Calvin Parker

Cover Letter
Calvin Parker
2027 Cross Trails Rd.
Windsor Mil, MD
21244
200 Holliday St. #600
Baltimore, MD
21202
Baltimore City Department of Public Works

Dear Director Rudolph S. Chow,

My name is Calvin Parker and I am an undergraduate studying Civil/Environmental
Engineering at the University of Maryland College Park. Through my undergraduate research
and coursework, I became aware of the Combined Sewer Overflow epidemic happening across
the nation. I was able to understand how serious of a concern this is, as this polluted water
poses a threat to humanity and its environment. As a student looking to eventually solve
environmental issues in the engineering profession, I was inspired to research the Combined
Sewer Overflow epidemic happening in my hometown of Baltimore, Maryland, and generate
additional resolutions to significantly reduce the occurrences of these events.
After doing my research on the history of the previous and ongoing resolutions of this
project including the original Consent Decree issued in 2002, the Modified Consent Decree
established in 2017, and the Headworks project under the Modified Consent Decree, I was able
to derive a three-part plan that I wanted to recommend to you and the Baltimore Department
of Public Works (DPW) to help you meet your goals. The first part of my plan was to
immediately hire an auditor for the project to be able to clearly track progress and properly
allocate duties and resources to increase the project efficiency and transparency with the
Baltimore taxpaying public. The second part of my plan would be to by the end of 2020 begin
construction of a 5-mile underground tunnel that will run simultaneously with the pipe
replacement project to further reduce CSOs for years to come. The third and last part of my
plan would be to immediately begin implementing more green infrastructure in Baltimore City
to increase infiltration and subsurface retention rates to decrease the high volumes of
stormwater runoff that is perpetuating the CSO issue.
Sincerely,
Calvin Parker

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Calvin Parker

Raw Sewage in Baltimore Waterway

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Sign posted along Baltimore stream warning that water may be unsafe for human contact because of pollution.
(Timothy B. Wheeler)

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Title Page

3 Part Policy Proposal on Reducing

Combined Sewer Overflows (CSOs) in
Baltimore, MD
Calvin Parker

Photo of a sewage outbreak in the Jones Falls, August 2015.

PHOTO CREDIT: CHARMCITY123/FLICKR

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Calvin Parker

Executive Summary
The main arguments that I will make during this proposal will be justifying why I believe

that my 3-part policy proposal will be advantageous for its goal of reducing the combined sewer

overflows in Baltimore city.

The first argument I will make is why the appointment of an auditor to the pipe

replacement project is necessary to keep up with the successes and failures to know if and how

the project is meeting its intended goals. I will talk about how this individual will continuously

track project spendings and correlate them with achievement of goals. I will stress how this

makes sense because we will be able to see exactly how the Baltimore taxpayer’s money is

helping solve the problem and if adjustments need to be made to make this process more

effective.

The second argument I will make is that a coinciding 5-mile underground tunnel needs

to be constructed during the pipe replacement project to be able to eventually further reduce

the volume and frequency of the combined sewer overflows then the amount would have been

with only fixing the misaligned pipe problem on its own. I talk about how even with the pipe

replacement project, there would still be room for improvement for additional CSO reductions

as the Baltimore DPW has actually stated this and expects to do more sewer upgrades and

rehabilitation projects after the first “phase” of the pipe replacement. I talk about how this

method was successfully implemented in Washington D.C. to help deal with the same CSO

problem as evidence that it could work in Baltimore too.

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Calvin Parker

My last argument is why requiring Baltimore city to increase its green infrastructure will

be another great aid in reducing the combined sewer overflows because less stormwater would

be able to get to the combined sewer pipes because this water would be properly managed and

infiltrated. I give examples of green infrastructure such as green roofs and permeable pavement

that could be implemented to massively reduce stormwater runoff thus reducing the potential

of the overflows (especially in wet weather).

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Table of Contents

8……………………Introduction/The Problem: Combined Sewer Overflows

12………………………………………………………. The Solution: 3 Part Plan

12…………………………. Policy 1: The New Auditor

13……………… Policy 2: 5-Mile Underground Tunnel

14……………. Policy 3: More Green Infrastructure

16…………………………………………………………………………. Conclusion

18……………………………………………………………………Annotated Bibliography

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Introduction/The Problem: Combined Sewer Overflows

The problem I will be addressing is that of the combined sewer overflows (CSOs) that

are happening in Baltimore City. These overflows are happening due to the deficiencies of 100-

year-old pipes and piping systemsi. A combined sewer system is one that is designed to collect

stormwater runoff, domestic sewage, and industrial wastewater in the same pipe ii. This mix of

wastewater usually transported to a sewage or wastewater treatment plant, treated, and then

discharged to a water body. However, during times of heavy downpour, this volume of water

can exceed the capacity of the treatment plant and cause this water that contains untreated

human and industrial waste, toxic chemicals, and debris directly into a nearby waterbody (such

as a stream or lake) therefore polluting that volume of surface water. The microbial pathogens,

suspended solids, and floatables that these CSOs convey can lead to beach closures, shellfish

closures, and contamination of drinking water supply when this toxic waste volume comes into

contact with surface wateriii. This problem also contributes to pollution of the Chesapeake Bay

Watershediv. These overflows can cause breaks in the sewer system that cause the raw sewage

to be discharged directly in the community around homes and streets making thus making the

area a serious health hazard. Even in separate storm drain and sewage systems in Baltimore,

the century old pipes yield leaks in which liquid from the systems mix thus mimicking the

sewage overflow problem in the combined sewer system for the stormwater entering the

sewage pipes, and causing untreated sewage water to go into storm drains and be directly

discharged into local water bodies thus continuing to contaminate the surface water (as

stormwater in these separate systems, with the exception of preliminary retention ponds and

other green infrastructure, is not treated).

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A consent decree was issued in 2002 where Baltimore taxpayers would go on to pay

hundreds of millions of dollars to suppress the CSOs by 2016 but the city has failed to meet that

deadline as frequent overflows continue to persist. In the attempt to modernize the piping

system under this decree, the engineers found that another major contributor to the overflows

was that there was a misaligned pipe of the Back-River Sewage Treatment Plant causing a 10-

mile backup of sewage. The current ongoing repair of this error is called, “the headworks

project.” This pipe misalignment is expected to continually cause overflows for the upstream

engineered sanitary sewer overflows structures along the Jones Falls watershed during heavy

rainfall. The original consent decree has been amended 2 years ago and it has more detailed

descriptions of the structural failings of the pipe system. The decree is splitting up the project

into two phases. The first phase is to have the Headworks project completed by 2021. This

initial phase is expected to handle 83% of the sewage overflows. The second phase is expected

to feature additional repairs that bring the CSO reductions down by 99% by the 2030. However,

problems with the consent decree that still persist are its lack of establishment of definitive

milestones linked to improvements in water quality. This is a problem because Baltimore

taxpayers demand transparency to know that their money is being well spent and causing

improvements. They are making efforts to improve this by posting information on the consent

degree program online for the public to see. Fixing the headworks by 2021 is estimated to cost

the city more than $300 million and $2.1 billion to make the remaining repairs by 2030. After

beginning in 2017, the city has completed 29,302 linear feet of pipe, cleaned 425,103 linear feet

of pipe, and installed more than one million linear feet of cured-in place piping, as of December

2018. A recent Quarterly Report filed by the city described the project as “progressing steadily.”

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Two other components of the project in the construction of the Influent Pumping Station

facility and the Grit Removal facilities are also currently underway. However, hundreds of CSOs

are expected in the meantime during wet conditions despite this work.

The Modified Consent Decree (MCD) was amended and officially entered on October 6,

2017. Although this consent decree has made improvements from the previous one in that it is

more comprehensive and addresses the most serious and complex structural failures of the

system, issues still persist. One is that as the city continues to try to meet its deadline of 2030,

the rates of Baltimore taxpayers continue to rise as the updated estimate of the cost of the

headworks project is about $430 million. Since hundreds of more overflows are expected in the

commencement of operation of the Back River treatment plant in 2020 and the end of

construction in 2021, it is urgent that current and future city administrations to administer the

work required under the MCD expeditiously and efficiently to ensure the Baltimore residents

receive the protection from the environment that they are financing and so that timelines are

met.

The headworks project is being done to protect surfaces waters from the volume of

sewage overflowing from the sanitary sewer system being discharged into them such as

streams, the Inner Harbor, and the Chesapeake Bay. One factor in the project is that there will

be a well that collects incoming sewage (through drainage) and a series of very powerful pumps

will be implemented to improve the sewage flow.

At this point, a backup of waste in the 12’ X 12’ pipe leading into the Back River

Wastewater Treatment Plant limits the speed the water and waste can flow into the plant. This

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explains why in the occurrences of large storms with water infiltrating the sewer pipe, miles of

sewage backup can be caused. This up to 10 mile back up of sewage can overflow into the Jones

Falls Watershed and thus the Inner Harbor (as Jones Falls drains to the Harbor). So the

headworks project will implement eight big pumps (each over 1,000 horsepower) to appease

these sewer backups and overflow. Four of these pumps will always be operating to continue to

transfer the great volume of waste coming into the plant. The remaining four pumps will only

be activated during critical times (significant wet weather events). The new screening and grit

removal facilities that are currently under construction will aid the treatment process by

speeding it up while also reducing the odors at the treatment plant.

Another concern is that in addition to Baltimore City, the Back-River Wastewater

Treatment plant also collects and treats wastewater from Baltimore County. So, although the

consent decree is with the city residents, the county residents are also putting stress on the

treatment plant. So, this is another inflow volume that designers and engineers will have to

consider going forward in this project. Moreover, an estimated 1.3 million residents in the 140

square mile area of Baltimore City and Baltimore County are served by this treatment plant. The

plant currently employs 300 people on teams such as supervisory, operations, maintenance,

and laboratory personnel. As the plant becomes more complicated with the addition of these

new pumps, there may be a need for more employees to properly maintain and operate the

treatment plant, especially with inflow volumes continuing to be rapid in the near future before

we can begin to see the reduction of frequency of the combined sewer overflows.

Due to the urgency and exigence Baltimore water quality due to the sewer clogs and

breaks, the Department of Public Works actually performs Water Quality Monitoring and

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publishes the results online. Having access to this information under the MCD improves the

transparency between the city and its residents as they are able to see what kind of impact

their tax dollars are making on the quality of their water whenever they wish. Thus, there is less

vagueness when classifying achievements.

The Solution: 3 Part Plan

So, there needs to be more policy put in place for Baltimore to meet its deadlines to

massively reduce these CSOs. The first policy I want to see put in place are for it to be required

for an auditor to come in and track progress and expenditures for the project. I believe this

individual should be appointed as soon as possible to immediately start evaluating the earned

value of the project to be able to make judgements based on those measurements. By this, I

mean the auditor would be responsible for evaluating the progress of the pipe replacement and

the expenditures on the project. I believe this would be important because with this policy in

place the citizens of Baltimore would be able to see how exactly their dollars are directly

correlating to improvements in the city’s piping system. Also knowing what benefits the money

is bringing can allow us to optimize resources to be able to complete remaining upgrades by

2030. In the first consent decree failure about $900 million was spent to point out where the

problems were and of that, $350 million was spent on closing 60 to 62 structured “relief valves”

to stem persisting overflows. Some would say that this $350 million was being spent

ineffectively. This is way too much hard-earned money being spent to improperly allocate it or

be unsure of the positive effects that it is leading to. In order to meet the deadlines to reduce

these CSOs by 99% by 2030 we will have to be able to practice resourceful spending. So, the

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auditor will be able to track every dollar spent in the project and effectively evaluate

adjustments we should make along the way to complete our goals.

My next policy proposal is for the commencement of the construction about a 5-mile

underground tunnel to run simultaneously with the pipe replacement project. I would want this

project to begin by the end of next year and have it be completed by 2025. This tunnel will be

similar to that of Washington D. C’s Blue Plains Clean Rivers Project v. The implementation of

this structure will help reduce the combined sewer overflows to an additional extent that the

pipe replacement would on its own. In the D.C. project, the depth of the tunnel was more than

100 ft. below the ground. Its function was going to be to captures CSOs during heavy rain

events to Blue Plains Advanced Wastewater Treatment plant. Similarly, we can have the water

from the water from the tunnel we are creating filter to a wastewater treatment plant. Since

we are currently repairing the pipes for the Back-River Treatment plant, we would most likely

have the water for this tunnel filter to another treatment plant so that we wouldn’t have to

worry about the continued excessive stress put on the same wastewater treatment plant. I

propose that we should have this tunnel filter to the Patapsco Wastewater Treatment Plant

until the Back-River plant was at a point where it could handle the additional inflow from the

tunnel (likely when the eight pumps are installed). The D.C. project also including various

technological systems in the tunnel including that of dewatering pump station, an enhanced

clarification facility (ECF), a coarse bar screen, fine screens, and a vortex grit removal system to

treat the stormwater properly. Baltimore could implement all of these similar systems into their

tunnel to achieve the same. The D.C. project has completed its first tunnel in the initial phase of

the project, and it plans to construct another tunnel in its second phase. The project started in

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2018 and is planned to end in 2023 to reduce CSOs by 98%. So, the continued success of this

project will continue to justify how Baltimore should begin a similar system to achieve the same

goal of CSO reduction. Baltimore can use Washington D.C. as a model and mimic their actions

(as Baltimore would have a few years of lag between their current point in the project and

D.C.’s point). Since D.C. projected a time of 5 years, I believe it is reasonable for us to do the

same. Also, having all upgrades complete by 2025 would comply with the regional plan to clean

the Chesapeake Bay which requires all jurisdictions to have strategies put in action by then to

reduce pollution. These actions will allow us both to treat and get a lot more water off the

streets to reduce more CSOs in the process of the city replacing its piping system. This is very

important because in the time Baltimore city will be fixing the piping system, hundreds of more

CSOs are expected during wet weather situations. The CSOs would continue to cause their

negative impacts including reduced water quality (in Baltimore surface water and the

Chesapeake Bay), algae growth and oxygen depletion which both have potential to damage and

kill off of aquatic life (fish and other plants), and bathing beaches can continue to be closed

because of bacterial contamination.

My last policy implementation that I would put in place is the requirement for an

extended amount of green infrastructure in Baltimore city. This would be another aid to the

process of replacing the piping system because the misaligned pipes of the Back-River

treatment plant that is currently under the works would encounter even less water because of

the abilities of the green infrastructure. This is an important route to take because climate

change could cause CSO mitigation investments to shoot up since the frequency and severity of

CSO events is contingent upon climate factors, most noteworthy, precipitation. So, it is

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important that we continue applying as many solutions and replications of the solutions as we

practically can to be able to have a buffer for uncertain and potentially worse climate

conditions. Green infrastructure implementations mimic the natural hydrologic processes to

reduce the quantity of stormwater runoff to combined sewer systems. Stormwater is controlled

by the influence of natural processes such as infiltration and evapotranspiration, and also via

capture and use processes such as rainwater harvesting. With the addition of green

infrastructure methods such as planter/tree boxes, permeable pavement, green roofs,

vegetated swales, and downspout disconnection the city would be able to achieve much more

infiltration (water percolating in the ground) (because of increased pervious surface) thus

reducing the stormwater runoff and further limiting the excess water that will make it to the

sewage system. Larger scale management strategies such as riparian buffers, flood plain

preservation, and wetland and forest preservation can also be utilized at the watershed level.

Although alone, green infrastructure would not be able to entirely control CSOs, it can reduce

the capital-investment, downstream of hard or gray engineering infrastructure such as pipes,

sewers, storage tanks and treatment facilities. This works perfectly in conjunction with my

second part of the proposal and the DPW’s current pipe replacement project because these

would be classified as treatment facilities and storage tanks. So, addition of green infrastructure

in alignment with a repaired treatment plant and an underground storage/treatment tunnel

would be able to lower costs for the plant and tunnel because they would be easier to manage

as they will have to deal with less inflow volume. Therefore, construction of these green

infrastructure systems would run simultaneous to that of the pipe replacement and the

underground tunnel projects control and would commence as soon as possible. Adding green

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infrastructure to aid a wastewater treatment plant and underground tunnel would also be great

long-term solutions to control the CSO problem.

Conclusion

In my policy proposal I presented and justified three specific actions that would have to

be executed in conjunction with the Headworks pipe replacement project of the Baltimore

Department of Public Works. Part of my justification for each was that they would help DPW

meet its goal of almost entirely eliminating CSOs by 2030. The first part of my plan was to

immediately appoint an auditor to track the progress and expenditures of the project. I

suggested this so that the Baltimore rate payers can visualize and understand how the rates

that they are paying to fund the Headworks project is helping reduce the CSOs and protect

them from these environmental hazards that they would cause. It also makes sense so that

DPW can properly allocate resources and make adjustments during the project to make sure

the funds are spent in a way that is achieving the maximum positive impact. The second part of

my plan was to, by the end of next year, begin constructing a 5-mile underground tunnel that

will help store water and filter it to a wastewater treatment plant during wet-weather

conditions. I wanted to model this project after that of Washington D.C.’s Blue Plains wet

weather treatment facility of the D.C Clean Rivers Project. This would be advantageous because

it would be an alternative route that the stormwater runoff and sewage can go during heavy

rainfall events to relieve the Back-River treatment plant while it is undergoing construction by

filtering it to the Patapsco treatment plant. This would reduce the CSOs because less water

would accumulate through the same pipes and treatment plants. The last part of my proposal

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was to implement a greater amount of green infrastructure such as green roofs, vegetated

swales, and permeable pavement to promote increased infiltration rates. This action assists

both the Headworks pipe replacement project and the operation of the underground tunnel

because the increase subsurface seepage that this infrastructure allows decreases the

contribution of stormwater runoff in these combined sewer systems and stormwater and

sewage pipe breaks and eventual mixings that contribute to the combined sewer overflow

issue. I would want to begin this immediately because it would work best with treatment

facility upgrade currently being completed and the underground wet-weather tunnel system

that I proposed to start next year. Please take these ideas and their projected benefits into full

consideration when deciding to implement these policies.

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Annotated Bibliography

Past Time to Fix the Pipes

This article (from the Chesapeake Bay Foundation) was about introducing and explaining
the intricacies of Baltimore’s Combined Sewer Overflow problem. It explained how the century
old pipes were leading to the mixing of stormwater and sewage water to cause these combined
sewer overflows. The article then begins to discuss a major root of the problem in a
misalignment in piping of a wastewater treatment plant which was causing a lot of overflow. A
consent decree agreement program between Baltimore and its citizens, its lack of success, and
its amendments and where it is going in the future was discussed thoroughly in the article. The
article projects the costs it will take to continue to fix the piping system and have the work
done by certain deadlines and the progress that has been made thus far.

Foundation, C. B., & Foundation, C. B. (2018). Baltimore City Sewage Overflow. Retrieved
December 13, 2019, from https://www.cbf.org/about-cbf/locations/maryland/issues/baltimore-
city-sewage-overflow.html

Sanitary Sewer Overflows

This was an article from the Baltimore City Health Department explaining the cause of Sanitary
Sewer Overflows (SSOs) (synonymous with combined sewer overflows) and the
detrimental environmental health effects that come form these events. It speaks about
how breaks in the sewer line can cause leaks that can bleed out into communities and
storm drains. The article goes on to talk about how the Baltimore Department of Public
Works (DPW) and the Baltimore City Health Department warn residents to abstain from
fishing and swimming in surfaces waters that could be contaminated with the raw sewage
from the overflows. It even states how the DPW does stream impact sampling and the
Health Department tells the reader steps he or she should take if he or she comes in
contact with these contaminated waters.

Baltimore City Health Department. (2018). Sanitary Sewer Overflows (SSOs). Retrieved
December 13, 2019, from https://health.baltimorecity.gov/sanitary-sewer-overflows-sso

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What are Combined Sewer Overflows (CSOs)?

This article from the Environmental Protection Agency is an in-depth explanation of combined
sewer overflows. It is very technical and states the specifics and technicalities of the
overflows. It talks about the different sources of wastewater that compiles in combined
sewer systems and the fact that during heavy rainfall, this total volume of water can
exceed the capacity of the wastewater treatment plant that it is designed to filter to and
get treated by. It explains how if this happens, the untreated wastewater, that can
contain toxic materials can be discharged in local water bodies. The article gives statistics
of the commonality of the combined sewer systems in the US and reiterates the cause of
the CSOs as heavy precipitation or heavy snowmelt events.

Foundation, C. B., & Foundation, C. B. (2018). Baltimore City Sewage Overflow. Retrieved
December 13, 2019, from https://www.cbf.org/about-cbf/locations/maryland/issues/baltimore-
city-sewage-overflow.html

Headworks Project

This source from the Baltimore Department of Public Works explains the ins and outs of the
Headworks project which is to upgrade the Back-River Wastewater Treatment Plant. It
talks about how it wants to reduce the volume of sewage overflow by over 80% to protect
various bodies of surface water from being contaminated. It conceptualizes how it will use
a series of powerful pumps to promote improved sewage flow and projects when the
project will be complete. It describes other upgrades to the treatment facility that will help
ease the sewage backup issue. The source goes on to estimate the cost of the entire project
and give a history on the treatment plant, its capacity and capability, and more.

Department of Public Works, B. C. (2018). The Headworks Project. Retrieved December 13,
2019, from https://publicworks.baltimorecity.gov/sewer-consent-decree/headworks-project

DC Water Protects the Anacostia Watershed

This article goes into depth explaining the operation of the Washington D.C. Blue Plains wet
weather tunnel that filters to the Blue Plains Advanced Wastewater Treatment plant. It
starts off my expressing why it is necessary due to the old infrastructure of the Combined
Sewer Systems that contained stormwater runoff and sanitary sewer water that would be

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too much for a treatment facility to handle in an event of heavy rainfall and cause this
untreated water to discharge directly into the Anacostia River. It gives data about how most
of the overflow water volume in CSOs is indeed stormwater and not sanitary sewage. The
article then goes into describing the different technologic systems and intricacies of the
Blue plains treatment plant such as the dewatering pump station, coarse bar screens, and
high-rate clarification as different parts of the water treatment process.

Ball, J. (2018, September 26). DC Water Protects Anacostia Watershed. Retrieved December 13,
2019, from https://www.estormwater.com/combined-sewer-overflow/wet-weather-team

Greening CSO Plans: Planning and Modeling Green Infrastructure for Combined Sewer
Overflow (CSO) Control

This document from the EPA is a guideline on the uses, advantages, benefits, and methods of
applying green infrastructure to reduce CSOs. The document begins by defining the root of
CSOs from combined sewer systems. It tells about how in wet weather situations the
combined sewer system volume can exceed that of the treatment plant and cause the CSOs.
The document talks about the various health hazards when this untreated mix of storm and
sewer water contaminate the surface water. The document than proceeds to explain how
green infrastructure’s operation of mimicking natural conditions allows it to promote
infiltration of stormwater and tells how it can be achieved at both site scale from a system
such as rainwater harvesting and watershed level by something such as a riparian buffer. It
even talks about how the benefits of green infrastructure go beyond just reducing CSOs as
these systems can conserve energy, create green jobs, improve wildlife and habitat
biodiversity, and more.

Protection Agency, E. (2014). Greening CSO Plans: Planning and Modeling Green Infrastructure
for Combined Sewer Overflow (CSO) Control. EPA.

Images

First Image

Broadwater, L. (2018). Baltimore Sun - We are currently unavailable in your region

[Photograph]. Retrieved from https://www.tribpub.com/gdpr/baltimoresun.com/#nt=standard-
embed

Second Image

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Wheeler, T. (2016). Bay Journal - Article: Regulators offer Baltimore another 14 ½ years to fix
chronic sewage problems [Photograph]. Retrieved from
https://www.bayjournal.com/article/regulators_offer_baltimore_another_14_years_to_fix_chroni
c_sewage_problems

Third Image

Foundation, C. B., & Foundation, C. B. (2018). Baltimore City Sewage Overflow. Retrieved
December 13, 2019, from https://www.cbf.org/about-cbf/locations/maryland/issues/baltimore-
city-sewage-overflow.html

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i
(Chesapeake Bay Foundation, 2018)
ii
(EPA, 2019)
iii
(EPA, 2014)
iv
(Baltimore City Health Department, 2018)
v
(James Ball, 2018)