Above is a scanned copy of the first page of TPWD Andrew Labay's Comment Letter to TNRCC's Ms. Faith Hableton dated Sept. 25, 1996.
The text of the memo is detailed below.
Here are the a scanned images of the seven page memo which are readable.
The gif image of each page of the memo averages about 25kb.
Page 1, Page 2, Page 3, Page 4
Page 5, Page 6, Page 7,
Texas Parks and Wildlife Department
4200 Smith Road
Austin, Texas 78744
25 September 1996
Ms. Faith Hambleton
Texas Natural Resource Conservation Commission
P.O. Box 13087
Austin, Texas 78711-3087
Re: Renewal of Champion International Corporation's waste water disposal permit, Permit Number 00368
Dear Ms. Hambleton,
Texas Parks and Wildlife Department (TPWD) appreciates the opportunity to comment on the renewal of Champion International Corporation's (Champion) waste water permit. The following comments result from personal observations and review of the following documents prepared by EA Engineering for Champion:
- Sampling Survey of Mill Creek, Paper Mill Creek and Angelina River
- Site Specific Dissolved Oxygen Criteria Development for the Riverine Reach of Segment 0610
- Use Attainability Analysis of Paper Mill Creek
and the following documents prepared by Champion:
- Summary of Results and Conclusions for Mill Creek Hydrology and Comparison Study
- 1 March 1996 letter from Mr. John Turner (Champion) to Mr. Dan Pearson (TNRCC) regarding Champion Permit Number 00368
I. Dissolved Oxygen in Segment 0610 of the Neches River Basin (Angelina River)
Champion has requested a site specific dissolved oxygen standard of 3.5 mg/l average and 3.0 mg/l minimum for the Angelina River downstream of Paper Mill Creek. TPWD does not support this change. The documents referenced above (hereafter referred to as "the study") indicate dissolved oxygen levels in the Angelina River above Paper Mill Creek are supportive of the High Aquatic Life Use classification of the Angelina River. However, dissolved oxygen concentrations in the Angelina River below Paper Mill Creek are not meeting water quality standards. Furthermore dissolved oxygen concentrations progressively decline downstream of Paper Mill Creek, reaching recorded levels as low as 2.28 mg/l at the last sample station. It is possible that dissolved oxygen concentrations may be even lower in the riverine reaches of Sam Rayburn Reservoir below the last sample site. Since this area was not sampled, it is unknown if the aquatic community in this portion of the reservoir has been impacted.
Champion argues that although dissolved oxygen concentrations are lower in the Angelina River below Paper Mill Creek than in the referenced sites, there has been no change in the aquatic community as a result of their discharge. Thus, the degraded water quality has not impacted aquatic life, which justifies site-specific dissolved oxygen criteria. This argument is invalid for the following reason:
- Possible impacts may exist downstream of the last sample station, as previously mentioned. The studies did not adequately describe aquatic life use degradation downstream of the downstream-most sampling site.
- Fish community sampling was biased towards larger fish and incomplete. Boat electrofishing was the only sampling method employed. A boat electrofisher is a poor tool for sampling smaller fish, especially in the turbid water of the study area. Thus, species of small size, such as darters and minnows, were disproportionally undersampled, if sampled at all. These species are an integral par of the mettics used to calculate aquatic life use subcategories. The scores assigned to each sampling station may not have accurately represented the read fish assemblages.
II. Classification of Paper Mill Creek and Dissolved Oxygen
Champion has presented information which suggests all creeks in Paper Mill Creek watershed are periodically intermittent, including Paper Mill Creek (excluding their
discharge). This would support an intermittent classification for Paper Mill Creek. Unfortunately, there is no documentation what the traditional base flow to the Angelina River from Paper Mill Creek watershed was. However, the study labels lower Mill Creek as perennial, which suggests Paper Mill Creek below the confluence of Mill Creek would have traditionally been perennial.
Regardless of what the classification of Paper Mill Creek is, the study ranked the fish assemblage in Mill Creek as High Quality. Thus, it stands to reason, that permit criteria reflect High Quality Aquatic Life Use in Paper Mill Creek downstream of the confluence of Mill Creek. The study demonstrated a degraded fish community in lower Paper Mill Creek. Furthermore, recorded dissolved oxygen concentrations in Paper Mill Creek reached levels as low as 1.2 mg/l. The study states that "dissolved oxygen concentrations in the lower Paper Mill Creek are less than the criteria for any of the aquatic life use designations in the Texas Surface Water Quality Standards".
It is evident that current effluent quality is not protective of any Aquatic Life Use in Paper Mill Creek.
III. Total Suspended Solids
Champion wishes to maintain current total suspended solids (TSS) mass limits, Champion has stated that "current TSS loading discharge to Paper Mill Creek and the Angelina River are not resulting in any adverse water quality impacts associated with TSS such as accumulation of solids on the banks or bottoms of the water courses, increased turbidity, or excessive oxygen demand". The study does not appear to support this statement by Champion. Obviously, there is an excessive oxygen demand in Paper Mill Creek and in the Angelina River due to Champion's effluent. Unless information can be presented which documents oxygen demands resulting from something other than TSS, then TSS loading should be reduced. Furthermore, TPWD has observed heavy accumulations of solids in eddy currents immediately downstream of FM 842 on 6 July 1994. The study states that "velocities in Paper Mill Creek have been high enough to scour the natural sand and substrate away and expose hard-pan clay". It is likely that unless depositional areas, such as eddy currents, are investigated, TSS will not appear to be a problem Paper Mill Creek. Current velocities will be high enough to carry solids into the Angelina River and continue down river until velocities allow. It is likely that solids are not settling out until they reach the riverine segment of Sam Rayburn Reservoir. Hydraulic velocity slows progressively downstream. For example, average velocity measurements for July 1995 are as follows:
|Lower Paper Mill Creek ||0.42 fps|
|Angelina R. 2 Km downstream PM Cr. ||0.28 fps|
|Angelina R. 6 Km downstream PM Cr. ||0.27 fps|
|Angelina R. 10 Km downstream PM Cr. ||0.19 fps|
These conditions are conducive to TSS settling in the riverine portion of Sam Rayburn Resrvoir. Dissolved oxygen concentrations are also lower downstream in this area.
The Study documented elevated chloride levels in the Angelina River downstream of Paper Mill Creek. Results of analysis of seven water samples collected on 24 through 26 August 1992 demonstrated chloride levels of 32.4 mg/l upstream of Paper Mill Creek and 451 mg/l downstream of Paper Mill Creek. This information suggests that the Texas Water Quality Standards for chlorides (70 mg/l) are not being attained.
The study documented elevated ammonia levels in Paper Mill Creek and in the Angelina River downstream of Paper Mill Creek. Results of analysis of seven water samples collected on 24 through 26 August 1992 demonstrated ammonia levels of 0.094 mg/l upstream of Paper Mill Creek, and 2.8 mg/l downstream of Paper Mill Creek. Thus more restrictive ammonia limits should be incorporated in the revised permit.
Excessively high temperature have been documented in Paper Mill Creek. On 6 July 1994, TPWD documented a water temperature of 99 F and the study documented temperatures as high as 101 F. TPWD suspects these high temperatures are impacting aquatic life in Paper Mill Creek.
Studies conducted for Champion document degradation of dissolved oxygen in Paper Mill Creek and the Angelina River as a result of Champion's waste load. Additionally, chloride, ammonia, and temperature levels are also elevated downstream of Champion's outfall. TSS levels are also a concern due to the oxygen demand placed on these water bodies. Aquatic life in Paper Mill Creek reflects the degraded water quality conditions and downstream degradation of aquatic life in the Angelina River is also likely.
The Angelina River and Sam Rayburn Reservoir are very important public resources and support a diversity of fish and wildlife. It is the goal of TPWD to support changes which help protect water quality and fish and wildlife. It is not the intent of TPWD to support change which bears undo economic burdens on Champion. TPWD recognizes the economic importance of Champion to surrounding communities and the State of Texas. Unfortunately, current waste water treatment practices are not protective of water quality in Segment 0610 of the Neches River.
Thus, TPWD asks that Champion and TNRCC consider these and other alternatives to supplement current conventional waste water treatment practices.
- Eliminate Most or All Direct Discharge to Paper Mill Creek and the Angelina River via discharge to Kurth Lake
It was stated by Mr. Ron Turner that Champion's effluent quality was excellent. It is TPWD's understanding that Champion's primary water supply is Kurth Lake. By diverting a portion or all of the excellent quality effluent to Kurth Lake, discharge to Paper Mill Creek and the Angelina River would be reduced or eliminated. It may be possible with the appropriate assimilative capacity to handle Champion's effluent. The end result would be partial or entire recycling of waste water and little or no discharge to Segment 0610.
- Construct Wetlands to Serve as Final Treatment of Waste Water
The benefits of wetlands for final waste water treatment are widely recognized an currently employed successfully in Texas. Wetlands are effective tools for "polishing" waste water. Constructing wetlands down gradient of the mill may provide an inexpensive and low-maintenance alternative to other advanced treatment technology needed to meet Texas Surface Water Quality Standards. Furthermore, water from wetlands could potentially be reused by Champion via diversion to Kurth Lake. Benefits of wetlands would not only serve as a final treatment of waste water, but would also benefit fish, wildlife, and the public.
We would be happy to meet with you and discuss these and other alternatives. Please call me at 903/566-2518 if you have any questions. Thank you for your time and consideration.
Andrew A. Labay
Environmental Quality Branch