Violations Land Rush Strong School On Federal EPA List – State Moving Forward With Enforcement

Rush Strong School has been listed by the United States Environmental Protection Agency as having compliance issues regarding the Clean Water Act. This compliance issue is in addition to compliance and enforcement issues with the State of Tennessee Department of Environment and Conservation, as well. In letters dating back to March of 2011, TDEC officials have reported violations with the sewage treatment at Rush Strong School. Excessive permit violations were noted in several letters over a four year time span, with the most concern centering around the amount of ammonia that is present at testing.

According to the State of Tennessee, testing is conducted and information is held at the Dandridge Water Facility and Michael Norton is listed on official paperwork as the Operator of the Rush Strong Sewage Treatment Plant. However, according to Dandridge Town Administrator Melissa Peagler, Dandridge is not connected with the Rush Strong site and Norton is personally contracted to oversee that facility. Norton, whose father was previously listed as the facility operator, directed questions to Jefferson County School’s Facility Director Michael Phagan and Kevin Davis, who is contracted as a soil consultant. Phagan stated Friday that there have been ongoing issues at Rush Strong School and that they are seeking alternative means to address those issues.

Kevin Davis had originally proposed teaming with a neighboring church that also has sewage issues, so that the school could put in place a drip irrigation system. Because the school’s soil quality is not feasible for a drip system, the school would have partnered with the church to trade use of an upgraded school sewer system with the property at the church for the drip irrigation. That proposal did not pan out due to limited property available from the church. However, Davis has proposed changing the composition of the soil at the school through extensive digging and hauling of suitable soil, to allow for the drip irrigation system.

The State of Tennessee has yet to give approval on the idea. In a certified letter to the Director of Jefferson County Schools, Charles Edmonds, dated in December 2014, TDEC noted that, though a solution was being sought to correct what was termed excessive violations, it appeared to be elusive. Though a corrective action plan had been requested several months prior, according to Phagan it has still not been filed with the State.

In a conference meeting with permitting officials for the State of Tennessee to request permission to pursue Davis’ plan for drip irrigation, which has not been utilized in Tennessee, State officials determined that plant upgrades and the elimination of the current violations would have to be addressed before consideration of the filled drip irrigation system.

According to notes from the compliance review meeting in January 2015, the ongoing issue with the sewage system at Rush Strong School is that the system is a recirculating sand filter with an NPDES discharge but due to the fact that no re-circulation apparatuses can be found, the system is not recirculating. The result is that it is operating as a “once-through intermittent sand filter.” In earlier correspondence it was noted that the system had never had the necessary apparatus to function properly.

In conversation with Davis, he spoke of installing the drip irrigation system at the school as early as this spring and noted that there is a time consideration because of the finding of violations. Another notable mention in correspondence in 2014 was the issue of a finding of two chlorine violations, though it has been reported that the school uses ultraviolet light as its means of disinfectant of discharge and that required signage marking the location of the influx site where it enters the Holston River via Crowder Branch was missing. It was also noted that a new violation exceeding the limits of dissolved oxygen was found in 2014 in addition to E.coli, settleable and suspended solids and other findings.

Loose estimations for the work needed at the Rush Strong site could be in the neighborhood of $100,000 to $200,000. It is unclear what fines could be associated with what was termed as a “gross number of violations”.