Aluminum and Fish Kill
Rayburn
Impaired Water Designation / Donohue Waste Water Permits / Revised Use Standards
By: B. W. Rayfor 1/21/2000
Impaired
waters List The
Texas Natural Resources Conservation Commission (TNRCC) has released the Draft of the Texas
Clean Water Act Section 303d Impaired Waters list dated January 2000 for public comment. Information excerpted from the list follows.
Sam Rayburn reservoir impairments:
· Fish consumption limited
because of excessive Mercury.
· Inadequate dissolved oxygen to support aquatic life in the upper
portion and “in several other areas”.
· Mean (average) lead concentrations exceed “chronic” exposure
concentrations in the main body of the reservoir. This means sustained exposure
causes death of fish
· Dissolved aluminum concentrations exceed “acute”
concentrations in the main body of reservoir. This means short term exposure will cause fish death.
· In the vicinity of the 147 bridge there are periods of time in which the pH concentrations are “outside of limits to safeguard
general water quality uses”. Excessive
acidity and excessive alkaline conditions were detected. This means it is not a good environment for fish and other critters.
Both Ayish Bayou and the Angelina River are now found in the impaired waters
list (finally) and are not safe to swim
or water-ski in because of “elevated
bacteria levels”. TNRCC has
dropped use of the words Fecal Coliform that formerly preceded the word bacteria
but it’s still the same old s…
TNRCC Waste
Water Effluent Reports A brief review of TNRCC
Waste Water Effluent Reports discloses that in 1998 and 1999 Donohue Paper
Company operated outside TNRCC imposed limitations on the quantity of dissolved
Aluminum and Zinc in their
discharges into Paper Mill Creek, which flows directly into the Angelina River
and Rayburn. Donohue has only been
required to report their discharges of Aluminum and Zinc Using the TNRCC Waste
water effluent records it is estimated that Donohue discharged a total of
464,133 lbs. of Aluminum into Paper Mill Creek in 1998 and a slightly smaller
amount in 1999. The maximum
reported discharge (656.35 lbs. per
day) of Aluminum released in the 1998, 1999 years, occurred in August, 1998;
shortly after the paper mill was sold to Donohue and concurrent with the major
Rayburn fish kill episode. The
August 1999 maximum discharge number was preceded by a June discharge rate of
640.15lbs./day and a July discharge rate of 630.3 lbs./day. One other discharge
rate in excess of 600lbs./day was reported in the available discharge records
for 1998 and 1999. The allowable
discharge of Aluminum to insure compliance with Designated Use Standards is
119lbs/day as stated in the “Final Limitations and Monitoring Requirements”
permit. Because “variances” and
“compliance” periods have been granted; the paper company has been required
to report discharges of Aluminum and Zinc under an “Interim
Limitation” – not limit their discharges.
TNRCC documentation defining the
permitted discharges from Donohue operations is confusing. The permit contains two tables – one identified as “Interim Effluent
Limitations and Monitoring Requirements” and another within the same document
identified as “Final Limitations and Monitoring Requirements”. The “Interim” table only requires reporting of Aluminum and Zinc
discharges and over-rides the
“Final Limitations and Monitoring Requirements .because a “variance” has
been granted The latter,
“Final Limitations and Monitoring Requirements” table lists a limit value
for Aluminum discharge of “119 lbs./ day average” and a “daily maximum value of 238 lbs. /day”. All
Aluminum discharge rates (average) were greater than 500lbs./day in 1998 and
greater than 363lbs./day in 1999. Assuming
that there was a scientific basis for establishing the limit of 119lbs./day listed in the “Final Limitations and Monitoring Requirements”
document it is very difficult, if not impossible, to develop a rationale based
on science that justifies unlimited discharges. Note that the paper mill has been operating with permit variances for
Dissolved Oxygen and Aluminum discharges for at least two permit periods.
Science
or Politics or Money Is it
possible that the “report only” requirement
is not based on science at all? Has
political pressure driven the
decision to only require reporting of discharges? Are community interests and the economy of a five county region dependent
upon the recreational value of Sam Rayburn being sacrificed for the benefit of a
few? Standards
Revisions The Texas Natural
Resources and Conservation Commission will release a set of revisions to
Designated Use Standards for waters of the entire state in the near future. These revised standards include revisions for the upper reaches of Sam Rayburn. At present
Rayburn has a designated use of “High Aquatic Life”. The proposed revisions solicited by the local paper mill reduce the
Designated Use Standards to Low or Intermediate Aquatic Life, dependent upon
season. Each standard has a
specific dissolved oxygen criteria and pollutant criterion associated with it. If the proposed standards
are adopted, the dissolved oxygen criteria for the upper end of Sam Rayburn will
be reduced to levels that will not support aquatic life such as Largemouth Bass
and Crappie. Recognize that under the existing standards and Waste Water Permit
arrangements there are periods of time in which the dissolved oxygen is
inadequate to support aquatic life as made evident by measurements at Etoille,
Hanks Creek and other areas. Moreover,
the current finding of “Acute”
concentrations of Aluminum is one of several causes of the lake classification
as “Impaired”. It
doesn’t take a rocket scientist to figure out what will happen when the
standards are reduced. There is a
legal requirement for remedial action when a body of water is classified as
Impaired. The work around to the
legal requirement is to change the Designated
Use Standard. It is logical to
surmise that the proposed change in standards is intended to avert the legal
requirements.
During the second week of January the proposed standards revisions were
presented to the TNRCC Commissioners. Donohue
paper Company officials, accompanied by the Mayor of Lufkin, other city
officials, U. S. Representative Jim Turner , and others traveled by bus to
Austin to lobby for the proposed revised standard of designated use for upper
reaches of Rayburn when it was presented to the commissioners. The technical justification for the proposed Rayburn standards revision
is based on a study presented to TNRCC and funded by the paper mill. The logic presented in the study is flawed with out rigorous scientific
merit. After all, why pay for sophisticated waste treatment when there is no
need? The increased profit that the
major “modernization and expansion” currently
underway will provide to Donohue paper Company and the promise of jobs for the
local community provide powerful
incentives. Are these incentives so
powerful that they over come environmental issues, the public interests and the
property and other investments associated with the recreational use and value of
the lake to the surrounding five county communities? We have been told that the local economy needs the job opportunities
provided by the mill, yet history tells
us that automation of industrial
processes results in reductions in work force. Are community interests and the
economy of a five county region dependent upon the recreational value of Sam
Rayburn being sacrificed for the benefit of a few?
The next legal step in making these revised standards active requires a period
in which public comment are solicited and a public hearing will be held – if
requested. The
public comment and hearing phase provide the last opportunity to stop this
tragedy from occurring.
Options to counter these proposed revisions include the following. Writing your
legislators. Writing the Texas Sunset Review Commission. Attending the upcoming public
hearings on Designated Use Standards. Organizing and forming a caravan of
Bass boats and descending upon Austin with parade permit in hand. Get active and
exert political influence of your own in every legal way available to you. If you value Sam Rayburn it is now or never.
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