Richmond's sewer system included 31 overflow outfalls along the James River
Source: City of Richmond, Combined Sewer Overflow (CSO) Project
Richmond's sewer system included 31 overflow outfalls along the James River
Source: City of Richmond, Combined Sewer Overflow (CSO) Project
Richmond was one of the first cities in Virginia to create a system to carry sewage away from the urban center. The city covered Shockoe Creek and converted the natural drainage in Shockoe Bottom into two underground systems, a 17-foot by 12-foot concrete sewer known as the Shockoe Box and a pressure conduit known as the Shockoe Arch. Sewage was dumped, untreated, in the James River. A wastewater treatment plant was constructed in 1958.
The state capital ended up with 12,000 acres draining into a combined sanitary/stormwater pipe system, the largest Combined Sewer Overflow (CSO) area in Virginia. There are 31 overflow outfalls along the James River or its tributaries (especially Shockoe Creek and Gillies Creek). About two-thirds of the city's total CSO Area is in the Shockoe Basin drainage.
Richmond built its wastewater treatment plant in 1958 and located it on the southern bank of the river, near the Port of Richmond. The city built a 96-inch Shockoe Creek Interceptor pipe to gather waste/stormwater from the north bank, plus twin 66-inch pipes to carry that polluted water underneath the river from the downstream edge of Chapel Island (near Great Shiplock Park) to the wastewater treatment plant on the opposite side of the river.
One third of Richmond has a consolidated sanitary/stormwater system. Like Lynchburg and Alexandria, Richmond separated some sanitary and stormwater pipes to reduce the amount of untreated waste that was discharged into the James River during rainstorms. The costs and disruptions caused by construction to separate pipes limits the benefits of that solution, so it designed a system to store the peak flows of sewage/stormwater.
in two-thirds of Richmond, sewage and stormwater are mixed in a Combined Sewer Overflow (CSO) system
Source: Richmond Department of Public Utilities, Richmond's Combined Sewer System
Richmond's primary solution in its Long Term Control Plan (LTCP) was to build a massive storage system to capture the surge of stormwater mixed with raw sewage after a rainstorm, then treat the captured water after the storm subsided and flows dropped to normal dry weather conditions. Two underground tunnels were excavated in the Petersburg granite to store 57 million gallons. The hard granite minimized the amount of groundwater that would infiltrate into the tunnels when they were empty, and blocked the wastewater from leaking out when the tunnels were full.
In 1983, the city built the Shockoe Retention Basin on Chapel Island just downstream from the former mouth of Shockoe Creek. It was designed to capture 35 million gallons of the initial surge or "first flush" of stormwater runoff from a rainstorm. The Hampton-McCloy Tunnel, designed to capture 7 million gallons, was completed in 2003.
At the beginning of a storm, the initial stormwater runoff contained the greatest amount of contaminants that had accumulated since the last storm. By capturing the dog waste, oil and grease from automobiles, and litter in the first flush, Richmond could reduce the impact of releases when heavy storms exceeded the storage capacity of the Shockoe Retention Basin and forced outfall gates to open.
The Shockoe Retention Basin has captured up to 35 million gallons of combined sanitary/stormwater flows, while pipes leading to it stored 15 million more gallons. The system can be filled with 50 million gallons in less than 30 minutes during a large rainstorm. That captured flow then drains over four days, released as the wastewater treatment plan has capacity for processing.
Before completion of projects in the Long Term Control Plan, Richmond was treating only 62% of the total volume in the combined sewers. When the other 38% flowed directly into local streams and the James River, raw sewage waste was diluted with stormwater but the smell was clearly evident.1
Shockoe Retention Basin on Chapel Island (red outline) is on the north bank of the James River, not far from the State Capitol (yellow circle)
Source: ESRI, ArcGIS Online
The underground retention basin included an aeration system intended to keep solids in suspension until the storage was emptied. By 2008, however, a 10-foot thick layer of sewage had settled on the bottom, similar to the solids that accumulate on the bottom of a septic tank.
The city had not designed a clean-out option in 1983. It had to spend over $12 million to build a ramp down to one wall of the Shockoe Retention Basin, cut a hole in the wall, and use backhoes to remove the solidified sewage.2
rainfall required for discharge from 29 different overflow outfalls in Richmond (before construction of the Hampton McCloy Tunnel)
Source: Richmond Combined Sewer Overflow (CSO) Water Conditions
Storing that initial runoff helped the city avoid overwhelming the wastewater treatment plant with too much inflow. Some Richmond CSO outfalls discharge sewage less than once/year on average, but others regularly pour a mixture of water and untreated waste into the James River.
CSO6, one of 29 overflow outfalls in Richmond, has a pattern of discharging polluted water at least four times in every month of the year
Source: Richmond Combined Sewer Overflow (CSO) Monthly Reports (June 2016)
To stop discharges from two CSO outlets upstream from the river rapids that attract a great deal of recreational use, the city built a $50 million, 600-foot long, 14-feet wide underground tunnel between Hampton and McCloy streets (the Hampton McCloy Tunnel) in 2003.
The city located the underground storage for 7 million gallons in Petersburg granite, to minimize the amount of infiltration. Engineers designed the tunnel so water from the James River and Kanawha Canal could be used to flush out the solids. The tunnel was carved out of the bedrock 70 feet below the sewer line, so special engineering was required to dissipate the energy of the water as it dropped into the tunnel.3
The underground retention basin and Hampton McCloy Tunnel could trap 60 million gallons of combined sewage and stormwater, but a 10-minute rainstorm can completely fill up the underground storage. Richmond still discharged untreated waste each year, and bacteria levels in the James River exceeded state standards for half the weekends in the summer of 2016.
The capture-store-treat approach would require additional projects,additional funding, and additional years of construction. As one Richmond official noted:4
the wastewater treatment plant (WWTP) and the Combined Sewer System (CSS) were built in stages
Source: City of Richmond, CSO Interim Plan Report (p.1-6)
Eliminating the discharges from overflow outfalls on the western side of the city resulted in cleaner water for recreational use downstream in James City Park, especially for popular rafting/kayaking activity at the Fall Line. However, cleaning up the pollution in the West End of Richmond exposed city officials to charges of environmental prejudice. The city's population on its western side is wealthier and includes less minorities.
the Hampton McCloy Tunnel stretches from McCloy Street near I-195 to Hampton Street east of Maymont Park, and red dots in the East End indicate where untreated sewage is still released as of 2016
Source: Richmond Combined Sewer Overflow (CSO) Project Overflow Points
EPA conducted a "knee-of-the-curve" economic analysis to define a point where increased clean-up expenses in a Long Term Control Plan would no longer be matched by a reasonable set of increased environmental benefits. For its Combined Sewer Overflow project, Richmond proposed to reach compliance with Clean Water Act standards for 92% of the James River.
Using EPA's willingness to consider costs as well as benefits, Richmond told to the State Water Control Board and EPA that the costs to implement 100% of the possible clean-up actions would fully exceed the benefits.
economic analysis indicates a point ("knee of curve") where incremental costs to reduce pollution increase dramatically after 92% of the James River miles comply with water quality standards
Source: State Water Control Board, City of Richmond Reasonable Grounds documentation
Richmond's proposed solution for avoiding the costs of the remaining 8% includes reclassifying Gillies Creek through a Use Attainability Analysis. Reclassification would exempt the city from reducing pollution enough to permit recreational use. Reclassifying the creek would eliminate recreational use as an objective would lower the threshold for clean-up.
after Richmond's wastewater treatment plant (WWTP) reaches its maximum inflow, the excess water/waste is discharged directly to the James River and its tributaries through different overflow outfalls
Source: Robert Steidel, Accommodating CSO Flows/Loadings in the Chesapeake Bay Nutrient TMDL (Wet Weather Partnership 2010 Workshop Presentation)
From where the creek enters the city to its confluence with the James River near the old Fulton Gas Works, the natural channel of Gillies Creek was replaced with concrete in 1974. Paving the creek reduced flooding and sediment erosion, but did not reduce the excessive levels of bacteria that contaminate the water.
The city claimed it would have to spend $300 million to construct a 30-million gallon storage tunnel to capture stormwater and divert it to the wastewater treatment plant. The city also noted that Gillies Creek:5
Richmond's proposal for a Use Attainability Analysis notes that Gillies Creek has a normal flow of water only 2" deep except in rainstorms, offering little opportunity for swimming or wading, so Primary Contact Recreation is not currently an existing use
Source: State Water Control Board, City of Richmond Reasonable Grounds documentation
In 2011, the State Water Control Board rejected the city's request to conduct a Use Attainability Analysis. The city could conduct its own study, but the state agency did not want to appear to endorse a solution that would not require any reduction in the pollution levels.6
Five years later, the city viewed Gilles Creek more as an asset rather than as an open sewer. The Gillies Creek Greenway was proposed, to create a pedestrian/biking corridor as part of revitalization in the East End. At the James River, the greenway would connect to the Virginia Capital Trail near the new Stone Brewing Company development at the former Intermediate Terminal. The other end would be anchored at the former Armstrong High School, in a low-income area of the city.7
Richmond chose to reduce CSO overflows on the West End first, and delayed cleaning up Gillies Creek on the East End
Source: ESRI, ArcGIS Online
The Virginia Department of Environmental Quality required Richmond in 1985 to develop and implement a Combined Sewer Overflow (CSO) control program. Consent Orders have been issued and revised several times since then.
The 2005 consent special order from the State Water Control Board allowed continued discharges while Richmond implemented the 2002 Long Term Control Plan (LTCP). Recognizing the massive cost involved, the state's order failed to define when the city had to eliminate the overflows into the James River. In 2018, over three billion gallons of untreated sewage/stormwater were released.
In 2020, the General Assembly set a deadline for Richmond to minimize discharge of untreated waste by 2035. Alexandria and Lynchburg were required to finish by 2027; Richmond was granted extra time because of the greater scope of the challenge.
The state legislature required Richmond officials to produce an interim plan to address discharge by 2021 and a final plan by 2025. The city initially estimated the cost to be around $500 million.8
The interim plan produced in 2021 examined 18 possible projects, and recommended spending $33 million to complete 10 of them first. When the interim plan was drafted, there were five projects required by the 2005 Consent Order which had still not been completed. Two of them were replaced by interim plan projects. Completion of the remaining three was delayed because of their relatively low cost-effectiveness for reducing E. coli bacteria in the receiving waters.9
the 2021 CSO Interim Plan Report recommended 10 projects
Source: City of Richmond, CSO Interim Plan Report (July 1, 2021)
the 2021 CSO Interim Plan Report recommended projects to divert additional flow to the Hollywood Interceptor and away from the CSO 3 Pipeline
Source: City of Richmond, CSO Interim Plan Report (July 1, 2021)
the 2021 CSO Interim Plan Report recommended three Dynamic Underflow Control projects to divert additional wet weather flow to the Gillies Creek Interceptor
Source: City of Richmond, CSO Interim Plan Report (July 1, 2021)
After the US Congress passed the American Rescue Plan in 2021 to stimulate the economy during the COVID-19 pandemic, Richmond requested $30 million to fund the 10 projects in the interim plan and $833 million to fund all the projects that were expected to be proposed in the 2025 final plan. Richmond had already spent over $300 million, so the total cost to eliminate overflows was projected at greater than $1 billion.
Combined with requests from Alexandria and Lynchburg, the state sought $1.4 billion for Combined Sewer Overflow (CSO) upgrades. If customers of the utility ("ratepayers") in Richmond were required to finance $833 million for the city's projects, rates were projected to triple from from $700 to $2,200 per year. One of the members of the State Senate, a key sponsor for passage of the the 2020 legislation setting the 2035 deadline, commented about the $833 million cost estimate:10
Governor Northam allocated $50 million to Richmond, which the city matched with another $50 million. The Governor also included another $100 million in fis FY22 budget proposal, which the city also committed to match. While far short of the $833 million needed to complete the project, that total would fully fund the projects in the interim plan.
When the interim plan projects were completed in 2027, the city expected to capture 91% of the overflows. To intercept 99% of the overflows was projected to cost roughly $800 million more. Finding that $800 million was a difficult challenge for Rochmond officials.11
In 2020, Richmond's entire general fund budget was $770 million. The ability of Richmond to fund another $833 million in sewage projects by 2035 was questionable. The Environmental Protection Agency had scheduled completion of the Long Term Control Plan for Lynchburg to put a cap on tax increases required to fund the project, but Richmond taxpayers had no such protection in the legislation passed by the General Assembly.
Richmond's mayor made clear, after getting just $50 million from the American Rescue Plan funding, that more assistance would be needed:12
While the General Assembly mandated Richmond reduce its flow of untreated waste into the James River, the State Water Control Board and the Virginia Department of Environmental Quality (DEQ) were more relaxed in dealing with overflows from Henrico County's sanitary sewer system. In 2021 the Chesapeake Bay Foundation, James River Association and Environmental Integrity Project sued the county for failing to fix leaks in its sewer pipes that had allowed 66 million gallons of raw sewage to flow into the James River since 2016. In addition, since 2019 the enrico County Water Reclamation Facility had violated its state permit 10 times, releasing excessive amounts of sediment.
Sanitary Sewer Overflows (SSO) occur when rainfall infiltrates the sanitary sewer system and overloads the pipe capacity
Source: Environmental Integrity Project, Henrico Photos and Video
The State Water Control Board and the Virginia Department of Environmental Quality (DEQ) response to the problems was to sign yet another consent order with Henrico County, the fifth consent order since 1990. The county also agreed to pay a $200,000 penalty.
The environmental organizations were not satisfied with the state response. They noted that the consent order did not include a plan or deadline for systemic improvements, and complaimned that the "piecemeal approach" with different consent orders would continue to allow raw swage to escape Henrico County's pipes during times of heavy rainfall. Unlike Richmond, Henrico County had not created a mechanism for notifying the public each time the sanitary sewer system overflowed.
When filing its lawsuit, the Environmental Integrity Project noted:13
sewer overflows on October 30, 2021 are highlighted in red
Source: RVAH20, Combined Sewer System Overflow Events
The 2022 General Assembly considered legislation that would require Richmond to accelerate its plan to end overflows by imposing a 2030 deadline, rather than maintain the 2035 deadline imposed by the legislature two years earlier. City officials warned that faster action would require raising wastewater rates paid by customers by 232% to more than $2,500 a year.
Toilets in the the Capitol and Executive Mansion send their sewage through the Combined Sewer Overflow system. Pipes 27 feet in diameter in Shockoe Bottom help discharge two billion gallons of sewage/stormwater annually into the James River, almost 10% of the flow in the city system. State Senator Chap Petersen, a Democrat who supported the faster deadline, said:14
"the General Assembly ultimately rejected a proposal in 2022 to accelerate the deadline for eliminating Combined Sewer Overflows in Richmond
Source: Virginia General Assembly, Substitute for SB354 for S-Finance and Appropriations Offered on 2/8/2022 (2022 Session)
One possible source of additional funding was the Infrastructure Investment and Jobs Act, passed by the US Congress in 2021 after the American Rescue Plan. The infrastructure bill included $50 billion for upgrading water and wastewater systems, and prioritized financially distressed communities. About 20% of the ratepayers for sewer service in Richmond were impoverished. Tripling sewer fees from $65 a month to $170/month, in order to raise $800 million more to eliminate wastewater overflows, would impose a major burden on those residents.
Environment Protection Agency Administrator came to Richmond in early 2022. During a tour of the Shockoe Retention Basin, former Richmond mayor and current US Senator Tim Kain said:15
The bill to accelerate the state-imposed timeline, SB354, passed the State Senate on a 36-4 vote in 2022. However, the legislation died in a House of Delegates subcommittee on a 5-4 vote. The proposed deadline was made conditional on the availability of additional Federal/state funding, but the one Republican to join the Democrats in voting against the faster timeline still said:16
The General Assembly did provide an additional $100 million when it reached a budget compromise in May, 2022.17
Sanitary Sewer Overflows (SSO) from Henrico County impair streams, together with Combined Sewer Overflows (CSO) from Richmond
Source: Environmental Integrity Project, Map 1. Sanitary Sewer Overflows and Waterways Impaired by Bacteria
in 2021, about 10% of the peak flows of combined sewage/stormwater were still flowing untreated into the James River
Source: Richmond Department of Public Utilities, RVAH2O
mixing sewage and stormwater in a Combined Sewer Overflow (CSO) system can result in untreated waste flowing into nearby streams
Source: Richmond Department of Public Utilities, Richmond's Combined Sewer System