharge event occurred on July 2, 2015, the West Area WQCF was operating under a temporarily bypass, as approved by EDP, and was out-of-service to allow repairs to the West Area Tunnel pumping station. Repairs included removal, rehabilitation and replacement of pump guide rails, facility pumps and dewatering pumps. These repairs were necessary to prevent failure of the operating systems and to restore needed operational capacity.”
Referring to the July 2, 2015 flows of combined sewage upstream from Memorial Park, the Quarterly Report states: “These initial flows of combined sewage did receive partial treatment (screening), but were not disinfected as required by the NPDES Permit, the CSO Consent Decree or the facility-specific Management, Operation and Maintenance (MOM) plans.”
Notifications sent of improper discharges
Prior to the July 2 combined sewage discharges, Schreiber had notified in February 2015 the EPD, EPA, Mayor Kasim Reed, DWM Commissioner Macrina, the city of Atlanta’s Law Department and others that the West Area WQCF was improperly discharging into Peachtree Creek adjacent to the R.M. Clayton facility.
“The discharges from the WQCF were supposed to be directly to the Chattahoochee River according to the 2005 permit” which was still the operational permit at the time, Schreiber told BuckheadView.
“On Aug. 3, 2015, EPD responded to my comment about Atlanta discharging to Peachtree Creek,” Schreiber said. The EPD said, “A CSS (Combined Sewer System) discharge to Peachtree Creek is prohibited and any discharge would be considered unpermitted.”
The new permit issued by EPD to the city on Aug. 19, 2015 still lists the receiving waters for “authorized” discharges from the West Area Combined Sewer System facility (referred to as West Area WQCF) as being the Chattahoochee River, not Peachtree Creek.
That same month (August), the state of Georgia issued a new permit to Atlanta with the same basic language as the former permit, but with modifications that appear to allow “unlimited” discharges from the CSO control facilities. The previous permit discharge limit was four (4) per year.
This turn of events struck both Wiedeman and Schreiber as unusual and strange.
The current permit states: “The permittee shall operate the West Area WQCF at maximum treatable flow once capacity at the POTW is reached and storage in the collection system is maximized in order to reduce the magnitude, frequency, and duration of discharges from the Combined Sewage Control Facilities.”
Change in terminology significant, puzzling
The most significant difference in the new permit is the change in terminology whereby the state reclassified the discharge from the control facility as a “discharge” rather than a “combined sewer overflow”, Wiedeman explained to BuckheadView.
This change in terminology is consistent with the change in terminology/definition made by the city on its own in 2014, before the new permit was issued.
“Curiously, I had clients (cities and counties) that were not able to revise their permits due to non-compliance issues often referred to as permit violations,” Wiedeman added.
“But the city of Atlanta, regardless of repeated material violations of the permit, were rewarded with more lenient terms that are, in my opinion, a violation of the Clean Water Act and the Consent Decree,” handed down by U.S. District Chief Judge Thomas Thrash Jr.
In fact, BuckheadView is aware that when the city was granted its new state permit on Aug. 19, 2015, the city was given 90 days to provide GA EPD with a plan for sampling for discharges and pollutants into the streams and tributaries.
BuckheadView also knows that the city failed to meet that 90-day deadline and only sent the plan to EPD in mid-December. As of this date, BuckheadView has not been able to determine if the city’s sampling plan was accepted by EPD, rejected or modified. As of Feb.18, the sampling plan approval and status of violations or fines, if any, for discharges to Peachtree Creek are still “in process.”
It also is not known if the city was fined by EPD for violating the terms of permit approval by not providing the sampling plan within the 90-day time limit.
“The State’s failure to enforce the combined sewer overflow facilities permit is not good for Atlanta and not good for the state of Georgia,” Wiedeman stated.