River Rest HOA Public Comment

The following has been submitted on behalf of River Rest HOA. There are still 10 more days in the public comment window for anyone who wishes to submit a comment about the permit modification. We have also garnered the support for a public hearing from our respective government representatives; county commissioners Barb Sturgeon and Drew Torres, Senator Jack Johnson and Representative Gino Bulso.

TDEC Permit No. TN0027278

Applicant: Limestone Water Utility Operating Company, LLC

Email comments to: water.permits@tn.gov

Dear Tennessee Department of Environment and Conservation,

On behalf of the River Rest community, we are writing to formally request that TDEC conduct a public hearing regarding permit number TN0027278, concerning the proposed Limestone Sewer Plant serving the Grassland Village community.

We have experienced recurring wastewater treatment failures, including blockages, leaks, and overflow events which have impacted property and public health, as well as the ability for us to simply enjoy our backyards or shared common spaces. Given these continuing issues, we believe a public hearing is essential before further permit action is taken.

Additionally, we submit the following comments and recommendations for inclusion in the permit review process. Some of these are specific from our community discussion, but many of them we have worked in partnership with respective knowledgeable people in our community to submit well-informed comments.

We understand this is a big endeavor and appreciate the care and attention you have already given to this process as well as moving forward.

The following should be noted, included and implemented:

Noise and Smell

Concerns:

We are a small neighborhood of 185 homes, plus the 120 adjacent condominiums in the community. Our shared common space runs along Cartwright Creek and a section of the Harpeth River and extends around and south of the treatment plant. There are a couple homes who sit directly along Limestone’s property line and two cul-de-sacs that are also nearby. To say the noise of the generators or pumps that are currently in use prohibits a reasonable enjoyment of both private and shared property is an understatement. This in combination with the smell of either treatment chemicals or sewage, at regular times and not always dependent on wind, are a major concern for the community regarding the construction of new facility.

Questions:

What options are suggested for smell management? Will the same treatment chemicals be used? Can we expect the same smell level with the new plant? What noise decibel level shall we expect from the operation of the plant as a whole? Can sufficient landscaping or noise barriers be written into the permit to offset the size and scope of the new plant, such as placing the blowers in noise attenuating enclosures?

Recreation Road and Treatment Plant Road

Concerns:

Our privately held road runs to our community clubhouse, pool and other shared amenities and common spaces before winding back to the treatment plant. With the current level of large trucks removing solids increasing to include 2 trucks a day at 5 days a week with the proposed new plant this will create a lot of wear on the current roads. Not to mention the construction traffic set to occur, we want to ensure the safe use of our roads.


Questions:

Can something in the permit include maintaining a safe roadway during the construction phase of the project? We are reviewing options for long term maintenance of the roads leading to the plant and we want to ask that approval to begin construction be contingent on a formal agreement in place between River Rest HOA and CSWR-Limestone.

Leaks, Communication and Collection System

Concerns:

A new plant addresses one aspect of our sewage treatment system, but does not address the pipes funneling into the treatment plant. The leaks in the past have occurred from issues with this collection system, whether from overflowing manholes or leaks in pipes. We have avoided using our lower soccer field as well as Cartwright Creek and the Harpeth River out of concern for contamination and previous sewage spills. We are not clear on how much time is needed for remediation, what is the long term safety of regular leaks that become obvious or a slow sewage leak that seeps into the ground undetected because it hasn’t spilled from a manhole?

Questions:

What is the process required in the permit for communication of leaks and spills to the community? The current method is inadequate. What is the maintenance plan for finding and fixing current problem areas in the collection system or does Limestone say that they have repaired all the problems in the collection system already? How much time is required after a sewage leak or spill for the area to be safe for use? How can this be determined? Also, can there be a requirement in the permit for Limestone to identify their manhole locations and maintain a clear path? The community is prepared to work in tandem with them on this considering the man holes sit within our common space.

Capacity

Concerns:

The current permit level is at .25 MGD, but with taps added by previous owner Cartwright Creek, and possibly Limestone, we are unsure if the current capacity is over the permit level for this reason and that is why the design expands to .45 MGD. Some of the data from the flow rates also gives the impression that Limestone is frequently handling flow beyond permit limits and it was suggested this was due to issues with the collection system. Also, we noticed that CSWR did not submit a plan for the capacity size as recommended by the engineering company who created their report. They were recommended to submit plans for .65 MGD and instead chose to submit for .45 MGD.

Questions: What is the justification for an increased capacity wastewater treatment plant? What is the process for Limestone to add additional taps, is there a division that is responsible for prior approval before additional taps may be added? What division is responsible for monitoring flow rates? Is there a compliance schedule and what are the penalties for not being in compliance with permit capacity and requirements? Can these things be specified within the permit?

The Following items came from several discussions with the Harpeth Conservancy, our county commissioners Barb Sturgeon and Drew Torres, and George Garden and we feel they align with our concerns and questions as well:

1. Compliance Schedule – Defined specific corrective actions for current deficiencies and a detailed completion timeline, with periodic reporting to TDEC.

2. Enforceable Deadlines – Include measurable milestones and clear enforcement procedures for any missed timelines.

3. Leak and Overflow Prevention – Require a proactive maintenance, inspection, detection and emergency response plan to prevent future occurrences.

4. Engineering Verification – Ensure all design and capacity calculations are documented and demonstrate the system’s ability to meet operational and effluent requirements.

5. Capacity Prioritization. -Ensure existing Grassland Village residents are prioritized for service improvements and increased capacity of this plant before new development hookups are approved.

6. Road Maintenance – Recreation Road + associated roads, Require the operator to restore and maintain Recreation Road within the River Rest Subdivision to offset construction damage and avoid placing the repair burden on residents.

Due to the plant’s performance history and the significant public interest in this matter, we respectfully request that TDEC schedule a public hearing prior to issuance or renewal of Permit TN0027278.

Thank you for your time, consideration, and commitment to transparency. Please include this correspondence in the public record associated with this permit.

All the best,
Autumn Moore
River Rest HOA President