MDE Report
MDE Report
The 2022 Joint Chairmen’s Report (JCR) required the Maryland Department of the Environment
(MDE) to submit a report on the status of the Back River and Patapsco Wastewater Treatment
Plants. The requested report is attached.
Also attached, in response to the JCR, is a comprehensive assessment report completed by the
Maryland Environmental Service based on their findings at the Back River Wastewater Treatment
Plant. Please note that there is not a comparable assessment report for the Patapsco Wastewater
Treatment Plant.
MDE greatly appreciates the two-week extension for submission of these reports.
If you have questions or need additional information, please contact me or have a member of your
staff contact Terri Wilson, MDE, at 410-537-4155 or [email protected].
Sincerely,
Horacio Tablada
Secretary
Attachments
In accordance with Section 16 of the directive issued to MES dated March 27, 2022, we
are pleased to present this comprehensive assessment report of our findings at the Back
River Wastewater Treatment Plant (WWTP). Our employees have been at Back River
since March 28, 2022, diligently working with the City’s staff at improving the
operations of the facility. While there remains much work to be done, we feel that we
have made progress towards solving the many problems we have encountered at the
plant and improving effluent quality. Our report not only addresses the work completed
thus far, it also offers substantive recommendations for future improvements.
We envision this Assessment Report will serve as a blueprint for future operational
improvements at the Back River WWTP. Our goal is improved water quality for Back
River and the citizens of Maryland.
Please feel free to contact me at 410-729-8200 if you have any questions or comments
regarding this report.
Regards,
Executive Summary
On March 27, 2022 the Secretary of the Environment, on behalf of the Maryland Department of
the Environment (MDE) directed (Appendix A) the Maryland Environmental Service (MES) to
oversee and operate the Back River Wastewater Treatment Plant (WWTP) in Baltimore City to
achieve the following objectives:
● Protect public health and the environment by addressing the numerous discharge permit
violations that were leading to poor water quality in Back River.
● Assess staffing levels and the competency of staff at Back River. Furnish trained MES
operations staff to augment the Back River WWTP facility’s staff.
● Evaluate treatment plant processes. Initiate repair or replacement of defective equipment
to achieve compliance with the plant’s National Pollutant Discharge Elimination System
(NPDES) permit (Appendix B).
● Assess the city’s maintenance program.
MES was directed by MDE to undertake a comprehensive evaluation and assessment of the Back
River WWTP’s operation, maintenance, staffing, and equipment. This report is a comprehensive
evaluation of our findings and recommendations for improving operations at the Back River
WWTP.
MES immediately assembled a team of operations specialists, engineers, maintenance,
environmental compliance, and safety staff for this project. MES assigned one supervisor and 11
MES operators to conduct operations tasks at the plant and assist Baltimore City Department of
Public Works (DPW) staff. With our teams in place, MES met with and collected information
from DPW staff to assess the existing situation at the plant.
MES reviewed biosolids management at the Back River WWTP, since solids
processing failures are a significant factor in the inability of the facility to meet its
discharge permit requirements. After conducting an extensive review of the data and
interviewing DPW staff and contractors, MES identified several solids processing bottlenecks
and deficiencies at the plant. These issues are addressed in our report.
Maintenance is another major focus of our efforts. MES maintenance staff diligently
worked with Back River WWTP facility employees to identify and repair many
critical pieces of equipment. While we made progress in this area, there still is much more
equipment repair, replacement, and rehabilitation that needs to be done at the facility.
Additionally, MES currently has two major rehabilitation projects in progress at the
plant – repair of two primary clarifiers and the cleaning of two high-rate anaerobic
digesters that have been out of service for years.
MES has identified other process-related problems at the plant. MES operations specialists and
engineers have recommended improvements to the nutrient reduction treatment processes at
the facility.
As directed by MDE, MES evaluated the facility from an organizational standpoint. We assessed
staffing, training, safety, and certification needs for the facility’s operations staff. These issues
are all noted in this report.
Finally, MES presents a detailed set of recommendations to improve operations at
the Back River WWTP. We divide our recommendations into two sections. The first section
provides recommendations, ranked in order of importance, that would get the facility in
compliance with the State-issued NPDES permits. This includes:
● Improve Centrifuge Operations (Repair all Centrifuges, Optimize Dewatering, and
Procure a Centrifuge Maintenance Contract)
● Install Potable Water Line to Synagro’s Pelletizer, Meet Contractor’s Specifications for
Feed Sludge
● Place More Primary Settling Tanks In-Service, Make Changes to Primary Settling Tank
Operations
● Repair All Pumps in the Hi-Rate Digestion Area - equipment is in dire need of being
repaired or replaced. This needs to happen as quickly as possible.
● Safety - there are some fairly basic items that need to be addressed, which could be
classified as “low hanging fruit” and can happen immediately.
● Denitrification Filters - These are critical for removing nitrogen and allow the facility to
stay in compliance with the nutrient limits of its NPDES permits.
● Sludge Thickening Equipment is badly in need of repair.
● Activated Sludge (AS) Areas are also badly in need of repair. This is critical to the solids
removal process.
● Sand Filters - of the 48 sand filters at the facility, only 12 are currently online. The sand
filters are needed to capture solids and allow the facility to meet its phosphorus
discharge limits.
The second set of recommendations outline additional changes that need to be made in the
immediate, short, and long-term planning horizons, and are necessary to keep the facility in
compliance going forward. These recommendations are based on observations and
data collection that show a system-wide catastrophic failure to operate and
maintain this facility at every level. These include personnel, morale, licensing,
and certification, hiring of competent personnel, firing of incompetent personnel,
accountability and more. After investing a significant amount of state resources getting the
facility back into compliance with its permits, it would be equally as disastrous to allow the
facility to fall back on the same level of disrepair.
Side note: In assembling a team of wastewater professionals to respond to this emergency, we
pulled MES staff away from their current assignments at other locations. MES would like to
thank our clients from across the state for their patience and understanding as we worked to
immediately address these serious environmental and public health issues.
Table of Contents
Facility Design ........................................................................................................ 1
Preliminary Treatment (Headworks) ........................................................................................................... 1
Primary Treatment ....................................................................................................................................... 1
Secondary Treatment.................................................................................................................................... 1
Denitrification Filter Facility ....................................................................................................................... 2
Sand Filtration Facility ................................................................................................................................ 2
Final Treatment ........................................................................................................................................... 2
Solids Treatment Processes ......................................................................................................................... 3
Stabilization ................................................................................................................................................. 3
Dewatering ................................................................................................................................................... 4
Biosolids Management – End Use .............................................................................................................. 4
Operations, Maintenance, and Improvement Activities ..........................................5
Operations Team ......................................................................................................................................... 5
Maintenance Team ...................................................................................................................................... 5
Safety and Environmental Compliance Team ............................................................................................. 5
Critical Factors Required for Successful Treatment Plant Operation ........................................................ 6
Operations Assessment and Findings .................................................................... 6
Solids Management ..................................................................................................................................... 6
Discussion of Solids Processing Failures .................................................................................................... 8
Primary Clarification - Process Evaluation and Impact on Solids Management ...................................... 11
Anaerobic Digestion - Process Evaluation and Impact on Solids Management ....................................... 14
Anaerobic Digestion – Condition Assessment of Equipment.................................................................... 16
Solids Thickening – Condition Assessment ............................................................................................... 16
City Dewatering Operations Process Evaluation and Impact on Solids Management ............................ 20
Septage Receiving Station- Evaluation and Condition Assessment .......................................................... 21
Nutrient Removal ...................................................................................................................................... 22
Unnecessary Work Arounds ...................................................................................................................... 23
Process Laboratory Operations ................................................................................................................. 23
Maintenance Assessment and Findings ................................................................23
Asset Management / Inventory Control .................................................................................................... 23
Workload.................................................................................................................................................... 24
Preventive Maintenance Management ...................................................................................................... 24
Procurement .............................................................................................................................................. 25
Planning ..................................................................................................................................................... 25
Staffing Assessment and Findings........................................................................ 26
Operations Supervision/Accountability/Culture ...................................................................................... 26
Vacancies/Workload .................................................................................................................................. 27
Hiring Practices ......................................................................................................................................... 28
Operator Certification Process .................................................................................................................. 28
Training/Cross Training Ops .................................................................................................................... 28
Succession Planning .................................................................................................................................. 29
Challenges of Working in the Back River WWTP Environment............................................................... 29
Comprehensive List of Process Equipment and Operational Status ..................... 29
Environmental Compliance ................................................................................. 29
Biosolids Management .............................................................................................................................. 30
Overflows and Ponding............................................................................................................................... 31
Laboratory Procedures for In-House Process Sampling ........................................................................... 31
Universal Waste ......................................................................................................................................... 32
Safety ....................................................................................................................32
Improper Lock-out of Energized Equipment ............................................................................................ 33
Inadequate Access to Emergency Response Equipment .......................................................................... 33
Exposure to Biohazards and Bloodborne Pathogens ................................................................................ 33
Areas with Hydrogen Sulfide (H2S) Buildup ............................................................................................. 33
Unstable Working Surface Areas............................................................................................................... 34
Insufficient Lighting .................................................................................................................................. 34
Operating Equipment in Manual Mode .................................................................................................... 34
Cranes and Overhead Hoists ..................................................................................................................... 35
Emergency Response Procedures.............................................................................................................. 35
Confined Space Entry ................................................................................................................................ 35
Lock-Out/Tag-Out ..................................................................................................................................... 36
Respiratory Protection............................................................................................................................... 37
Chemical Handling Procedures ................................................................................................................. 37
General Housekeeping............................................................................................................................... 38
Organizational Management ................................................................................ 38
Communication ......................................................................................................................................... 38
Responsiveness .......................................................................................................................................... 39
Recommendations ............................................................................................... 40
I. Back River WWTP – List of Recommended Improvements to Achieve NPDES Compliance,
Ranked in Order of Importance. ............................................................................................................... 40
II. Recommendations for Short-, Medium-, and Long-term Issues. .................................................... 42
III. Staffing Recommendations ................................................................................................................. 47
Conclusion ........................................................................................................... 49
Appendices .......................................................................................................... 50
Appendix A – MDE Directive .................................................................................................................... 50
Appendix B – NPDES Discharge Permit ................................................................................................... 59
Appendix C - Comprehensive Repair, Replacement, and Priority Lists ................................................... 99
Appendix D - Daily Reports ...................................................................................................................... 114
BACK RIVER WASTEWATER TREATMENT PLANT
ASSESSMENT REPORT
Facility Design
The Back River WWTP occupies a 466-acre site. It is designed to treat 180 million gallons per
day (MGD) of wastewater and serves an estimated 1.3 million residents in a 140 square-mile
area of Baltimore City and Baltimore County. It is the largest WWTP in the state. The plant is
designed so that wastewater receives four levels of treatment: preliminary, primary, secondary,
and tertiary. A process flow diagram of the facility is depicted in Figure 1.
Primary Treatment
Following preliminary treatment, the wastewater is distributed among 11 primary sedimentation
tanks (nine are 170 ft. in diameter and two are 200 ft. in diameter) where large and denser
suspended organic solids settle. These solids (primary sludge) are removed continuously by
rotating scraper mechanisms. While the primary sludge removed from the tanks goes to solids
processing, the clarified effluent proceeds to secondary treatment.
Secondary Treatment
Effluent from the primary treatment process, which still contains some dissolved and fine
suspended solids, flows to the activated sludge process (secondary treatment). At the Back River
WWTP, flow from primary treatment enters three fine-bubble-activated sludge facilities where a
culture of microorganisms is maintained to absorb and metabolize organic pollutants. Air is
continuously added to the aeration basins to meet the oxygen demand of the bacteria and other
organisms that comprise activated sludge. After treatment, the activated sludge is then
separated from the wastewater by sedimentation in secondary clarifiers, similar to those used in
primary treatment.
After sedimentation, a portion of the settled solids are then recycled back to the aeration basins
in a form commonly referred to as return activated sludge. This maintains the required biomass
concentration, while the excess sludge commonly referred to as waste activated sludge is
pumped to additional solids handling processes and removed from the treatment system.
All activated sludge facilities operate as biological nutrient removal facilities. This means that
nutrients (nitrogen and phosphorus) are removed from the waste stream or converted to a less
toxic form. Ammonia (NH3) is converted through nitrification into nitrate (NO3-) where the
bacteria can remove it.
To reduce the phosphorus loading to the Back River, the chemicals ferric chloride and polymer
are added separately to the aeration tanks prior to secondary clarification. As an option, polymer
can also be added to the effluent after secondary clarification. Together, these chemicals cause a
precipitate to form that can be removed by sedimentation or during filtration.
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Denitrification Filter Facility
Secondary effluent then flows to the denitrification filter facility (DNF) for further nitrogen
removal. The DNF facility consists of four “quads” of 13 filters each, for a total of 52 filters. The
filters provide an anoxic environment for the bacteria to remove nitrogen through a process
called denitrification. Methanol is fed to the filters as a carbon source to help the bacteria thrive
and enhance the process. Through the denitrification process, nitrate (NO3) is converted into
nitrogen gas (N2) and is released into the atmosphere, thus removing it from the wastewater
stream.
Final Treatment
The final steps in the treatment process are disinfection using sodium hypochlorite (bleach),
dechlorination by sodium bisulfite, and post-aeration. After filtration, the effluent passes
through four separate three-pass chlorine contact tanks. Each chlorine contact tank provides a
total volume of over three million gallons and provides additional chlorine contact/disinfection
time.
After chlorination, sodium bisulfite solution is added to neutralize the chlorine residual, thus
minimizing the potential effects that chlorine, and compounds that form because of its addition,
could have on aquatic life.
Finally, the effluent spills down a step-dam cascade system where it is re-aerated. This treated
effluent then passes through a 1,200 ft. long outfall pipe where it is discharged into Back River.
Up to 50 MGD of the effluent is diverted to Outfall 002, located at the Tradepoint Atlantic
property, where it had been used for cooling water when the property had an active steel mill.
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Figure 1 – Process Flow Diagram, Back River WWTP
Thickening
At the Back River WWTP, primary sludge is thickened by gravity sludge thickeners while waste-
activated sludge from the secondary clarifiers is thickened by gravity belt thickeners and/or the
dissolved air floatation process. Up to eight gravity sludge thickeners are used to thicken
primary sludge from a dilute liquid content to a thickened sludge concentration.
Similarly, solids from secondary treatment, which are lighter and more readily floatable than
primary solids, are processed through eight gravity belt thickeners and up to four air flotation
thickeners. During the sludge thickening process, waste activated sludge, at a dilute liquid of
0.8%, is thickened to a sludge solids concentration between 3-7% solids.
Stabilization
At the Back River WWTP, thickened sludge stabilization is currently achieved by first being
pumped to an innovative, 2-million-gallon (MG) acid phase reactor vessel, then to two, 3 MG
egg shaped anaerobic digesters and finally six 1.3 MG conventional high-rate anaerobic sludge
digesters.
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Anaerobic digestion (AD) is a microbiological treatment process where anaerobic bacteria
decompose and stabilize the organic matter in the thickened sludge at an elevated temperature
of 95oF. The goal of the AD stabilization process is to reduce pathogens in the incoming sludge
to safe levels prior to reuse as a low-grade fertilizer. Consequently, this sludge stabilization
process reduces the volume of the sludge by metabolizing volatile solid material while producing
combustible gas as a by-product. Most of the biogas generated from the digesters is used to heat
the digesters to its process temperature and produce heat for use in other areas in the WWTP.
Reduction of sludge volume greatly reduces costs for handling of plant sludge. Once digested,
the sludge that is treated to reduce pathogens by digestion is called biosolids.
Dewatering
After digestion, the biosolids are conditioned with polymer and dewatered in the facility’s
centrifuges. These centrifuges use a large solid walled bowl with horizontal axis-rotation.
Centrifugal forces developed by the rotation causes the denser solids to adhere to the bowl wall,
which are then continuously scraped off by a helical screw conveyor.
The solid bowl centrifuges concentrate the digested biosolids from a thick liquid slurry of
approximately 3-5% solids content to a cake of 20-25% total solids content. Centrifugation also
has the added benefit of reducing the tonnage of biosolids, thus reducing trucking and other
handling costs for end use of the biosolids.
Figure 2 – Process Flow Diagram, Back River WWTP Biosolids Management Process Flow Diagram
(Courtesy, HDR Inc., “Baltimore City Comprehensive Biosolids Plan, 1/17”)
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Operations, Maintenance, and Improvement Activities
On March 27, 2022, the Secretary of the Environment, on behalf of MDE, issued a directive to
MES. The directive stated:
“The Secretary hereby directs that [MES] take charge of the Back River WWTP,
including its operations, maintenance and improvement [of] functions in order to work
with Baltimore City to ensure that Baltimore City meets the following objectives:
protecting public and environmental health; abating any further nuisance; providing
appropriate levels of qualified staff; conducting appropriate maintenance,
improvements, and modifications; operating the Back River WWTP in compliance with
all terms of the Back River Discharge Permit; and ceasing all unpermitted discharges
from the Back River WWTP.”
In response to this directive and to quickly resolve the most urgent problems at the Back River
WWTP, MES immediately formed three teams of employees: an Operations Team, a
Maintenance Team and a Safety and Environmental Compliance Team. These teams were
supported by staff from MES’ Finance Group, Procurement Section, and from the Office of the
Attorney General.
Operations Team
MES assembled an Operations Team of seasoned operators, led by an Environmental Systems
supervisor, to begin working with the Back River WWTP operations staff. The team assessed the
current operations staff’s capabilities, staffing levels, and reviewed all plant operations, to
determine how they could immediately improve plant operations. The Operations Team is
focused on operating procedures, supervision, and cross-training of operations staff.
Maintenance Team
The MES Maintenance Team immediately began working with the Back River WWTP
maintenance supervisors to address the current maintenance staffing capabilities and the level
of out-of-service equipment at the facility. The Maintenance Team used MES’ emergency
procurement procedures authorized under state law to immediately begin
repairing essential equipment. The MES Maintenance Team was supplemented with
members of the Back River WWTP maintenance team, in addition to outside contractors
specializing in wastewater equipment repair. The Maintenance Team continues to be focused on
repairing out-of-service equipment, supervision, and preventive maintenance.
With these three specialized teams in place, MES began meeting with and collecting information
from the following groups between March 28 to June 1, 2022, to complete this assessment.
● DPW Leadership
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● The Back River WWTP Facility Manager
● Senior Supervisory Operation Staff at the Back River WWTP
● Senior Supervisory Maintenance Staff at the Back River WWTP
Critical Factors Required for Successful Treatment Plant Operation
After working on the site for more than two months, the MES Team has concluded that basic
areas of need would greatly help in moving toward the facility’s successful operation:
● Accountability - Management must be able to hold staff accountable for issues
and problems that arise because of lack of communication or lack of proper
management and supervision.
● Teamwork - The entire staff, including management and employees, must work
together as a team to keep the facility functioning at a high level, meeting all
regulatory requirements, and maintaining a safe working environment. This is
essential in any work environment. Based on what MES has observed,
there appears to be a significant breakdown in communication
between management and facility staff, and between the facility’s
operations and maintenance staff, and even within the different
shops (mechanics, electricians, instrumentation techs) at this one
facility.
● Leadership - A facility of this size must have effective leadership to set
expectations and communicate a cohesive vision for the plant and staff. The
leadership at the facility should have the ability to coordinate all operations and
maintenance activities as well as asset management and capital programming.
Solids Management
Back River WWTP utilizes AD to stabilize sludge solids. There are nine digesters at the plant.
Thickened sludge solids from the holding tanks are first introduced to a 2 MG anaerobic acid
phase reactor, which is designated as Digester 9. Sludge from the reactor is pumped to two egg-
shaped digesters (digesters 7 and 8). Each digester has a 3 MG volume, for a total of 6 MG of
volume. Digested sludge from the egg-shaped digesters is sent to six, in-ground, conventional
high-rate digesters, which have a 1.3 MG volume capacity each, for a total capacity of 7.8 MG.
The digestion system operates at mesophilic temperatures (95oF). A summary of some of the
design criteria for the digestion and solids dewatering systems is shown in Table 1.
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Table 1 – Solids Processing Design Criteria at the Back River WWTP
Back River WWTP ’s normal, prescribed solids management processing plan is to distribute the
digested, liquid sludge to two outlets. The first option involves pumping sludge to city-operated
centrifuges. The digested, dewatered biosolids from the city-operated centrifuges is then
transported under contract to Veolia’s Baltimore City Composting Facility located on
Quarantine Road. There, the biosolids are further processed to meet the U.S. Environmental
Protection Agency’s (EPA) Class A pathogen treatment and exceptional quality (EQ) standards
using in-vessel composting. Veolia markets the finished compost as a branded product called
Orgro. Veolia’s tonnage acceptance obligation is 2,167 wet tons (WT) per month (or
approximately 500 WT/week). This has been a reliable, successful program in place for over 30
years.
The second management method encompasses pumping sludge to a privatized drying and
pelletizing facility located at the Back River WWTP, but owned and operated under contract to
Synagro. The heat dryer is an indirect, vertical, multiple tray drying system. Pellets generated by
this system are also marketed as a Class A, EQ trademarked biosolids product called Granulite.
The pellets are sold as a slow-release fertilizer in bulk and bagged form. During normal
operations, Synagro produces approximately 1,000 dry tons (DT) of pelletized product per
month. This is an important part of the facility’s solids processing since it represents about 70%
of the solids load.
It is important to note that Synagro’s pelletizing facility requires the use of plant non-potable
(NPW) flushing water to satisfy the demands of its fire suppression system. For reasons
described below, this became an important issue starting in 2021.
In this report, MES describes our efforts to perform a root cause failure analysis to ascertain the
events that led up to the solids processing failures at the facility. It is widely accepted that the
inability to process solids was a significant factor in the inability of the facility to meet its
discharge permit requirements.
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MES has determined that there are at least three main issues that are currently contributing to
the solids processing failures at the Back River WWTP. These are:
● In May 2021, the quality of the NPW supplied to Synagro’s fire suppression system showed
an increase in total suspended solids (TSS) content. According to Synagro, the TSS of the
supplied NPW exceeded its specifications for their system, clogging their equipment. The
amount of sludge solids accepted by Synagro’s dryers began to steadily decrease eventually
falling to 0 DT (i.e., not in operation) starting the month of November 2021 through March
2022 (see Figure 3). This had a significant adverse effect on the ability of the facility to meet
its discharge permit.
● The loss of 70% of Back River WWTP’s solids processing load, due to the lack of
Synagro’s capacity, contributed to a buildup of solids in the primary settling tanks
(PSTs). The PSTs filled with solids (see Figure 4), which resulted in nine of the 11
clarifiers being taken offline. When MES initiated its involvement at the plant on March
28, 2022, the plant had put another online, but only three of the 11 primary clarifiers at
the plant were in use (PSTs numbers 8, 9, and 11). The other PSTs were either filled with
solids, had mechanical problems, or both. Most recently, PST 9 experienced a failure of
its skimmer arm falling off. As of May 10, 2022, only two PSTs were in operation. The
status of the PSTs is given in Table 2 below.
● The centrifuge dewatering equipment has not functioned properly. At some point in
2020 the facility started experiencing diminished dewatering performance. This was
most likely due to centrifuge equipment problems and operator process control issues.
Plant data shows the centrifuge solids capture rate, which was previously acceptable at
greater than 90% (September 2021), now averages approximately 47% (October 2021 to
date). At one point, the average centrate solids concentration was 30,312 mg/L TSS in
September 2021. (This is, at minimum, an order of magnitude higher than it should be.
An elevated centrate TSS means that the centrifuges are not being operated efficiently.
The centrate is rerouted back to the head of the plant and exerts a solids load that must
be treated all over again.) In March and April 2021, the centrifuges were out of service
and operated for only a total of 8 days (out of 61 days). A summary of select centrifuge
data is depicted in Table 3 below.
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Figure 3 - Back River WWTP - Synagro Pelletizer Tonnages Accepted
(Data from Back River, DPW Records)
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Table 2 – DPW Centrifuge Performance -January 2020 Through March 2022
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Primary Clarification - Process Evaluation and Impact on Solids
Management
A summary of the status of the PSTs is given in Table 3. This discussion details the impacts of
the current operational practices on solids management at the plant.
Select data for tank performance from January 2020 through March 2022 is noted in Table 4.
MES’ conclusion based on empirical evidence is that the current operating protocols for the
tanks do not follow established practices. There are very little to no sludge blankets in the online
tanks, which results in two problems. First, the primary sludge total solids are very low, ranging
from 0.07% to 0.80% total solids. Typical contents should be in the range of 2.5% to 5%.
Primary sludge with a low percentage of total solids will result in difficulty thickening sludge.
Low percentage solids content requires more volume to be pumped to remove the same amount
of solids load as a sludge with higher solids content. This also affects digestion, since poorly
thickened sludges results in greater volumes fed to the digesters, and hence lowered hydraulic
retention times.
Also examining the data in Table 4 shows that the PST TSS effluent concentrations are elevated,
in the range of 144 to 474 mg/L. These values approach those for raw sewage (WWTP) influent.
This suggests poor solids capture for the PSTs, which leads to excessive solids introduced into
the downstream activated sludge basins, resulting in high mixed liquors (Mixed Liquor
Suspended Solids (MLSS) concentrations.
Remedies to these problems will be addressed in the recommendations section of this report.
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Table 3 - Back River WWTP Current Operational Status of primary settling tanks as of May 10, 2022
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Table 4 - Summary of Select PST Data, January 2020 Through March 2022
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Anaerobic Digestion - Process Evaluation and Impact on Solids
Management
The Back River WWTP uses AD to treat a blend of thickened solids generated from the primary
clarifiers and secondary (activated) unit operations. This section will evaluate the plant’s process
data to determine if the nine digesters at the plant are performing satisfactorily.
A summary of select AD performance data obtained from DPW staff for the period of January
2020 through March 2022 is presented in Table 5. City staff analyzes process data for volatile
fatty acids (VFA), alkalinity, pH, total and volatile solids, and digester temperature for all units.
Data in Table 4 is shown as a combined tabulation for all digesters (1–8) except for the acid
phase reactor (Digester 9).
A properly operating AD system should maintain a VFA/alkalinity ratio not greater than 0.10.
Inspection of the data in Table 5 shows this consistently to be the case. In addition, to meet the
federal and state regulations for vector attraction reduction (VAR), the volatile solids (VS)
reduction should be greater than 38% for land application (note: VS reduction was calculated
using the Van Kleek formula, which is standard practice for AD systems). Except for the period
from June through December 2021, this condition was met. Since digested material was further
treated by the two contracted Class A processing options (heat drying and composting), this
period is not concerning. However, any material generated during the period of June through
December 2021, should not have been allowed to be land applied because they did not meet the
requirements for Class B biosolids.
Note that MES included the average percentage VS data of the digested biosolids generated by
the plant. Synagro’s drying/pelletizing operation contractually requires a digested biosolids VS
content of less than 60% (Personal Communication, Joe Hurt, Synagro, May 2022). While the
facility comes close to meeting this condition, we recommend that some adjustments to
operating protocols be made to achieve the 60% condition.
Finally, MES did a cursory evaluation of the data to assess additional performance metrics,
including gas production per lb. VS destroyed (ft3 biogas/lb. VS destroyed). A properly operating
AD system should produce between 13 and 18 ft3/lb. VS destroyed. The actual average value for
the period of January 2020 through March 2022, was 57.6 ft3 biogas/lb. VS destroyed, which
seems unlikely. Some investigation into why this value was achieved, and the measurements
taken including inspection or repair of the gas meters at the plant, need to be further examined.
Time constraints did not allow us to evaluate organic loading (lb. VS/ft3 digester volume /day).
MES suggests that this parameter should be routinely monitored by staff to ensure that design
organic loadings are not being exceeded.
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Table 5 – AD System Performance January 2020 Through March 2022 (Data furnished by DPW staff)
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MES notes that like many of the other solids processing tanks at this facility, all digesters suffer
from excessive debris accumulation. This negatively influences AD performance. For example,
accumulated debris (rags, grit, screenings, etc.) effectively reduces the active volume of the
digesters available for microbiologically treating solids. This debris also clogs pumps and affects
other critical process equipment. The temperature of the acid phase reactor is routinely 74oF, far
below the required mesophilic temperature of 95oF. This is likely because debris has partially
clogged the steam feed line into the acid phase reactor that heats that digester.
Another example of the consequences of accumulated debris is the fact that the inlet feed lines
to high-rate digesters 1 and 4 are clogged. Due to this clogging these two digestion units have not
been fed sludge solids in what looks like a period of several years; accordingly, this lack of
maintenance has rendered them inactive.
MES currently has initiated a project to clean high-rate digesters 1 and 4. Also, the facility has a
CIP (contract SC 992), which includes the cleaning, inspection, and repair of all digesters within
the next four years.
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Table 6 - Status of Select AD Equipment
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Table 6 - Status of Select AD Equipment (continued)
One set of equipment problems that has not been addressed by the facility personnel has been
the Huber, “Sludge Cleaner” Strain Presses. These presses screen course material such as rags
and other screenings from the sludge prior to sending it to other processes. Back River WWTP
operations staff anecdotally reported to MES that these units have not worked in at least six
years. Given the excessive amounts of debris that are in all the process tanks at
Back River WWTP, particularly in the digestion system, replacing this screening
equipment needs to be given a high priority. These are slated to be replaced in an
upcoming capital improvement plan (CIP) project (City contract SC 992). MES recommends
that these be replaced sooner to alleviate the screenings problems in the facility.
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Table 7 - Status of Sludge Thickening and Screening Systems
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Figure 5– Vegetation Growing in GST-6 Tank
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outs, such as restaurants and food service establishments, a convenient place to take their
material. This helps to keep grease out of the collection system, as well as lower the businesses’
costs.
Nutrient Removal
When MES first arrived onsite, many of the tanks contained excessive levels of
vegetation, which have since been removed. Due to the high solids inventory, the
denitrification filters were overloaded and not functioning as designed. Operators were not
operating the denitrification facility very efficiently and an outside contractor was
brought in, in place of facility staff, to operate the denitrification facility.
Without properly functioning process equipment, optimal nutrient removal cannot be achieved.
An initial review of the activated sludge process resulted in the discovery of an excessive amount
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of sludge throughout the process as well as numerous return-activated sludge pumps and
process mixers in a state of disrepair. Nearly half of the pumps are offline or leaking
sludge and over 30 process mixers are offline. There are issues with the blowers, valves
that will not function, and lines that are plugged. Due to the high solids inventory, various
clarifier skimmer/rake mechanisms are in a state of high torque alarm and overworking the
motors and gear boxes, which are resulting in premature failures of the equipment.
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Workload
There are a considerable number of failing (in-service) and damaged (out-of-
service) assets that require immediate attention at the Back River WWTP. The
state of disrepair is the result of years of neglect that will take time and dedication
to correct. The facility’s maintenance staff does not appear to have the resources to repair all
the affected pieces of equipment and will require:
● Hiring additional staff to fill vacancies
● Employee training and development
● Development and implementation of a preventive maintenance strategy
● Implementation and administration of asset management, inventory control,
and work order programs
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for completed tasks are not readily available. The competency and productivity of maintenance
personnel is not monitored. Safety issues are not properly documented and reported. Every key
piece of information a maintenance team needs to run an efficient, productive, and safe
operation is not being captured, analyzed, or improved.
In short, the Back River WWTP maintenance operation is disorganized,
unfocused, and appears to lack any sense of urgency or accountability.
Procurement
Baltimore City follows a process that guides all procurement. The emergency procurement
process provides some relief from the full process, as it does not require the procurement to
move through the Board of Estimates prior to execution. This provides for a shorter purchase
timeframe. The Water & Wastewater Bureau Head informed MES and MDE on May 16, 2022,
that DPW is working toward developing an abbreviated process to aid in getting the facility into
compliance. Expedited procurement certainly would aid in the compliant operation of the
facility.
Even with that relief, procurement is likely to remain a major issue at the plant. In response to
getting equipment back online, the team often hears the Maintenance Supervisor say, “it is on
order” or “we are awaiting delivery.” We are all aware that the pandemic has created supply
chain issues and delays in getting equipment/parts.
MES wanted to take a deeper dive into where these orders are in the process to see if there are
apparent bottlenecks. MES have made multiple requests of the Bureau Head and Special
Projects Lead to provide a listing of all backlogged orders by: Item Name, Date of Quote, Date of
Request, Date Approved, Date Ordered, Quantity, Cost, Expected Delivery Date, and if
processed as an Emergency. As of the date of this report, MES has not received that
information. Analyzing this data can certainly help pinpoint bottle necks to determine viable
solutions in getting parts needed to get critical processes back online. The fix might be simply
adding an expeditor in procurement to track these orders or looking for alternate suppliers to
get the equipment needed.
Planning
MES participated with DPW and Greely and Hanson, an engineering consulting firm, to review
the capital projects and prioritize them using compliance as a primary determinant. The
priorities were to remove the solids and fix the processing capacities by removing sludge from
the facility. MES requested the final document from Greely and Hanson, but we
were informed that it could not be provided until it was “reviewed by the city.”
Getting a handle on asset management should enable DPW leadership to properly plan out the
course of the facility for the future.
One of the most impactful issues with regards to planning, as presented earlier, is the lack of
reliable and user-friendly asset management. The effort is underway to catalog all the assets at
the facility as a precursor to bringing Cityworks Maintenance Management and Permitting
software online at the facility. As that process moves forward, the Chief of Asset
Management is working to see what he can salvage from the current, non-
functioning, work order system and incorporate it into a preconfigured Cityworks
package as a short-term measure. Upon completion of the asset inventory, that inventory
and the data gathered in the preconfigured system is expected to be migrated to the final
Cityworks package developed for Back River.
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The lack of an asset management system at this facility makes any short-term maintenance
scheduling and budgeting difficult. This also creates difficulties for the long-term planners in
justifying replacement without the asset’s history. The installation of Cityworks is underway and
is expected to provide a great tool for planning at the facility. The phased-in approach by the
Chief of Asset Management will provide some immediate relief to short term planning efforts
and start to gather much needed information for long-term planning as well.
Operations Supervision/Accountability/Culture
Multiple factors have negatively affected staffing at Back River WWTP, which has undoubtedly
contributed to the facility’s dilapidated conditions. MES has witnessed and documented
many unprofessional acts and we present a few in this section. Given the high vacancy
rate, high turnover rate, and poor ability to attract mid-level managers, there appears to have
been a high loss of institutional knowledge. This has led to a lack of management control. Most
managers at the facility have only been in their current positions a few years due to turnover.
MES has observed several operators exert only minimal effort in accomplishing tasks, and most
tasks are poorly executed. On multiple occasions, MES staff have observed staff sitting
at desks on their cell phones or sleeping in their cars. Staff have been relocated to assist
with shortages in other areas, but because they have not been cross-trained, this usually results
in a “free day” for them, as they are not familiar with the work to be done and tend to do almost
nothing for their entire shift.
The maintenance team at Back River is divided into four sections (shops): electrical, mechanical,
instrumentation, and building and grounds. The overall level of supervision that
currently exists within the maintenance division at the Back River WWTP is also
questionable. There appears to be a lack of accountability, organization, planning,
communication, and teamwork, like that seen with the operations team. Employees
receive little to no training toward improving their knowledge base and skill sets.
Malfunctioning equipment and system failures that require attention are continually deferred or
passed between sections and are rarely corrected. Interdepartmental relations have
moved beyond a general lack of team cohesion and into an open unwillingness to
cooperate, including animosity that currently exists between the maintenance and
operation groups.
Negative behaviors ranging from sleeping on the job to verbal/physical
altercations between employees have been observed on both the supervisory and
subordinate level. MES has witnessed city staff washing personal vehicles during
the workday and they have admitted to receiving payment or free lunch for
services provided, see Figure 7.
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Figure 7: Car wash photo
Of greatest concern, however, is the lack of attention toward site and employee
safety. A significant number of deficiencies were observed in this regard, such as improper
lockout-tagout, failing electrical and mechanical assets left in service, poor housekeeping, and
no documentation which creates a hazardous work environment. Overall, the current
maintenance operation at the Back River WWTP is inadequate, ineffective, and
dangerous.
MES has initiated housekeeping tasks such as picking up trash outside, removing unused gear
from walkways, and throwing away unserviceable or out of date supplies/equipment, because
these simple tasks were not being performed by maintenance staff. Facility staff sometimes
question the need for this work, and this attitude affects the morale of the more dedicated
operators. Discussions with managers about discipline of poorly performing staff have resulted
in conversations about the disciplinary process taking too long, employees filing grievances that
result in no action being taken, and employees subsequently being reassigned, which further
exasperates the staffing issues. Visible animosity between area managers and
supervisors has been witnessed and the lack of teamwork and communication
between the various area supervisors has resulted in process upsets and
disruption to planned activities.
Vacancies/Workload
There are approximately 50 vacancies (roughly half) in operations at Back River WWTP, as well
as staff who are out on leave for various reasons. The remaining staff has been stretched so thin
that full coverage is nearly impossible, and staff are frequently required to work multiple shifts.
This creates quality of life issues, resulting in low morale and unproductive performance from
operators that would otherwise be productive employees. The working conditions, negative
attitudes, low morale, and lack of incentive for success are the key contributors to
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staff leaving Back River WWTP. Experienced operators do not enjoy working at a facility
that is not being maintained properly. The vacancies must be addressed as a properly staffed
facility will go a long way to addressing many of these issues.
In addition to the operations vacancies, there are approximately 44 vacancies throughout the
different maintenance shops ranging from entry level to Supervisor. All shops are understaffed
and operating at the following capacities, based on an organizational chart provided to MES:
● Mechanical – 50% capacity
● Electrical – 75% capacity
● Instrumentation – 58% capacity
● Buildings & Grounds – 69% capacity
Hiring Practices
There appears to be a “no interview” hiring process at the facility, which does not
lend itself to a productive process for hiring qualified staff. MES has observed
minimal communications with the hiring managers, and new employees have been sent to work
without ever stepping foot into the facility and not fully understanding the full scope of their job
responsibilities. In some cases, new hires have their employment rescinded due to
driving restrictions that were not flagged by the hiring staff. A training program for
new managers needs to be established so hiring staff understand the role and responsibilities for
the positions they are filling. New managers are hired into positions with little to no
mentoring or guidance.
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from the headworks to the disinfection areas. Baltimore City does not offer any incentives to
successfully complete the apprentice program and become fully certified operators, and there
are no repercussions when apprentices fail.
Back River WWTP maintenance staff also do not receive sufficient training to
perform their work tasks accurately and efficiently, which has had a negative effect
on productivity. Supervisors fail to provide the necessary support in developing their
employees’ job skills. There does not appear to be any semblance of a uniform set of expectations
established for the maintenance team collectively or within the individual shops. New personnel,
it seems, are trained by co-workers. This has led to inconsistencies regarding their knowledge
base and the adoption of improper work habits. This issue will continue to perpetuate unless
addressed.
Succession Planning
Development of staff to fill critical positions is needed at the Back River WWTP. However, a
progression program does not exist and must be developed. Staff must understand the
importance of their jobs, the importance of wastewater treatment on the environment and the
community and have a strong professional work ethic and strong leadership traits. There also
needs to be a training program for new managers to help them understand the role and
responsibilities for the position they are filling. New managers are hired into positions with little
to no mentoring or guidance. Strong leadership will result in a positive working environment,
improving plant operations and morale.
Challenges of Working in the Back River WWTP Environment
The Back River WWTP management team seems to have trouble disciplining
employees when necessary; the thought of firing someone appears nonexistent.
Due to this, productivity suffers. When teaming with the city’s maintenance staff, MES learned
the apprentices were not permitted to complete tasks assigned by MES; a rigid system ensures
that apprentices only receive direction from a third level supervisor, even though some of the
apprentices appeared eager to learn and help MES staff.
Environmental Compliance
The Back River WWTP effluent has been in non-compliance status for failure to
consistently meet permit limits for TSS, total phosphorus and total nitrogen.
Biochemical oxygen demand violations have also occurred periodically. Bringing the facility
back into consistent permit compliance will require primary and secondary clarifiers functioning
and operating properly.
MES does not receive and is not included on laboratory results or reports to compare with
process results, in-house laboratory effluent test results, and laboratory results reported on the
facility monthly operating reports and daily monitoring reports reported to MDE. DPW only has
insufficient staff (three to four staff total, based on our observations) who are responsible for
directing operations such as when and how to make process changes during the day-to-day
operations of the facility. It is unclear who directs DPW operations to make treatment
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process adjustments and changes when needed, and if there is any verification that
operations staff make those process changes. All operations staff could benefit from
frequently meeting with laboratory and reporting staff to review laboratory and monitoring
results, plant performance deficiencies, and goals for achieving permit compliance.
Biosolids Management
Compliance with Maryland and federal (EPA) biosolids management regulations is essentially
comprised of three separate standards:
1. Heavy metals concentration limits
2. Pathogen treatment
3. VAR performance
Of those three, only heavy metals concentrations are typically within the city’s control. The other
two parameters are met by the two contractors that convert the city’s biosolids into a Class A
product. The city only has to be concerned with the pathogen treatment and VAR standards
when they generate a Class B cake for land application. The city land applied in 2021, and
continues to do so today as they work towards reducing their solids inventory in the plant.
The city takes samples of dewatered, digested biosolids from their centrifuges on a weekly basis
and submits them to their contract lab for analysis. This far exceeds the prescribed frequency in
the regulations to sample monthly (for a facility the size of Back River WWTP). Data provided by
DPW staff is noted in Table 9 below. Annual average heavy metals concentrations for the nine
EPA parameters noted in the regulations, including Polychlorinated Biphenyls (PCBs) were
calculated based on the furnished data. Those annual averages were compared to the regulatory
limits for an EQ biosolids (there is no EPA EQ limit for PCBs, as this is a standard imposed in
MDE’s regulations).
As can be seen from the table above, Back River WWTP easily meets the heavy metals limits for
Class A, EQ biosolids as set in federal regulations (40 CFR 503.14, Table 3). Furthermore, to
satisfy our review during the period of January 2020 through March 2022, MES looked at each
analytical result to ensure that none of the metals concentrations exceeded the monthly limits
set in the regulations. No monthly exceedances were noted. This outcome is typical of most
municipal WWTPs in the country.
It should be noted that the facility samples many more metal parameters than just those required
by the regulations. This is a good practice and should be continued.
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The facilities EPA classified biosolid preparers, Veolia and Synagro, use Class A pathogen and
vector reduction treatment methods prescribed in the Federal regulations. Veolia uses in-vessel
composting technology to achieve Class A standards. Synagro utilizes heat drying to meet the
regulations. MES did not review those contractors’ data, but we assumed based on their past
performance and lack of known enforcement actions by MDE that they both treat the dewatered
cake to Class A standards. These two technologies (in-vessel composting and heat drying) are
well established and should be easily met by both companies.
During 2021 and 2022 (to-date) some of the facilities material was land applied as a Class B cake
by Synagro to sites in Maryland and Virginia. In this case, the facility has the responsibility to
meet the Class B pathogen and VAR/VSR treatment standards for their anaerobically digested
biosolids. This requires the facility to meet two standards:
● The standard to meet a process to significantly reduce pathogens, or the Class B
requirement as stated in federal regulations (40 CFR 503, Appendix A, Section A.3) for
AD, which requires a mean cell residence time (MCRT) of greater than 15 days at 95oF
(mesophilic digestion).
● Vector attraction reduction (VAR/VSR) method noted in federal regulation (40 CFR
503.33(b)(1)) to reduce VS content by a minimum of 38%.
As noted previously in this report in “Table 5 – AD System Performance January 2020 Through
March 2022,” the MCRT easily exceeds the minimum 15-day requirement. Inspection of data
from that same table showed that the monthly average VS reduction exceeded the
regulatory requirement (38%) except for the period of June through December
2021. The average monthly VS reduction achieved during that period was less than the 38%
VSR requirement, with a value of 32.31% (range = 29.13% to 34.70% VSR). The cause for this
exceedance is not known, but could be related to the excessive solids inventory accumulated at
the facility.
Verification that temperature requirements during sample storage retention is not occurring,
particularly when refrigerating composite samples. DPW Operators were not consistently
reflecting sample collection times to demonstrate that permit requirements were met for
composite samples.
Universal Waste
MES found non-compliance with Maryland Universal Waste handling, storage,
and disposal requirements throughout the facility.
Safety
MES recommends that employees should not be permitted to work alone in any of
the treatment and building areas of the facility. MES Maintenance has implemented a
standard requirement that all employees always work in teams of at least two due to the
unknown status of equipment (operable or inoperable), the potential for walking surfaces to give
way, the threat of overhead danger in several buildings that could collapse and injure
employees, and the potential for employees to be injured by encountering biohazards and
bloodborne pathogens.
A Maryland Occupational Safety and Health (MOSH) Investigation commenced September 9,
2020, due to an anonymous employee complaint about arc flash and equipment. The
investigation closed February 11, 2021, and citations were issued by MOSH on
March 4, 2021. As of the date of this MES report, these citation items have not been
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abated. DPW did not provide MES with information regarding items that were corrected since
the onsite inspection date or items that remain out of compliance with regulatory requirements.
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Figure 9 – Sludge Storage Tank 26 with Overgrown Vegetation and Inadequate Lighting
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to determine whether respiratory protection was required for employees entering the contact
chamber.
In Figure 10 below, the confined space is labeled a non-permitted confined space and labeled
with “Caution: Large Vertical Drop.” A fall hazard present when entering dictates a space is
permitted since a hazard to the employee is present during the entry.
Lock-Out/Tag-Out
MES requested, but has not yet received, a written lock-out/tag-out program for
the control of hazardous energy when working on equipment at the facility.
Procedures for locking out equipment must be written for each piece of equipment that has
energy connected and employees are responsible for working on. Authorized employees need to
be identified and need training on lock-out procedures for all equipment.
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Figure 11 – Drained and cleaned chlorine contact chamber. DPW employees completed entry, unclear if
permitted confined space entry procedures were followed.
Respiratory Protection
MES requested, but as of the date of this report has not received, the respiratory
protection program for the facility. The March 4, 2021, MOSH citations included lack of a
written respiratory protection program for the facility and failure to fit test employees prior to
requiring they wear respiratory protection, specifically for welding operations. A third citation
was for failure to provide Appendix D information to employees that voluntarily wear
respiratory protection. Without fit testing clearance, including medical clearance, there is a high
potential that employees who are not physically able to wear respiratory protection may be
directed to wear it and a high likelihood that employees are not properly fitted with the correct
respiratory protection to prevent exposure to hazardous atmospheric conditions.
● the lack of eye protection provided to employees when working with hazardous
chemicals;
● eye wash stations were not located in work areas where employees work with
hazardous chemicals;
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● chemical containers were unlabeled throughout the facility;
● Safety Data Sheets (SDS) were not available to employees;
● employees were not trained prior to working with hazardous chemicals; and
● the facility does not maintain a hazardous chemical list.
MES Operations working at the facility have not been briefed on how to respond in
the event of a major chemical release at the facility. Some of the chemicals used at the
facility include:
● Ferric Chloride
● Methanol
● Phosphoric Acid
● Chlorine
● Hydrochloric Acid
● Nitric Acid
● Sodium Hydroxide
General Housekeeping
Overall, all areas of the facility are generally unmaintained and unkept. Debris,
tools, supplies and trash are often left piled throughout buildings, in walkways, and near
equipment. Broken equipment is located throughout every area and the outdoor treatment
sections of the plant. Leaks from equipment, particularly sludge leaks, have pooled and
accumulated in many buildings, in multiple treatment sections of the facility. Slips, trips, and
fall hazards are prevalent and pose a risk of employees contacting biohazards or experiencing a
serious injury when working in most locations of the plant. The disrepair and unkept state of
most of the buildings and grounds creates an atmosphere that is undesirable to work in and
deters employees from accessing most of these areas.
Doors are broken to many buildings, rendering it impossible to lock many of the buildings
throughout the facility campus. This has led to wildlife, birds, and insect populations taking up
residency, and to rainwater accumulation occurring during and after rain events. Rainwater
accumulation has short circuited electrical units, clogged floor drains and led to pooling of water
inside building areas where standing water is unintended.
MES recommends implementing routine housekeeping into the daily job duties of
all operators and maintenance staff working at the facility. In addition, routine
industrial janitorial services would greatly improve the condition of the facility and help foster
site conditions that operations and maintenance would then be responsible for maintaining by
cleaning up after working on equipment, post spills and leaks, and after themselves.
Organizational Management
Communication
Communication at the Back River WWTP needs improvement. Process upsets and productivity
interruptions are commonplace due to communication shortfalls. Communication between the
various sections must be improved to ensure successful uninterrupted operations throughout
the plant. Changes to any part of the process have an impact on the rest of the plant and if an
area supervisor is not aware of changes being made in another area, process upsets and
interruptions can occur. To promote efficiency and to increase morale, managers should inform
their team of happenings around the plant and explain why things need to be done. This is
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accomplished by opening the lines of communication and ensuring that information is being
distributed among staff.
Responsiveness
In a government organization, set guidelines are normally the rule and are seldom deviated
from, unless there is a catastrophic event such as flooding or a major snowstorm. The
violations occurring at the Back River WWTP have evolved into a situation where
this is now equivalent to an extreme event, and these issues need to be addressed
on an emergency basis. The impacts on the environment are harmful to our public waters
and certainly elevate responsiveness to a level that demands immediate attention and actions to
remedy.
Based on what MES has seen in the roughly two months at this facility, the gravity
of this issue does not seem to resonate with DPW staff as their response to the
MDE order seems to have been met with a “business as usual” approach. When
“business as usual” includes all the issues mentioned throughout this report, that is simply not
acceptable. The tone was set at the first weekly meeting, April 1, 2022, during a discussion
relating to bringing potable water to the plant for the headworks and to the pelletizer. The
Synagro line was most important as it would provide potable water that would eliminate
interruptions to the solids removal process. As this discussion intensified, the DPW Director
defended the city’s position on moving forward with the water lines saying, “it has only been
7days” (since the order was issued.) The MDE representative at the meeting reminded DPW that
it had actually been 7 months of non-compliance. At the May 16,2022 meeting, the water line to
both the headworks and Synagro was a topic of discussion. The City Engineer reported that the
headworks line had been tapped and brought across Eastern Avenue, and there was another
2,000 feet of pipe to be placed inside the plant fence. When asked about the Synagro line, MES
was told DPW would get something started soon.
In subsequent discussion at the May 16, 2022, meeting, the Bureau Head of Water and
Wastewater discussed the differences between regular procurement versus emergency
procurement. The main difference is that emergency procurements do not have to go through
the Board of Estimates. The Bureau Head informed the meeting attendees that DPW was
working on an abbreviated procurement method to shorten the timeframe for the Back River
WWTP procurement needs. After seven weeks, they are still looking at how to
streamline this process. In our judgment, this indicates there may be a lack of
understanding regarding the urgency of the issues at Back River WWTP.
The lack of responsiveness in addressing critical issues that need to be addressed
to get the plant back in compliance keeps frustration high and is having an impact
throughout the facility. There are many examples of this as listed below:
● MES staff has a contract from the specialty piping company TEAM to insert two stop
valves into the lines in preparation for cleaning egg digesters. On May 9, 2022, MES let
the city know that the contractor had outstanding invoices the city needs to pay, and they
would not do the work until it was paid. The Special Projects Lead directed MES to tell
TEAM what they needed to submit to get paid. The Bureau Head told the Special
Projects Lead to take care of that, which was one of the first calls for a response by the
leadership at Back River WWTP. There was no update at the May 16, 2022, meeting to
report if TEAM was paid.
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● Preventative maintenance (PM) is a regular topic at the weekly meetings and always met
with the same response. The maintenance people are doing reactive maintenance and do
not have time to do PM. PM is critical to keep the equipment operating.
DPW’s responsiveness to the MDE Directive has been limited. The fact that the same ideas
and issues keep being rehashed - week after week - in the weekly meetings speaks
volumes. This was best expressed by the MDE representative at the May 16, 2022, meeting
when the sense of urgency by DPW was questioned during the discussions on the water line for
the Synagro facility. The silence in response was a testament to the lack of responsiveness to this
issue and to the MDE Directive in general.
The lack of leadership is a major contributor to this lack of responsiveness to the
issues. There are many dedicated employees who want to see changes and bring the Back River
facility back to being a world class facility, but they see no reason to jeopardize their livelihood
and retirements in fighting the management team. The lack of attendance by DPW
Director and the defensive attitude by the Bureau Head does not bode well in
expecting workers to be responsible and accountable.
Recommendations
MES has chosen to divide our recommendations into two different sections. The initial section
addresses, as the MDE Directive requires, recommended improvements in order to bring the
facility back into compliance with the NPDES permits. These are ranked in order of
importance. However, in the two months MES has been at the facility, it is clear
there are substantial systemic problems that go well beyond the facility’s structure
that are crucial for the facility’s long-term viability and operation. We would be
remiss to gloss over those issues, which are inherently difficult to rank in terms of compliance
with permits.
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2. Install Potable Water Line to Synagro’s Pelletizer, Meet Contractor’s
Specifications for Feed Sludge
Synagro’s drying/pelletizing operations are responsible for processing 70% of the
WWTP’s solids load. As such, it is important that Synagro always has clean fire
suppression water supplied to their unit to maintain processing capacity. The city
should install the planned potable water line to Synagro immediately.
Synagro also has other contractual specifications for the feed sludge sent to its unit
(i.e., total solids content, volatile solids content limits). The city should focus on
these contract specifications as well.
3. Place More PSTs In-Service, Make Changes to PST Operations
Currently, there are only two primary settling tanks (PSTs) in service. This is not
sufficient to treat the plant’s average daily flow of 130 MGD. The lack of primary
sludge solids capture due to out-of-service PSTs impacts downstream processes
(activated sludge, denite filters, etc.). Priority needs to be given to repairing
three more PSTs in the short term (next six months) that can be accessed
right now without waiting for them to be cleaned – PSTs 7, 9, and 10. This
will bring the total of PSTs in service to five.
4. Repair All Pumps in the Hi-Rate Digestion Area
This area of the WWTP has many pieces of equipment either partially functional, or
completely out-of-service. Below is a list of equipment in the digestion area
that needs to be repaired or replaced. MES has found that the pumping
capacity in the hi-rate area is a critical bottleneck that must be addressed:
● Thickened Sludge Holding Tanks 2 and 4 - Variable Frequency Drives (VFDs).
● Acid Phase Reactor (APR) Recirculation Pumps 1, 2 and 3 - mechanical seals
● APR Effluent Pumps 1 and 2 – replace bearings and seals install motor for pump
no. 2
● Egg Shaped Digesters (ESDs), Recirculation Pumps 7, 9, 10, and 11 replace
mechanical seals
● Strain Presses- all are out-of-service. Replace or repair at least two of the six
units.
5. Safety
Elevate safety tasks to ensure that all can work in a safe secure environment.
Immediate safety improvements include:
● Install better lighting wherever needed so that those working at night can safely
navigate the facility.
● Institute a lock-out-tag out (LOTO) program.
● Hire an industrial janitorial firm under contract to maintain housekeeping at the
facility.
6. Denitrification Filters (DNFs)
These are critical for removing nitrogen and allow the facility to stay in compliance
with the nutrient limits of its NPDES permits. Repair DNF set 3, as this portion
of the facility is totally off-line.
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7. Sludge Thickening Equipment
There are three sets of sludge thickening equipment that badly need repair. The list
of equipment includes:
● Gravity Belt Thickeners (GBTs) 2, 3 4 and 7 are offline. Repair so that they are all
operational.
● Repair GBT WAS pumps 1, 2, 4 and 5, which are currently out of service.
● Only two of the six Gravity Sludge Thickeners (GSTs) are online. Many of them
have vegetation growing in them which needs to be removed. Once this is done,
they can be inspected to determine what mechanical repairs need to be
completed.
● Only one of the four Dissolved Air Flotation (DAF) units is online. Thickened
sludge pumps for DAF Units 2, 3 and 4 need to be repaired.
8. Activated Sludge (AS) Areas
Two of the AS units, numbers AS2 and AS3, have been online for some time now. Unit
AS 4 was recently constructed and is currently being brought online. Even though AS2
and AS3 are online, many of the mixers in AS2 and 3 are out-of-service. Either repair or
replace these mixers. Some of the RAS pumps are either off-line, or only partially
functional (e.g., need mechanical seals). However, the waste activated sludge (WAS)
pumps are crucial to the solids removal process. These need to be repaired
immediately so that sludge can always be pumped to the hi-rate digestion
area. If the WAS pumps all go offline, then this will create a critical bottleneck at the
plant.
9. Sand Filters
Of the 48 sand filters at the facility, only 12 are currently online. The other 36 have issues
ranging from the traveling bridges to filters clogged with solids. While rehabilitation
of these filters is part of a future DPW CIP project, MES suggests that at
least some of the filters be brought back online within the next 6 months.
The sand filters are needed to capture solids and allow the WWTP to meet its
phosphorus discharge limits.
Solids Handling
The primary reason for the occurrence of noncompliance at the Back River WWTP is the
accumulation of solids throughout the plant. Recognizing that DPW needed the ability to
transport and dispose of sludge without the assistance of a contractor, MES took
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the initiative to acquire four Sewage Sludge Utilization (SSU) Permits from MDE
on a fast-track basis. This removes any regulatory issues should DPW need to transport and
dispose of sludge without relying on a contractor. The four SSU permits listed below were issued
to the city:
● SSU Permit Number, 2022-STR-6169, issued to the Bureau of Water and Wastewater for
the transport of sludge from the Patapsco WWTP and Back River WWTP to Virginia.
● SSU Permit Number, 2022-STR-6170, issued to the Bureau of Water and Wastewater for
the transport of sludge from the Patapsco WWTP and Back River WWTP to
Pennsylvania.
● SSU Permit Number, 2022-STR-6171, issued to the Bureau of Water and Wastewater for
the transport of sludge from the Patapsco WWTP and Back River WWTP to the
Quarantine Road Sanitary Landfill.
● SSU Permit Number, 2022-SLD-6065, issued to the Bureau of Solid Waste to allow for
the acceptance and disposal of sludge from the Patapsco WWTP and Back River WWTP
at the Quarantine Road Sanitary Landfill.
In addition, MES staff provided guidance to the city’s DPW Bureau of Solid Waste on how to
accept sludge at their Quarantine Road Sanitary Landfill. This included suggestions on how to
incorporate the sludge stream with the landfill’s daily solid waste load once it arrives at the site
and recordkeeping duties. MES made staff available from our Mid-Shore II Regional Landfill
facility to answer operational questions from city staff.
MES also recommends the following tasks be immediately implemented.
● Institute a new process control and testing routine to obtain better solids capture in the
city’s centrifuges. Perform polymer dosage testing with different polymers.
● Eliminate the use of totes for polymer storage. Investigate the installation of larger tanks
for polymer deliveries and storage. There could be a cost savings associated with this
change.
● Have MES oversee the fast-track cleaning and rehabilitation of three more PSTs;
Numbers 6, 9 and 10.
● Procure a contract for all centrifuge maintenance, including routine periodic
maintenance tasks.
● Institute a process for high-rate staff to do daily calculations on volatile solids loading to
the digesters. This will ensure that process failures (stuck or sour digesters) do not occur.
● Avoid generating unstabilized sludge as a routine practice.
Operations
● Continue daily meetings with MES and plant staff to coordinate activities throughout the
plant.
● Channels of communication between the various area supervisors must be kept open.
Regular meetings between area supervisors need to continue.
● Staff must understand their job duties and must be held accountable for poor
performance of their duties.
● Begin cross-training Operations staff so that they are knowledgeable about all plant
operations.
● Have Back River WWTP participate in formal team building sessions to improve
communications and teamwork.
● Continue to improve housekeeping efforts by removing unnecessary or unusable
equipment and supplies around the facility.
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● Managers above the area supervisor must routinely tour the facility to identify
problematic areas. Identify housekeeping issues, personnel issues, equipment issues, and
structural issues. Speak to apprentices and staff to identify potential problems early.
● Ensure staff have the proper equipment to complete job tasks. Replace old and outdated
lab supplies, sampling gear, and cleaning supplies.
Maintenance
● Continue to use the city’s and MES’ emergency procurement process to make purchases
of critical items needed to bring the plant to compliance.
● Have MES staff identify and work with the Back River maintenance staff on high priority
repairs necessary to bring the plant into compliance.
● Reactivate the work order system that is currently down.
● Improve plant appearance by cutting grass and removing loose items.
Staffing
● Revise hiring practices to bring applicants to the plant to be interviewed and selected by
plant supervisors.
● Continue to have MES provide management support and operating staff for the Back
River WWTP.
● Provide training and tools for operators to succeed.
● DPW needs to keep staff informed and give them the information needed to do their job
intelligently and to inspire their initiative, enthusiasm, and loyalty. Treat them with
respect.
● Expedite the filling of vacancies to normalize the workload being placed on staff.
Environmental Compliance
● From a solids management perspective, implement monthly compliance review meetings
to ensure that all biosolids management functions, including reporting, are being
satisfied. This includes reviewing data to ensure the digesters are meeting Class B, VAR,
and heavy metals concentration standards. Develop a checklist so that management can
use this to track compliance.
● Designate a staff member to review new or proposed regulations as needed and report
these to senior management.
● Improve daily communication to operations staff of process changes that need to
manually be completed and confirm desired outcome.
Safety
● Immediately replace light fixtures that are not illuminating.
● Repair all service elevators to move heavy equipment for repairs and replacement.
● Prohibit employees from working on unstable or corroding surfaces with the potential to
give way or give out from underneath the employees footing.
● Schedule routine pesticide services to reduce or eradicate the insect population
employees are exposed to in work locations throughout the facility. Increase landscaping
and mowing efforts throughout the facility grounds to reduce exposure to pests (bees,
ticks, poisonous vegetation).
● Create clear pathways for employees to access sample locations throughout the facility
and maintain those pathways with a routine landscaping schedule.
● Reassess all confined spaces to determine if they are permitted or non-permitted spaces.
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Short-Term Recommendations (Between Six Months and One Year)
Solids Handling
Environmental Compliance
● Establish routine audits of laboratory data, compared to monitoring reports; frequent
review of operations completing sampling procedures correctly.
● Schedule preventative maintenance for all treatment processes and equipment to
prevent the degradation of equipment and inefficient removal of pollutants.
Safety
● Institute industrial janitorial services in all working areas – needed to establish a
baseline for operators to maintain housekeeping in all buildings and working areas.
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● Establish routine maintenance and housekeeping performed by all employees working at
the facility daily.
Long-term Recommendations
Solids Handling
● The Back River WWTP is a prime candidate for implementing a Biosolids Environmental
Management System (EMS). The EMS is loosely based on ISO 14001 programs for
ensuring compliance and quality in environmental systems. Key aspects of the EMS are
that it allows for a teams-based approach to environmental management and uses
outside auditors to verify compliance. Eventually, organizations with Biosolids EMS
move beyond compliance to improving their performance to cutting edge programs.
● Diversify Back River’s biosolids management by developing another outlet for a portion
of the plant’s solids generation. We suggest that the option be Class A-based and
operated by DPW staff (not contractual operations). Perform a screening process to
choose candidate technologies to investigate for pilot testing and eventually full-scale
operations.
● Clean the remaining digesters of debris.
Operations
● Implement facility-wide automation to allow for remote monitoring and improved
process control.
● Increase attendance at training courses for staff. This will improve operations by having
a well-trained operations team. Implement and maintain an operator apprenticeship
program. The apprenticeship program will need to be monitored to keep apprentices on
track and to assist them in areas they may be struggling with. A successful
apprenticeship program will increase the MDE certification exam passing rate. Provide
training for new managers and refresher classes for senior managers on effective
leadership.
Maintenance
● Complete the implementation of Cityworks for work order and asset management.
● Continue to have MES staff identify and work with the Back River maintenance staff on
high priority repairs and upgrading old inadequate equipment for at least one year.
● Assist Back River WWTP maintenance staff in the training of junior staff.
Safety
● Designate Site-Specific Safety personnel responsible for:
o Conducting employee training
o Implementing standard operating procedures
o Conduct inspections of the buildings, grounds, and equipment
Oversee and implement a standardized lock-out/tag-out program. Employees should not be
using a shared lock system. Employees should remain in control of their own locks
identified with individual names.
● Certify employees in First Aid Administration.
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III. Staffing Recommendations
Biosolids Manager
This Assessment Report establishes the fact that many of the compliance problems at the Back
River WWTP were attributed to failures in biosolids management at the facility. Remedial
actions to correct the problems were not recognized by staff who were not well-
versed with solids management. This was particularly true when it came to identifying the
problems associated with in-plant processing failures and end use options. One remedy to this
problem would be to employ a biosolids professional who is well-versed with not only solids
treatment technology, but also understands the implications that improper solids treatment can
have on solids end use “outside the gates” of the deteriorated WWTP culture and staffing
structure. Many large utilities across the country employ a dedicated biosolids manager position
to ensure satisfactory performance.
MES recommends that the city hire a dedicated Biosolids Manager and two technical staff to
support that person. This new staff member should have a technical background and
documented experience with biosolids technologies, end-use practices, and regulatory reporting.
At a minimum, this staff member would be responsible for the following functions:
● Tracking solids production and end use tonnages.
● Following contractor performance and compliance with contract conditions.
● Arranging for process control testing of the solids processes at both WWTPs; review
daily test results and report any irregularities or performance deficiencies to
management; foster proactive responses to problems.
● Be responsible for regulatory compliance, permitting and reporting; track analytical
results for compliance with the regulatory standards (i.e., heavy metals concentrations
for example, or pathogen treatment).
● Act as the city’s DPW biosolids representative in professional associations.
● Update DPW staff on new technical advances in the profession.
● Participate in CIP and execution of projects.
● Track equipment status throughout plants’ solids processing trains.
● Finally, the Biosolids Manager would keep management updated on the latest regulatory
developments and trends. For example, attention has been focused in recent years on
resource recovery at WWTPs, in areas such as energy recovery, sustainability, emerging
technologies and carbon sequestration.
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Conclusion
The Back River WWTP has fallen into disrepair over the last several years and has
experienced failures at nearly every level.
MES was directed by MDE to immediately assist Back River WWTP staff and evaluate the
facility for all major deficiencies. We were further directed to write a report and provide a set of
achievable actions and recommendations to get the facility into compliance with federal and
state regulations and laws. While we have accomplished these initial tasks, much more
work lies ahead. The issues at Back River are immense and are years in the making, but they
are not insurmountable. With a renewed sense of urgency, a focus from city leadership, we can
quickly bring the Back River WWTP back into compliance, and - together - do our part to protect
the waters of our city, county, and state.
We need willing partners to embrace a cultural and structural change with a
renewed commitment to this critical environmental mission.
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Appendices
IN THE MATTER OF *
BACK RIVER WASTEWATER *
TREATMENT PLANT *
8201 Eastern Avenue *
Baltimore, Maryland *
*
*
SECRETARY OF THE *
ENVIRONMENT
SERVE ON: *
MARYLAND ENVIRONMENTAL *
SERVICE *
259 Najoles Road *
Millersville, Maryland 21108 *
*
* * * * * * * * * * * * *
The Secretary of the Environment (“Secretary”), on behalf of the Maryland Department of the
Environment (“Department”), pursuant to the powers, duties, and responsibilities set forth in the Maryland
Annotated Code, Environment Article, § 9-252(a) and (b), and Natural Resources Article, § 3-109(c) and
(d), issues this Directive to the Maryland Environmental Service (“Service”) in order to ensure protection
APPLICABLE LAW
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1. The General Assembly has empowered the Secretary with the duty and powers to protect
public health and the environment. Among other powers and duties enumerated in the Environment Article,
§ 9-252(a) authorizes the Secretary to take action to address pollution of waters of the State; specifically:
(a)(1) To prevent or correct pollution of the waters of this State, the Secretary may:
(i) Require any public water supply system, public sewerage system, or refuse
disposal system to be operated in a manner that will protect public health and comfort; and
(ii) Order the alteration, extension, or replacement of any public water supply
system, public sewerage system, or refuse disposal system.
2. Section 9-252(b) of the Environment Article grants the Secretary the power to require that
any public sewage system be operated in a manner that will protect public health and comfort; specifically:
(1) Has supervision and control over the sanitary and physical condition of the waters
of this State to protect public health and comfort;
(3) Shall examine all public water supply systems, public sewerage systems, and refuse
disposal systems; and
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(4) Shall approve or disapprove the design and construction of any public water supply
system, public sewerage system, or refuse disposal system that is to be built in this State.
(1) Upon the failure of a municipality or person to comply with an order of the Secretary
of the Environment to correct deficiencies on the operation of sewerage systems or refuse
disposal works as provided in Title 9 of the Environment Article, the Secretary of the
Environment shall direct the Service to take charge of and operate the systems or works to
secure the results demanded by the Secretary of the Environment.
(2) Except as provided in subsection (e) of this section, upon the receipt of the directive
from the Secretary of the Environment, the Service immediately shall take charge of and
operate the systems or works to secure the results set forth in the directive of the Secretary
of the Environment. All costs for maintenance, operation, and other services including
legal fees incidental to taking possession of the sewerage system or refuse disposal works
shall be charged to the municipality or person against which or whom the original order
of the Secretary of the Environment was served.
(3) (i) Funds to pay the Service for services rendered under this subsection shall be
raised in the case of a municipality under Title 9 of the Environment Article.
(ii) If the order is issued against a person, the Service shall bill the person for the
full cost of services rendered.
(iii) If payment is not made within 60 days, the costs become a lien against the
sewerage system or refuse disposal works if it is recorded and indexed as provided in this
subtitle, and the Director shall refer the matter to the Attorney General for collection.
(1) Upon failure of a municipality or person to comply with an order of the Secretary of
the Environment to extend or alter a sewerage system or refuse disposal works as provided
in Title 9 of the Environment Article, the Secretary of the Environment shall direct the
Service to make alterations or extensions to the systems or works, or install a new system
or works as the Secretary of the Environment deems necessary to correct the improper
conditions.
(2) Except as provided in subsection (e) of this section, upon receipt of the directive
from the Secretary of the Environment, the Service shall assume jurisdiction over the
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systems or works and make the alterations, extensions, or new construction required to
comply with the directive of the Secretary of the Environment. All costs, including legal
fees incidental to assuming jurisdiction over the system or works, shall be charged to the
municipality or person against which or whom the order of the Secretary of the
Environment was issued.
(3) Funds to pay the Service for costs incurred as a result of actions taken under this
subsection may be raised as provided in Title 9 of the Environment Article. If the order
was against a person, the Service shall charge the person with the cost of making the
necessary improvements to comply with the directive of the Secretary of the Environment.
If the person fails to pay within 60 days, the cost becomes a lien against the property served
if it is recorded and indexed as provided in this subtitle, and the matter shall be referred to
the Attorney General for collection.
(1) In the event the Service determines, at any time, that it will be unable to recoup all
or a portion of its costs from the municipality or persons subject to the order of the
Secretary of the Environment, the Service shall provide to the Secretary a full accounting
of all costs incurred or anticipated to be incurred by it in complying with the Secretary's
directive.
(2) Within 30 days of receipt of the accounting, the Secretary may request that the
Service provide additional information.
(3) Within 90 days of receipt of the accounting or, when applicable, the additional
information, the State shall pay to the Service the full amount of the Service's costs that are
not paid or reasonably expected to be paid by the municipality or persons.
(4) (i) The State’s payment of any amount to the Service does not preclude the State
from seeking or obtaining reimbursement from the municipality or persons subject to the
order of the Secretary.
(ii) The Service shall cooperate fully with the Secretary in seeking reimbursement
from the municipality or persons.
FACTUAL BACKGROUND
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6. The Mayor and City Council of Baltimore (“Baltimore City”) applied for, and the
Department established conditions and requirements and authorized Baltimore City, pursuant to Title 9,
subtitle 3 of the Environment Article and NPDES Discharge Permit Number MD0021555, State Discharge
Permit Number 15-DP-0581A (effective May 1, 2018; modified January 1, 2020; expires April 30, 2023)
(“Back River Discharge Permit”), to discharge from the Back River Wastewater Treatment Plant (“Back
River WWTP” or the “Plant”), located at 8201 Eastern Avenue, Baltimore, Maryland.
7. The Back River Discharge Permit (a) details the actions that Baltimore City is required to
take to operate the Back River WWTP, and (b) limits Baltimore City’s discharges of pollutants to (i) Outfall
001A in the Back River, and (ii) Outfall 002A at Bear Creek. The Back River, which is designated as Use
II waters protected for estuarine and marine aquatic life, then flows to the Chesapeake Bay.
8. On or about June 16, 2021, September 20, 2021, and December 29, 2021, the Department
conducted inspections at the Back River WWTP. During these inspections, and as a result of reviewing
information and materials submitted by Baltimore City before and after these inspections in accordance
with the terms of the Permit, the Department observed extensive violations of General and Special
9. On March 22, 2022, the Department conducted an additional inspection of the Back River
WWTP. This inspection revealed a precipitous decline of the functioning of several critical processes at
the Plant in comparison with prior Department inspections. The March 22, 2022, inspection revealed
significantly increased noncompliance with the Back River Discharge Permit that is causing new or
increased unpermitted discharges to Back River. Additional data from Discharge Monitoring Reports
submitted by Baltimore City indicate monthly violations of total suspended solids (“TSSs”), total nitrogen,
10. Specifically, the March 22, 2022, inspection report revealed that:
1
As a result of the extensive violations of General and Special Conditions contained in the Back
River Discharge Permit observed by the Department, on January 21, 2022, the Department filed an action
against Baltimore City under Title 9, subtitle 3 of the Environment Article in the Circuit Court for Baltimore
City, Case No. 24-C-22-000386.
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a. Only 2 of the 11 primary settling tanks (“PSTs”) were in service, and 1 of the 2
operating PSTs requires maintenance to function properly. The Back River WWTP does not have
the presence of a high solids concentration in the DN Filter influent. The Plant has 52 DN Filters
arranged in 4 quads of 13 DN Filters each. Quads 1, 2 and 4 are not functioning properly because
they are underwater. Additionally, the 13 DN Filters in Quad 4 are not functioning properly
because they require various mechanical maintenance. These improperly functioning DN Filters
are causing DN Filter influent to bypass permit required Enhanced Nutrient Reduction (“ENR”)
treatment. In addition, the Department observed the presence of hydrogen sulfite (sewer gas) at
the DN Filters which indicates operational or treatment process deficiencies; this is possibly related
292 mg/L. This indicates that the solids settling processes are failing. These high concentrations
d. Significant algal and vegetation have grown on the weirs of the secondary
clarifiers. This has caused the short circuiting of the system and likely negatively impacts TSS
f. Significant amounts of vegetation (e.g., reed grasses) have grown and are
established in the secondary clarifiers. This is preventing the proper functioning of these
clarifiers; and
g. Significant amounts of vegetation (e.g., reed grasses) have grown and are
established in the biological reactors. This is preventing the proper functioning of these reactors.
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11. The Department has determined that the decline in the proper maintenance and operation
of the Plant risks catastrophic failures at the Plant that may result in environmental harm as well as adverse
pollution of the waters of the State and to ensure the Back River WWTP is operated in a manner that will
protect public health and comfort, the Secretary Grumbles ordered Baltimore City on March 24, 2022, to
operate the Back River WWTP in compliance with all terms of the Back River Discharge Permit, including,
but not limited to, providing an adequate number of operating staff that are qualified to carry out the
operations, maintenance, and testing functions required to ensure compliance with the Back River
Discharge Permit, and to cease all unpermitted discharges from the Back River WWTP. The Secretary
further ordered Baltimore City to make all necessary and appropriate alterations to the Back River WWTP
and its operations in order to comply with the March 24, 2022, order, and within 48 hours of service of the
order, to submit to the Department sufficient documentary evidence that the Back River WWTP is operating
in compliance with all terms of the Back River Discharge Permit and that it has ceased all unpermitted
discharges.
13. On March 26, 2022, more than 48 hours after service of the March 24, 2022, order, the
Department conducted a follow-up inspection of the Back River WWTP. The Department documented that
the corrective actions identified in the March 22, 2022, inspection have not been completed, and extensive
violations of General and Special Conditions contained in the Back River Discharge Permit continue
unabated.
14. As of the date of this Directive, Baltimore City has failed to comply with the March 24,
2022, order and to operate the Back River WWTP in compliance with all terms of the Back River Discharge
Permit and cease all unpermitted discharges from the Back River WWTP.
15. Pursuant to § 3-109(c) and § 3-109(d) of the Natural Resource Article, the Secretary hereby
DIRECTS that the Service take charge of the Back River WWTP, including its operations, maintenance,
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and improvements functions, in order to work with Baltimore City to ensure that Baltimore City meets the
following objectives: protecting public and environmental health; abating any further nuisance; providing
modifications; operating the Back River WWTP in compliance with all terms of the Back River Discharge
Permit; and ceasing all unpermitted discharges from the Back River WWTP. 2 The Service shall work with
Baltimore City to the extent it deems practicable, but in any event, shall achieve the aforementioned
objectives with the means and methods the Service, in its discretion, deems most effective and efficient.
Specifically, the Service shall take actions to ensure that the Back River WWTP is operated in compliance
with all terms of the Back River Discharge Permit and cease all unpermitted discharges from the Back River
b. Immediately begin assessing the adequacy of both the number and qualifications
Department on the adequate number of qualified operating staff that are necessary
to carry out the operations, maintenance, and testing functions required to ensure
c. Identifying and implementing all necessary and appropriate alterations to the Back
River WWTP and its operations and maintenance, including, if necessary, the
River WWTP.
16. The Secretary further DIRECTS the Service to undertake a comprehensive evaluation and
assessment of the Back River WWTP’s operation, maintenance, staffing, and equipment and, by June 6,
2022, to submit a report to the Department of the Service’s findings and recommendations, including a
2
Nothing in this Directive imposes liability on the Service under Title 9, subtitle 3 for violations of
the Back River Discharge Permit.
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comprehensive list of needed improvements, ranked by their impact on compliance with discharge permit
effluent limitations.
17. The Secretary further DIRECTS the Service to abide by any amendments or modifications
to this Directive issued by the Secretary of Environment if the Secretary believes any such amendment or
18. The Secretary further DIRECTS the Service to seek recoupment as referenced in § 3-109
of the Natural Resources Article and may record and index one or more liens against Baltimore City, and
19. The Secretary further DIRECTS the Service to complete all tasks in this Directive until the
STATE OF MARYLAND,
DEPARTMENT OF THE ENVIRONMENT
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Appendix B – NPDES Discharge Permit
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Appendix C - Comprehensive Repair, Replacement, and Priority Lists
Comprehensive List of Repairs, Replacements, and Rehabilitations Needed at the Back River WWTP
Item to Repair/Replace/Rehab or known
Capital Project currently in the CIP (include
all ancillary components ie.motors,
controls, pumps etc. in the next column) Description of the known items or
Note: When entering a capital project, skip component that need
the next column and note the planned Repaired/Replaced/Rehabbed (Add as many
Process year in the remarks column) lines as necessary Remarks
Installation of Cityworks Asset management system The asset inventory is being collected with City works expected
CMMS sometime toward the end of FY 23. CIP
SCADA System
Computer System Upgrade Contracted by the City
Replace all communication components that
are not working, obsolete, and
SCADA integration throughout the plant noncompatible.
Install a fiber backbone throughout the plant
to provide reliable communication for the
SCADA
Headworks
Hydrogen Sulfide Scrubber 1 thru 4 Connect potable water to the scrubbers and Potable Water Line is being installed by the City to make potable
start up water available to the site. The potable water will need to be
plumbed to the scrubbers.
Grit Blower 3 and 4 Need to be repaired. Potential warranty items.
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Activated Sludge 2
All DO probes on all reactors All probes need to be repaired or MES obtained quote for repairs/replacements from Kershner Env.
overhauled. Wiring may need to be replaced Technologies.
also.
Activated Sludge Reactor 5
Mixer 2 Replace or Rehab Entire Unit
Activated Sludge Reactor 6
Mixer 6 Replace or Rehab Entire Unit
Mixer 7 Replace or Rehab Entire Unit
Activated Sludge Reactor 7
Mixer 2 Replace or Rehab Entire Unit
Mixer 3 Replace or Rehab Entire Unit
Activated Sludge Reactor 8
Mixer 3 Replace or Rehab Entire Unit
Mixer 4 Replace or Rehab Entire Unit
Mixer 5 Replace or Rehab Entire Unit
Activated Sludge Reactor 9
Mixer 1 Replace or Rehab Entire Unit
Mixer 2 Replace or Rehab Entire Unit
Mixer 3 Replace or Rehab Entire Unit
Mixer 4 Replace or Rehab Entire Unit
Mixer 5 Replace or Rehab Entire Unit
Mixer 6 Replace or Rehab Entire Unit
Mixer 7 Replace or Rehab Entire Unit
Activated Sludge Reactor 10
Mixer 4 Replace or Rehab Entire Unit
Mixer 5 Replace or Rehab Entire Unit
Mixer 6 Replace or Rehab Entire Unit
Centrifugal Blower 1 Replace or Rehab Entire Unit
Centrifugal Blower 2 Replace or Rehab Entire Unit
Secondary Clarifier 10B Replace or Rehab Entire Unit
Pump Station #1
RAS Pump 5 A/B Replace or Rehab Entire Unit
RAS Pump 5 A/B Replace or Rehab Entire Unit
RAS Pump 5 B Replace or Rehab Entire Unit
RAS Pump 6 A Replace or Rehab Entire Unit
RAS Pump 6 A/B Replace or Rehab Entire Unit
RAS Pump 6 B Replace or Rehab Entire Unit
RAS Pump 7 A Replace or Rehab Entire Unit
Pump Station #2
RAS Pump 8 A Repair Unit
RAS Pump 8 A/B Repair Unit
RAS Pump 8 B Repair Unit
RAS Pump 9 A Repair Unit
RAS Pump 9 A/B Repair Unit
RAS Pump 9 B Repair Unit
RAS Pump 10 A Repair Unit
RAS Pump 10 A/B Repair Unit
RAS Pump 10 B Repair Unit
WAS Pump 8 Repair Unit
WAS Pump 8/9 Repair Unit
WAS Pump 9/10 Repair Unit
WAS Pump 10 Repair Unit
Activated Sludge 3
All DO probes on all reactors All probes need to be repaired or MES obtained quote for repairs/replacements from Kershner Env.
overhauled. Wiring may need to be replaced Technologies.
also.
City to remove AS3 from service for Rehab Total Rehab of the process CIP
Denitrification Filters
Filter Set 3 Controls Replace Controls wiring
Repair Controls
All sand filters Rehab of entire system is needed- This rehab CIP being further evaluated by the City to dermine need in the
will make all sand filters fully functional. treatment train
Sand Filters
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Disinfection
Flushing Water Pump 1 Repair or replace unit
Outfall 002 Pump 5 Repair or replace unit
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Acid Phase Reactor (APR) Complete Rehab of Acid Phas Disgesters 7 &8
Sludge Dewatering
Motor was delivered waiting on control company to come in and
Centrifuge 3 Controls need replaced install controls and provide start up.
Centrifuge 4 Manufacturer is repairing this centrifuge Scheduled return is August 2022
Centrifuge Feed Pump 4A Repair Unit
Centrifuge Feed Pump 4B Repair Unit
Provide adequate clean water to run Install potable water line to provide water
continuously at maximum capacity. necessary to continue operations without
Synagro interruptions
Provide feed sludge per specification City needs to concentrate on meeting
speciation for total solids and volatile solids
content
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Priority List
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Appendix D - Daily Reports
Once tour complete, Harry took us to meet with his boss Walt. Discussed what we noticed and once again
asked if we could begin to provide aid. Walt said he would need to discuss with Prim.
At 1500, Greg Stehli did receive word that we can begin to have staff on-site to assist.
Will begin to put together a schedule and discuss with staff.
Engineering/MBE: Al Razik
• Confirmed a 9:00AM walk though of the plant with Back River personnel to identify potential
contracting opportunities for small and minority businesses.
• Set up a meeting with Chris Kroen, Back River WWTP Supervisor to tour the plant on 4/1
Tried to set up a meeting with Michael Hallmen for Friday but he was off. I will see him Monday
4/4 at City/MES meeting at Back River.
April 1, 2022
• Visited the site today and toured with Todd Boulden, Trish Lyons, Skip Immler and Tim Barnes.
(I have attached Joe's observations to this email as well.)
• Operations staff to report Monday morning and have been given instructions on hotel check-in
and treatment plant address.
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• Maintenance will need MES's input as to what we should focus on. After seeing multiple pieces
of equipment LOTO, we want to make sure we are working in the areas that will make the best
impact.
• Starting Monday, maintenance should have more detailed updates. Just need to get on-site and
begin our assessment.
Headworks
• Headworks is working fine outside of the odor control system. I was able to clarify comments
made about the headworks screening issues. The coarse screening system is operating without
issue. There is an intermittent issue with the fine screeners and the spray water due to the use
of effluent water for spray water which clogs up due to elevated solids in the effluent. On
occasion they must take a unit offline and clean the spray heads, but the unit is only offline
for a brief period of time. There are six total fine screens and having the one offline briefly
does not affect operations.
• Odor control on, but not filtering. Need clean spray water.
• Dumpster removal issues due to the need for truck to remove dumpster. Current truck not
adequate and causing damage to dumpster, which they have a hard time getting repaired by
maintenance. 14 dumpsters are unusable. Truck on order but lifting portion of the truck not
available for several months.
• There are only two fully operational PST’s online as of today. Details are as follows:
• PST 8 and 11 are online, and all mechanical components are functional.
• PST 10 is clean and online, but none of the mechanical components are functional.
• PST 1, 2, 5 and 6 are online but full of debris and flow is just passing through. None
of the mechanical components are functional.
• PST 3 and 4 are offline and being cleaned out by Ulliman Schutte. Mechanical
components still need to be assessed, but structure will require repairs.
• PST 7 is offline and being cleaned out by Synagro. Mechanical components still need
to be assessed, but structure will require repairs.
• PST 9 was cleaned out and a leak in the scum box was found when they were filling
it, so it remains offline awaiting repairs to the scum box.
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Pancake Digesters
• The #1 DAF unit was the only one functional out of four available units.
• DAF units 3 and 4 have not worked for the past 5 years.
• Drive mechanisms aren’t functional.
• One out of the three available recirculation pumps is working.
• Crane hoist not functional.
• Building staff recommended a Muffin Monster ahead of the building, which would help with
the trash issues they have that clog pumps and pack up volutes.
• Rehab of the digesters is scheduled to begin in May. Expected to take two years.
Sludge Dewatering
• Solids processing appears to be increased. There is now a transfer pad full of sludge that was
not at the site on Monday.
• Dewatering operations are Monday through Friday only.
• We saw a room on the backside of the old solids building that contained file cabinets and
drawings. Room door was wide open to the elements and critters.
• Preston Trucking is the contract sludge hauler.
• There are three Activated sludge zones (2, 3 & 4). Activated 4 has not been released by the
contractor yet and all tanks remain empty.
• Each zone has 12 clarifiers.
• Four of the 24 clarifiers are offline due to issues with pumps and drives.
• Return Activated Sludge (RAS) pumps that are offline are 26 weeks out for delivery.
• As fast as spare parts come in, they are installing them and awaiting more spare parts.
• MLSS 3500-6000 (goal is 2600-3000)
Denite Filters
• There are 52 Tetra Denite filters and all are blinded with sludge. Basically being bypassed
due to blinding.
• They remain online, but backwash cycles have been reduced.
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• Had issues with sand blowing out of them during backwash and the excess sand has made its
way to the Denite clarifiers.
• One of the two Denite clarifiers is offline due to the sand wearing down the equipment.
• Kaylani Environmental onsite working on the offline clarifier. Evaluating it.
• They are setting up a contract with Tetra to come to site and evaluate the filters.
Sand Filters
Disinfection Area
General Observations:
April 4, 2022
April 5, 2022
• Staff arrived this morning and the shift supervisor for the City was not aware what MES was
there to do and staff had to wait for Dana Garris (Supervisor II) for direction.
• This caused some irritation and confusion for MES staff. The day went much smoother as things
moved along.
• ESS Demond Miller toured the operations area we are assisting with at this time to assess the
areas that require our attention, and he assigned a few operators to areas that needed cleaning and
others helped collect samples.
• Randy Gaver is working in the lab running samples for the activated sludge portion of the facility.
• Demond Miller is assessing available sampling and testing equipment and will be reporting to me
on any needs for process testing. He mentioned they only have one portable Dissolved Oxygen
meter, and it is outdated and there are not enough sludge judges (core samplers for measuring
sludge blanket depths) for the many tanks located around the plant. A supply list is being created
and Tiff and I will review.
• Demond mentioned that no one on day shift today for the City was familiar with operation at the
Denitrification building and accompanying process. I will find out who is the lead person for
operations of the denitrification process and will review the operations. I will bring MES
operators up to speed on the operations on the system.
• MES staff are not allowed to operate City vehicles, so an MES vehicle or two are needed for
operators to collect samples and move about the treatment plant.
• I will be working out of the Back River office all day tomorrow.
We received April 1st through April 5th process lab data from Dana Garris.
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• I requested, and received a status update (clarifier cleaning update, number of units in service,
and status of clarifier repairs) on the PSTs from Mike Hallmen. Mr. Hallmen stated that they will
take care of phragmites removal from the gravity thickeners.
• Had a telephone conversation with Yosef Kabede about their contract with Greely and Hansen to
do an assessment of the plant, as per the MDE order given to the City dated March 4th. Mr.
Kabede sent documents to me. We discussed other biosolids end use options that I would like to
pursue. I also emailed Mr. Kabede and emphasized to him that we want to be an active participant
in Greely and Hansen’s assessment.
• Received a call from Matt Tabisz of Synagro, RE: they stand ready to do work for us (i.e.,
digester cleaning). Mr. Tabisz told me that the dryer has been down for an entire year, and not the
3-4 months that we were told by the City.
• Virtual Meeting with City staff (Betty Jacobs, Bill Sammons, Dana Garis) and MES staff (Skip
Immler , Tim Barnes) to discuss solids removal from the secondary process. I will visit the plant
on April 7th to select some pumps to start replacing.
• Attended in-house meeting to discuss various issues.
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New Shop
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April 6, 2022
• Today’s Work
Continue with rebuild on GST 2A Gravity Sludge Thickener Pump
Pump housing, bearing housing, & worm gear. Some repair parts provided were
incorrect & others are not in stock onsite.
Scoped out request to replace motors & gearboxes on Centrifuge (Clarifier) #10. While at
location noticed that electrical controls & disconnects are in extremely bad shape or do
not work & need to be replaced. Also noticed structural damage to skimmer arms,
gearbox platform, catwalk. Contractor may be needed & possibly have MES Engineering
investigate.
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• Scheduled 4/7/22 Thursday
Greg Stehli will be attending daily morning meetings with Prim and Walt.
Greg is also scheduled to attend daily end of shift meeting with Prim and Walt if
available.
Staff – Currently get assignments each morning from Harry. Will change soon as Greg
becomes more involved with daily morning meetings.
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April 7, 2022
• Site visit with Skip Immler, Heather Fritz, and Casey Hanna
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• Scoped out future digester cleaning project logistics for hi-rate digesters no's 1 and 4
• Identified two pumps (Recirculation Pump No 1 and 4) in the digester area to replace. We will
need these pumps to be able to remove sludge from the hi-rate digesters when we clean them.
• Scoped phragmites removal from the gravity sludge thickeners
• Identified polymer feed pump (Polyblend Unit 2A) that needs to be replaced.
• Took dewatered sludge sample for TCLP lab analysis (we will use the results to gain landfill
disposal approval)
• Maintenance staff will look up the pump nameplate data for the identified pumps in Water 360,
so we can order the pumps.
Walked a few of the areas MES operations is working in with Demond Miller, W/WW ESS. Demond
started by reporting none of the MES operators have seen the entire facility, they have not been to the
headworks, including grit removal, they have not seen the digesters and they have not seen the primary
sludge thickeners. They have been told by City staff they are here to assist with the activated sludge areas
and the denitrification areas. However, MES operations was also told they do not need to be in the
denitrification buildings. Demond and I did go into a few of the denitrification buildings anyways today,
where he was seeing some of those areas for the first time.
Currently, the wildlife that are residing in the buildings are of concern. There are buildings where snakes
have been discovered in the basements, ducks are living inside another building, and although I did not
think I would come across geese more aggressive than our resident geese at the Cambridge WWTP, they
are no match for the ones residing at Back River... one actually ran to peck at my vehicle while it was in
motion! Of immediate concern is operations and maintenance working in unlit areas (particularly during
the second and third shift) and being injured by animals and insects that they cannot see to avoid.
Improving lighting at the facility in general, outside along the grounds and inside many building areas,
needs to be a priority.
Typically, MES operations collects process samples from the reactors, however it appears to Demond that
is not currently happening at the reactor stations at Back River. We did identify areas where MES
operators are collecting samples from, which includes the final outfall area. I also saw control panels that
were locked out, they did have tags indicating who locked out the equipment on the few locks I saw, I did
not have any major concerns with the few lock outs I saw today. The final effluent was visibly brown
today. There were areas throughout the grounds and roadways that are puddled with excessive amounts
of standing water. The areas we noticed today were around the first stage clarifiers. Most of the first
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stage (final) clarifiers have parts where sediment has built up and collected, some have sludge visibly
built up to high levels, some are inoperable, and some have problems with even flow distribution.
I apologize if I'm using the incorrect terminology, I'm not familiar with the different parts of the process
yet and still trying to get a handle on the plant in its entirety. We really need a flow diagram of the entire
plant to be able to refer to the different areas accurately. I do need to begin determining where chemical
alarms are located and if they are working or not, as of now, I asked operations to avoid the major
chemical storage buildings until we have the proper equipment to enter those areas and determine the
work we would need to be doing in those buildings.
I plan on attending the walk through with some of the MES staff this coming Monday 4/11.
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GST 2A Pump Drive Collar Lower-Level High Rate Building 1 (Floor Sludge)
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Lower-Level High Rate Building #2
and Metal Fabrication. I've requested a list of all potential Prime Contractor from Al Razik, Ron Turner &
Betty Jacobs to pursue MBE subcontracting opportunities.
Finally, Skip noticed billowing plumes of sludge in the Chorine Contact Tank - see attached photo.
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Billowing Sludge
April 8, 2022
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Set up & organized safely equipment & tools in provided shop area.
Installed rotor stator GST Pump 2A/start on housing
Receiving assistance from John DPW maintenance to acquire correct parts.
DPW is unsure what is in Stockroom and lack of parts.
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Photos:
• GST thickened sludge pump 2A after completing rebuild.
GST thickened sludge pump 2A before MES arrived.
Goals:
• Stehli to meet with DPW Maintenance heads to streamline processes each morning.
Maintenance Shop
Motor Shop
Electrical Shop
• Begin to contact and bring in vendors for upgrades and hard to find parts/equipment and out of
service equipment.
• Through meetings with DPW Maintenance, continue to try and push a joint effort of maintenance.
Staff Notes:
• Poor housekeeping
• Some DPW staff out working
• Polymer everywhere near feed units in Dewatering Building.
• MES Maintenance expressed the need for gantry crane.
Will get quotes and submit for approval.
• MES Maintenance needs to begin working with DPW Electrical and Instrumentation
departments.
Greg Stehli met with both departments this morning. Some pushback from Electrical.
Both Greg and I (Wayne) will meet with both Electrical and Instrumentation again
tomorrow.
Instrumentation - Caroll Wells, Kim and James Dorsey
Electrical - Met with George/good meeting
Electrical - Met with Darrell head of electrical/not a good meeting/he walked
away from conversation.
Greg met with Prim and was instructed if he encountered any issues to report back to
Prim (DPW).
• Staff expressed a need to wash uniforms on-site or a cleaning service. Currently Stehli and I are
working on solution.
• Still no access to Store/Stock Room. Greg and I (Wayne) will revisit tomorrow.
Mr. Price's office does not have direct control to demand the elevators be in operation, it sounds like the
issues we are finding have been noted in their past inspection reports for the facility. His summary was it
doesn't do any good to keep rehashing how did it get to the point it's at, the focus now needs to shift to
digging out of the hole they are in so to speak and getting the facility operating as it was designed to.
Greg Stehli spoke with Fastenal rep. Discussed ceramic coated volte repairs.
Greg Stehli is working with DPW Procurement team to assist with lead time on orders.
DPW Procurement is also working with Greg by sharing some of their repair shops
quotes to see if we can order with better lead time as well as assisting with purchasing
inventory.
• Maintenance
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Completed tour of supply room.
Completed repairs for Digester Recirculation Pump#4 in High Rate Lower Level.
Unable to test & run due to VFD & other control components missing.
Replaced packing for bearing housing shaft on Digester Multi-Purpose pump #3 in High
Rate lower level. Will work with DPW Operators tomorrow morning to test & return to
service.
• Notes from staff
Received assistance from DPW Operators to shut down valves to work on Digester
pumps.
Sent nomenclature to Hill's Electric to begin getting quotes for replacements.
Contact vendor Rob Hayden with STH, he will be on-site next Wednesday at 9am to look
at any pumps, motors, and controls we may need replaced and what they may be able to
assist with.
Spoke with Walt about mobile crane, and he informed staff that they do have a crane and
other equipment that can assist with repairs. Walt will speak with the Grounds
Department tomorrow and introduce our staff to their head of department. More details to
follow tomorrow's introductions.
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High Rate Lower Level
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April 14, 2022
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Mike pointed out that everyone in the room (except himself and maintenance) were
certified operators and he and he tasked them with pointing out issues that may be made
that will negatively impact operations. Work as a team.
Mike said the Scada system was being upgraded plantwide and the procurement had been
approved.
Centrifuge programming and instrumentation is being looked at by an outside contractor
currently onsite and this will occur immediately. I did not catch the name of the
contractor.
• After the meeting we were discussing their struggles with dealing with disciplinary issues and the
struggle with union rules when Ramona Harry (Operations Officer I) walked in and I called her
over. She is part of their HR team. I told her what we were discussing, and it opened up some
very interesting dialogue between her and the other city managers. She was clearing up some
misconceptions they had about the disciplinary procedures for operators and was tutoring them on
the steps allowed to address problem employees under the union agreement. Wayne and I
removed ourselves at this point and I was happy to see this conversation occurring. It appears
there needs to be an educational session for their managers to understand th steps for effectively
managing and disciplining staff.
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GST Pump 2A Inspected GST Pump 2B
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• Joe Wright and I attempted to open the city water yard hydrant located behind the dewatering
building. The valve is seized on the hydrant and will not open. We need this water in order to use
as washwater for the temporary dewatering equipment to be set up by the contractor that we
choose to do this work. Until this hydrant is repaired, the temporary dewatering price quote
process will be put on hold. We will work with our Maintenance people to get a contractor
at Back River to either repair, or replace the hydrant.
• Sludge judged PST-6 to determine the solids profile in that clarifier. It is mostly dense, solid
material interspersed with pockets pf water.
• Visited the hi-rate digesters in order to scope out the purchase and installation of new biogas
mixing compressors for hi-rate , in ground digesters 1 and 4.
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GST Pump 2B Seal Replacement GST Pump 2B Seal Replacement
• GST Sludge Pump 2B High Rate - Installed replacement bearing packing. Made and installed
replacement inspection plate gaskets. Set and realigned motor and gearbox. Opened valves and
tested pump found the stator is corroded and not sealing properly. Parts should be available in the
warehouse we will attempt to install and replace tomorrow 4/19/22.
• Met with vendor Will Soistman from EESCO pumps and valve. They will be preparing a quote
for the rebuild or replacement of the centrifuge feed pumps 4A and 4B in the basement of the
vacuum filter building. (Casey Hanna handling)
• Opened and exercised yard hydrant behind the Synagro building. The hydrant is operational.
• Asked by DPW Maintenance supervisor Walter Kelly to evaluate the replacement of the Silo #7
rubber containment flap. There are safety concerns about this repair, and we do not believe it to
be a priority task currently. Contractors may be needed. (I will discuss safety concerns with staff)
• Continued working with ABB PLC representative Rick Gayo. Waiting for call back to schedule
site visit.
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Hydrant behind Synagro Bldg. – after exercise and flush
• Attended Huddle meeting with MES and Back River staff. Discussed several equipment issues
• Assisted with coordinating Back River staff and MES staff to get the cl2 contact tanks cleaned
• Assisted coordinating elevator evaluations with MES staff and elevator contractor. All o/s
elevators were looked at
• Answered several questions from Sean regarding the contract with GMH for repairing 2 PSTs
• Forwarded info to GMH questioning their ability to do business in Maryland. GMH filed the
appropriate application with the State.
• Completed price quote specs for sludge removal and disposal from PST-6. Emailed specs to 3
contractors (Denali, Mobile Dredging and Waste Mgt). On a phone call with Denali they
indicated that they probably will not give us a price quote for this work because they cannot find
a landfill to accept this sludge due to lack of landfill capacity.
• Attended in-house meeting on documenting Back River failures.
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• Casey Hanna escorted G.C. Jones Elevator Company to all Back River elevators for repair
evaluations. They will supply an itemized list for each elevator and what repairs will be needed.
• RLG Consultants rep will be onsite Monday 4/25/22 at 0700 to assist with Instrumentation. Will
help with PLC issues. (Rick Gayo)
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April 21, 2022
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Operations: Joe Wright
• Demond Miller reported that there is a contractor onsite that is currently working on the lighting
in some of the pump stations around the activated areas.
• Demond provided a list of out of service equipment around the activated area.
• Ron Turner called Joe and notified him that they had sludge bubbling from the ground again.
They have a truck coming from the Patapsco plant to clean up the spill. They are having issues
locating the source of the leak and cannot isolate the line until they know where it is coming
from. Joe will be investigating the source of the leak with the city staff tomorrow.
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Pump Station #2 RAS – Pump seals to be replaced
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April 27, 2022
Page | 158
• Our sludge disposal permit application is done. We will send it to the Solid Waste Bureau head
tomorrow to sign.
• Attended weekly meeting with Greeley and Hansen, City staff.
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Centrifuge #2 Leak
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Centrifuge #1
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Centrifuge #2
Centrifuge #3
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Centrifuge #4
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Sludge Thickener Pump 6B Rebuild
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Cross Connection Valve
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April 29, 2022
Page | 169
Operations: Joe Wright
• Added equipment updates to the Back River WWTP priority list.
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Activated 2, 3 and 4 Mixer-Aerator
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Anerobic Digestor APR Building DPC Panel
May 2, 2022
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Sludge Thickener Pump 7
May 3, 2022
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Digestor Recirculation Pump 3
May 4, 2022
Page | 177
• Received a memo from Lance Fierro on centrifuge operations, detailing a pattern of some DPW
employees not wanting to run all available equipment to get the solids down. Mike Hallmen to
address the DPW employees.
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Sludge Thickener Pump 7
May 5, 2022
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• Attended the Thursday "Huddle" with Back River supervisors for each area. They discussed the
various equipment that are out of service and equipment that is being fixed. They plan to install
temporary lighting outdoors at the tanks until the lighting needed becomes available. City
maintenance have been directed to begin fixing the traveling bridges that are offline at the filters.
• I have requested a copy of the equipment list that each area supervisor provided to Ron that
indicates equipment status.
• Ron advised his staff that there will be repercussions for staff not cooperating or not working in
general. He wants names, dates, and investigative reports on all personnel complaints.
• MLSS remains around 6,000 mg/l in the activated sludge process.
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Process (Gravity Belt Thickener)
Sludge Thickener Pump 6B
• Continued with rebuild of CARTER Drive.
Process (Anaerobic Digester)
Digestor Recirculation Pump 3
• Completed rebuild of housing
• Transported to location and will complete install on Monday.
Process (Gravity Belt Thickener)
Installed motors for Polymer Feed Pumps #1 and #2
Process (EDG)
APR Effluent & Recirculation Pumps
• Escorted Hill's Electric rep to begin supply quotes for replacement
mechanical seals, pumps, & motors.
Process (Gravity Belt Thickener)
Escorted Hill's Electric rep to begin supply quotes for replacement mechanical
seals, pumps, & motors.
Process (Activated II)
Escorted Hill’s Electric rep to begin researching & quoting RAS pump
mechanical seals & replacement motors & pumps with mechanical seals for all
four WAS pumps.
Process (Sludge Dewatering)
Escorted Hill’s Electric rep to begin assessing SCADA/PLC communications
issues & automation functions for centrifuges & polymer feed. Hill’s will review
information & quote for their Technicians T&R SCADA/PLC issues.
Process (Sand Filters)
Escorted Hill’s Electric rep & work DPW to create repair plan to begin Sand
Filter repairs to return facility functionality.
Process (DAF)
DAF Sludge Thicking #2, #3, #4
• Locate & collect nomenclature on TSP pumps & control & create plan to
return to service
Notes
• We have determined that the reason for high number of rebuilds is due to improper rebuilds.
DPW is using TAPE to hold grease spacer plates together when assembling. The TAPE is never
removed, thus blocking grease ports (see attached pics). When greased, the lubrication never
reaches the bearing and is run dry and causes premature failure.
• EESCO will be onsite Monday to start Centrifuge Feed Pump repairs for 4A and 4B.
• DPW Walt is working with Stehli to begin troubleshooting failed PLC systems.
• Attended MES/DPW Huddle
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Bearing Housing Grease Channel
Dry worn bearing removed Polymer Feed Pumps #1 and #2 motor installs
May 6, 2022
May 9, 2022
• In service
• Operates in manual
Process (Sand Filters)
Sand Filter #1
• Conducted replacement of non-functioning backwash pump, tested, and
returned to service. Replaced malfunctioning proximity switch on
carriage, tested all functions and returned to service. Cleaned, exercised,
and greased discharge valve. Once vegetation and debris are removed
from sand filter, the area can be filled and tested completely.
• Out of service
• Operates in manual
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Sand Filters #1 Backwash Pump
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May 10, 2022
Mixer PM Activated 2
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May 11, 2022
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Mixer AS2-05-MA-3
Performed PM. Changed oil and installed new drain valve to streamline future
oil changes. Tested and returned to service. Will need to place bulk order for oil
to continue PM's. Two of the large mixers used 40 gallons of oil.
In Service
• Process (DAF Sludge Thickening)
Lower-Level Floor Drains
Conducted Jetting of lower-level floor drains until DPW Jetter line broke.
New hose will be installed tomorrow by DPW.
Worked with DPW Valve Crew to remove standing water in grates to locate line
to be jetted.
Scheduled to circle back tomorrow when Jetter fixed.
• Process (Sand Filter)
Sand Filter #1
Installed replacement suction hose for wash water pump on Sand Filter #1 and
returned to service.
In Service
Operates in manual
Sand Filter #5
Conducted replacement of Back Wash pump on Sand Filter #5. Completed oil
change on carriage gearbox and greases all points, tested all functions, and
returned to service.
In Service
Operates in manual
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DAF - Jetter Head cut in floor drain from years ago
Sand Filter #5 Backwash Pump – Before Sand Filter #5 Backwash Pump - After
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May 12, 2022
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Operations: Demond Miller
• Lance will be going over to centrifuge tonight to help them transfer sludge to tank 26 to keep it
going.
• I think the city would like these operators for centrifuge now because they cannot rely on their
folks to do anything.
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• Was directed by Matt Lapinsky to assist Al Razik with the purchase of 3 air compressors for the
solids side.
• Spoke to Al. He will give me specs for the compressors next week
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within the Union guidelines. The Apprentice would report to the Technician III
and we can all work together. Ramona will discuss with Yosef and the Union.
According to Walt (DPW Maintenance Supervisor) he has six (6) veteran
mechanics.
MES has two (2) Maintenance Supervisors, one (1) extremely experienced Lead
Mechanic and two (2) excellent mechanics able to break into multiple teams.
Combing both DPW and MES, we should be able to put together six (6)
outstanding teams and decrease the turnaround time. This will also assist MES
with navigating the DPW procedures and again decrease the turnaround time and
begin to reduce the backlog of open work orders.
• Attended meeting with Prim and Walt to begin discussions on how we can combine staff and
some of the issues everyone may encounter.
DPW concerns
MES embarrasses their staff
MES becomes frustrated with lack of performance from DPW maintenance
DPW staff expressing that if they work with and teach MES their jobs; MES will
push them out of a job.
I assured Prim and Walt that we can handle and work through all these issues.
This is not the first time we have been in this situation. MES Maintenance went
through the exact scenario with the airport and learning to work with and
navigating the Union with State employees working for the MAA.
The plan is for Walt to speak with his staff Monday and hopefully begin working
together next Tuesday.
DPW work order program is back online. Both Greg and I met with Mike. Mike is
working to provide MES with a report of all Open Work Orders.
Currently, no one knows how to pull reports from work order program. Program
is called ELKE. The individual who performed this task, has retired.
I was able to view some open work orders in the system. There is a significant
amount of open work orders in the program. Some date back to 2001. 21-year-
old open work orders.
Work Performed
• Process (Activated II)
Mixer AS2-05-M-5
Performed PM on Mixer AS2-05-M-5. Changed oil and installed new drain valve
to streamline future oil changes. Tested and returned to service. Will need to
place bulk order for oil to continue PM's.
In Service
Mixer AS2-05-M-4
Performed PM on Mixer AS2-05-M-4. Changed oil and installed new drain valve
to streamline future oil changes. Tested and returned to service.
In Service
Process (DAF Sludge Thickening)
TSP Pump #2
• Conducted troubleshooting of TSP pump #2 in fault. Found discharge
plug valve not operating in remote. Opened valve manually and tested
pump and returned to service.
• In Service
• Operates in manual
Process (Sand Filter)
Sand Filter #9
• Conducted shut down of Sand Filter #9. Closed effluent valves to drain,
will begin repairs tomorrow 5/13 once draining is complete.
• Out of Service
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• Operates in manual
Sand Filter #13
• Evaluated Sand Filter #13 to diagnose backwash pump issues.
Troubleshooting will begin tomorrow 5/13.
• Out of Service
• Operates in manual
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May 13, 2022
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washing vehicles. It may be their lunch break, but don't believe this is an ethical practice using
City resources to make a secondary income or receive lunch as payment for services provided.
• Sent all invoices to Ramona for her records. (Only MES Maintenance invoices)
• Received quote for replacement pumps at Sand Filter. Each pump is $9,288 and want to purchase
at least 12 to begin. DPW will let Greg Stehli know Monday if they have any on order. Pumps are
10–12-week lead time. Once we have confirmation whether DPW has any on order, I will send
quote up the chain for approval.
• DPW still working to give MES a complete report of all open work orders. (I believe this to be
crucial tool in accomplishing our goals)
No Back River employees seem to know how to run a report in their work order program
(ELKE)
• Small crew onsite today
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• Grass around the facility (inside of the gate) is waist high, with vines and poison ivy growing in
many commonly used pathways. City maintenance has even reached out to MES maintenance to
ask if they had staff to assist with cutting grass.
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Thickening Sludge Pump #2 – Rebuild (before & after)
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Inspected actuator valve to ensure all opened and closed manually in local. The
problem is on the control side and the task will be handed to the instrumentation
department.
In service
Operates locally
• Process (Activated 3)
Sludge Pumping Station #3 RAS Pump 11B
Attempted to change bearing packing, loosened packing seal and could not get
positive shut off on valves. Packing has been tightened back down so the pump
can continue to operate. Another point of shut off will need to be located to
replace packing.
In service
Operates in manual
• Process (Activated 3)
Clarifier 15B
Conducted repair of broken scum arm. Installed new bolts and arm back in place.
In serv ice
• Process (DAF Sludge Thickening)
Thickener Sludge Pump 1
Had operator shut pump down and isolate valves to remove clog in pump feed
line. Once removed had operator test pump and make sure level was going down.
In service
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Building D Recirculation Sludge Pump #10
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Blower Water Booster Pump #2 – seized potable supply valve
Clarifier 15B Scum Arm – Before Clarifier 15B Scum Arm – After
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May 18, 2022
Page | 206
Photos
• Car Washing on Back River Site (above)
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APR Recirculation Pump #2
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Dangerous Open Electrical Trough- sludge pump bldg. 4
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• Met Joe Wright and Tim Wolfe onsite today to formulate a solution to yesterday's problem with
the diminished pumping capacity at the APR. This was causing a bottleneck to sending enough
sludge to the downstream dewatering units. We decided to first bypass the APR and feed sludge
directly to the ESDs. Then we will refill the hi-rate digesters because they were low in volume.
Finally we directed MES Maintenance to repair several APR pumps as a priority. We should have
the City's centrifuges back online tomorrow and Synagro's temporary dewatering up and running
on Monday.
• Synagro's pelletizer shut down one dryer train today due to elevated TSS in their fire suppression
water supply. Tim Wolfe and I visited the pelletizer facility to scope out where the City water is
supposed to go. Tim told me that United Rentals is supposed to be onsite Monday to start
installing the potable water line.
• I completed all of my assigned sections of the Assessment Report. Only my portion of the
Recommendation section remains.
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Sludge Pump House 4 Actuator Connections
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Sludge Pump House 4 Actuator Connections
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May 20, 2022
Page | 214
Thickened Sludge Pump #7
Page | 215
APR Recirculation Pump #2
Page | 216
Maintenance: Wayne Jackson
Work Performed
• Process (Gravity Belt Thickening)
Thickened Sludge Pump #7
Conducted installation of trough drain line, replaced damaged gasket and
tightened flange bolts, tested, and returned to service.
In service
Only runs in bypass
• Process (EGG Shaped Digesters)
APR Recirculation Pump #2
Continuing break down and rebuild of pump and bearing housing. We will need
replacement mechanical seals to complete the rebuild.
Out of Service
• Process (Activated 3)
Sludge Pump Building 4 Actuators 14 A/B, 14A, 14B
Replaced broken and damaged wires, cleaned corrosion from terminals. Returned
power to actuators, tested, and returned to service.
In service
Operates locally
Page | 217
Sludge Pump Bldg. #4 Actuators 14AB, 14B – new wire installed
Page | 218
Sludge Pump Bldg. #4 Actuators 14AB, 14A, 14B – new wire installed
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Evaluated Air Compressor #3 for not operating. Turned on switch and returned
power, tested, and returned to service.
In service
Air Compressor #1
Conducted evaluation of Air compressor #1. Found compressor locked up due to
no oil. DPW Supervisor Harry was informed and will order a replacement
compressor.
Out of Service
Thickened Sludge Pump #3B
Conducted evaluation of Thickened Sludge Pump 3B for not operating. Found
broken belts, replaced belts, and attempted to test and found carter drive to be
bad. Began to break down carter drive and bearing housing. Will continue rebuild
tomorrow 5/24.
Out of Service
• Process (EGG Shaped Digesters)
APR Recirculation Pump #1
Continuing breakdown and removal of APR Recirculation Pump #1. Will begin
rebuilding the pump once mechanical seals arrive.
Out of Service
Air Compressor #3
Page | 220
Air Compressor #1
Page | 221
Thickened Sludge Pump 3B – Control Panel & Junction Box with duct tape
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Thickened Sludge Pump 3B – Sludge Judge found in pump
Page | 223
May 25, 2022
Page | 225
Thickened Sludge Pump 3B Install
Page | 226
DNF Level Transducers
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Thickened Sludge Pump #3B
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• Continued working on our Assessment Report. Was tasked with writing a recommended
improvements section , and a section on how we obtained sludge permits.
Worked with DPW Electricians to T&R control fault for Polymer Recirculation
Pump #1. Breaker was tripped & VFD needed to be reset. Flushed discharge line
for Polymer Recirculation Pump #2 & tested.
In service.
Operates in manual.
o Thickened Sludge Pump #3B
Assembled new 8” intake line & began install, will complete 6/2. Discharge valve
is still broken in closed position.
Out of Service.
• Spoke with Heyward Valves/Evoqua and requested an evaluation of all the Gas compressors,
rotary valves and control panels associated with the high-rate digesters.
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