UPDATE: January 15, 2014
THREE SEWER PLANTS ON HARPETH in FRANKLIN and Williamson County
VIOLATING POLLUTION LIMITS IN STATE PERMITS:
HRWA sends notices of intent to sue under Clean Water Act
press release issued January 15, 2014
The City of Franklin, Berry's Chapel Utility, and Cartwright Creek LLC were sent a 60-day notice of intent to sue on January 13, 2014 by the Southern Environmental Law Center on behalf of HRWA detailing repeated violations of pollution limits. In the past 5 years, approximately 1495 numeric violations (violations related to the amount of pollutants discharged), 18,600 monitoring violations (days out of compliance in the monitoring period), 385 reporting violations, as well as hundreds of other violations of the permits held by the three facilities, have been identified. (see notices below for details, including charts). The Clean Water Act and the Tennessee Water Quality Control Act require sewage treatment plants to obtain permits for the discharge of their treated wastewater. The permits held by these three facilities limit discharge amounts and set specific requirements for monitoring and reporting these discharges.
60 day notice of intent to sue to City of Franklin
60 day notice of intent to sue Berry's Chapel Utility
60 day notice of intent to sue Cartwright Creek LLC
Photo of raw sewage overflow from sewer line in River Rest in May 2013. Raw sewage in drainage just upstream of Cartwright Creek.
The Harpeth River does not meet state Water Quality Standards in the summer. Reduction in discharges from sewage treatment plants from the city of Franklin and two small facilities in Williamson County is needed in order to increase oxygen levels in the river.
HRWA is calling for a new pollution reduction plan to be done. One important need is for a river-basin wide water quality monitoring program to provide key data. HRWA has prepared examples and options for a collaborative effort under a Technical Advisory Committee. Some aspects of this are in the new draft sewage treatment permits. HRWA has prepared a draft Harpeth river-basin comprehensive monitoring plan with input from various state and federal agencies and experts to jumpstart the work of the TAC. This map shows the monitoring locations. See below for background. Here are HRWA's detailed comments:
ASK the state to:
1. Start the process for a new pollution reduction plan to be overseen by a Technical Advisory Committee.
2. Require all 3 sewer permitees to participate in funding the needed river studies to set a new required pollution reduction plan.
3. Set the city of Franklin's permit limits at the CURRENT levels the sewer plant currently produces and for the two smaller plants as well. The city's current levels are less than HALF of what the permit currently allows and will help keep the river's water quality from degrading as the city's is designing sewage treatment expansion while the work over two years to get critical river data and a new pollution reduction plan is done.
**Where you enjoy paddling, swimming, fishing and having fun.
**How much you appreciate the Harpeth and want to see it meet all state standards year round.
**Where you have seen problems in the river such as areas in the river that are green and/or have lots of algae. Too much algae, especially long strands and a strong green color, mean that too much pollution that is feeding the algae is in the river.
**Where you have seen or noticed possible sewer pipe collection problems by spotting toilet paper around manholes or in a creek, and or smelled strong sewer odors.
**Any other relevant concerns or information about the sewer systems: City of Franklin, Berry's Chapel -- that serve Cottonwood, Legend's Ridge and River Landing, or Cartwright Creek-- that serves River Rest. See map below.
For more information and to work with HRWA, contact us and sign up for our updates!
Send your comments to Gary Davis, Gary.Davis@tn.gov , (615) 532-0649, at TN Department of Environment and Conservation.
Why the Harpeth River is not Meeting Water Quality Standards in the summer:
Do you enjoy swimming, paddling, tubing, fishing, and playing on the Harpeth River? No matter where your favorite spot is along the main Harpeth, from the headwaters in Eagleville down 90 river miles to the Harpeth River State Park in Cheatham County, the river does NOT meet water quality standards during the summer. TDEC counted close to 300,000 people who visited just the highly popular Harpeth River State Park in 2010.
In 2010, for the first time, the 3 state sewage treatment plant permits that serve all the growth in Franklin and northern Williamson County were revised simultaneously as a step toward reducing pollutant load into the river. While some aspects of the proposed permits are tighter, they still allow twice as much pollutant load than the river can handle in order to meet state water quality standards based on analysis done by the EPA.
IN 2012, the city of Franklin consultant's presented a proposal for a long-term sewer and water plan. It not only did not improve the water quality in the Harpeth, but was proposing a new sewer plant just upstream of the city's drinking water plant. The "Toilet to TAP" would have the city's drinking water customers be the first in the country to do this. See details. The City aldermen did not support this proposal, but worked from this significant study to choose some logical steps forward.
BACKGROUND: The Harpeth River in the summer is “effluent dominated."
For over a decade, studies by the EPA, TDEC, HRWA and others, have recorded oxygen levels in the river water well below state standards. Dissolved oxygen levels in the river water have been recorded at less than half the state standard of 5 mg/l and even lower, at levels that stress fish which have trouble breathing and feeding and will not reproduce. See two charts below that show TDEC data and HRWA results from our 2006 Dissolved Oxygen study. (This report includes all D.O. data from TDEC and EPA up to this year. More recent studies from 2007 and 2008 are in a separate report.) Pollutants from sewer plant discharges, septic seepage, and urban and agricultural runoff feed the growth of algae and bacteria that cause the water’s oxygen levels to drop very low and give the river a green color when in healthier conditions it would be clear.
The largest pollutant sources are the sewer plants that serve Franklin and Northern Williamson County that discharge into the Harpeth in one 17 mile stretch (Franklin, Lynwood that serves Cottonwood, and Cartwright Creek that serves River Rest). The largest sewer plant in the entire river system is the city of Franklin’s with a design capacity of 12 million gallons per day (12MGD). In comparison, the flow in the Harpeth in downtown Franklin can be as little as only 1/2 million gallons per day. This is the extreme low flow condition for the Harpeth that the sewer permits are supposed to be designed to protect. The other two sewer plants are much smaller (each around ½ million gallons a day), but still large enough to affect the river’s water quality as seen in the river dissolved oxygen studies and discussed in a water quality analysis funded by HRWA.
Over ten years ago, poor water quality conditions and past sewer plant problems in the Harpeth River have been the focus of concerned citizens who felt compelled to sue in years past that led to the EPA’s pollutant load reduction plan (known as a TMDL) for the Harpeth in 2004 and improvements with Lynwood that was violating its permit under prior owners. In recent years, Williamson County, Franklin, TDEC, and the current sewer plant operators have all invested in efforts that will improve water quality. Williamson County led the way to hook up the neighborhoods on septic that were experiencing failures around Lynwood and northern Franklin to central sewer. TDEC helped this effort by reserving half the new capacity of Lynwood for these neighborhoods when they approved that plant’s expansion. Now these areas will be treated by Franklin which has a much more efficient system. Franklin built a new plant that produces very clean effluent, well below its current and proposed permit limits, and is only at half capacity. In addition, the city has been forward thinking in developing alternatives for discharging treated effluent with its effluent reuse program. This means the city has the ability to limit the amount of effluent it discharges in the summer into the Harpeth, while the rest is used to irrigate several golf courses. Franklin’s set a goal to reduce its effluent discharge into the Harpeth in the city’s Sustainability Action Plan.
HRWA's GOAL FOR THE HARPETH RIVER: Meet Water Quality Standards and Maintain Natural River Flows
Draft and final permits and further information is available by contacting Gary Davis, Gary.Davis@tn.gov , (615) 532-0649, at TN Department of Environment and Conservation.
Comments submitted by the HRWA and Dissolved Oxygen Studies are all accessible in the Library of this web site. HRWA comments to TDEC on the revised permits: December 2009, and additional comments for the public hearing in August 2010.
Not all of the attachments to HRWA's comments nor comments submitted by other entities are on this web site. If you would like these documents, please contact, Dorene Bolze, Executive Director.