Above is a photo copy of Larry Bonner's letter to Ms. Gloria A. Nasquez of the
TNRCC, dated June 27, 1996. The text of the letter is detailed below.
Here is a scanned image of the original letter which is readable. The gif image of the memo is 23kb.
U.S. Department of Agriculture
National Forest and Grassland in Texas
701 N. 1st Street
Lufkin, TX 75901
File Code : 2600
Date: June 27, 1996
Ms. Gloria Nasquez
Texas Natural Resource Conservation Commission
P.O. Box 13087
Austin, Texas 78711-3087
Dear Ms. Nasquez:
This letter is in regard to the request by Champion International to lower the dissolved oxygen (DO) levels, in their Sam Rayburn Reservoir effluent, from 5.0 to 3.0 ppm.
We are assuming that this request is a by-product of the recent proposals to reduce the State minimum to 4.0 in East Texas. We attended a meeting at Stephen F. Austin University on March 26, 1996, where Texas Natural Resource Conservation Commission (TNRCC) officials explained the logic behind this was due to naturally lower DO levels in East Texas. Our studies in East Texas and western Louisiana do not indicate that overall annual averages are below 5.0 ppm. Due to late summer droughts, some stream flows subside to levels where sub 5.0 readings may be noted, but these are only for a brief period and intolerant species are able to migrate to major tributaries for relief.
It is also know that sub 5.0 levels induce fish stress and slow growth. We have frequent reports of Aeromonas sp. bacterial infections from the referenced area of Lake Sam Rayburn. Bacterial infections are usually the result of elevated stress levels and concurrent lowered resistance.
It is our position that allowing a 3.0 ppm discharge will not emulate natural levels and, furthermore, will compound naturally occurring deficits and result in greater fish stress, disease and potential die-offs. Since this will be a continuous condition, slowed fish-growth will be a definite result. We do no concur with any recommendation for lowering the current allowable discharge levels.
Larry H. Bonner
Natural Resource Team Leader
cc: Glenn Donohue, Angelina District Ranger