Above is a photo copy of EPA's Stephen Bainter's Comments Letter regarding the WER Study conducted for Donohue Industries. 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 30kb.
Comments to File
Donohue Industries Inc.
Water Effects Ration for Aluminum
by: Stephen Bainter
Based on my review of Water Effects Ration (WER) study conducted for Donohue Industries, Inc. formerly Champion International, I have the following comments:
The April 19, 1995 sample data included grab samples collected from the Angelina River to prepare simulated downstream water. During the sampling period the flow in the Angelina River was 3,610 cubic feet per minute. Low-flow for the Angelina River is 38.7 cubic feet per second. This means the flow in the Angelina River was about 93.3 times greater than the low-flow conditions. This type of flow is atypical and should not be used for Water Effects Ration study.
The range of aluminum concentrations used in the dilution series to estimate LC50 values for the synthetic lab water, simulated downstream water and 100% effluent was too large to accurately determine the LC50 values. A separation of no more than a factor of 0.6 to 0.8 should be used, as apposed to the 0.1, 0.2, 0.25 and 0.5 factors typically used in the Donohue study.
The pHs of all test solutions must be maintained with the range of 6 to 9 standard units. If the pH cannot be maintained within this range then the control, or a second control, must have a similar pH to discount any significant toxicity from an unusual test solution pH.
Based on conversations with Donohue Industries and its consultants on 6/8/00 and subsequent conversations between Donohue and TNRCC, the proposed WER of 8.6 will be withdrawn from this triennial revision of standards. The facility will conduct additional sampling in order to calculate a WER for aluminum. Donohue will prepare a revised sampling plan for review by TNRCC and EPA, prior to initiating sampling.
The proposed TX WQS also contained a narrative provision of WERs (§307.6(c)(9)), which allows the use of a WER prior to incorporation of the value during the triennial revision. This approach is consistent with federally-promulgated standards, as well as other state standards. Assuming this provision is adopted by TNRCC and approved by the EPA, EPA will review each WER for technical approval as part of the review of permits under the Texas Pollutant Discharge Elimination System (TPDES). EPA will also consult with the U.S. Fish and Wildlife Service on WERs during the review. Public review on WERs will occur during the permit public review process. EPA requests that all persons who submitted written comments on the WER and/or the use attainability analysis for the Angelina River during the triennial revision, be added to the TNRCC notification list for this facility's discharge permit.