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MSD’s $ 850 Million CSO Overflow Basin Plans ignore flood of rain water from parking lots

    A large concrete sewer overflow basin will be constructed by MSD contractors at the old Public Works property at Logan and Breckinridge Streets next to the concrete channel of the South Fork of Beargrass Creek. Integral to the basin construction is a separate,  $ 29.4 million dollar contract to install a large capacity sewer interceptor pipe running from west of the  Medical Center at Poplar Level and Eastern Parkway along the concrete creek channel to the CSO Basin.

    According to the 2012 Integrated Overflow Abatement Plan Update, the Logan Street CSO Basin was “upsized” between its 2009 projected size of 11.83 million gallons of overflow storage to the 2012 projected size of 16.6 million gallons. The price jumped from

$ 30.3 million dollars in 2009 to $ 52.2 million in 2012. Much of the millions of gallons of overflows to be captured by the CSO basin could be avoided by requiring green infrastructure on major parking lots.

Mid-city Mall and CSO overflow     HERE

Mid-city Mall multi acre parking lot drains to CSO 152

Traditional JCPS School parking lot at Morton and Edward St. Here,  an area drain  dumps rainwater into the combined sewers. 1 acre-inch = 27,154 gallons that could be absorbed by bio-retention rain gardens that reduce heat island effect.

    The combined cost of the $ 52.2 million Logan Street Basin and the new interceptor,  according to the 2012 data produced by MSD and the recent contract No. 350,941 awarded to Garney Companies Inc. for $ 29,431,087 amounts to about $ 81.6 million dollars.

This enormous expense of high maintenance concrete basins and automated CSO diversion and relief gates opens MSD to questions of cost inflation and corruption. Most glaring is the fact that MSD has not proposed comparatively low cost green infrastructure projects to remove and divert rainwater from getting into the sewer system in the first place in the Logan Basin system.

I walked the area recently and photographed many parking lots and road area drains that could be removed from the sewer system reducing the size of the overflow basin. MSD should present the potential basin reduction possible in a cost comparison where green infrastructure is implemented.

MSD has complained that Metro Council has not granted it the authority to compel large parking lot owners -by ordinance- to install rain barrels, rain gardens or other rain harvesting measures on private property.

Much of the information for this article comes from MSD’s webpage  HERE

Scientists calculate  annual tire wear particulate in Japan would fill Tokyo Dome stadium

    A well researched open access article distributed under the Creative Commons Attribution License, is available online and concludes:

The annual volume of dust resulting from tire wear, calculated based on the number of automobiles registered in Japan, was 1,747,245.4 m3.[cubic meters] To put it simply, this translates to approximately 1.4 times the volume of the Tokyo Dome, a famous Japanese baseball stadium. Particulate substances are categorized into three groups depending on their size, and dust resulting from tire wear is classified into the coarse particle mode along with mold spores, pollen, and dust produced from brake pads. This study examined whether or not tire dust causes health damage similarly to pollen, a particulate substance in the same group. There were 38/cm2  dust particles resulting from tire wear on a busy road in Osaka Prefecture, and this number was larger than that of cedar pollen/cm2 (35), a cause of hay fever, identified in Hokkaido. The results suggest that tire dust may also adversely affect the health of people if any of its constituents has a toxicity or causes allergies.

See, Masakazu Yamashita, Shohei Yamanaka,

Dust Resulting from Tire Wear and the Risk of Health Hazards, Journal of Environmental Protection, 2013, 4, 509-515 Published Online June 2013 (

BadwaterJournal previously estimated that:

“Every year, the abrasion of motor vehicle tires from some 280 million to 290 million U.S. vehicle tires, releases 4 times the Deepwater Horizon spill volume in TWP (tire wear particulate) composed of zinc, latex rubber, carbon black, polyaromatic hydrocarbons and other constituents. This volume is equivalent to 4 ultra supertanker capacities of tire rubber particulate spilled into the U.S. environment every year.” See related webpage ‘Tire Story‘     HERE

    “A common respiratory disorder caused by dust is pneumoconiosis. It is usually caused by inhaling dust from soil, metal particles, and other inorganic substances, or mineral dust while working over a long period of time. These dust and fine particles accumulate in the lung, serving as nuclei, and cause fibroplasia and pulmonary fibrosis.

In patients with pneumoconiosis, fibrous tissues are formed and the tissues of the alveoli, bronchioles, and blood vessels are destroyed. Patients develop dyspnea, and become vulnerable to pulmonary tuberculosis, secondary bronchitis, and other complications. Agents responsible for causing pneumoconiosis and occupations associated with it are listed in Table 5 [13]. Talc, black lead, and carbon, shown in Table 5, have been reported to cause pneumoconiosis in the process of producing raw materials of tires. As professionals work, these sub- stances accumulate in their bodies little by little every day, and they eventually amount to an enormous volume. In general, the volume of accumulated tire dust is not large enough to cause pneumoconiosis, although the concentration of tire dust contained in the air above heavy traffic roads may be high enough to cause chronic bronchitis and bronchial asthma.


EPA “Report on Environment” is a cover-up of failed regulation of

ultra-fine particulate pollution


Stephanie Sanzone, EPA     Re:

EPA's Report on the Environment (ROE) 2014:

Please communicate my comments to the appropriate committee members.


I object to the present form and content of the ROE Particulate Matter Emissions chapter. EPA is producing a misleading report that misinforms Congress and will result in failure to properly assess the public health dimensions of ultrafine particulate anthropogenic emissions, leading to policy failure to regulate same.

REQUEST:  Update and rewrite the Particulate Emissions Chapter to explain the failure of gravimetric method air quality monitoring to detect the major health threat of UFP.

Describe the necessary changes in monitoring methods--particulate counts--to detect concentrations  of UFP in urban traffic corridors. Describe the penetration of UFP deeper into lungs and crossing blood cell barrier and nervous system. Describe the changes to automobile  combustion engineering to make smaller particulate to avoid NAAQS violations from PM2.5 or PM10 mass concentrations

Describe EPA complicity with transportation industry in delaying effective monitoring despite a decade of peer reviewed research on the threat of UFP.

  ARTICLES INCLUDED:  Ultrafine Particles on and near Roadways: Exposure Assessment and Mechanism Yifang Zhu , Ph.D. Environmental Health Sciences Department Fielding School of Public Health University of California Los Angeles

[available for download online--Google search the title]

Impact of Vehicle Development and Fuel Quality on Exhaust Nanoparticle Emissions of Traffic   Huan Liu, Topi Rönkkö,and Jorma Keskinen

Environ. Sci. Technol. 2013, 47, 8091−8092

    EPA is revising its 2014 Report on the Environment--a foot dragging exercise if there ever was one. I sent the letter shown at right. EPA has been aware for a decade that the mass gravimetric NAAQS protocols that are the basis of MOVES and MOBIL emission factors do not account for heavy urban concentrations of ultra-fine particulates. Many peer reviewed journal articles and EPA public funded studies demonstrate that severe health impacts are affecting millions of citizens because EPA’s NAAQS monitoring excludes ultrafine particulate number concentrations.   The consensus of peer reviewed is that UFP penetrate deeper in the lungs, blood and nervous system than coarse particulates which are reported under NAAQS.

"The exhaust of modern vehicles contain nanoparticles.  They differ from soot particles by their size, being typically smaller than 30 nm in diameter, by formation process, and by physical and chemical characteristics. Consequently, the effect of technical abatement methods on them is different. Due to the small particle size and the formation process, where most of the particle mass is formed during exhaust cooling process in the atmosphere, the present

emission regulations do not take into account these particles.

However, several urban air studies conducted in the vicinity of traffic, report ambient air particle number

size distributions dominated by nanoparticles."


    The MSD concept drawing of the Logan Basin at left. Buildings in the area have roof leaders disappearing into the collection system. The chain link fenced basin location just above.

The CSO basin will have a pump station that lifts the sewer overflow volume out of the creek channel and then gravity flows the sewage back in dry weather through sewer interceptor pipes all the way to the treatment plant on Algonquin Street in the west Louisville area. The circles on the drawing below appear to represent ventilation ducts.