Above is a scanned copy of the first page of a TNRCC Interoffice Memo from Jo English to
Ernest McFarland Waste Water Permits Section dated Dec. 16, 1996.
The text of the memo is detailed below.
Here are the a scanned images of the three page memo which are readable.
The gif image of each page of the memo averages about 30kb.
Page 1, Page 2, Page 3
Texas Natural Resource Conservation Commission
Date: December 16, 1996
To: Ernest McFarland, Wastewater
Permits Section, Agriculture and
Watershed Mangement Division
Thru: Georgie Volz, Water Program Manager,
Region 10, Beaumont
Vic Fair, Regional Manager,
Region 10, Beaumont
From: Jo English, Field Investigator, Region 10, Beaumont
Subject: Champion International, Lufkin Paper Mill
Permit No. 00368
For your review and consideration, I would like to make the following comments on the proposed permit amendment request by Champion Paper.
- Please note that this report doe not state that the effluent is discharged to Sam Rayburn Reservoir. This lake is a flood control impoundment operated by the US Army Corps of Engineers (USACE). Stations N1 and N2 are located within the floodzone boundary of the lake; Stations N3 and N4 are located in the upper reaches of the reservoir. The lake reaches almost to State Highway 7 bridge crossing the Angelina River, however, the USACE generally acklowledges the upper limits of Sam Rayburn to be upstream of the US Highway 59 bridge crossing. As the largest freshwater impoundment within Texas, this lake is not only well known for recreational uses, but also contributes significantly to the drinking water supply to the cities of Beumont, Port Arthur, Groves, Nederland and Port Neches, as well as West Jefferson MUD, in Jefferson County. Water from Sam Rayburn is also sold for industrial and agricultural water supply by the Lower Neches Valley Authority (LNVA). Water rights for sale of the water in Sam Rayburn to 149' MSL belong to LNVA.
- The request for an exemption to the dissolved oxygen standard should be denied. The documentation furnished by the permitee does not support their conclusion that a downgrade to Intermediate Aquatic Life Uses (ALU) designation is warranted. The report prepared by the EA Engineering indicates that the Angelina River is exceptional habitat up to the confluence with Paper Mill Creek. This report also states that the downstream stations range from Intermediate to Exceptional ALU, with the exception of the driest months (7/7/95 and 8/31/95 sampling events).
- The D.O. levels tend to fall as the flow moves downstream. Line graphs (attached) developed from the E.A. Engineering attachment entitled "Monthly River Monitoring", demonstrate that the D.O. levels tend to decrease from Station N1 to Station N4. It should be noted that N1 is the upstream most station and N4 is the downstream most station. Please note that D.O. levels in Paper Mill Creek were not monitored during this study. A review of the TNRCC surface water quality monitoring stations in the general area from 02/22/95-11/2/95, also indicates a general trend downward in the D.O. levels.
Since flows were not recorded for each sampling event, a correlation between river flow and lake level is impossible. The normal conservation pool elevation for Sam Rayburn is 164' MSL however, the lake level can fluctuate widely in any given year. During the study period, Sam Rayburn's level changed by 11.08 feet. The lowest recorded elevation (159.56' MSL on 10/4/94) represents a drop of 7.44' from pool, and the highest recorded elevation (170.64' MSL on 3/21/95) is a rise of 6.64' from pool level. The lake levels on D.O. monitoring dates as provided by USACE, are attached. The SWQM reports indicate variability in impact to the Angelina River/Sam Rayburn Reservoir. The greatest impact appears to be during periods of low flow. A lowered minimum D.O. in the permit could lead to a D.O. sink, and create more stress in the aquatic environment than is already in place. The affected area is easily identified by observation due to the staining of the waters mixing with the mill effluent. The discoloration is clearly visible in the water. The attached SWQM tables show that transparency is reduced and conductivity is increased downstream of the Paper Mill Creek confluence. This is particularly pronounced during low flow periods.
On May 16, 1996 the USACE conducted an overflight of the reservoir. On this trip, the USACE photographed and videotaped the lake area from the project office, at the dam, upstream to the US 59 Bridge, as all of this area is within the boundary of the reservoir. A copy of the videotape and the photographs are enclosed. Please note that both of the flows from Paper Mill Creek, and the lake levels are extremely low. Champion's flows on this date were below normal due to maintenance shut down. The flow from the mill on 5/15/96 was 2.5 MGD, with the 5/16/96 flow at 7.7 MGD (well below the average flows of 15-19 MGD). The lake elevation on this date was 153.48" MSL, some 10.5' below the normal pool elevation, due to the drought conditions in the basin.
- The permitee is also requesting a variance on the aluminum standard. The report contends that no toxicity exists at 50 mg/l and 100 mg/l CaCO, hardness. The tests used in synthetic dilutions at fixed hardness, which generally do not represent actual in-stream conditions. TNRCC SWQM TOXNET samples taken of Paper Mill Creek just upstream of the confluence indicated a hardness between 191 mg/l on 11/2/95 and 126 mg/l on 1/29/96. The 11/02/95 sample (attached) indicated a toxicity in the test species.
The SWQM program began analyzing aluminum along with the routine annual heavy metal analysis in sediment samples at station 0610.200 (Sam Rayburn at Highway 103) in 1994. These analysis indicated significant concentrations of aluminum. Limited data is available for aluminum concentrations in the area soils. The Soil Survey for Angelina County published by the NRCS provided some data for extractable aluminum in eight soil types found in that county. These concentrations ranged from a low of 0.1 milliequivalents /100 grams to a high of 14.5 milliequivalents /100 grams. The Region 10 SWQM team has planned to collect sediment samples for metals from the Angelina River in the monitoring schedule for this year.
Composite samples were taken of the mill effluent during the regional inspections on 1/23/95 and 2/8/94. The total aluminum concentrations were 4620 ug/l on 1/23/95 (18.2 MGD flow) and 3500 ug/l on 2/8/94 sample results revealed total copper (12 ug/l), lead (30 ug/l), nickel (10 ug/l), mercury (12.2 ug/l), and zinc (141 ug/l), in addition to the aluminum. SWQM samples collected at Station ID # 0610.0200 (Sam Rayburn Reservoir at Highway 103) on 5/16/95 indicated total aluminum concentration of 31800 mg/kg in the sediment. A table containing the last three year's SWQM sediment results is attached. The TDH has posted a fish advisory concerning elevated mercury concentrations in the edible tissue for Sam Rayburn. This fish advisory prompted a special study for metal concentrations in the reservoir during the FY 96, by the regional SWQM team. The report for this study has not been completed.
Signed: Jo English, Investigator