Formal Requests for Disclosure and Committee Action

Lebanon WWTP Site Selection — Public Record Archive  |  Return to main page

The following requests are contained in Revision C of the Public Record Statement (June 15, 2026 draft), organized by the section in which each request appears. Each request identifies information that materially affects how one or more candidate sites should score under the committee’s own criteria — and that has not, to the petitioners’ knowledge, been entered into the public record. Corresponding public records requests have been filed with the City of Lebanon for each of these topics; see the public records requests page.

Opening remarks Septage receiving — initial request

1. Enter into the public record where septage receiving operations will be located after the new plant comes online, and factor that answer into every site’s Community Impact score.

Appendix C Hydrological exposure — private wells and LaGuardo Utility District

1. Commission a hydrogeological study from a qualified third party documenting — or formally refuting — hydraulic connectivity between each proposed site footprint and the LaGuardo Utility District well field.
2. Require coordination with the LaGuardo Utility District Board of Commissioners as a prerequisite to any further consideration of the Mann Road and Berea Church Road addresses.
3. Enter the TDEC well-count data and the accompanying ring map (Exhibit C-1) into the official public record of the site selection proceedings, and supplement it with an independent staff verification against the most current TDEC Water Well Locations database.
4. Provide written notification to each identified well owner, and to all LaGuardo Utility District ratepayers, of the proposed siting and the karst-aquifer contamination pathway described in the statement.

Appendix D Septage receiving operations — full disclosure

1. Disclose where septage receiving operations will be located after the new plant comes online — at the existing Hartmann Drive facility, at the new plant, or split between the two — and the engineering basis for that determination.
2. Provide written confirmation of whether the design RFP and the consultant’s preliminary engineering report specify, contemplate, or design for septage receiving capability at the new facility.
3. If septage receiving is specified at the new facility, disclose the projected daily truck volume on which the design is based and the source of that projection.
4. Disclose the planned hours of operation of the septage receiving station at whichever facility receives the trucks, including weekend and after-hours access.
5. Provide a road sub-base condition assessment for the approach roads to whichever site receives septage trucks, and an estimated cost of road improvements required to accommodate the projected traffic volume — including any road-widening cost necessary to permit safe two-way commercial traffic on roads currently measuring 17–18 feet of actual pavement width (Exhibit D-1).
6. Commission a noise and air-quality impact analysis for any site within one-quarter mile of existing residences, prepared by a qualified third party.

Appendix E Effluent force main reclassification (F1 and F2)

1. Confirm or refute on the public record whether the proposed plan repurposes the existing 30-inch effluent force mains (F1 and F2) to carry raw sewage upstream of each candidate site’s tangent point.
2. If that reclassification is confirmed, enter the following into the public record:
   • The original installation date, material composition, and design pressure rating of F1 and F2.
   • The current condition of F1 and F2, including the most recent inspection date and any documented defects, repairs, or remaining service life estimates.
   • Whether the proposed operating pressure for raw-sewage service exceeds the original pipe specifications.
   • The geographic route of F1 and F2 between Hartmann Drive and the convergence point near the top of Berea Church Road, including all residential parcels, surface waters, and karst-feature crossings traversed.
   • Whether the city intends to reuse F1 and F2 in their current condition, line them, parallel them with new force main(s), or replace them — and if lining or replacement is contemplated, the cost, schedule, and permitting timeline for that work, separately identified from the per-site “over and back” pipe cost estimates.
   • Whether the proposed reclassification of F1 and F2 was disclosed to TDEC at the time of NPDES Permit No. TN0028754’s application (permit issued June 24, 2024), and whether TDEC’s approval of a standard treated-effluent outfall permit reflects an assumption of continued treated-effluent use of F1 and F2 through the permit’s expiration on May 31, 2029.
3. Require an engineering certification, signed by a licensed professional engineer not in the employ of the City of Lebanon, that F1 and F2 in their current condition are fit for purpose as sanitary sewer force mains under the proposed operating conditions.
4. Coordinate with TDEC to confirm in writing the regulatory pathway required for reclassification of F1 and F2 from treated-effluent outfall service to sanitary force main service, and the schedule for that process.
5. Notify all property owners along the F1 and F2 alignment of the proposed change in pipe contents and any associated engineering risks.

Appendix F Treatment technology and acreage threshold

1. Disclose, in writing and on the public record, the treatment technology (conventional activated sludge, membrane bioreactor, MBBR, or other) planned for the new facility, and the engineering basis for that selection.
2. Confirm whether the stated 60-acre minimum is technology-dependent, and if so, identify which technology assumption it embeds.
3. Require a recalculation, entered into the public record, showing whether sites currently scored as marginal or eliminated for size would be viable under membrane bioreactor or MBBR design at 20 MGD initial capacity.
4. Consider expanding the candidate site list to include industrial-adjacent or smaller parcels — including those referenced by Mayor Bell in connection with the Rockwood and brickyard area — that may meet a recalibrated, technology-informed acreage requirement.

Appendix G Shortlisting methodology and procedural safeguards

1. Adopt written, anchored scoring levels for each of the five criteria — specifying in writing what characteristics make a site a 1, 2, 3, 4, or 5 for each criterion — and enter those anchors into the public record before any scoring occurs.
2. Identify in writing which candidate sites have engineering-grade data and which do not; either supplement underdocumented sites with additional engineering review, or expressly note the data limitation against each affected score in the record.
3. Document in writing the basis for the 1–3 importance factor weights assigned to each of the five criteria — including why those weights are defensible on engineering and policy grounds independent of which sites would benefit from any given weighting.
4. Conduct and publish a sensitivity analysis demonstrating that small variations in scoring — a one-point change in a single site’s score, or a one-step change in a single importance weight — do not change which sites survive elimination.
5. Document in writing the list of scoring criteria that have been deferred to a later stage of review, and identify the specific meeting at which each will be evaluated before final ranking.
6. Adopt, by motion, a formal reservation of authority to revive any eliminated site if shortlisted sites prove unsuitable in deeper engineering review.
7. Enter the complete scoring methodology and all documented safeguards into the public record so that affected property owners can review it for completeness and consistency.
8. Defer any elimination vote until the procedural safeguards above have been adopted and made publicly available.
9. Require that the city engineer provide, for each site confirmed to lack three-phase electrical service, an estimated cost for the electrical infrastructure extension required to serve a 20 MGD facility — including per-foot line extension, transformer requirements, and any utility infrastructure upgrades — and enter those estimates into the public record before the Existing Infrastructure criterion is scored.

Appendix H Columbia Gulf Transmission pipeline — symmetric application

1. Produce and enter into the public record the parcel-specific Columbia Gulf Transmission pipeline risk analysis prepared for the Rockwood site, including the analytical basis on which Rockwood’s “limited usability” determination was made.
2. Apply that same analytical framework to every candidate site within the Columbia Gulf alignment, including Sites 1 through 7 and any other Mann Road, Berea Church Road, Maple Hill Road, and Coles Ferry Pike sites currently under consideration.
3. Document in writing why any candidate site within the Columbia Gulf alignment should not be subject to the same deprioritization applied to Rockwood — or apply that deprioritization consistently.
4. Coordinate with Columbia Gulf Transmission, LLC and PHMSA to obtain the route alignment, easement width, depth-of-cover, last inspection date, and class location status for the Mainline 100, 200, and 300 segments crossing each candidate site.
5. Coordinate with the City of Lebanon Fire Department and Wilson County Emergency Management to assess emergency response capability in the event of a Mainline 200-class rupture along the corridor adjacent to each candidate site.

Appendix I Biosolids disposal and traffic impact

1. Identify on the public record the intended biosolids management approach for the new facility — on-site digestion and gasification, haul to the existing Hartmann Drive plant, land application, or landfill disposal — before any site is eliminated from consideration, so that outbound truck volumes and road adequacy can be scored as part of the Community Impact and Existing Infrastructure criteria.