Friends of Lick Creek submitted a letter detailing our opposition to the WADC’s proposed wastewater treatment plant to TDEC on March 3. Read the executive summary below and read the full letter on the TDEC Data Viewer.
Summary of Objections to WADC Proposal to Build a Sewage Treatment Plant in Hickman County to Discharge into Lick Creek
- WADC’s latest submission does not address the fundamental flaws in the WADC proposal to build a treatment plant in Hickman County that would discharge up to 12 million gallons a day in into Lick Creek, an Exceptional Tennessee Water, on the basis that:
- Lick Creek is not a true long-term regional solution. Rather, it continues a band aid approach to creating infrastructure to support growth and simply adds another small stream that now faces negative impacts.
- The WADC proposal allows sewage from the plant to enter the Duck River watershed, one of the most biologically diverse waterways in the United States.
- Most discharge from the new plant would come from wastewater currently being sent to the existing Jones Creek plant, or from growth in Williamson and Dickson County. Only a small portion of the capacity would serve a portion of eastern Hickman County. This proves that the WADC proposal is not about growth in Hickman County.
- Hickman County residents would bear the increased costs from any growth to address other needed infrastructure, fire, police, etc. They would bear these costs whether they opt into sewer or remain on septic.
- In early March, the Friends of Lick Creek (FLC) submitted to TDEC a compelling and detailed rebuttal to the WADC’s proposal. The WADC submitted supplemental information to TDEC in December 2022. The FLC response outlines numerous ways that the WADC fails to meet the legally required “anti-degradation” analysis. In its response, the Friends of Lick Creek group demonstrates that:
- The WADC failed to consider the inherent economic value of conservation and preserving Lick Creek as a pristine waterway.
- The WADC failed to evaluate all reasonable alternatives, including a no action alternative, in its analysis. The analysis was purely a “straw man” exercise with a predetermined outcome in mind.
- The WADC failed to consider the negative “costs” of growth in its analysis: higher cost of living, increased traffic, overcrowding, reduction of vital natural resources and more.
- The WADC’s claim that growth could not occur without a plant discharging into Lick Creek is false. FLC showed that key indicators such as poverty rates, income levels and growth in businesses all exceeded the statewide average without the proposed sewer.
- The WADC could not show that the plant would not adversely impact the Coppercheek darter, a state listed (Threatened) species.
- The water quality model and data used for modeling impacts on the Creek were fatally flawed and could not support a conclusion that the proposed plant would not degrade Lick Creek.
- A permit to build a plant to discharge to Lick Creek must be denied. However, this issue is not a win or lose situation. The WADC can expand its capacity and address problems with its existing plant operations by looking to the Cumberland River as the true regional long-term solution. Utilizing the Cumberland River combined with additional measures such as reclamation,and infiltration repair to the Jones Creek plant, would effectively expand the WADC’s capacity. This route would protect Lick Creek and the Duck River, while still accommodating any growth that may occur.
On the WADC’s site, they have a FAQ page that lists the below questions and answers. We wanted to answer those questions as well. It is important that all facts are shared!
Why does WADC need a treatment plant in Hickman County?
WADC operates three wastewater treatment facilities in Dickson and Williamson Counties. Looking at projected growth patterns over the next 20 years shows that it makes sense to add capacity in East Hickman County. Currently, all Hickman County wastewater is pumped north under the I-40 to WADC’s Jones Creek plant in Dickson County.
Growth projections are very speculative and are not guaranteed. Hickman County thrives within its rural atmosphere and does not desire tremendous growth (i.e., subdivisions) that would require Hickman to have substantial sewage access. Even with the ambitious growth projections used by the WADC, more than 95% of the sewage discharge from a new plant will come from outside Hickman County. Wastewater from Hickman does not justify a new plant in Hickman County.
Currently, all Hickman County wastewater is not pumped north to WADC’s Jones Creek plant; only a small portion of the county sends sewage to Jones Creek, primarily from the East High School. The vast majority of Hickman wastewater is handled by individual property owners with septic or sent to Centerville’s treatment plant.
Why not just expand the Dickson County plants?
Projecting growth patterns in the region, we believe the area south of 1-40 will present the greatest need for additional wastewater treatment. Treatment plants are centrally built and located where service is needed.
WADC’s own plans for the new plant show it intends to divert flow from their current plants to the proposed East Hickman plant. The area of the most projected growth south of I-40 would be in Williamson and Dickson Counties, not Hickman County. Alleged growth in Hickman County is an excuse to sacrifice the county for the benefit of wealthier communities. We have learned that some of the same developers working in Fairview are looking to overdevelop in Hickman County if the new plant comes online.
It is almost always cheaper and more efficient to upgrade and expand existing facilities than site entirely new facilities, but that option has been given little consideration. Moreover, a recent report by a consultant demonstrated that the existing facility has significant leaks in the system such that they are wasting more than 50% of the capacity of the existing plant. The estimated cost of fixing those leaks to increase usable capacity is a tiny percentage of the cost of the proposed new plant.
Won’t releasing raw sewage into Lick Creek create problems with flooding and wildlife?
WADC won’t be releasing raw sewage. In fact, we’ll be treating the effluent to EPA and TDEC standards which are designed to protect the creek’s current uses, such as recreation and irrigation. We’ll also be testing compliance with water quality standards daily, with those test results being submitted to TDEC for regulatory oversight.
Wastewater treatment will not achieve the level of natural water purity that currently exists in Lick Creek; sewage plants such as proposed do not achieve 100% treatment. It is common for periodic spills of raw sewage to occur from collection systems and plants, including all three of WADC’s existing sewage systems at Dickson, Fairview, and White Bluff. Current permit regulations allow for some degradation, even if permits are fully met. Degradation is the lowering of water quality, such as lower dissolved oxygen as the remaining sewage decomposes in the stream. Permits require testing for some, but not all contaminants. Testing that is done does not occur each day for all contaminants, with some done only weekly, monthly, quarterly – or not at all, such as for pharmaceuticals and PFAS (dangerous “forever chemicals” found in sewage.)
Why Lick Creek?
Other release points adjacent to high growth areas of the WADC service area don’t have enough water flowing on a regular basis to accommodate the additional flow. Larger rivers like the Harpeth or the Cumberland would raise the cost of the plant because it would require long pipeline systems that make it cost prohibitive. Releasing the water into the Cumberland would require over 50 miles of new pipeline, 15 stream crossings and digging under I-40, a very expensive undertaking.
Lick Creek is not adjacent to a high growth area. WADC plans to build a pipeline up to nine miles long to get to Lick Creek from an area where they want to create growth by providing sewer service.
Going to the Cumberland River may not be the easy or inexpensive solution, and if the treatment plant were instead built in Dickson County, it would not require digging under I-40, but it would be a better alternative than discharging to Lick Creek. It seems the option has been given little consideration. WADC already has an intake pipeline from the Cumberland River and presumably an easement to get there, so we believe this option needs further examination.
Isn’t Lick Creek home to endangered species?
Lick Creek is home to a species of fish known as the Coppercheek Darter which TDEC lists among dozens of species “in need of conservation” but is not listed as a federally “endangered” or “threatened” species. The quality of the effluent from a wastewater treatment facility on Lick Creek will not adversely affect aquatic wildlife, such as the Coppercheek Darter. Opponents have also argued Lick Creek is a trout stream, but it is not recognized by the state of Tennessee as home to any species of naturally reproducing trout.
We have pointed out that the state has listed the Coppercheek Darter as present in Lick Creek and the reason the creek is classified as an Exceptional Tennessee Waterway. WADC has admitted in recent correspondence that their discharge will cause some degradation, but they claim it won’t be bad or harm the fish population. The truth is WADC doesn’t know what impact the degradation will have on the Coppercheek Darter or any aquatic life.
We know that the state has not designated Lick Creek as a trout stream. As the plant proposal has been made public, people have quickly come forward with stories and photos of trout caught in Lick Creek. Trout are present and therefore, trout designation would be warranted since the state and federal laws require that existing uses be protected.
But TDEC defines Lick Creek as an “exceptional Tennessee water.” Doesn’t that mean something?
The presence of the Coppercheek Darter gives Lick Creek that designation simply because that species is “in need of conservation.” The discharge will not in any way affect that species. In fact, there are tributaries of Lick Creek, such as Dog Creek, which TDEC has listed as an exceptional Tennessee water but is also classifieds as “impaired.” ETW designation in this case doesn’t apply to water quality.
No, it gets the exceptional waterway designation because the stream is clean enough to support this rare fish, and that designation is to protect the creek from being degraded. That’s why the regulations have a very involved process to prove that degradation is necessary, which has not been shown here. WADC doesn’t know or care about how clean Lick Creek is or what water quality conditions allow the darter to live.
Won’t a treatment plant make flooding problems along Lick Creek worse?
Lick Creek already floods periodically depending on rainfall. The lowest weekly average flow of Lick Creek measured over a ten-year period, basically drought conditions, is 8 million gallons per day. That means on most days, there is much more than 8 million gallons per day flowing in Lick Creek. WADC is seeking a 12 million gallon per day permit from the state, but that refers to the plant’s capacity, not its daily release. Lick Creek was chosen because it’s capable of handling the effluent from the facility. The presence of the facility will not make flooding on Lick Creek worse.
If a wastewater treatment plant is permitted and constructed for 12 million gallons per day and it operates over 90% capacity (like WADC’s other three plants), treated wastewater becomes a significant part of the creek flow and most of the stream flow becomes treated sewage. As the flow increases, they can impact on the flow by making it swifter and this change in habitat could impact small fish like the Coppercheek Darter.
Also, adding millions of gallons of effluent to Lick Creek could significantly increase flood risk by increasing flood flows in the area.
Finally, sewage treatment plant permits renew every five years – the WADC can always apply for more than 12 million gallons per day in the future.
Why have you made amendments to the permit application?
WADC amended the application following conversations with TDEC officials. The first amendment focused on certain technical aspects of the application regarding how the pre-treatment program would change if a large industrial facility became a customer. Large industrial facilities are required to pre-treat their effluent to remove harmful chemicals before sending it to the WRF. The other amendment included a more precise location for the discharge point.
Initially, WADC was vague about the location of the proposed plant, the discharge site, the size of the plant flow and if there would be industrial waste flows. The proposed location has yet to be disclosed and state regulations require a public notice to be located at the entrance to the proposed plant. However, the utility posted a sign on the Highway 7 bridge assuming this action would suffice. The WADC has said it is amending the application again and addressing some of the concerns raised by TDEC and the Friends of Lick Creek. To date, they have provided no additional information nor formally submitted an amended application. In response to an initial open records request for more information, they provided virtually nothing.
Why haven’t we learned about this plan before now?
A lot of engineering studies and creek modeling were needed for the application. When we felt we had sufficient data and a plan to protect Lick Creek’s water quality, we made an application to TDEC. The application process involves public hearings, so the public will have ample opportunity to make their views known to the state of Tennessee. We’re still very early in this process.
The truth is WADC was trying to keep their plan a secret knowing most Hickman County residents would be opposed.
WADC says they conducted studies and modeling – where is it? Friends of Lick Creek have asked to see all documentation submitted to the state that supports the utility’s claims but have received next to nothing to support a project of this size and scope.
The plant doesn’t screen for industrial waste and pharmaceuticals. Won’t those chemicals just be dumped into Lick Creek?
Large industrial users are required to pre-treat any water released from their plants to remove harmful or hazardous chemicals. They’re required to file a pre-treatment plan with the state and WADC before they’re allowed to operate and begin discharging into the system. There are no large-scale pharmaceutical manufacturers currently utilizing the WADC system. Households are advised not to dump old medications into the sewer system, but if that happens, the volume of water flowing through the plant would dilute the active ingredients to the level that they would not be harmful.
This is an example of WADC avoiding answering their own questions. Industries may be required to do testing and pre-treatment, but not all. The treatment plant may test for some industrial pollutants, but not all. And few (if any) industrial chemicals will be on the permit.
The pharmaceutical issue is not about manufacturing of drugs, but rather about what gets flushed down the toilet. If you conduct tests on a treatment plant’s effluent, you will find pharmaceuticals, personal care products, industrial chemicals and “forever” chemicals (PFAS) that are not removed by the plant.
Will Hickman County become a dumping site for Dickson and Williamson Counties?
Looking at population growth patterns in WADC’s 3-county service area, our engineers are able to make reasonable projections of service demand. To suggest the East Hickman WRF would only draw 3% of the wastewater flowing in from Hickman County misinterprets the data provided to the Tennessee Department of Environment and Conservation. WADC plans include maintaining treatment capacities at all its other plants, while directing only the flow from areas south of I-40 to the new facility.
The numbers that yielded the 3% estimate came from WADC’s engineering report. The utility states that their other three plants are over 90% loaded. This is a serious problem that never should have been allowed to get to this point and proposing a new plant is not the solution. Residents living in the Lick Creek valley of rural Hickman County don’t need or want sewers, let alone the effluent from the sewage from other counties.
*WADC statements taken from their website as of November 14, 2022. https://wadc.us/