NC residents state concerns at hearing on Rabun sewage permit
Macon County residents fearful that a proposed sewage treatment plant in Georgia will harm the Little Tennessee River turned out en masse at a public hearing last week to voice those concerns.
The Little Tennessee River flows north from Rabun County into Macon County and Franklin. Rabun is proposing to rehab a treatment plant at a now-closed factory and Georgia’s Environmental Protection Division is reviewing the draft permit.
Macon residents are worried they may be second-class citizens at best from the state of Georgia’s point of view when it comes to their concerns being considered and their suggestions adopted.
The series of Macon speakers testifying at the public hearing therefore strategically put their points in terms of a “good neighbor” theme.
“Everybody lives downstream from somewhere,” said Franklin Alderman Bob Scott.
Ronnie Beale, chairman of the Macon County Board of Commissioners, cited a speech by FDR early in his presidency in which he pledged to be a good neighbor to Latin America.
“We have good relations between the residents of Rabun and Macon counties,” Beale said. “The proposed plant affects not only your neighborhood but your neighbors to the north. We ask that not only latest technology but also common sense be applied. We would hope if the situation were reversed, Macon would be a good neighbor to you.
“Macon County and the people of Georgia need to work together to protect the Little Tennessee River,” Beale said.
Chlorine in disfavor
The technology issue Beale mentioned referred to alternatives to using chlorine to treat effluent before discharge. Chlorine is one of the most effective chemical disinfectants, but it is harsh and highly toxic. A well-publicized call to ban it from many industrial uses in the mid 1990s failed due to the chemical’s effectiveness and because of widespread dependence on it in many applications — and because practical alternatives are few. Chlorine is also very volatile and dissipates rapidly into the environment in minuscule concentrations, according to industry advocates.
Meanwhile, an alternative in the realm of water treatment involving disinfection using ultraviolet light (UV) has been increasingly adopted by industry, though at a higher initial cost.
Jenny Sanders, director of Little Tennessee Watershed Association, expressed her concern about chlorine in the plant’s effluent.
“We do see some very significant benefits of UV treatment over the proposed chlorine treatment. Even with the potential for the dilution of chlorine, the draft permit specifies a tenth of a milligram per liter, while the point at which it affects fish is a hundredth of a milligram per liter,” Sanders said. “If you invest more upfront, you’ll eliminate the problem.”
Sanders added that there are other benefits to using UV.
“Disinfection occurs 30,000 times faster, there’s no residue, and it raises oxygen levels, which is good for fish,” she said.
David Bullard, a unit manager of municipal permitting for the Georgia DNR’s Environmental Protection Division, was reached by phone following the hearing. He said Sanders’ concerns about residual chlorine concentrations are already taken into account in the proposed limit.
“The limit is a calculated limit based on the dilution of the discharge by the receiving stream, so when you back-calculate it, it gets to the amount they were talking about,” Bullard said.
Still, he acknowledged that UV treatment is increasingly state-of-the-art.
“There are several plants in Georgia that are using UV instead of chlorine,” he said. “In this case, the chlorine limit is calculated to be considered not to be a danger to aquatic life.”
Bill McLarney, an aquatic biologist working with the Little Tennessee Watershed Association, still doesn’t like the chemical.
“I agree about trying to get off chlorine. There are alternatives,” McLarney said at the hearing. “If I wanted to kill aquatic life, I would say there’s only one chemical to use: chlorine.”
Power over the permit
Bullard said Georgia officials mulling the permit do have the authority to stipulate use of UV for disinfecting the effluent.
“We could require it. We can make changes to the permit that might be more stringent than what is in the draft right now,” he said. “I’m not sure what the difference in cost would be. That condition in itself wouldn’t necessarily be more stringent; it’s just another way of treating the wastewater in its final stage of treatment.”
Bullard gave an initial presentation on the proposed permit at the hearing, and touted it as imposing tighter limits on several discharged pollutants than the plant was allowed to release under its previous permit.
According to the draft permit summary, to which Bullard referred in his presentation, monthly average limits are as follows for some selected parameters (in milligrams per liter): biochemical oxygen demand, 10; suspended solids, 20; ammonia, 2.0; phosphorus, 1.0; residual chlorine, 0.10. The monthly average limit for fecal coliform bacteria is 200 per 100 milliliters. Acidity of the effluent must be between 6 and 9 pH, which is a range from relatively neutral to more alkaline.
Limits under the old permit for relevant parameters for the closed treatment plant are: biochemical oxygen demand, 35; suspended solids, 132; ammonia, 10.0.
Treated flow capacity under the old permit is 2.5 million gallons per day; under the proposed permit flow would be up to 2 million gallons per day.
Todd Silliman, an Atlanta attorney helping shepherd the permit through approval, also promoted it at the hearing based on its more stringent limits on contaminants and other tougher provisions.
“The river downstream is currently impaired for fecal contamination, so the lower limits [for coliform bacteria] are important,” Silliman said. “The draft permit is designed to ensure the discharge doesn’t contribute to violation of water quality standards. It went further than other permits Georgia or North Carolina have issued for the Little Tennessee River.”
Transfer or no transfer?
Silliman also sought to allay fears on an issue that’s been raised by concerned North Carolina residents about possible transfer of water among river basins. Rabun County would potentially be able to make such transfers once it is in the sewage business.
“No interbasin transfer is currently planned,” Silliman said at the hearing. “The permit is for treating water used at the plant within the same basin, and to allow return of water to the basin in a way that is cleaner than the alternatives.”
Still, subsequent speakers such as Sanders expressed their concern about possible transfers out of the Little Tennessee River basin into the adjacent Savannah River basin, where it could be made available to perennially thirsty Atlanta.
“When you start exchanging water among river basins without any equitable accounting, that’s a problem,” Sanders said. “For example, if I transfer money between my bank accounts and don’t keep good track of it, one account is going to run out. We don’t want to see bad accounting.”
Rabun County residents and officials alike have said Macon residents have mounted the interbasin transfer issue as a bogeyman just to buttress their general opposition to the treatment plant. Several Macon County residents — and even a Georgia man — therefore suggested the state put its money where its mouth is and write a ban on interbasin transfers into the permit.
“Have the final permit prohibit interbasin transfer,” said Joe Gatins of Rabun County. “There’s no reason to raise that bugaboo. Take it out right now.”
Susan Ervin, a longtime Macon County Planning Board member, echoed that suggestion as well as others that had been made about Rabun’s plans to attract industrial users with the treatment plant.
“Requiring UV, revising the permit for industrial use, putting in no interbasin transfer is reasonable,” she said. “The river is also used for recreation and other needs. In planning for the future, we must plan for all of these. Only a small piece of the river is in Rabun, but it is the heart of Macon County.”
Other residents raised concerns about the plant’s potential for collecting and concentrating a category of pollutants only beginning to be recognized, for which there are as yet no mandatory testing and limits — household pharmaceuticals and other chemicals from as-yet unaddressed household products.
“Pharmaceutical products can cause human health problems but also sex changes in fish,” said aquatic biologist McLarney. “You see a lot of it where there’s runoff from hospitals, nursing homes.”
McLarney praised the draft permit, except for the chlorine use.
“The permit presently being applied for appears to be a good permit; it appears to be a sewage treatment permit,” McLarney said. “I hope you get something that relieves the unemployment situation.”
Industrial: Horse of a different color
McLarney did, however, repeat others’ concerns about industrial use of the plant.
“I do not agree about using the same permit for a different use; industrial discharge needs a different process,” he said.
He stated a concern about liability if Rabun accepted industrial users under the proposed permit and something bad happened.
“Who would be held responsible?” McLarney asked. “If a different category of permit is under discussion [for possible industrial users], then design for it.”
Comments by Rabun resident Pete Cleaveland were representative of the local attitude there.
“I’m a citizen of Rabun and proud to say that. We have almost 10 percent unemployment. It’s above the state average, above the average of North Carolina,” he said. “We need jobs. The best opportunity to draw employers is the Rabun Gap area; we have a plant, land set aside for an industrial park where small businesses can get started. We need water and wastewater treatment.”
When the county bought the old mill treatment facility, it made a pledge to protect the river’s water quality, he said.
“I spoke personally to Jenny to assure that,” Cleaveland said. “We want to be good neighbors and we think we have been.”
Cleaveland said the table with the current and proposed contaminant limits shows that good-neighborliness.
“We’re not trying to pull wool over Macon County’s eyes, dump a lot of stuff on you and say, ‘Aha, you clean it up.’
“Chlorine vs. UV, that’s above my pay grade,” he said. “You could use a strainer; as long as you got the results like [in the table], I’d be happy. We all care about water quality. We’re all in the same boat. I’m glad to see we’re working toward good quality water.”
NC comments to be given weight
In the subsequent interview, EPD’s Bullard sought to reassure North Carolina residents about both the process and the outcome of the permit evaluation.
“We’re definitely going to take [Macon residents’] comments into consideration,” he said.
Bullard sought to downplay the hot-button issue of interbasin transfer. But his comments made it sound as if the permit would probably not ban it.
“I think it would be too early to be definite about that, just like whether we’re going to require the UV disinfection,” he said. “We don’t really have any laws against interbasin transfer.”
But Bullard also said the transfer would not be allowed.
“They wouldn’t have authority to do interbasin transfers,” he said.
“There is a wastewater plant in Clayton that is in the other basin,” he said. “It sits on a ridge between the Little Tennessee and the Savannah. The plant is owned by the city of Clayton; it pretty much serves everything on that end of the county. They should be able to handle everything on that side of the county.”
Bullard said the process of evaluating the permit application would take at least a couple of months.
“We have to get the rest of the comments and then evaluate all the comments in total and determine if there are some modifications to the permit warranted,” he said. “Then we have to put together a document that we call a Response to Comments. We will issue a Response to Comments to everyone who commented at the hearing or who sent us a letter while it was out in draft. If we make any changes to the permit, that will be addressed in the response.”