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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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