Landfill Treatment Line Followup


On Thursday, January 22nd, the Carthage City Council met at 5:30pm to discuss the following agenda:

The purpose of this meeting is for invited Waste Water Treatment specialists to inform the Council about the compliance requirements and legal responsibility of our elected city officials with regard to the Carthage Waste Water Treatment Plant. The Council may also vote on how to proceed with the Memorandum of Understanding that exists between the city and the county related to disposal of waste in the Carthage Waste Water Treatment Plant after the reports from the specialists.”

Persons on the Agenda were as follows:

  • Mr. Brett Ward, the MTAS Specialist for Waste Water

  • Mr. Barry Sulkin, a consultant for TDEC Compliance and a specialist on Waste Water

  • Mr. Steve Key, Superintendent of the Carthage Waste Water Facility

  • Mr. Ricky Brown, 20-Year Employee of the Carthage Waste Water Facility

We as a council were asked to hold our questions until the end of the presentations. While I understand this, in the future, I would like to be able to ask clarification questions as we go since a lot of information is presented in a short period of time and we can only write down information and questions so fast. This is something I will request for future meetings. I may have missed some things due to this, but in the end, I think we covered everything.


Mr. Ward proceeded to explain to us a few facts from our municipal audit. As a city, we have over $10,000,000 invested into our water and sewer treatment, over 3 times the capital invested into all of our other assets combined. Our sewer treatment plant is governed by a document called NPDES, which allows us to discharge into the Cumberland River. This permit is set to expire by the end of February 2019. As of now, there is no draft of a new permit. It is an easy permit to obtain as we are a very small community on the edge of a very large river. When discharging, we are not allowed to discharge any distinctive scum or visible content into the river nor can there be questionable color.


Mr. Ward spoke about different testing compliances and about our sewer capacity, which is rated at 625,000 gallons a day. One issue is that the original design was only meant for 500,000 gallons a day and it is unknown where the extra 125,000 gallons number came from. Our average daily flow is about 400,000 gallons a day, which is around 80% capacity.


Biochemical Oxygen Demand (BOD) is basically the organic strength of the wastewater. Our plant is designed to handle 800 lbs of BOD daily, which we are currently at capacity. Mr. Ward then said we could probably handle up to 1100 lbs, but we were still cutting it close with the BOD levels. He also stated that the plant is not designed to remove large amounts of ammonia. It probably did at lower levels, but not at larger volumes. The water plant uses gas chlorine as a disinfectant.

Mr. Ward then spoke about some of our risk factors we currently have with our sewer treatment plant. They include:

  • Hydraulic Overload

  • High BOD Load

  • High Rust Content

  • Proximity to the River (Possible Erosion)


Mr. Barry Sulkin then spoke about his opinion regarding the plant. He said nothing jumped out at him on the plant except for the capacity issue. He also reported the Leachate intake over the years which is as follows:

  • 2016 - 900,000 gallons of Leachate came through from the county.

  • 2017 - 2,300,000 gallons of Leachate came through from the county.

  • 2018 - 3,000,000 gallons of Leachate came through from the county.

He also discussed higher ammonia levels which were as follows:

  • 2014 we had 8mg of Ammonia per Liter

  • 2015 we had 6mg of Ammonia per Liter

  • 2016 we had 30mg of Ammonia per Liter

  • 2017 there was no data collected

  • 2018 we had 161mg of Ammonia per Liter

Mr. Sulkin then said the safe levels of Ammonia were around 20mg - 25mg and we were well over those levels. He also mentioned that our Chloride levels were high and that our plant cannot take Chloride out. No specifics were given on the Chloride levels. He basically said that these levels may trigger the state to issue us an industrial treatment permit as we are close to violating the current permit we are issued, which expires in February.


Mr. Steve Key then spoke about his responsibility to maintain compliance, to watch out for the health of the town and its waterways and about being frugal with taxpayer money. He spoke about the plant being built in 1978 as well as a 2017 grant that was awarded to the water plant. As the plant was built in 1978, he is hoping to get 50 years out of it, which would maybe give us one more decade. Steve mentioned he didn’t feel receiving the leachate was a good idea due to the I&I.

Mr. Ricky Brown then said he agreed with everything Mr. Key had said and had no additional comments.

Mr. Ward then was admitted to take questions from the council. I asked Mr. Ward how many criminal charges resulted in fines and jail time for non-compliance. He said they didn’t happen much, but did happen. I asked him under which circumstances jail time was given and he mentioned a time where records were falsified. The reason I asked this is I felt a lot of intimidation was being used on the council to not accept the leachate or we would all be put in prison. I don’t believe in making decisions out of fear, but out of logic and reason. I will not be threatened or bullied by jail time in order to get a particular agenda passed. I will make decisions based on hard facts.

Mr. Ward also stated that should we need an industrial permit, TDED will force us to get one.


The discussion of leachate capacity holding was then brought to the table. Currently the leachate pond can hold 42 days worth of capacity should we have heavy rains to where we cannot process it through the plant. Mr. Ward mentioned that almost every plant in the state is over capacity.

Mr. David Bass, the city attorney, then recommended that the county would need to follow city guidelines should it attach the force main line.

Mr. Sulkin then mentioned that an additional pond would help alleviate the problems with receiving the leachate and that adding more air to the leachate would be beneficial for its treatment.

Councilman Sam Petty then asked if we could get better guidelines and Mr. Sulkin recommended that CTAS give those guidelines.


Mr. Lee, the Landfill Superintendent was then asked how much trash the county receives that is not its own. He stated we receive about 50% of our trash from other counties, that this is general trash and no hazardous waste. The 50% trash received pays for our own trash usage, offsetting the cost so the taxpayers don’t foot the bill.

I asked that we possibly look at putting a cap on the amount of Leachate received so that the county does not move into the trash business and expand the amount of trash taken from other counties, but just enough to pay for its day to day operations so the taxpayers don’t foot the bill.

I then requested a few times that Ms. Kim Raia, the CTAS specialist on wastewater be allowed to speak so we could hear another opinion. This was questioned procedurally by Mayor Smith and City Attorney Bass recommended she speak as we would need to hear more from the county side and the county experts.


Ms. Raia mentioned that the testing at the landfill was only required quarterly, not daily as it is at the sewer plant. She recommended that the county have more frequent testing and additional testing for Ammonia, BOD’s and Chloride. She said it was extremely common for leachate to be treated through city sewer plants and said industrial permitting may be the way to go.

Mayor Smith asked several times about liability and how to know who is liable for what which was agreed upon by all parties that if we are testing at the landfill, we would be able to determine high levels of ammonia, BOD’s and chloride that came from the landfill would put the landfill liable.

It was then stated that the landfill falls under Red Grove Regulations and the leachate is treated, no untreated leachate is being pumped currently or would be going through the Force Main Line. It was recommended that we verify the landfill is under an industrial pre-treatment program.


The engineer stated there is 2 shutoffs for the Force Main Line, one directly controlled by the sewer treatment plant and one by the landfill, both of which the city would have jurisdiction to shut off should the need come.

Mr. Key also mentioned that with some of these additions, another city employee may be required.

At this time, I motioned that we hold off the vote of this until the next meeting so we as council members could speak with our constituents. Discussion was had (out of order) as to amendments to my proposal to move this decision to the March meeting as the council had decided before, and all were in favor.

I then motioned to adjourn the meeting as no one else had anything to add to the discussion.

Here is what I took away from this meeting. There were a few questions I didn’t think about asking until reviewing my notes later. They were as follows:

  • What were the Chloride Levels Mr. Sulkin mentioned and where should they be?

  • What are we doing to get a new permit for the Sewer Treatment Plant?

  • What is I&I?

  • Should we move the county along faster than the March meeting due to the expiration of the permit in February?


Additionally, as it stands now, these would be my recommendations and conditions for the county to put in the leachate line:

  • Clear definitions of liabilities between the city and the county to include measurements on both sides of Ammonia, Chloride and BOD’s with more frequency on the Landfill side.

  • Putting a reasonable cap on the landfill to where should they exceed this cap, it would need to be voted upon by the city council as a guard to protect the city from unnecessary growth of the landfill from outside the county.

  • More treatment of the leachate on the landfill side to reduce the Ammonia, BOD’s and Chlorides currently coming through.

I would also like to hear of any concerns of yours. Please contact me should you have any so I can address at our next council meeting.


Last, there is business, and then the politics and order of business. We have been told as a council we need to follow Roberts Rules of Order. This is Parliamentary Procedure to make sure our governing body is correctly governing to where everyone can be heard in a respectful and orderly manner. I am completely fine with this and use it all the time in many of the other boards I have been elected to take part in. If we are going to do this, we need to follow this.

When a motion is on the table, this motion must either be seconded or fail. Until this is determined, interruptions on the motion are not binding until we enter into discussion. This procedure was constantly ignored. A motion can be made, if it is seconded, then we can enter into discussion, make amendments, vote on the amendment, vote on the motion and then business is over.

Additionally, when a point of inquiry is made and interrupted before the inquiry is finished, that is also out of order. I think it is professional for us to respect each other when speaking and not talk over others.

I would like for all of us to study up on RRO and use it effectively so that all can be heard. Whether I agree with you or not, you deserve my respect to listen to your opinion, as you were voted in by the people. Let’s not pick and choose when RRO applies and when it doesn’t. All opinions matter, all sides should be heard, especially the ones we disagree with.

Thank you all once again for the opportunity to serve you.

Cole Ebel