Sam Rayburn Reservoir
Sam Rayburn Reservoir is a 114,500 acre reservoir in East Texas which stretches from the Sam Rayburn Dam in Jasper County to the aqueduct crossing one kilometer (0.6 mile) upstream of the confluence of Paper Mill Creek on the Angelina River Arm in Angelina/Nacogdoches County and to a point 3.9 kilometers downstream of Curry Creek on the Attoyac Bayou Arm in Nacogdoches/San Augustine County.
Water Quality Issues in the Reservoir
The reservoir is designated for contact recreation, high quality aquatic life, and public water supply under the State of Texas Surface Water Quality Standards. It has a history of water quality problems, however, and in 1994, 1996, and 1998 portions of the reservoir did not meet the high quality aquatic life use due to low dissolved oxygen levels. In addition, in 1996 and 1998, elevated fecal coliform levels caused the reservoir to fail to meet contact recreation use in the upper portion. Finally, there are concerns for other water quality parameters, including dissolved aluminum, dissolved lead, sulfates, nutrients, and metals in sediment. These concerns are described in the current and proposed "303(d) List" developed by TNRCC under requirements of the federal Clean Water Act to identify "impaired" streams- those not meeting water quality standards.
Pollution Discharges Affecting the Reservoir
The problems associated with high nutrients and low dissolved oxygen are caused principally by organic pollutants contributed by Paper Mill Creek. The water from this creek is often foamy and discolored and includes a discharge from the Donohue Industries Paper Mill (formerly the Champion International Corporation Paper Mill) in Lufkin. There were 21 discharge permits affecting Sam Rayburn in 1996.
The Donohue Paper Mill is currently operating under a permit from the Texas Natural Resource Conservation Commission (TNRCC) that authorizes variances from the permit limitations that ordinarily would be imposed in order to meet the high water quality standards that have been in place for Sam Rayburn Reservoir. Discharge limits are supposed to be set to meet water quality standards. Donohue has been allowed a variance to discharge an average of 2900 pounds per day (over one million pounds per year) of pollutants that use up oxygen in the water when they decompose (fish and other aquatic life need oxygen to live, of course). Donohue will not be able to continue this variance after a few years if the current high water quality standards are not lowered. The mill would have to reduce these pollution discharges to an average of 626 pounds per day during critical hot weather months and to reduce them substantially during other months _ for a total of about 484,000 pounds per year, about a 50% reduction in those pollutants.
Similarly, Donohue has been operating under another variance allowing it to discharge aluminum without any limit. Aluminum can be toxic to fish and other aquatic life. Donohue's annual discharges of aluminum apparently have been around 190,000 pounds annually in recent years. If required to meet current high water quality standards, the limit would be about 44,000 pounds per year in other words, less than one-fourth of the amount of aluminum being discharged now.
Proposed Downgrade of Water Quality Standards for a Portion of Sam Rayburn
TNRCC is required by the U.S. Environmental Protection Agency (EPA) under the federal Clean Water Act to review the state's surface water quality standards every three years to determine whether or not revisions are warranted and to propose any needed revisions. During the last year and a half TNRCC has been conducting the latest "triennial review" of the state's standards. In the February 4, 2000 issue of the Texas Register, TNRCC proposed revisions of the state's standards based on that review.
One of the proposed revisions is a proposed downgrade of standards for a portion of Sam Rayburn Reservoir. TNRCC proposes to accomplish this downgrade by:
· dividing the current reservoir segment into two "stream segments;"
· setting weaker water quality standards, such as lower requirements for dissolved oxygen, for the stream segment that encompasses the upper portion of the reservoir- the portion most directly and immediately impacted by discharges from the Donohue paper mill; and
· weakening some of the pollution limits in the stream segment that encompasses the lower portion of the reservoir.
Basis for the Downgrade: Studies Done for the Polluting Paper Mill
The proposed downgrade for Lake Sam Rayburn is based on the results of studies done by consultants hired by the paper mill (owned at that time by Champion International Corporation) in the mid 1990s. The studies are described as determining that the tributaries and the areas of the Angelina River/Sam Rayburn Reservoir sampled actually provide only "intermediate" rather than "high" quality habitat for fish and other aquatic organisms. (High quality aquatic habitat has a greater diversity of fish and other aquatic organisms as a result of factors such as higher oxygen levels in the stream.) Therefore, according to the studies, these areas should not have to meet the dissolved oxygen standards, for example, required for high quality aquatic habitat. A preliminary review of these studies indicates, however, that their conclusions are full of methodological and data set problems and that the data and results are open to different interpretations.
Opposition to the Proposed Downgrade
Anglers and environmentalists are mobilizing opposition to this proposed downgrade because of the adverse effects on fish and other aquatic life from the additional pollution that would be allowed. Comments in opposition to the downgrade may be sent to Bettie Bell, TNRCC, Office of Environmental Policy, Analysis, and Assessment, MC 205, P. O. Box 13087, Austin, TX 78711-3087. Deadline: March 31.