By MARK MCGEE
“The situation is a concern but not yet at the critical level.”
That is how Jason Reese, General Manager for the Shelbyville Power, Water and Sewerage System (SPWSS) views the new proposed water withdrawal limits by the Tennessee Department of Environment and Conservation (TDEC) on the Duck River.
TDEC held a public hearing in October of 2023. Six different systems on the Upper Duck River were discussed including SPWSS. TDEC proposed a cap of 8.35 million gallons (MGD) per day for SPWSS.
“Some people are categorizing this as a crisis situation, but we are not there yet,” Reese said. “On average in calendar year 2023 we withdrew 4 ½ million gallons from the Duck River.”
Reese spoke at the public hearing in October. Public comments were sent to TDEC in December. Reese said SPWSS has received no response.
“In 1997 our water system underwent a study performed by our consulting engineers,” Reese said. “Part of the study was to project the population in the City of Shelbyville and Bedford County through 2020 in order to determine and plan for potential system upgrades and improvements.”
As a result of the study SPWSS upgraded the water treatment plant to handle a capacity of 10 million gallons per a day.
“In 2001 TDEC approved plans for our water treatment plant to be expanded to a capacity of 10 million gallons per day,” Reese said. “Our studies showed we needed to do that. TDEC obviously agreed.”
Another part of the TDEC proposal was a stipulation that would result in a reversion to 6.04 MGD as the withdrawal limit if the Duck River’s flow falls below 175 cubic feet per second (CFS). TDEC refers to this as a grandfathered amount which constitutes an existing water withdrawal as of July 25, 2000.
Reese wonders why TDEC wants to change the withdrawal capacity level after so many years.
“Our biggest question is why 23 years later is TDEC is issuing us a permit for a maximum pumping capacity of 8.35 MGD with low flow river constraints holding us to 6.04 MGD?,” Reese said. “Those were withdrawal records pulled from July 25, 2000. How can TDEC go back an entire year prior to 2001 when they approved our plant expansion to 10 MGD? Why are we being held to something less?
“We had nine days where we were in excess of the 6.04 million low flow condition in 2023. We had 81 days where we were more than 90 percent of that number and 109 days where we pumped more than 80 percent. That is 199 days where we withdrew at least 80 percent of the 6.04.”
The main issue is basically what happens during dry weather when water demand is the highest. The SPWSS reached 7.94 million MGD in October of 2022. Reese said that record was broken during the bitter cold and snow period in January when 8 ½ MGD was withdrawn in one day.
“Peak demands can happen at any time,” Reese said. “Our concern is what if it happens when the flow of the river is below 175cfs?
“These permits are being issued to all of the water systems along the Duck River. Why is Shelbyville being held to this grandfathered amount?”
“A lot of this has to do with environmental issues,” Reese said. “The Duck River is known as the most biologically diverse river in North America, and I understand the environmental and endangered species concerns.
However, TDEC states in our draft permit that the 6.04 MGD low flow conditions will not become effective for five years while they perform studies of threatened and endangered mussels and other species. Why do you issue a draft permit before you’ve performed your study?”
At one time TDEC approved 10 MGD and Reese wants that level of water withdrawal to be renewed.
“What we are asking for and what we want is 10 million,” Reese said. “There are still a lot of meetings ahead. We are not sure how or when TDEC is going to respond. By holding us to anything less than 10 million gallons per day, TDEC is basically saying our system has wasted tax ratepayer’s money by upgrading the system.”
Reese points out that SPWSS’ wastewater treatment plant effluent is released into the Duck River about one mile downstream from their raw water intake.
Amid SPWSS’ current daily peak demand of 7.94 MGD, the combined treated effluent from their wastewater system and Tyson Foods amounts to 2.73 MGD discharged directly into the river.
Consequently, the net impact on the Duck River during peak demands is currently 5.21 MGD. Reese believes SPWSS should receive credit for this.
The fact SPWSS returns treated wastewater directly into the river also makes it unique among water systems along the Duck River.
“Some of the other systems are septic tank based. None of their wastewater is being sent back into the river. It is going into septic tanks and into the ground. Systems that do have wastewater treatment discharge their water back to creeks or tributaries but not directly to the Duck River.”
Reese added SPWSS takes pride in eliminating waste of water.
“We take pride in trying to minimize our leaks,” Reese said. “We are well below the average of the AWWA Water loss guidelines and percentages and what the state likes to see. We keep waste at a minimum. We do a good job.”