Project River: Water, Wastewater & Watershed

Project-specific evidence and unresolved questions about water supply, recovered water, cooling, wastewater, stormwater, and watershed effects.

A closed loop still needs a complete water balance.

Open · Detailed issue review

Current status

Project River and Azure Engineering describe a design in which water recovered from biomass drying supplies process and cooling needs through closed-loop systems. The reviewed materials do not yet provide a complete phase-by-phase water balance covering startup, a gas-only first phase, outages, drought conditions, treatment losses, wastewater pathways, or emergency demand.

Sources:RIV-008RIV-009RIV-013RIV-014RIV-017RIV-028

What is documented in the record

The public record establishes the existence of project water claims and the separate state permitting process; it does not yet establish the final operating water balance.

Government Statement

Water permitting is separate from city land-use approval

TDEC maintains water-related public-participation and permitting processes that are distinct from municipal annexation and zoning. A city land-use action does not by itself show that a Project River water permit has been issued.

Sources:RIV-008RIV-009

Developer Statement

Project River describes recovered water as the routine process-water source

Project materials say moisture recovered during biomass drying would be condensed and reused for process and cooling needs, with routine operations not relying on withdrawals from the Hiwassee River or residential wells.

Sources:RIV-013

Developer Statement

Proposed PUD language described a 90% onsite process-water requirement

The project says proposed PUD 77 would require 90% of process water to be generated onsite, excluding initial priming, and would prohibit a direct utility connection to the Hiwassee River.

Sources:RIV-014

What the project and engineering team say

These are attributed design claims. They still require a complete design basis, operating assumptions, and permit-grade documentation.

Developer Statement

Routine operations will not depend on city water

Project River says biomass drying recovers water for process use and cooling and that normal operations will not draw from the Hiwassee River or residential wells.

Sources:RIV-013

Developer Statement

Closed-loop chilled-water and reverse-osmosis systems

Azure Engineering describes closed-loop cooling and reverse-osmosis systems, with dryer condensing systems supplying makeup water.

Sources:RIV-017

Developer Statement

The water system is tied to the biomass design

Both the project and engineering descriptions connect recovered process water to biomass drying. That linkage makes phasing and outage scenarios important because the water source described for routine operation depends on another major project component being available.

Sources:RIV-013RIV-017

Permitting, watershed & outside analysis

Water quantity, water quality, stormwater, wastewater, and watershed questions can involve different records and permitting pathways.

Government Statement

TDEC notices are the authoritative place to confirm project-specific filings

TDEC water notices and the Chattanooga Environmental Field Office are the relevant government sources in the current register for confirming actual water, stormwater, discharge, or related filings as they occur.

Sources:RIV-008RIV-009

Third-Party Analysis

SELC has challenged aspects of the water claims

The Southern Environmental Law Center raised questions about the project’s water and biomass assumptions in a September letter. Placeward treats those statements as third-party legal and technical analysis, not as agency findings.

Sources:RIV-028

Placeward Analysis

“Closed loop” does not answer every water question

Even a recirculating system needs a documented initial fill, makeup-water assumptions, treatment-loss accounting, contingency planning, and a defined pathway for any blowdown, reject water, wastewater, or stormwater that leaves the process loop.

Sources:RIV-013RIV-014RIV-017RIV-029

Placeward Analysis

Site hydrology still matters even if routine process withdrawals are low

The final grading footprint, streams, wetlands, floodplains, private wells, erosion controls, spills, stormwater, and construction-phase water management remain separate site questions from routine process-water demand.

Sources:RIV-008RIV-009RIV-029

What remains unresolved

  • ?Gas-only first phase: if power generation begins before biomass drying is operating, what supplies cooling and process water?
  • ?Initial priming: how much water is required to fill the closed-loop system, and from what source?
  • ?Seasonal variability: how does recovered-water output change with biomass moisture content and operating conditions?
  • ?Biomass outage: what supplies makeup water during days or weeks when dryers are offline?
  • ?Alternate end user: how would a different industrial customer change cooling, process-water, and wastewater demand?
  • ?Fire protection and emergencies: what water reserve is required independently of normal process water?
  • ?What streams, wetlands, floodplains, groundwater receptors, and private wells are near the final grading footprint?
  • ?Will any cooling blowdown, treatment reject stream, process wastewater, or other discharge leave the closed process loop?

Evidence needed

Integrated water balance
Normal, peak, startup, outage, drought, and expansion scenarios by project phase, with source and disposition for every material water stream.
Cooling-system design basis
Heat loads, equipment specifications, circulation rate, treatment losses, blowdown, evaporation, and makeup-water assumptions.
Initial-fill and contingency-water plan
Volume, source, storage, delivery capacity, and operating triggers for initial priming and emergency or outage makeup water.
Source and discharge documents
Utility agreements, wells or other sources, wastewater pathways, stormwater plans, treatment rejects, and actual permit applications.
Comparable operating references
Owner-verified operating data from facilities using the same water-recovery and cooling configuration at a relevant scale.
Baseline watershed conditions
Streams, wetlands, floodplains, wells, groundwater, drainage, and water-quality measurements collected before site disturbance.
Supporting detail

Go deeper without losing your place

Expand chronology, community concerns, research priorities, verification methods, and related guidance as needed.

Community concerns in the record3 items

These entries document concerns raised by residents or outside advocates. They are not presented as proven factual conclusions.

Community Concern

Outside-water dependence if recovered water is insufficient

Community commentary has questioned what supplemental water source would be used if recovered water is lower than projected, unavailable during startup, or interrupted during a biomass outage.

Sources:RIV-022RIV-027

Community Concern

Watershed and neighboring wells

Residents have raised concerns about potential effects on the Hiwassee River, local drainage, groundwater, and private wells. Those concerns require site-specific hydrologic and permitting evidence before impacts can be characterized.

Sources:RIV-022RIV-027

Community Concern

Phasing before biomass is operating

Because Azure describes phased development beginning with gas generation, the public record needs to show how water and cooling would operate during phases in which the biomass drying system is not yet available.

Sources:RIV-017RIV-027

Additional considerations3 items

Potential advantage if demonstrated

A system that materially reduces outside water demand could reduce one of the major infrastructure pressures associated with a large industrial campus.

Potential risk if assumptions fail

If recovered water is lower than expected or unavailable during a project phase or outage, supplemental water infrastructure or operating constraints could become necessary.

The verification question

The issue is not whether water recovery and closed-loop cooling are possible in principle. It is whether the actual Project River design produces enough usable water under realistic operating conditions with enforceable limits and contingency plans.

How the water system can be verifiedMethod
  1. Build a complete water balance.Track every source, internal recycle stream, loss, discharge, storage volume, and contingency source for each project phase.
  2. Test the non-routine cases.Evaluate startup, gas-only operation, dryer outages, drought, seasonal fuel-moisture variation, maintenance, emergencies, and expansion rather than relying only on normal-operation averages.
  3. Match claims to actual equipment.Identify the cooling, drying, condensing, treatment, and storage equipment and compare design assumptions with vendor data and comparable operating references.
  4. Separate process water from site water impacts.Review stormwater, erosion, wastewater, wetlands, drainage, spills, and nearby wells independently from the project’s routine process-water claim.
  5. Verify permits and enforceable limits.Use actual agency filings and issued conditions to determine what is monitored, reported, limited, and enforceable.
Related guidance1 links
General Water & Cooling guide
Reusable questions and evidence standards for evaluating water and cooling claims in major development projects.
Open →
Research addendum · October 1, 2026

PFPI audit: watershed context and water-balance claims

PFPI raises water and watershed concerns, but two different questions need to remain separate: the condition of the receiving watershed and whether Project River’s proposed recovered-water system is sufficient.

Full PFPI technical audit →
Placeward Analysis

A specific Hiwassee water-quality concern is officially documented

TDEC’s April 2025 fish-advisory list identifies a Hiwassee River segment spanning Meigs, McMinn, and Bradley counties with a precautionary largemouth-bass advisory for mercury. That supports describing an existing mercury concern in the watershed. No authoritative national ranking or methodology was identified for PFPI’s broader characterization that the Hiwassee is “one of the most polluted watersheds in the country,” so that phrase should not be repeated as a Placeward fact without a defined national ranking and methodology.

Sources:RIV-038RIV-044

Placeward Analysis

Generic thermal-plant water assumptions cannot settle the Project River water question

Project River describes closed-loop cooling, no cooling towers, and recovered biomass moisture as the routine process-water source. Those claims are unusual enough that generic water-consumption factors for conventional wet-cooled plants are not a reliable substitute for the actual design. The unresolved requirement remains a complete phase-by-phase water and heat-rejection balance, including startup, gas-only operation, dryer outages, treatment losses, emergency water, and any discharge streams.

Sources:RIV-013RIV-017RIV-038

This addendum compares PFPI’s analysis with stronger or more direct sources and identifies which claims are supported, assumption-dependent, unresolved, or unverified. PFPI’s conclusions remain third-party analysis rather than project facts.