For many years, the Harpeth Conservancy has been concerned that the Franklin sewage treatment plant was not being operated as efficiently as it could be or in compliance with legal requirements. In 2014 the Harpeth Conservancy was forced to file a citizen suit under the federal Clean Water Act when Franklin rebuffed attempts to resolve issues amicably (citizen suit available HERE). The Harpeth Conservancy raised a number of issues in that action, including repeated sewer overflows and Franklin’s failure to submit a nutrient optimization report as required by the discharge permit for the plant. We successfully settled that case, resulting in a number of improvements in the operations of the Franklin sewer plant.
On June 1, 2017, TDEC issued to Franklin the permit for the City’s sewer plant (permit available HERE). The fundamental problem in the permit issued by TDEC was that it failed to recognize that the Harpeth River is impaired by phosphorus pollution (and violates State water quality standards for dissolved oxygen) and is on the State’s 303(d) list.
The Harpeth River is impaired for phosphorus downstream of the City of Franklin where the Franklin sewer plant is located. For another almost 50 river miles River is also below water quality standards.
According to TDEC’s 303(d) list, a biennial report of waters that are “impaired” and don’t meet the water quality standards TDEC itself sets, the cause of the phosphorus pollution is Franklin’s sewage treatment plant (and Franklin’s stormwater systems). To read the State’s 303(d) list, click here.
Franklin’s own monitoring data show that just one (1) river mile downstream from the plant, from 2002 to 2014, 73% of the load of total phosphorus in the Harpeth, and 50% of the river’s load of total nitrogen, are from the Franklin sewer plant when effluent is 15% or more of the river’s flow. During October 2016, the last drought period, the daily average amount of treated sewage effluent just one (1) river mile downstream from the plant was 55% of the entire river’s flow.
Over the period of 2012 to 2017, Franklin’s sewer plant discharged approximately 72 pounds of phosphorus per day in 2018. At this level, the Harpeth River is impaired by phosphorus pollution. The 2017 permit allowed Franklin to discharge more than double the amount of phosphorus it was actually discharging. The permit allowed Franklin to discharge 174.5 pounds of phosphorus per day. By comparison, Georgia and Virginia have achieved phosphorus outputs of 8 to 13 pounds per day.