FINAL
ENVIRONMENTAL IMPACT STATEMENT
FOR
CONSTRUCTION OF WASTEWATER FACILITIES
RED OAK, TEXAS
WPC-TEX-533
IMPACT STATEMENT NUMBER 7103
Prepared By
OFFICE OF GRANTS COORDINATION, REGION;VI
ENVIRONMENTAL PROTECTION AGENCY
DALLAS, TEXAS
APPROVED BY:
Arthur W. Busch
Regional Administrator
May 26, 1972
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SUMMARY
TABLE OF CONTENTS
Page
I. DESCRIPTION OF THE PROPOSED ACTION 8
: II. ENVIRONMENTAL IMPACT OF THE PROPOSED ACTION 11
• •
;i A. Ecological disruption 11
/ B. Land use 12
C. Population growth 12
D. Effect of effluent on Red Oak Creek 13
III. ADVERSE IMPACT WHICH CANNOT BE AVOIDED SHOULD THE
PROPOSAL BE IMPLEMENTED 20
1. Odor production 20
2. Noise production 21
3. Insect propagation 21
4. Building up of organic sediments in the 21
stream
5. Effect of chlorine on the stream 21
6. Plant shutdown's effect on the stream 22
(future TRA connection)
IV. ALTERNATIVES TO THE PROPOSED ACTION 23
a. Grant rejection (Construction of Proposed 23
Project Without Federal Funds)
b. Provide the facilities of alternative (a) 23
with advanced waste treatment facilities to
supplement effective secondary treatment
c. Construct an interceptor to transport waste- 24
water to the TRA regional treatment facility
•
d. Total retention ponds sufficiently large to 25
preclude any effluent discharge to any stream
*
e. Irrigation of a privately owned golf course 25
f. Haul wastes by truck to a regional treatment 27
facility
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g. Discharge to a stream with less aesthetic 28
value
h. A no action concept of continued use of 28
septic tanks
V. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF 29
MAN'S ENVIRONMENT AND THE MAINTENANCE AND EN-
HANCEMENT OF LONG-TERM PRODUCTIVITY
VI. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF 30
RESOURCES WHICH WOULD BE INVOLVED IN THE PRO-
POSED ACTION SHOULD IT BE IMPLEMENTED
VII. A DISCUSSION OF PROBLEMS AND OBJECTIONS RAISED 30
BY OTHER FEDERAL, STATE, AND LOCAL AGENCIES AND
BY PRIVATE ORGANIZATIONS AND INDIVIDUALS IN THE
REVIEW PROCESS
VIII. CONCLUSIONS AND RECOMMENDATIONS OF THE ENVIRON-
MENTAL PROTECTION AGENCY
Exhibits
APPENDIX A - COMMENTS AND OBJECTIONS
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LOCATED AT END OF REPORT
List of Exhibits:
EXHIBIT No. 1 - Transverse Mercator Projection
EXHIBIT No. 2 - Sewer System for Red Oak, Texas
EXHIBIT No. 3 - Red Oak Creek, Water Quality Data
EXHIBIT No. 4 - Permit to dispose of Wastes
EXHIBIT No. 5 - Estimated Population, Red Oak, Texas
EXHIBIT No. 6 - Summary of Costs
EXHIBIT No. 6A- Cost Estimate Proposed Project
EXHIBIT No. 7 - Revised Project Cost estimate for Sewer System
for the City of Red Oak, Texas
EXHIBIT No. 8 - Well Water Analysis
EXHIBIT No. 9 - Classification of Irrigation Waters
EXHIBIT No. 10- Hearing Commission Report
EXHIBIT No. 11- Attendance List - City of Red Oak
EXHIBIT No. 12~ State Health, Department Field Report
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SUMMARY
( ) Draft Environmental Statement
(x) Final Environmental Statement
Environmental Protection Agency
Region VI, Air and Water Programs Division
Dallas, Texas
1. Name of Action
Administrative Action (X)
Legislative Action ( )
2. The proposed action consists of federal grant assist-
ance as authorized by Section 8 of the Federal Water
Pollution Control Act. The City of Red Oak, Ellis
County, Texas has applied for federal funds to aid in
constructing a complete wastewater treatment system.
The portions of this system eligible for federal funds
include the wastewater interceptors and treatment plant.
The treatment plant will employ an extended aeration
process including pretreatment grit removal, flow measure-
ment, and effluent chlorination. The treatment process
will take place in an oxidation ditch followed in series
by a clarifier. The biologically active solids from the
aeration unit will be collected in the clarifier and
returned to the oxidation ditch to aid in stabilizing the
raw sewage. Sludge drying beds will be constructed on
the site with ample volume to handle clarifier sludge
accumulations and waste sludge from the treatment process.
3. The total project includes all facilities necessary for
the collection, transportation, and treatment of wastewater
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generated in the City of Red Oak, Texas. Discharge of
the treated effluent will be to an unnamed tributary of
Red Oak Creek. The project is designed to eliminate
the septic tanks that are presently contributing to
pollution of surface water and creating potential health
hazards in the area. The alternatives being considered
are intended to improve the health and welfare of the
people residing within the city while enhancing the
water quality of Red Oak Creek and its tributaries. The
final selection of the most feasible alternate is con-
tingent on thorough evaluation of both economic and
ecological aspects to assure that the project concepts
will minimize adverse effects on the human environment
without unduly burdening the citizens.
4. The alternatives being considered include:
a. Grant rejection - The proposed project might be financed
without federal grant aid if federal requirements will
impose total project costs that are not within funds
available to the City of Red Oak. The Project would
be designed to meet the requirements of the Waste
Control Order issued by the Texas Water Quality Board
and consistent with design criteria established by that
agency. It is assumed that this project would be the
same as the one proposed.
b. Provide advanced waste treatment facilities to supple-
ment effective secondary treatment, further improving
the quality of the effluent to a degree that will
exceed current criteria formulated by the Texas Water
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Quality Board.
c. Construct an interceptor to transport waste water to
the Trinity River Authority's regional treatment
facility.
d. Total retention ponds sufficiently large to preclude
effluent discharge to a receiving stream.
e. Irrigate a privately owned golf course with the treated
effluent/ thus precluding discharge to a receiving
stream.
f. Hauling raw waste by truck to a regional treatment
facility.
g. Discharge of treated effluent to a receiving stream
with lesser aesthetic value.
h. A "no action" concept of continued use of septic tanks.
5. List of Federal, State, and local agencies from which
comments have been solicited. (Attached)
6. The Draft Environmental Impact Statement was made
available to the Council on Environmental Quality on
February 25, 1972.
The Final Environmental Impact Statement was made
available to the Council on Environmental Quality on
JUN 5 1972
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Federal Agencies
Forest Service
Bureau of Outdoor Recreation
Army Corps of Engineers
Soil Conservation Service
Geological Survey
Department of Housing & Urban Development
Office of Economic Opportunity
Department of Health, Education & Welfare
EDA
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State Agencies
Office of the Governor
Texas Air Control Board
State Department of Health
Texas Industrial Commission
Texas Parks & Wildlife Department
Texas Water Quality Board
Texas Highway Department
Railroad Commission of Texas
Texas Water Rights Commission
Texas State Historical Survey Committee
Department of Agriculture
General Land Office
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State Agencies
Texas Animal Health Commission
Forest Service
State Soil & Water Conservation Board
Texas Tourist Development Agency
Texas Water Development Board
Association of Texas Soil & Water Conservation Districts
Texas Conservation Council, Inc.
Bureau of Economic Geology
Texas Council for Wildlife Protection
Texas Forestry Association
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Individuals and Local Agencies
Wisenbaker and Fix
Mrs. Ed Prude
Honorable P.P. McCalman, Mayor
Robert N. Tharp, Regional Manager, Trinity River Authority
North Central Texas Council of Governments
Honorable Milton Hartsfield
David Fearis, M.D.
Mr. Don Shields
Red Oak Creek Landowners Association
Mrs. Franklin Wright
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ENVIRONMENTAL IMPACT STATEMENT
I. Description of the Proposed Action
The City of Red Oak, Ellis County, Texas, located approxi-
mately 23 miles south of Dallas (Exhibit No. 1), plans to
construct a wastewater collection and treatment system to serve
its residents. The city's proposal calls for a complete col-
lection system, interceptors, and extended aeration treat-
ment plant. Discharge of the treated effluent will be to a
tributary of Red Oak Creek. The facilities will be designed
for 2000 population equivalent expected in the late 1980's,
but initial service will be to the approximately 800 current
residents of Red Oak. All of the proposed facilities will
lie in or near the developed areas of the City of Red Oak.
(Exhibit No. 2)
At present, the City has no municipal sewerage facilities.
A preliminary plan for the proposed system was prepared by
the city's consulting engineers in 1958, but the project was
found to be cost prohibitive at that time. The present pro-
posal, based on a Red Oak Creek discharge, has been found
to be financially acceptable to the City. The project has
been reviewed and approved by the Texas Water Quality Board,
Texas State Department of Health and the North Central Texas
Council of Governments. Documents from these agencies are
included in this statement. These documents refer to an
oxidation ditch - stabilization pond system which was originally
proposed by the City. Since these agencies approved a pond
system, it is expected that they will approve a clarifier
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in lieu of the ponds. Review of the plans by the Environ-
mental Protection Agency, following the grant application,
indicated a need for an Environmental Impact Statement to
respond to the objections of some downstream landowners. This
review studied the design, economics, and ecological aspects
of the project and initially concluded that total retention
or reuse would be the best interim solution pending connection
to a regional system when financially practical. These con-
clusions were then made conditions of the $55,550 Grant Offer
made on 30 June 1971. EPA representatives further recommended
using plant effluent to irrigate a nearby golf course as an
effluent reuse alternative.
The following is an excerpt from a statement presented
at the Public Hearing held in Duncanville, Texas, on October
8, 1971. This statement was prepared to clarify the position
of the Environmental Protection Agency on the Conditions
of the Grant Offer.
Although the grant offer was made contingent on these
conditions, additional alternatives may prove feasible
for further consideration. However, the City of Red
Oak will be responsible for justifying any other alter-
native with due consideration given to economics and
the effect on the human environment.
The Environmental Protection Agency will give approval
to a'ny such proposal that is judged to be the best
course of action consistent with national environmental
goals .f
In accordance with this statement the Environmental Pro-
tection Agency and the City's engineers conducted a more
detailed study of the irrigation system proposal and concluded
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that this alternative was ecologically and financially
impractical. A review of all alternatives concluded that
the City's proposal was the most practical and the reuse-
retention condition was dropped from the Grant Offer.
The City's existing treatment facilities are comprised
of septic tanks owned and operated by the residents of the
city. Due, in part, to the poor permeability of the calcareous
clay soil of the region, these facilities are hydraulically
overloaded. Sewage pools have been observed, in-several
^action* of the city. P
In addition, these pools represent a potentially serious
public health hazard. Representatives of the EPA and the
Texas State Department of Health have observed these conditions
on several occasions and a copy of the Health Department report
is given in Exhibit No. 12.
Among the most seriously affected areas of the City are
the schools. This daily concentration of people has taxed
the soil system's limited absorption capacity and overflows
are evident. To help alleviate this condition, and the odors
associated with it, the Red Oak Independent School District
has recently added 1000 feet of lateral lines to the school's
drain fields. This is only a temporary solution, however, since
the schools are expanding rapidly as evidenced by a proposed
high school addition.
The aesthetic value and sanitary quality of Red Oak Creek
is also endangered by the septic tank seepage occurring in the
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City. Runoff flushes these pools and carries the sewage
to the creek where it may pose a threat to the health of
anyone using the creek for recreational or agricultural
purposes. Increased seepage could have a significantly
degrading effect on the stream, producing an aesthetically
unpleasant change in the area.
II. Environmental Impact of the Proposed Action
The project, as proposed, will affect the environment in
four specific areas:
1. ecological disruption during construction;
2. land-use;
3. population growth;
4. effect of effluent on Red Oak Creek.
A. Ecological disruption, as a result of construction,
is a problem common to all wastewater facilities projects.
Installation of the collection system in the developed areas
of the City will have little or no ecological impact other
than the short-term impact of being unsightly and inconvenient
to the local residents. Construction of the interceptor will
be along a route through undeveloped land. Any damage done
along this line will be short-term since no permanent above
ground facilities will be needed and the restorative provisions
of the contract specifications will return the area to near pre-
construction conditions.
In most cases, construction of a wastewater treatment plant
will have a long-term ecological impact. Removal of trees and
shrubs, site excavation and road building, and tiie installation
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of numerous permanent structures will drive off most animal
life and destroy the natural setting of the area.
The proposed Red Oak plant, however, is part of an
interim plan and, while construction will result in the
condition mentioned previously, removal of the plant's
structures followed by proper landscaping will return the
site to its natural state. For this reason, the overall
impact of the plant on ecological development in the area
of the site can be regarded as short-term.
B. Land use changes, like the ecological disruption that
results from construction, can be regarded as having only a
short-term environmental impact. In the developed areas of
the City, no land use changes are anticipated since the
sewers will be designed to serve the land as it is presently
used. The undeveloped lands adjacent to the interceptors
will be limited in development by the location of the
line; on the other hand, this same line will stimulate
development of the adjacent land. The land adjacent to the
treatment plant will be adversely affected by the presence
of the facilities, since the existence of a plant is aesthet-
ically objectionable to landowners and developers. However,
these facilities are regarded as an interim solution and
should be closed before extensive development begins in the
general area of the plant.
C. The population growth trend, like land development, will
be beneficially stimulated by the installation of a sewerage
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system. The removal of the aesthetically objectionable
seepage will help to improve the City's residential image
thus drawing prospective homeowners to the area. Exhibit
No. 5 shows a population projection to the year 2,000. It
can be seen that the rate of population growth increased
after 1962, the year of completion of.a major highway
(Interstate Highway No. 35E) connecting Red Oak and downtown
Dallas. The construction of a sewerage system, combined with
the introduction of a modern highway for commuting, will
make Red Oak a desirable site for residential development.
This development should effect an increase in the population
growth rate which may exceed the projection presented in
Exhibit No. 5
D. The controversial aspect of this project is its overall
effect on the quality of the proposed receiving stream, Red
Oak Creek. In considering the overall effect on the stream,
four questions must be answered.
1. What is the present quality of the stream?
2. What is the safe assimilative capacity of the stream?
3. How effective is the proposed treatment?
4. How will plant operation affect the effluent quality?
1. What is the present quality of the stream?
In response to the first question, no detailed analysis
of the stream's quality is available. Exhibit No. 3 gives
the results of two samples analyzed to determine some of
the stream's physical and chemical characteristics. As
evidenced by these results, the stream appears to be accept-
able for most uses.
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The apparent good quality of the stream is further
evidenced by varied uses which include swimming, cattle
watering, and some reported crop irrigation. In addition,
the stream basin's pleasing environs attracts hikers, pic-
nickers, and other groups and individuals who enjoy the
stream's natural setting.
One consideration regarding present quality that
has not been fully developed is the effect of septic tank
seepage on the stream. No analysis of the stream in the Red
Oak area has been conducted to determine the degree to which
the stream has been contaminated by runoff carrying raw or
partially treated wastes from leaking septic tanks. Natural
drainage from the City is carried to Red Oak Creek but the
strength of the wastes contained in the runoff is unknown.
As evidenced by the present quality of the stream, the
wastes reaching the stream are apparently having no significant
effect. However, if the City's population continues to
grow, this condition may change adversely and visible stream
damage will result.
2. What is the safe assimilative capacity of the stream?
As in the previous question, no precise response is
possible due to the lack of detailed data on the stream's
flow and quality. Exhibit No. 3 gives some indication of
the flows in the stream as well as some indication of the
stream's assimilative capabilities.
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The analysis of the first sample shows the water quality
in Red Oak Creek below the discharge from the Cedar Hill
treatment plant. This plant consisted of a primary clari-
fier, trickling filter, and oxidation pond. It produced
treated effluent (50,000 gpd) meeting the TWQB 20 mg/1
BOD,- and TSS standards. The plant was phased out in 1970,
following connection of the City's collection system to the
Trinity River Authority's (TRA) regional facilities. These
notes infer that the effluent had a negligible effect on the
stream at this rate of flow. Exhibit 3 also shows the results
of tests conducted on samples taken at a point below the
cattle feed lot located between Red Oak and Rockett. These
samples were taken after closing the Cedar Hill plant, and
the results infer that, at this rate of flow, the stream
is relatively unpolluted.
In addition to the available data, a literature review
indicated that, in general, streams with low discharge,
shallow flow, high velocity, and areas of riffles, such as
Red Oak Creek, will have the highest rates of reaeration.
This indicates that the stream should be able to recover
quickly from an oxygen sag induced by point loads such as
a treatment plant outfall.
During periods of low flow the rate of reaeration will
remain high due to the decreased depth of flow. This results
in increased turbulence in the areas of riffles which effects
an increase in reaeration.
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This process will keep the flow from becoming septic unless
large, deep pools are encountered; a condition which is not
expected on Red Oak Creek.
Based on the stream's physical characteristics, the avail-
able flow and quality data, and the fact that an upstream
treatment plant's effluent had little effect on the stream,
it is believed that the stream will be able to assimilate
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the organic loading from the proposed plant without signifi-
cant adverse changes in the area.
3. How effective is the proposed treatment?
The City proposes to construct an extended aeration
wastewater treatment plant. This process is a modification
of the widely used activated sludge process. Exhibit No. 2
shows a diagram of a Huisman Orbal Activated Sludge Process
plant which is one alternative being considered by the City.
The extended aeration process proposed for Red Oak will
employ some form of oxidation ditch followed by a clarifier.
Raw sewage will be aerated, mixed, and retained in the ditch
while stabilization of the wastes begins. The wastewater
will then be carried to the clarifier where the biologically
active floes and any other solids will be settled. This
material, along with a portion of the clarifier effluent,
will be returned to a point near the head end of the oxida-
tion ditch to seed the raw wastes with active microorganisms
and to be recirculated through the plant for additional treat-
ment. Liquid clarifier effluent will be carried to a chlorina-
tor for treatment as prescribed by the State. Following
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chlorination, the treated effluent will be discharged to
the stream, approximately 300 feet above Red Oak Creek.
The extended aeration process generally includes maximum
sludge recirculation techniques. In small plants, such as
Red Oak, all of the settled sludge is recirculated. This
permits nearly complete biological oxidation of the organic
load. In theory, the only solids that will build up in the
system, will be the nonbiodegradable residues of the sludge.
When sufficient build up has occurred, the solids are drained
from the clarifier onto sand beds where it dries in a few
days. This wasted sludge will be stable and odorless since
it will consist primarily of nonbiodegradable residues from
an aerobic treatment system.
In 1960, the U.S. Department of Health, Education and Wel-
fare released the results of a study covering 59 extended
aeration treatment plants. This report stated that the plants
were averaging 86% BOD5 removal with minimum operation and
ma in ten an ce p roblems.
The City of Forney, Texas is presently operating a 150,000
gpd, extended aeration treatment plant which is removing approxi-
mately 91% of the influent BOD5, producing a clear, inoffensive
effluent, and operating without odor or noise nuisances.
Based on the HEW report and the data a/ailable from the
Forney, Texas treatment plant, it can be concluded that the
extended aeration treatment process can effectively produce
an acceptable effluent that will meet the TWQB permit standards.
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4. How will plant operation affect the effluent quality?
A key factor in effective plant operation is the plant
operator. The training and skills of the operator will deter-
mine whether the plant will be an asset or a detriment to the
community. The degree of training required for plant operators
is specified by the TWQB.
The North Central Texas Council of Governments, in conjunc-
tion with local, State, and Federal Agencies, and local Univer-
sities, conducts operation training schools and seminars where
operators are familiarized with waste treatment techniques.
The accessibility of such schools will make it possible for the
Red Oak plant operator to receive an excellent education in
plant operation. Thus, the Red Oak plant should not adversely
affect the environment due to a lack of operator training.
After considering the apparent quality of the stream, its
estimated assimilative capacity, the effectiveness of the pro-
posed process, and availability of operator training, it is
assumed that the proposed Red Oak plant will produce an effluent
that will not significantly detract from the overall value of
Red Oak Creek.
Based on the available information, a final determination
of the actual effect of a 20-20 effluent on the stream cannot
be made until after the treatment plant is operating. The
TWQB will conduct a monitoring program to measure any changes
in the quality of the stream due to the effluent. If the
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Board determines that there is a significant adverse effect,
they can require the City to upgrade the facilities to pro-
duce a higner cpality effluent. This authority is granted
under Section (e) of the Standard Provision of the Permit
(Exhibit No. 4).
The proposed facilities can be easily upgraded to produce
an improved quality effluent; extensive design flexibility
is one feature of this type plant. Should the 20-20 standard
effluent prove ecologically damaging, the addition of final
filters, chemical treatment, or another type of advanced
waste treatment would produce an effluent of more acceptable
quality. To satisfy the Public Health Department's require-
ments governing recreational uses of the stream, additional
chlorination units may be installed to reduce the bacterial
concentration of the effluent. This increased chlorine con-
centration could have an adverse impact on the stream as
discussed in the next section.
Elimination of the septic tanks and installation of a
sewerage system would help to conserve water as a natural
resource. The present practice of subsurface disposal has
resulted in surface pollution and probable contamination of
the ground water. Elimination of the septic tank systems
would remove these problems and, at the same time, make the
treated plant effluent available as surface water for use down-
stream. The proposed plant would dis-
charge 200,000 gpd (0.31 cfs) as the average daily flow at
design capacity. This flow would be negligible during flood
conditions. No flooding is anticipated at the plant site.
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III. Adverse Impact Which Cannot be Avoided Should the Pro-
posal be Implemented.
No significant, unavoidable, adverse impacts are expected
as a result of this project.
The project's effect on land-use, ecological disruption
during construction, and the expected effect of the effluent
on the stream have been discussed previously and the impact
of each is expected to be negligible and/or short-term.
There are six potentially adverse aspects associated with
the proposed treatment plant.
1. Odor production
2. Noise production
3. Insect propagation
4. Build up of organic sediments in the stream
5. Effect of chlorine on the stream
6. Plant shutdown's effect on the stream (future TRA
connection).
1. The unpleasant odors associated with treatment plants are
the products of anaerobic decomposition. The proposed extended
aeration plant will employ aerobic decomposition throughout.
Septic odors may result, however, from prolonged electrical
power failures, mechanical breakdowns, or excessive sludge
build up in the system; all of which are unlikely.
These conditions result in a decrease in aeration which
may lead to anaerobic conditions and septic odors. In order
to avoid these conditions, a stand-by power supply and spare
parts for on-site repair of machines will be required. Proper
plant operation should be adequate to avoid excessive solids
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build up.
2. The treatment plant will be designed to minimize noise
by enclosing or muffling all primary noise producers (motors,
pumps, and blowers).
3. Insect propagation is generally confined to areas of
standing water. The turbulent conditions of a mechanically
aerated oxidation ditch would be unsuited for insect propa-
gation. Any surface-dwelling insects or larvae present in
the clarifier would pass through the weirs to the chlorination
tank where contact with chlorine and turbulence would destroy
them. Liquid sludge in the drying beds would dewater quickly
and be removed before insect nesting could become firmly
established. For these reasons, no insect nuisance problems
are expected at the plant and no extensive use of insecticides
at the plant site should be necessary.
4. The proposed treatment process will effectively produce
an effluent with less than 20 mg/1 TSS. This concentration
should not cause an excessive build-up of bottom sediment in
Red Oak Creek.
5. Chlorination will be included to disinfect the effluent
before discharging it to the stream. In order to protect the
stream's recreational value, tests should be conducted during
plant start-up to determine the best chlorine residual to maxi-
mize fecal coliform reduction while minimizing the effect of
chlorine on aquatic organisms in the receiving stream.
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6. The nutrients in the plant effluent will stimulate the
growth of additional plants and aquatic organisms in and
along the stream. The sudden cut-off of this nutrient
source could, but is not expected to, result in the destruc-
tion of a large portion of these plants and organisms. The
sudden presence of large quantities of decaying matter could
seriously degrade the stream. This problem can be avoided by
gradually reducing the volume of plant effluent over a period
of time. The TRA interceptor is expected to connect to the
Red Oak system at the head end of the treatment plant. This
will facilitate a phased shutdown of the plant. The need for
a phased shutdown must be determined at the time plans for the
TRA connection are finalized. In view of the available data,
a phased shutdown is not expected in Red Oak.
In considering the TRA connection, no data is presently
available to aid in determining what effect the removal of
approximately 100,000 gallons of water per day from the Red
Oak Creek basin will have on the ecology of the area. A geo-
logical report states that the City's potable water comes
from two wells penetrating the Woodbine Formation (1000 feet
deep). This strata is overlain by a layer of Austin Chalk
which is practically impervious. The Woodbine aquifer is
recharged through an outcropping of the formation west of
Ellis County. From this information it is evident that the
transfer of flow to the TRA system will not affect aquifer
recharge.
Ground water studies in the Red Oak area do not indicate
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the percentage of creek flow contributed by the present sub-
surface disposal system. Since all drainage from the City
carries to Red Oak Creek, it is assumed that the TRA connection
will effect a slight decrease in stream flow. An inspection of
the stream above and below Red Oak found no apparent difference
in flows. Based on these observed flow volumes, no significant
impact is expected due to the diversion of flow from the basin.
IV. Alternatives to the Proposed Action
The following alternatives were considered.
a. Grant rejection. Should Federal grant conditions signifi-
cantly raise the cost of the proposed project, the City of Red
Oak may reject the Federal grant offer and finance the project
through other means. In this way a possible cost savings to
the City may result. Under this plan, the City may elect to
construct the minimum plant required to produce 20-20 standard
effluent. For this alternative it will be assumed that the
City will construct the facilities as proposed in the grant
application. Exhibit No. 6 shows a cost comparison of the
alternatives proposed here, and it indicates that alternative
a, the proposed action, is the least expensive.
b. Provide the facilities of alternative (a) with advanced
waste treatment facilities to supplement effective secondary
treatment. This advanced waste treatment may be nothing more
than the addition of final filtration or chemical treatment
to produce a better quality effluent. As indicated
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previously, a detailed study of the effect of the
effluent upon the stream is required to determine
how extensive advanced waste treatment must be in order
to produce an effluent of accpetable quality. This
determination of degree of treatment required must be
made based on the data gathered by the Texas Water
Quality Board monitoring program.
c. Construct an interceptor to transport wastewater
to the Trinity River Authority's regional treatment
facility. This alternative represents the ideal solu-
tion. It combines acceptable waste treatment avail-
able at the TRA's regional plant, with a plan that would
be acceptable to all parties from an ecological point
of view. Unfortunately, at the present time, the TRA's
system has not reached a point close enough to Red Oak
to permit a financially feasible connection. Meetings
held with representatives of TRA indicate that an expan-
sion of this system is planned for 1978, and for this
reason a grant condition requires connection to this system
as soon as it becomes practical. Based on this future
connection, it is felt that the treatment facilities within
the City of Red Oak proposed for the immediate future
represent only an interim solution to the overall problem;
therefore, an extensive treatment plant is not considered
practical since the cost of construction would be an
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irretrievable outlay on the part of the City.
d. Total retention ponds sufficiently large to preclude any
effluent discharge to any stream. This proposal would be
acceptable to the downstream landowners and to EPA, since no
stream pollution would result if this proposal were imple-
mented. Unfortunately, the cost of such a facility would
be prohibitive since approximately 45 acres of land would be
required for ponds. This is a result of the very low net
evaporation rate in this part of the country (about 28.7
in./yr.).
e. Irrigate a privately-owned golf course with the treated
effluent, thus precluding discharge to a receiving stream.•
This alternative also meets EPA's requirements; i.e., total
retention or reuse.
As previously mentioned, a more detailed study of this
proposal has been completed by EPA and the consulting
engineers and it has been found that the revised costs of
this proposal may be prohibitive to the city. The original
estimate differs from the revised estimate in three specific
areas; first, the original estimate covered a basic irriga-
tion system employing movable plastic hoses whenever possible;
second, the original estimate did not include an automated
control system to meet the Texas State Department of Health's
ban on day-time irrigation; and third, the original system did
not include the extensive safety features that are required
by the Texas State Department of Health. Such features
include valves which prevent discharge by unauthorized persons.
25
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The revised estimate is given in Exhibit No. 7.
The proposed future TRA connection would result in the closing
of the Red Oak Plant and the termination of irrigation with
treated effluent. The value of any unsalvageable material
used in the holding pond, pump station, and plant-to-golf
course force main would represent an irretrievable loss to
the city.
A survey of the soil and water characteristics of the area
has disclosed that the extended use of effluent as supplemen-
tal irrigation water may have a harmful effect on the soil
The City of Red Oak presently obtains its potable water from
two nearby wells. These wells penetrate to a depth of
approximately 1,000 feet and extend into the water-bearing
Woodbine Formation. This formation is comprised of sandstone
interbedded with shale and sandy shale. An analysis of
samples taken from these wells is presented in Exhibit No. 8.
It indicates a high sodium concentration and high specific
conductance while the calcium and magnesium concentrations
are very low. These factors produce a high sodium adsorption
ratio (SAR).
Analysis of the upper layers of soil indicates a high concen-
tration of calcareous clay. The Texas Water Development
Board Report Number 62, Ground Water Resources of Ellis County,
Texas, is the source of this soil and water analysis data.
The report also points out that, when soil with a high calcium
26
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content is irrigated for extended periods with water having
a high SAR, sodium replaces calcium in the clay. This
phenomenon results in soil deflocculation producing a soil
that is relatively impermeable to water. Hybrid turf grasses
used to sod golf course greens require ideal growing conditions
and are especially sensitive to soil water concentrations.
Exhibit No. 9 is a table reprinted from the report and shows
the suggested limits for SAR and salinity in supplemental
irrigation water. It can be seen that all Woodbine sources
are unacceptable for extended irrigation. This report
indicates that the average 35-inch rainfall is the only
acceptable source of irrigation water available. Any contract
between the golf course owner and the city will probably
include a clause which permits the owner to discontinue
irrigation with the effluent, if such action proves harmful
to the golf course vegetation. If the owner took this action,
the city would be forced to discharge into Red Oak Creek until
such time as another alternative could be implemented.
f. Haul the wastes by truck to a regional treatment facility.
This would have the effect of meeting all the requirements of
EPA, the downstream landowners, and the City of Red Oak from
an ecological standpoint. Unfortunately, this alternative
would be cost-prohibitive in that the trucks would be low in
initial cost, but would be high in operating cost; therefore,
any initial savings would be quickly negated by the operation
and maintenance costs of such a system. In addition, spills
or leaks from the trucks would be a source of odor nuisances
to the people along the truck route.
27
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g. Discharge to a stream with less aesthetic value. This pro-
posal would, in effect, relocate the problem rather than solve
it. While this may not generate objections from downstream land-
owners, it will still have the same ecological and aesthetic value
on the stream while increasing the cost of transporting the
effluent to the second stream.
h. A no action concept of continued use of septic tanks. This
alternative would satisfy the requirements of the downstream land-
owners in that no treated effluent would be discharged to the
stream. However, an increased use of septic tanks within the area
would increase the amount of sewage seeping into the stream and
aesthetically undesirable conditions would worsen. The potentially
serious health hazards present within the City of Red Oak as a re-
sult of the septic tank seepage is the reason for rejecting this
alternative.
Based on all the data available, the proposed project repre-
sents the optimum alternative to the problems of sewage treatment
within the City of Red Oak, Texas. Adoption of the proposal would
create an aesthetically acceptable condition within the City, while
producing an effluent meeting the Texas Water Quality Board 20-20
standards. A monitoring program by the Texas Water Quality Board
and by the City of Red Oak to study the effect of the effluent
upon Red Oak Creek will aid in determining the exact degree of treat-
ment required to produce a non-degrading effluent. While this may
not, in effect, resolve all of the objections raised by the down-
stream landowners, it would serve as a temporary solution to the
problem until such time as the City is financially capable of con-
structing a connecting line to the Trinity River Authority's Regional
system.
28
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V. Relationship Between Local Short-Term Uses of Man's
Environment and the Maintenance and Enhancement of
Long-Term Productivity
Adoption of the proposal will enhance the environment for
future generations by eliminating the danger of septic tank
seepage within the City of Red Oak. The proposed system will
improve the health conditions of the present and future resi-
dents of the City. The final effluent from the plant is not
expected to have an adverse effect on the creek or the surround-
ing environment. As an interim facility, the discharge will
have no long-range effect on the stream's ecosystem and no sig-
nificant changes in stream productivity are anticipated. In
fact, there is the possibility that water quality in the creek
could improve in the near future, since the introduction of a
limited supply of nutrients to the stream can stimulate the
growth of microorganisms important to in-stream purification.
The overall effect of the project should be the enhancement
of long-term productivity. The collection system should increase
land values, accelerate land development, and encourage popula-
tion growth. These facts should greatly outwigh the short-
term, adverse effects the treatment plant will have on nearby
land pending the TRA connection.
The costs for constructing the collection systems will be
shared by the present and future residents of the City. The
treatment plant costs will also be shared by the residents, but
the plant may be closed (TRA connection) before the bonds are
retired. This will impose the responsibility for these bonds
on residents who did not directly benefit from the plant's
presence. It may be reasoned, however, that these residents
29
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are contributing to the healthy environment that they found
in Red Oak when they arrived.
The potentially serious threat to the health and welfare of
the residents created by the existing treatment facilities
justifies immediate action on the proposal.
29 a
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VI. Irreversible and Irretrievable Commitments of Resources
Which Would be Involved in the Proposed Action Should
it be Implemented
No phase of the proposed project appears to be irreversible.
Complete land restoration at the plant site would be possible
by the removal of any structures present. The effluent is
expected to have a negligible effect on Red Oak Creek; thus,
any change that did occur would be reversible through normal
biological recovery. Such recovery would begin following
the closing of the treatment plant.
The treatment facilities would represent an irretrievable
commitment of resources since the construction materials would
be unsalvageable. In addition, the cost of construction and
some of the plant land value would represent an irretrievable
commitment of funds.
VII. A Discussion of Problems and Objections Raised by Other
Federal/ State, and Local Agencies and by Private Organi-
zations and Individuals in the Review Process
The following summary of comments from downstream landowners
was received during the review process leading up to this Environ-
mental Impact Statement.
COMMENT 1 - The discharge represents a public health hazard to
the people who use the creek for swimming, fishing, picnicking,
hunting, and camping.
RESPONSE - As stated in the report, the effluent is not expected
to significantly degrade the stream and disinfection by chlori-
nation will greatly reduce any potential health hazard.
30
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COMMENT 2 - The value of property located along the creek will
diminish if the stream is used to convey treated sewage from
the City.
RESPONSE - The effluent is not expected to degrade the stream
and, therefore, should not affect land values. Should some
value decrease result, the TRA connection will negate it and
return the land to its normal value. Stream degradation due to
uncontrolled discharges and non-point sources that are presently
contributing to stream pollution is a more realistic problem.
COMMENT 3 - Potable water lines cross the creek at several
locations downstream from the point of discharge. If a break
occurred in one of these lines, the water could become contamina-
ted with the sewage and harm those ingesting the water. Several
wells, located in the creek'bottomland, might likewise become
contaminated.
RESPONSE - These wells and water lines should not be adversely
affected by the effluent since chlorination will greatly reduce
the concentration of potential disease-producing organisms.
Well infiltration by stream water carrying treated sewage
plant effluent does not necessarily mean the well will be
contaminated. Bacterial contamination of the well will be
restricted by three factors: filtering, sorption and attenuation.
1. The benthic and sedimentary layer of the stream bottom
will have a filtering effect on the bacteria, trapping most
before they can enter the soil.
31
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2. Bacteria not trapped by filtration will have a tendency
to become attached to soil particles by the process of sorption.
3. Bacterial attenuation (loss of potency) occurs with
time and the slow passage through the soil will have a decaying
effect on bacteria.
Studies of bacterial infiltration have concluded that most
pathogenic organisms will not survive travel over 100 feet
through most soils. Considering the three factors listed above,
this distance does not seem unreasonable for this area.
In the event floods cover the well's physical surface
structure, well contamination by direct seepage may result.
This seepage will occur primarily in poorly or improperly con-
structed and operated wells. Should such seepage occur, the
well should be disinfected before it is placed back in operation.
This should be done regardless of whether the stream is carrying
plant effluent.
COMMENT 4 - The sewage will be harmful to fish in the creek.
RESPONSE - The effluent nutrients will increase the stream's
productivity slightly and a minimal increase in the size and
number of fish present should result. During low flow conditions,
some species of fish may be adversely affected by the effluent
and will therefore migrate to a more acceptable environment.
The periods during which these fish would be absent from the
affected area are expected to be short-term and reversible.
COMMENT 5 - The creek water would be detrimental to crops if it
was used for irrigation.
32
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RESPONSE - The Texas State Department of Health's policy on
crop irrigation restricts the use of plant effluent on food
crops that may be consumed in a raw state. Since cotton and
sorghum are the leading area crops, effluent irrigation is not
expected to be a problem.
COMMENT 6 - The towns of Ferris, Forreston, and Lancaster have
the same treatment system as Red Oak has proposed and the
odor and pollution downstream is objectionable.
RESPONSE - City of Ferris: No flow or loading data was available
for this study. Reports indicate that there were some odor
problems but no explanation was available. City officials
reported that on-site operation was limited to two daily spot
checks at the plant. The city's Consulting Engineers reported
that a minority housing area near the plant employs a septic
tank system. The area soil is clay in flat terrain and overflows,
spills and odors are common. Since no plant problems were known
to the engineers, these odors seem to explain, in part, the
plant's apparent odor problem. City of Forreston: The Forreston
Sewer Service Corporation discharges 10,000 gpd of treated
effluent from a package extended aeration treatment plant.
Average BOD is 3.5 mg/1 and TSS is 24 mg/1. The City recently
hired a plant operator to further improve its effluent. An
inspection trip on March 7, 1972, found no odors or stream
pollution in the area. City of Lancaster: No data was available
and no records were kept on this plant.
33
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RESPONSES TO COMMENTS SUBMITTED BY
MEMBERS OF THE RED OAK CREEK LANDOWNERS'ASSOCIATION
COMMENT 1 - The plant effluent will significantly degrade water
quality in Red'Oak Creek.,
RESPONSE - As stated throughout the Impact Statement, the
proposed facilities are expected to produce an effluent that
should not significantly degrade water quality in Red Oak Creek.
Noticeable effects will be infrequent and of short duration,
limited primarily to periods of zero on low natural flows
affording minimum dilution.
A primary reason for assuming negligible effects on the
stream is the fact that the plant's initial flow will be less
than 50% of its design capacity. This overdesign factor will
result in extended retention periods, minimum flow rates through
the clarifier, and approximately 95% solids reduction and
recycling to the oxidation ditch. The increased sludge age
that will result will permit maximum stabilization of
carbonaceous and nitrogenous wastes. As a result, the effluent
BOD is expected to be below 12 mg/1 . This high quality effluent
is not expected to degrade water quality in Red Oak Creek.
The oxidation ditch-stabilization pond system originally
proposed for Red Oak has been found to be acceptable to EPA in
most project applications. However, the present quality of
water in Red Oak Creek justified installation of a more
effective type of plant (oxidation ditch-final clarifier and
chlorination) to protect the stream from degradation. Since
this upgraded plant is considered acceptable, EPA does not
\
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intend to impose additional requirements which would raise the
project costs and force the City to abandon the project or
reject Federal participation. If the City is forced to reject
the grant funds, they may elect to construct the originally
proposed plant, which has already been approved by the Texas
Water Quality Board.
COMMENT 2 - The City can connect to the TRA system for $I/person.
RESPONSE - The additional cost to the City for this alternative
is approximately $90,000. The present population is less than
1,000. No basis for this $l/person cost increase is clear.
COMMENT 3 - Plant design capacity will be achieved within 3 years
of completion.
RESPONSE - Exhibit No. 5 is considered a liberal estimate of
population increase and does not support a 3 year plant design
life.
COMMENT 4 - Why isn't the effluent being recycled for use as
drinking water for Red Oak?
RESPONSE - Effluent will not be recycled because there is no
water shortage in the area to justify the expense of recycling.
COMMENT 5 - Breaks occur in the Rockett Water Supply Corporation
lines at the points where they cross Red Oak Creek. These breaks
will allow contamination of the lines.
RESPONSE - A representative of the firm supplied the following
information:
1. Line breaks are infrequent (3 or 4 in the past 5 or 6
years).
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2. Pipes are laid in a concrete encasement beneath the
stream beds. This casing prevents direct contact between pipe
and stream water during normal flow conditions. Flow can reach
unprotected pipe only during flood conditions when maximum
dilution of wastes occurs, thus reducing the possibility of
contamination.
3. Pipes are PVC and are prone to crack rather than break.
4. Line pressure varies between 70 and 150 psi at all
times. This high pressure would force water out of the pipe and
prevent stream water from entering.
5. All repairs include disinfection by chlorination.
The residual chlorine in the water system is reportedly
sufficient to maintain safe water quality in the lines.
Based on the information presented in Items 1-5, no
contamination of the potable water lines by treated effluent
seems likely.
Chlorination and detention time in the treatment units will
greatly reduce the concentrations of pathogenic organisms so
that no health hazards should result from discharge of effluent
to Red Oak Creek.
COMMENT 6 - Stream water carrying treated effluent will have an
adverse effect on dairy cattle that drink the water.
RESPONSE - The Texas State Department of Health does not impose
quality standards on drinking water used by cattle. Department
officials are more concerned with cattle wallowing or walking in
-------
such water due to the possibility of contamination of the udders
or teat canals. In order to determine potential health problems,
field inspections are made by Department personnel. In the
event these inspections reveal potential problems, fencing and
other barrier devices will eliminate the problem of cattle
entering the stream.
COMMENT 7 - The cities of Palmer, Balch Springs, and Kleberg are
operating treatment plants that are producing odors.
RESPONSE - The City of Balch Springs (Dallas County WCID No. 6)
operates a trickling filter plant, discharging 284,000 gpd of
treated effluent meeting the Texas Water Quality Board 20-20
standards. District officials contacted know of no odor
problems other than the infrequent, short duration problems
associated with mechanical breakdowns.
The City of Kleberg (Dallas County WCID No. 7) operates an
activated sludge treatment plant employing aerobic treatment
throughout. The plant discharges 228,000 gpd of treated effluent
meeting the Texas Water Quality Board 20-20 standards. District
officials know of no odor problems at the plant.
The City of Palmer reportedly operates an acceptable plant
meeting Texas Water Quality Board standards. Odors occur at the
plant occasionally due to line blockage caused by discharges from
a commercial establishment. State officials attribute the odors
to septic sewage that builds up in these blocked sewers. No
plant process problems are known.
-------
The Texas Water Quality Board representatives reported that all
three plants have infrequent, short-term odor problems attributed
to mechanical breakdowns. None of the plants are hydraulically
or organically overloaded.
-------
RESPONSE TO COMMENTS BY
TEXAS PARKS AND WILDLIFE DEPARTMENT
An activated sludge process such as the proposed oxidation
ditch produces an effluent with a very low nitrogenous oxygen
demand. Prolonged aeration of 6 to 10 hours coupled with sludge
age in excess of 20 days allows nitrification to occur in the
oxidation ditch. Studies have shown that sludge ages such as
those anticipated in the proposed process effect substantially
complete nitrification.
The ultimate oxygen demand in terms of BOD^ and COD is
exceptionally low in effluents produced by oxidation ditch
facilities with extended aeration capability.
It should be noted, however, that a high quality effluent
is possible only as long as the treatment facilities are not
overloaded. For this reason, the effluent should be closely
monitored by the Texas Water Quality Board.
During extreme low flow conditions, most fish species will
migrate to an area of the stream where the quantity of water is
sufficient. This will occur regardless of whether or not an
effluent is discharged. However, the discharge of effluent will
increase total flow in the stream and might produce an acceptable
environment for some fish species that would migrate to another
location if the effluent were not increasing streamflow.
Discharge of a nitrified effluent is not expected to
adversely affect the natural dissolved oxygen profile of the
stream.
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RESPONSE TO COMMENTS BY
BUREAU OF OUTDOOR RECREATION
The lack of current detailed water quality data is a
problem here as always when an impact statement is prepared.
A stream study to gather this data would require several
months since the critical period would probably occur during
the summer months. The question is whether or not further
delay of the project until this data is obtained would be
justified. In this statement, engineering judgment and stream
flow data on similar streams receiving effluent from similar
plants were used as a basis for the analysis.
The cause and effect of "urban sprawl" is a problem
beyond the scope of this impact statement for an interim treat-
ment facility designed for a 2000 population equivalent. The
statement includes a general analysis of land use and popula-
tion projections.
The Texas Water Quality Board has the legal authority to
impose additional conditions or new terms as outlined in the
Standard Provisions of the Permit to Discharge.
Substitution of the words "will require for "can require"
infers that the EPA would encroach on the authority of the Texas
Water Quality Board.
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VIII. CONCLUSIONS OF THE ENVIRONMENTAL PROTECTION AGENCY
Review and comment prompted by the preparation of a
detailed environmental statement for the project has revealed
the acute desire of landowners to preserve the aesthetic
and recreational value of Red Oak Creek.
The Environmental Protection Agency and the Texas Water
Quality Board recognizes the need for enhancing water quality
in the stream and for safeguarding against future degradation
of the stream. The EPA and TWQB have required the City of
Red Oak to revise the type of treatment facilities originally
proposed; that is, a more efficient and virtually "fail-safe"
treatment scheme will be required.
The Huisman Orbal Activated Sludge System will be employed,
followed by effluent chlorination and polishing ponds. The
polishing ponds will further ensure that pathogenic organisms
do not enter the receiving stream from treated wastewater
effluent. In addition, the ponds will serve as emergency
holding ponds to eliminate bypassing of untreated wastewater
during emergency conditions. The treated wastewater stored in
the polishing ponds will be available for irrigation purposes
to supplement existing water sources during periods of water
shortage.
The increased project costs due to these revisions are
justified by the reduction in adverse environmental effects
that will result.
The project as revised, is consistent with local, state,
and national environmental goals.
------- An error occurred while trying to OCR this image.
-------
34
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Exhibit No. 3
Red Oak Creek
•*•
Water Quality Data *
Sample Between Red Oak
Location ' Below Cedar Hill1 and Rockett (Feed Lot)
Date 4/30/69 9/29/70
Time 1:00 p.m. 10:45 a.m.
Temp °F 58 65
Flow (gpd) 150,000 200,000
pH 7.7 8.1
DO mg/1 7.0 4.0
BOD mg/1 2.0 3.5
Armenia N mg/1 Negligible ^ 1
Conductivity micromhos/cm 672 465
TSS mg/1 <10 23
COD mg/1 — 20
TOD mg/1 — ' <20
TC mg/1 — ' 50
TOG mg/1 — 25
* Supplied by TWQB
1 Cedar Hill Plant in operation
2 Cedar Hill Plant closed
34 a
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PERMIT
NO yjJL?
PACK NO.J: TEXAS WATER QUALITY BOARD
1100 LAVAOA STKF.KT
AUSTIN, TEXAS 73701
PERMIT to dispose of wastes under provisions of
Article 762Id-l, Vcrnon's Texas Civil Statutes
1. Name of Permittee
I. Name City of Red Oak
2. Address p. Q. Box 393
3- Ch>r Red Oak, Texas 75151
II. Type of Permit: Regular *xff Amended
III. Nature of Business Producing Waste
Municipal Sewerage Syotem
IV. General Description and Locution of Waste Disposal System
Description; Oxidation ditch including bar ncrecn, Parshall flume and two
1.15 acre stabilization ponds. _ ;
Location; Approximately % mile south of Rod Oak, Texae and immediately west of
M.K. & T, Railroad which point is west of cemetery on State Highway 342.
V. Conditions of the Permit
1. Character, volume and disposal arca(s) or point(s) of discharge authorized under this Permit. The conditions on tlie re-
verse side arc a part of this Permit and apply for all purposes.
Cha rector; Treated rrunicipal sewage effluent.
Volume.; Not to exceed an average cf 100,000 gallons per day;
Not to exceed a maximum of 250,000 gallons per day;
Not to exceed a maximum of 145 gallons per minute.
Quality; __ NOT TO_E_XCEE_P _
Monthly 24 Hr. Daily Individual
Item __ Avo-ILsl'-lS forrpoRite ran? to
B.O. O. TOpfrl 25 nig/1 30 rrg/1
'•• u :
jPoint of^Dineha.nro ; Into an unnamed branch adjacent to the plant sits in
Ellis County, Texas; thence into Red Oak Creek; thence into the Trinity
River in the Trinity River Basin.
2. Special Provisions
SEE ATTACHMENT
August 28, 1970
S. Tliis permit liccome* effective - - and is valid until amended or revoked by the Homo.
o /
*M*^--
For id.
35
Exhibit No. 4
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Standard 1'iovisions
(a) This permit is granted in accord.mce will) the Texas \S'alcr Quality Act of !9f>7 (Aiticle 7621(1-1.
V.T.C.S.) and the mlrs adopted l>y tin' Hoard, and i.< granted subject to tin- rules of the Hoard, the laws of
tlie Stale of Texas, and further orders of the Hoard issued in accordance with said rules and laws.
(b) In the event the permittee discl^irgcs wastes which exceed the quantity or quality authorixed by this
permit, the permittee shall Rive immediate notice to the office of the Hoard.
(c) Acceptance of this permit constitutes an acknowledgement and agreement that the permittee will com-
ply with all the terms, provisions, conditions, limitations and restrictions embodied in this permit and with
the rules of the Board, the laws of the State of Texas, and further orders of the Board. Such agreement is
a condition precedent to the granting of this permit.
(d) This permit cannot be transferred without prior notification to the Board.
(c) This permit is issued subject to the terms of Section ll(f), Article 762ld-l, V.T.C.S., which reads in
part as follows: . . - ,
"The permittee may be required, for good cause, from time to time, after notice to the permittee
and after public hearing initiated by the Board, to conform to new or additional conditions and
terms imposed by the Board following such hearing. The Board shall allow the permittee a reason-
able time to conform to such new or additional terms and conditions; provided, however, that upon
application of the permittee, the Board, in its discretion, may grant the permittee an additional
period of time within which to conform to such new or additional terms and conditions. Such permit
or amended permit shall never become a vested right in the permittee, and it may he revoked or
suspended for good cause shown, after notice to the permittee and after public hearing initialed by
the Board, in the event of the permittee's failure to comply with the terms and conditions of such
permit as issued or as amended."
(f) The application pursuant to which the permit has been issued is incorporated herein; provided, however.
that in the event of a conflict between the provisions of this permit and the application, the provisions of ;liv
permit shall control. f
(B) (The provisions of this paragraph (g) of the Standard Provisions of this permit apply only to drinking
water supply systems and sewage disposal systems designed for public use as contemplated in Section 12.
Article 4477-1, V.T.C.S.) There may be substituted for the foregoing features of the plant other mechanism*
equipment, or treatment methods on prior approval of the State Health Department, provided such substi-
tutions do not result in a reduction of the efficiency and operating safety of the plant nor result in the di<-
charge of a Jesscr quality of effluent1 than'that authorized under the permit.
36
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,,',.;ite Ccuil rol Older Mo. 11339 Attachment
City Of lied 0;i>: Effective Pate- August 23, 1970
This order is granted subject to the policy of the Board to encourage
'the development of: area-wide waste collection, treatment and disposal
cyflteiiis. The Board reserves the right to amend this order in accord-
ance: v;ith applicable procedure)}, requirements to require the system
covered by this order to be integrated into an cirea-widc system, should
r.uc:h be developed; to require the delivery of. the wastes .authorized to
).>e collected in, treated by- or disohnrgod from said system, to such arca-
vn.de system; or to amend this order in any other particular to effectuate
the Board ' a policy. Such amendments may be made when, in the judgment of
Die Board, the changes required thereby are advisable for water quality
control purposes and are feasible on the basis of waste treatment
technology, engineering, financial, and related considerations existing
nt the time the changes are required, exclusive of the loss of investment
in or revenues from any then existing or proposed waste collection, treat-
ment or disposal system.
These public sewerage facilities shall be operated and 'maintained by a
sewage plant operator holding a valid certificate of competency issued
under the direction of the Texas State Health Department as required by
Section 20 (a) of Article 4477-1, Vernon's Texas Civil Statutes.
The City shall comply with the provisions of Board Order No. 69-1219-1
relative to monitoring and reporting data on effluent described in
"Conditions of the Waste Control Order".
37
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COST ESTIMATE
PROPOSED PROJECT
Total
Eligible
1. Construction:
(a) Lateral sewer lines
(b) Outfall sewer lines
(c) Sewage treatment plant
(2,000 PE)
(d) Subtotal for Construction
2. Technical Services:
(a) Engineering fee
(b) Inspection fee
(c) 0 & M manual
(d) Subtotal for Technical
Services
3. Legal & Fiscal Fees
4. Administrative
5. Government Field Expense
6. Site
7. Contingency
8. Totals
$113,000
43,000
125,000
$281,000
25,000
13,000
2,000
38,000
$ 9,000
1,000
2,200
40,000
' 26,800
400,000
0
43,000
125,000
$168,000
17,000
8,000
2,000
27,000
5,600
700
0
0
15,200
216,500
0.55 x $216,500 = $119,075 Grant Offer Possible
EXHIBIT No. 6A
40
-------
WISENBAKER, FIX, & ASSOCIATES
Consulting Engineers
Tyler, Texas
December 14, 1971
REVISED PROJECT COST ESTIMATE FOR SEWER
SYSTEM FOR THE CITY
EPA Project No
HUD Project No
OF RED OAK, TEXAS*
. WPC-Tex-533
. PFL-Tex-260
ITEM TOTAL PROJECT
1. Construction:
a) Lateral sewer lines
b) Outfall sewer lines
c) Sewage treatment plant
(2,000 GPD)
(d) Effluent irrigation system
(e) Subtotal for Construction
2. Technical Services:
a) Engineering fee
b) Inspection fee
c) 0 & M manual
(d) Subtotal for Technical
Services
3. Legal & Fiscal Fees
4. Administrative
5. Government Field Expense
6. Site
7. Contingency
8. TOTALS
Method of Financing:
PL 660 Grant (55% x $353,000)
State Loan (25% x $353,000)
HUD Loan
Additional Funds Required by City
TOTAL ESTIMATED PROJECT COST
$ 113,000
43,000
125,000
126,000
$ 407,000
34,600
15,000
2,000
$ 51,600
8,000
1,000
2,200
40,000
24,200
$ 534,000
$ 194,000
88,000
150,000
102,000
$ 534,000
PORTION ELIGIBLE
FOR PL 660 GRANT
0
$ 43,000
125,000
126,000
$ 294,000
25,000
10,500
2,000
$ 37,500
5,600
700
0
0
15,200
$ 353,000
*Includes effluent irrigation Astern.
Exhibit No. 7
41 DEC 16 1971
-------
WISENBAKER, FIX, & ASSOCIATES
Consulting Engineers
Tyler, Texas
December 14, 1971
ESTIMATED COST OF IRRIGATION SYSTEM
FOR RED OAK SEWAGE TREATMENT
PLANT EFFLUENT
EPA Project No. WPC-Tex-533
1. Pumping Station:
3 - Turbine pumps (360 GPM @ 327' TDH)
1 - Turbine pump (100 GPM C 231' TDH)
1 - 300 Gallon steel pressure tank
1 - Electric panel w/switches
1 - "Nu-Matic" pressure tank control
1 - 3" Pressure relief switch & by-pass valve
1 - 200 amp Disconnect switch
1 - Flume, header, welded fittings, valves & piping
1 - Metal pump station building w/conc. slab
Lump Sum for Item No. 1 $ 18,816
2. Irrigation Piping: (160 psi - rubber gasket joints)
2,000' - 8" PVC
6,200' - 6" PVC
5,400' - 4" PVC
4,300' - 3" PVC
4,000' - 2V PVC
8,800' - 2" PVC
Lump Sum for PVC Pipe $ 51,500
4" Bore under railroad 750
Cast iron & PVC fittings 2,610
320' - 4" Aluminum irrigation pipe
w/valve & fittings 1,756
Subtotal for Item No. 2 $ 56,616
3. Irrigation Sprinklers:
107 - #13 Aqua Dial sprinkler
6 - #14 Aqua Dial sprinkler
160 - #15 Aqua Dial sprinkler
12 - Aqua Dial controller
160 - #5110 Aqua Dial valves (IV)
113 - #5110 Aqua Dial valves (1")
2 - #5181 Aqua Dial check valves (3/8")
19 - #44 Aqua Dial quick coupling valve (1")
6 - #44C-3/4" Aqua Dial double-keyed couplers (1" x 3/4")
6 - #72 Aqua Dial brass hole ells (1" x 3/4")
Lump Sum for Item No. 3 $ 31,935
4. Control Tubing:
350,000 - PVC Control tubing (V)
(1)
42
DEC 16 1971
-------
Estimated Cost of Irrigation System
For Red Oak Sewage Treatment
Plant Effluent (Continued)
4. Control Tubing: (Continued)
V Brass compression fittings & controller filters
Lump Sum for Item No. 4 $ 9,173
5. Miscellaneous Items:
Swing joints for sprinkler heads $ 2,460
Gate valves (misc. sizes) 1,252
Steel pipe & bridging for creek crossing 1,800
Subtotal for Item No. 5 $ 5.512
Estimated Construction Cost $ 122,052
Estimated Sales Tax (on material only) 3.850
Total Estimated Construction Cost $ 125,902
SUMMARY OF PROJECT COST
1. Construction Contract $ 125,902
2. Technical Services:
(a) Engineering fee $11,000
Inspection fee 3,000
Subtotal 14,000
(b)
(c)
3. Legal & Fiscal 2,500
4. Administrative 500
5. Contingency 7,098
6. Total Estimated Project Cost $ 150,000
Method of Financing:
(a) PL 660 Grant (55% of $150,000) = $ 82,500
(bj State Loan (25% of $150,000) = 37,500
(c) City Funds from other sources
(20% of $150,000) = 30.000
(d) Total Project Cost = $150,000
43
-------
Exhibit No. 8
Well Water Analysis
Well No. 1 2
Date 6/9/65 9/24/62
Ca mg/1 3 2
Mg mg/1 1.8 1
Na mg/1 496 460
HCOo mg/1 604 608
Ionic Concentration %Na 98 98
Sodium Adsorption Ratio 56 55
Specific Conductivity 2180 2145
44
-------
100 2 345678 !COO Z 34 5000
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O
EXPLANATION
Source of water
4 Alluvium
• Taylor Marl
n Woife City Sand
Member of Taylor Marl
O Woodbine formation
A Paluxy Sand
• Hosston Formation
Salinity hazard
Exhibit No. 9
Classification of Irrigation Waters
U. S. Geological Survey in cooperation with iha Texas Water Development Board
45
-------
C • • •
W ' • ' HEARING COMMISSION REPORT
• ' . •
SYNOPSIS ' .
I. Applicant '.•....
• '™ •
At Name: City of Red Oak
B. P. 6. Box 393, Red Oak, Texas
' 'ftr^ Discharge " " • - —- .
"•"A; Volume: An average of 100,000 gallons per day
B. Type: Treated domestic sewage
C. Course; Into an unnamed tributary, thence to R^d Oak Creek,
thence to the Trinity River in the Trinity River Basin.
^ III. Hearing ^
; A.. Date: July 14, 1970 ^
B. Location: Austin, Texas •
C. Hearing Commission: Lee H. Mathews, Presiding Officer,
John M. Johnston, Technical-Services
D. Appearances: See attachecV.a-fetendance sheet
*£..;y$.^;- .
' ,i£¥ii8&fi3-.. . i .
IV. Findings ^;^«":
• •*— 'te*-";- -• .'*."•• -.•'tit'j. • -
^-;^; ":.:?*j4'
A. The need for a. sewerage sys'tem'fbr the City of Red Oak is
acute; presently inadequate septic tanks pose a potentially;
' " serious health and pollution problem:
B. The City is financially unable?-'to join the Tenmile Regional.
Sewerage System at the present; the City's proposal for a
local system is the more desirable alternative. •
C. .Although some recreational and other uses are made of the •
receiving waters (Red Oak Creek), an effluent conforming
to the conditions and terms of the proposed Waste Control
. • Order should not adversely affect those uses.
* , • •
"V. Recpmmenda t ions
A. Waste Control Order Granted: Yes
B. Effective Date: August 28, 1970 - - .
C. Status: Final Approval
D. -Special Provisions:
( 1. Area-wide treatment clause
2. Certified operator clause • • .
3. Self-reporting clause
Exhibit No. 10
46
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O ' ; . ATTENDANCE LIST - CITY OF RED OAK
Public Hearing, July 14, 1970
1. Proponents; • '
| . Robert E. . Fix, P. E. . ....._•
!- - ---Ronnie B. Johnson, City Attorney ..
i Lester Watkins, Builder
Don Shields, Supt. of Schools
j A. Hardy Eubanks III, Financial Advisor
i J. M. Hart, Mayor ..• .
; Glendon E. Haney, City Councilman
2. Opponents; . ' '
•'•] " James K. Presn9l, Attorney
!• Horace E. Carter . ••''.'•
| . . W. A. Fuller .-'
' s-- C. E. Spain, Jr. ' . . •
•;' v... . LaVoy Strain
| ' ' T. M. Harper . ' '•'" I . • ' .••'-. •
| . S. L. Adais ; ' '
• Charles L. Prude . ' .
} Pete Clopton ' . • : - . •
I Lu Prude . • - 1
.1 ' • - • . • •
'•'. * •-*•** •
3. Observer; . r" , " "
I Sam Kinch/ Jr-i Reporter, The Dallas Morning News
' . 47
Exhibit No. 11
-------
•*
o ' . •• . ' • •
• . SUMMARY OF THE EVIDENCE
I .
The City of Red Oak, Texas has made application before the Texas
Water Quality Board for an initial Waste Control Order authorizing
the discharge of treated domestic sewage from facilities located
approximately % mile south of the ci,ty:,. A pxiblic hearing was held
'on Jul 14 1970 in Austin Texas d'anfc which vidence s
on July 14, 1970 in Austin, Texas, dti^anfc( which evidence was received
pertaining to the application. Trh^^piicant v/as represented by-
several city officials; numerous^aridoi/pers and other interested
parties appeared in protest. '':^tV*H*'. •
The applicant has submitted an affidavit from'the publisher of The
Waxahachie Daily Light attesting that'liptice of the public hearing
v/as published within the statutorjly prescribed time period. Notice
was also given to interested parties in accordance with established
policy of the Texas Water Quality Board.
City officials and Mr. Robert Fix, Consulting Engineer, testified to
the following: •
1. The need for a sewerage system in Red Oak is,critical.
The present population (about 750) is now served by septic
tanks which for the most part do not function properly.
Overflows and seepage are'common; raw sewage often collects
in ditches and holes throughout the city. Much of this
- ' seepage finally collects in Red Oak Creek.
Commissioners Note; A letter received from Dr. David Leslie
Of the Ellis County Health Department recommends approval
Of a sewerage system for Red Oak because of the serious
septic tanks problem in the city. . —
. * .•••''..
2. The City proposes to install treatment facilities comprised
of an oxidation ditch, bar screen, and two stabilization
ponds. The plant will be designed to serve 1,000 persons;
a flow measuring device will be installed. The State Health
'Department has -approved the plans and specifications for
the proposed facilities. . ..
3. Red Oak Creek, the receiving stream for the effluent, contains
water 'most of the year - some recreational use has been noted.
The creek contains some septic tank discharge and treated
sewage from at least one other city: Cedar Hill
'Examiner' s Note ; It has been reported that Cedar. Hill v/ill
eventually join the Tanmile Regional Sewerage System and j
thus eliminate its discharge into Red Oak Creek. :
• • * . . "
. . • • . ' -48 . •'- . -' . : V ';'/• !'.'-:
-------
: . ' ' 4. The Trinity River Authority has been consulted about a.
possible tie-in to the. Regional System. In 1968 the
Authority informed city officials that the estimated
cost of connection was $220,000.00; this cost to cover
the construction of the necessary outfcill lines and lift
station. Other projected costs would raise the figure
to $411,000.00 total cost (based on 1968 cost figures).
If, however, the City builds its own plant and system of
lines, total cost would be about $241,000. 00; • thus the
... . cost to the City of a tie-on with the Tenmile System is
; . • ;, 71% higher than the City's proposal. In terms of anticipated
: , . water and sewer rates, the City's plan embodied in this
application will result in about a $84.00 per year charge
• . per person for water and sewer services; a contract with
7'•; ' '". the Trinity River Authority would increase these rates to
--.'.; approximately $144.00 per year. S (See addendum for a
.; ' breakdown of anticipated costs.)
-y' • • i '.'.'.
-.".:'• i ' . • ' ' ' • •'
;.• ! The above computations do not take into consideration any
"]K; increases in estimated construction costs of the Tenmile
•]',;'( . outfall lines and pump station since 1968 nor the costs of
j / right-of-ways for the pump station and lines.' A requirement
i'j - by the Board that the City join the Tenmile system would
ll! ' necessitate the resubmission of the City's approved
f :j • . Department !of Housing and Urban Development loan agreement,
:.:i5 and the resubmission of the City's request for a PL 660
-;j Grant. Due to the urgency of the City's sewage problem,
! the additional delay that the resubmissions would entail
;j would not be in the best interests of Red Oak. ;
I • Protestants owning land in the vicinity of the proposed treatment"
! plant and Red Oak Creek presented testimony that can be .summarized ,
; as follows: j . ' . ;. .
•' L r " "
1. Red Oak Crepk is a source of recreation for the area.
. . ' .-. Uses includb swimming, picnicking, and fishing; additionally,
i . . children ofpen play in and around the creek.
; • "2. Discharging; effluent into the creek will cause health and
odor problems, especially in the dry weather months' when
water pools! in the stream bed and stagnates. .In wet
weather, the effluent may contribute to overflow problems.
49
-------
'•'*.
The necessity of preserving ..Reel; Oak Crock as an important
natural resource for the cire.^:ibhould override the cost
consideration of connecting'liiQ^the Tenadle Regional System.
^iiv-
: 4. The value of property lociitted j^Jlong the creek will diminisjh
if the stream is xised to convey;'treated sev;age from the city.
*A letter of protest v/as received from .yernon C. Coffey who feels that
water contaminated v/ith treated sewage'^would harm cattle that water
. ' at the creek and destroy other domestic uses of the water. The writer
urges a tie-on to the regional sewerage system.
A petition signed by over 160 residents of the surrounding area was
[ presented to the Hearing Commission. These residents protest the
< xxse of Red Oak Creek by the. City for sev/age discharge because
J (a) sewage discharges are a continuing nuisance; (b) the value of
adjacent property will be reduced; (c) sev/age effluent will contaminate
•; Red Oak Creek; (d) springs feeding the creek will be contaminated;
5 (e) the adulteration of the creek's waters will restrict the'normal
•i uses of the stream. • .
; ! ' '
i Governmenteil units that have commented on this application include
\ ^~) the North Central Texas Council of Governments, the Commissioners
J ""' Court of Ellis County, and the Texas Parks and Wildlife Department.
•t The NCTCOG recommends that "the proposed project is urgently needed,
jj '*. and it is reasonable'to expect that it will be consistent v/ith
• area'-wide comprehensive planning and functional programming. " The
\ • Ellis County Commissioners Court adopted a resolution at its June 23,
} . 1970 meeting opposing the granting of all applications that propose
' to discharge waste into Bear Creek or Red Oak Creek. The resolution
I . recommends that such applicants be required to connect to the Trinity
: River Authority's sev/erage system.
:' Examiner's Note; A letter written by Hon. Milton Hartsfieid, County
; Judge of Ellis County and received after the public hearing states
that the Commissioners Court "did not have in consideration" the Red
Oak treatment plant when the resolution was passed. Apparently, then,
; the Commissioners Court would not object to the building of the City's
I • '. plant. } I . . • ••
The Parks and Wildlife Department will offer no objection to the
: application provided I the applied for parameter for suspended solids
; (25 mg/1 monthly average, 30 iug/1 24-hour daily composite, 30 mg/1
j individual sample) can be reduced to normally acceptable limits
! (20, 25 and 30 mg/1 respectively).
50
-------
. *•
( • • • Findings and Recommendations
The Hearing Commission makes the following findings:
1. Septic tanks presently serving the City of Red Oak are
inadequate; they pose a potentially serious pollution
. - ' and health hazard to the cornfnuiilty. Septic tank seepag
is currently degrading thevqju.lji'ity of water in Red Oak
. Creek and threatening the/wali^: supply in the city.
•&&.'•'?$' .«&>•
, . . . . >.f''... yd A
' 2. It is economically impractito require the City of
i •• ' Red Oak to attempt to contract with the Trinity River
• • . Authority's Tenmile Creek Sewerage System. A balancing
i ••'.'. of the interests involved indicates that the City should
I . not have to bear the economic hardship and untimely delays \
' - in construction that would be entailed by a tie-in to a )
j .regional system. Representatives of the Trinity River
i! .have recommended that the City proceed with its plans to
build a separate treatment plant; eventually the City can
-.'; join the regional system when economics and population
j growth so indicate.
' * - " • *
' r ' • '
. ( 3. A properly constructed and maintained treatment plant of
. • the type proposed by the applicant should not adversely
ll' affect normal uses of Red Oak Creek. Such a plant would
,; ' eliminate present septic tank seepage into the creek
•| from the City of Red Oak.
, -. In light of the consideration given all the evidence, the Hearing
; Commission recommends that an initial Waste Control Order be
granted in accordance with the terms and conditions of the proposed""
: Waste Control Order attached hereto.
Lee H. Mathews, Presiding Office:
August 14, 1970 . ;.
LHM:ha
i
f
51
-------
•v
ADDENDUM
ESTIMATED COST OF SEWERAGE
SYSTEM FOR CITY OF RED OAK. TEXAS
1. Construction Costs:
a. Lift .Station and line
to regional system
b. Sewage Plant
• c. Local outfall line
d. Lateral sewer lines.
f'^i c. Subtotal
X_x' . ' .' • • . .
2. • Other Project Costs
Using
•Local
Sewage
Plant
$ 50,000
37,168
85,390
$ 172,558
68,442
3. Total Estimated Project Cost $241,000
Joining
•10-Mile Creek
Regional
System
$ 220,000
• * .
37,168
., 85,390
$342,558
'68,442
$411,000
*1968 Estimate by Trinity River Authority based on 8 inch outfall line
which would be inadequate in 15. years. . •"', .
52
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PROPOSED WASTE CONTROL ORDER . #815
A ' •
C
NAME: . City of Red Oak
ADDRESS: P. 0. Box 393 > .
CITY: Red Oak, Texas 75151
TYPE OF WASTE CONTROL ORDER: Regular ,. ., .-
NATURE OF BUSINESS PRODUCING WASTE: ' M£ij$gi|Xcil sewerage system
'>I^1§^.
GENERAL DESCRIPTION AND LOCATION OF V^S&mSPOSAL SYSTEM-
. - ** ''t',> • ''**rir"'V . "
.
Description; Oxidation ditch inducting'bar screen, Parshall
; flume and two 1.15 acre stabilization ponds.
- ' ' . . ." • '•!:
*"V *
1 . Location: Approximately ^ mile south 'of Red Oak, Texas and
i ' immediately west of M.K. & T, Railroad v/hich point
CN -is west of cemetery on State Highway 342. k
' • j • - : ; : .. '
CONDITIONS OF THE WASTE CONTROL ORDER: . .'
; Character; Treated municipal sewage effluent
i *
j ' .
Volume; Not to exceed an average of 100,000 gallons per dayj
Not to exceed a maximum of 250,000 gallons per fiay;
. Not to exceed a maximum of 145 gallons per minute,
Quality;
Item
NOT TO EXCEED
.. Monthly 24-hour Daily Individual
Average Compos ite Samp 1 e
B.O.D.
Point of Discharge;
20 mg/1 25 mg/1 30 mg/1
Into an unnamed branch adjacent to the
plant site in Ellis County, Texas; thence
into Red Oak Creek; thence into the
Trinity River in the Trinity River Basin.
no. •
.53
-------
" . •••.;• ' * •' .'• '
•u • t*>i
, Prpooscd Waste Control Order - Page 2
! CiC_. of Red Oak
SPECIAL PROVISIONS: ' .-•- £'> . 'V
f- .*•;*•••»•.. ... i ' " •
, .•••--7^.- . •-.--;.
— '•V;!->7-WiVi- ' '. '
This order is granted subject to the pol^c^'of the Board to encourage
.the development of area-wide waste col;fe!$|pt]b'n, treatment and disposal . .
systems. The Board reserves the righ.^tot^mend this order in accor.d-
.•• Jt**.%' j,J'. ••*"••'
ar.ce with applicable procedural requirerneat^'-to require the system
covered by this order to be integrated into an area-wide system, should
such be developed; to .require the delivery k,pf the wastes authorized to
be collected in, treated by or discharged f£om said system, to such area-
wide system; or to amend this order in any other particular to effectuate
the Board's policy. Such amendments may be made when, in the judgment of
the Board, the changes required thereby are advisable for water quality
control purposes and are feasible on the basis of waste treatment
technology, engineering, financial, and related considerations existing
at the time the changes are required, exclusive' of the loss of investment
in or "revenues from any then existing or proposed waste collection, treat-
mer^ or disposal system.
\.s
These public sewerage facilities shall be operated and maintained by a
sewage plant operator holding a valid certificate of competency issued •
'under the direction of the Texas State Health Department as required by
Section 20 (a) of Article 4477-1, Vernon's Texas Civil Statutes.
The City shall comply with the provisions of Board Order No. 69-1219-1
relative to monitoring and reporting data on effluent described in
"Conditions of the Waste Control Order". . . ——
» • ' • • .
JMJ:ns - - ,. ' .
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Exhibit No. 12
June 2U. 1971
Mr. Don T. Shields
Superintendent of Schools
P. 0. Box 117
Red Oak, Texas 7515U
Dear Mr. Shields:
S-DMC
RE: Red Oak Elementary
School
Sewage Disposal
Mr. Ron Freeman, P.E., rational representative for'the Texas State
Department of Health, inspected sewage disposal facilities at the
elementary school at lied Oak on June 17, 1S71. He reports that
you were in his company during the inspection, as well as Mrs. W.
B. Bond; a nearby resident to the school, and Mr. David Leslie,
R.S., of the Ellis County Health Department.
A review of Mr. Freeman'§_ evaluation of the school's sewage hand-
ling facilities indicates that a health hazard does exist, since
sewage can be observed flowing on the surface of the ground. This
condition, we understand, has existed for a number of years.
Corrective action must be token to prevent continued exposure of
students to sewage. The most desirable and effective way to dis-
pose of the wastewater generated at the school is to discharge
into a community collection system. We have been advised that the
funding for a proposed sewerage facility for the City of Red Oak
has been delayed. If assurance cannot be given by the City, or
other agencies involved, that the sewerage system will be installed
in the very near futura, ths school should repair and enlar^a the
present facility to tha degree, that it will serve the demand placed
upon it without creating a public health nuisance. If a definite
commitment from the City is not forthcoming, the school should
wait no longer than two weeks prior to the beginning of the fall
semester to start construction on the renovation and expansion of
the septic tank disposal system.
-------
Mr. Don T. Shields
Page Two
June 24, 1971
Enclosed are copies of bulletins dealing with the"design of septic
tank systems. It is recommended that you maintain close liaison
with Mr. Leslie as you progress toward the solution of this prob-
lem. You may also wish to engage the services of a Professional
Engineer. ^
Sincerely,
David M. Cochran, P.E., Chief
Plans and Specifications
Division.of Wastewater Technology
and Surveillance
DMC/dec
ocs: Honorable J. M. Hart, Mayor
City of Red Oak
Miss Lucy Chapman, City Secretary
City of Red Oak
Trinity River Authority
Water Quality Office, EPA
ATTN: Hsndon Crana, P.E.
Mr. and Mrs. W. B. Bond
Ellis County Health Department
Local Health Services
Region II
Texas Water Quality Board
ATTN: Robert G. Fleming, P.E.
bcc: Wisenbaker, Fix and Associates
Consulting Engineers
-------
STATE DEPARTMENT OF HEALTH
AUSTIN TEXAS
INTER-OFFICE
Henry L. Dabney, P. E.N,-'Director,
Ron Freeman, P.E., Region II TO. Division of Wastewaterminology'^y
and Surveillance ^^vi^J-^-'-^
Complaints at Rankin and Red Oak, Ellis County
The Writer contacted Mr. and Mrs. Bill Rankin, Owners of the private
water well in Rankin, Mr. John Thomas, Route 4, Ennis, Texas, who lives adja-
cent to the Rankin property, and Mr. David Leslie, R.S., Ellis County HHealth
Department, on Thursday, June 17th in regard to a complaint involving waste-
water from the Thomas's septic tank polluting the Rankin's private water well.
Mr. Leslie, who is acting City Manager at Waxahachie, did not have the time to
accompany the Writer to Rankin.
An inspection of the well and surrounding area revealed that the field lines
serving the septic tank were not functioning properly as raw sewage was ponding
at the surface of the ground which is approximately 15 feet from the dug well, 38
feet in depth. It was pointed out to the Rankin's that the well is to close to the
field lines even is operating properly. Therefore, a new well should be dug or
continuous chlorination facilities provided if the well is to be used for drinking
purposes.
Mr. Thomas was not to receptive to the Writer's suggestions that the septic
tank system be repaired or the pollution of the neighbors well-but did state
that the lines would be repaired within 30 days. In addition to the health
hazard involved in contaminating the well, the Writer explained the hazards
concerning fly and mosquito breeding with the wastewater standing on top of the
ground within 20 feet of his residence. The Writer urged that immediate action
be taken to correct the problem. Samples for bacteriological analysis were
collected at the Rankin's Residence.
Mr. Leslie stated that if corrective measures are not taken in the near
future, the County HHealth Department would issue a notice to Mr. Thomas to
correct the matter. Once again, the Writer encouraged immediate action as it
was felt that 30 days was too long a time to correct the unsanitary condition.
Mr. Leslie assured the Writer that corrective measures would be taken by the
Health Department.
Mrs. W.B. Bond, Mr. David Leslie, R.S., and Mr. Don T. Shields, School
Superintendent at Red Oak, were contacted while the Writer was in Red Oak on
Thursday, June 17th. According to those contacted as well as the adjoining
residents, the wastewater flows constantly during the school year although
dry at this time since school is out for the summer. Arroximately 2000 feet
of field lines and two large septic tanks are presently in use according to
Mr. Shields. Some of the field lines are fairly old and not operating pro-
perly therefore Mr. Shields has suggested to the School Board that additional
lines embedded with large rock be installed. Mr. Shields indicated that the
Board was not to receptive to the idea. Until a sewer system can be obtained,
this seems to be only solution since the Board is reluctant to spend much money
for permanent improvements. The soil conditions are such that a septic tank
system is very undesirable. Mr. Shields requested a letter from the State «$—•
Health Department requesting that immediate improvements be made to eliviate
the unhealthy conditions created by the overflowing septic tank system. Also,
he welcomes any suggestions which might improve the problem, in paticular, the
addition of additional field lines. It was suggested that such improvements be
made as soon as possible since school is out and the ground is not saturated.
Any correspondence to Mr. Shields should be addressed to P.O.Box 117, Red Oak,
Texas 7515^. This problem existing at the elementary school has been in existence
for many years according to Mr. Leslie.
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APPENDIX A
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EXECUTIVE DEPARTMENT
DIVISION OF PLANNING COORDINATION
PRESTON SMITH BOX 1MM« CAF1TO1- "AT.ON ED GRI8HAM
OOVCHNOM AUSTIN, TEXAS 78711 DlMOTOR
PHONE B12 475-2427
March 30, 1972
Mr. Ancil A. Jones
Air and Water Programs Division
Environmental Protection Agency
1600 Patterson Street, Suite 1100
Dallas, Texas 75201
Dear Mr. Jones:
The Office of the Governor, Division of Planning Coordination (the
State Planning and Development Clearinghouse), and affected Texas
State agencies have reviewed the draft environmental impact state-
ment for construction of wastewater facilities at Red Oak, Texas.
The Texas Parks and Wildlife Department disagrees, in part, with
the environmental assessment presented for this project. The
specific areas of contention concern the impact on fish in Red Oak
Creek and the assimilative capacity of the stream. The comments
of the Texas Parks and Wildlife Department are enclosed.
Other State agencies responding concurred with the present content
of the draft statement.
Thank you for the opportunity to review this draft environmental
impact statement.
Sincerely,
Ed Grisham
Di rector
EG:jsb
Enclosure
cc: Mr. James U. Cross, TP&WD
APR 1 0 1972
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OOCH:I:UNLCHER TEXAS WATER QUALITY BOARD JAMESU -CR08S
J. E. PEAVY, MD
LISTER CLARK
VICC-CHAINMAN BYRON TUNNELL
J. DOUG TOOLE ilsS HUGH C. YANTI8. JR.
EXECUTIVE DIRECTOR
HARRY l». BURLEIOH
PH. 478-2081
A.C. 812
314 WEST 11TH STREET 787O1
P.O. BOX 13248 CAPITOL STATION 78711
AUSTIN. TEXAS
May 24, 1972
Re: Red Oak, Texas
WPC-Tex-533
Environmental Protection Agency
Water Quality Office, Region VI
1600 Patterson Street, Suite 1100
Dallas, Texas 75201
Attention: Mr. Dan Sherwood
Gentlemen:
This letter will confirm the conference which was held on May 23,
1972, with representatives of the City of Red Oak, Wisenbaker,
Fix, and Associates Consulting Engineers, the Texas Water Quality
Board, and Mr. Dan Sherwood of your staff. It was necessary that
we hold this conference by telephone because Mr. Sherwood was
unable to be here in our office due to mechanical difficulties
experienced by the airline on which he had proposed to travel to
Austin. Prior to our telephone conference involving Mr. Sherwood,
we held a conference here in our office with the representatives
mentioned above. Present at the conference were: Mayor Perry
McCalman, Councilwoman Lucy Chapman, Councilman M. E. Brown,
Councilman Lester Watkins, City Attorney Ronnie B. Johnson, Robert
E. Fix, Wisenbaker, Fix, & Associates; Pat dePhamphilis, Wisenbaker,
Fix, & Associates; Nick Classen, and Joe Copeland, Water Quality
Board.
The following is a summary of the conduct of the conference:
Consulting Engineer Robert E. Fix explained the latest proposal
for treatment facilities at Red Oak. The facilities will include
a bar screen and comminutor, the Huisman-Orbal activated sludge
process with clarifier, sludge drying beds, chlorine contact
2 B MY 193,
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Environmental Protection Agency
Page 2
May 24, 1972
chamber designed for 20 minutes contact time at peak flow, and
will also include the two oxidation ponds that were proposed in
the original design. Sludge will be pumped to the drying beds.
Part of the plant effluent can still be used for irrigation of
the golf course, if desired. In the event of power failure,
the wastewater can flow by gravity through all of the units to
the ponds. It was suggested that a bypass line be incorporated
in the design so that the final clarifier could be de-watered
for maintenance, if necessary. Mayor McCalman expressed acceptance
of the proposal for the city and the City Attorney, Ron Johnson,
concurred in the decision. We (TWQB) stated that the process was
an acceptable one capable of producing a good quality of effluent
and that we could foresee no problem in granting approval to the
plans and specifications.
Mr. Sherwood stated that the proposal sounded satisfactory and
that EPA would concur with our approval. He said that the final
Environmental Impact Statement would be filed on or about June
2, 1972, with the Council on Environmental Quality and that no
administrative action could be taken by EPA for 30 days following
the filing of the statement. He stated, however, that the city
could advertise for bids prior to about July 3 if they so desired,
and that the contract could be tentatively awarded pending formal
approval by EPA.
The engineers stated that they were having to revise the entire
proposal and scrap the original plans and specifications; that
plans would be ready for advertising about July 15 and that con-
struction would begin about September 1. A wage determination
was requested during this telephone conference.
Mr. Sherwood went on to say that the EPA Executive Office will
stand by this proposal and will approve a surface discharge of
the effluent. He said that EPA is continuing to receive letters
of complaint from the downstream landowners, and that they have
assured the downstream landowners that the plant operation and
effluent quality will be monitored at reasonable intervals after
the plant goes into operation. He asked that we establish some
reasonable inspection and monitoring schedule involving our field
personnel and so advise him. We have discussed this matter with
Mr. Dick Whittington, our Director of Field Operations, and he
has assured us that his field personnel will inspect this plant
and monitor the effluent at reasonable intervals.
6 MAY 197Z
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Environmental Protection Agency
Page 3
May 24, 1972
Please advise us if additional information is needed to clarify
any of the points that were discussed during this conference.
We will look forward to receiving a copy of the final Environ-
mental Impact Statement in the near future. Incidentally, your
assistance in processing a request for a new wage determination
for this project will be appreciated.
Sincerely yours,
Nicholas W. Classen, P.E.
Municipal Services
NWC:mr
ccs: Honorable Perry McCalman, Mayor
Mr. Ronnie B. Johnson, City Attorney
Wisenbaker, Fix, & Associates
TWQB District 4
2 6 MAY to/2
-------
TEXAS
PARKS AND WILDLIFE DEPARTMENT
COMMISSIONERS
JACK R. STONE
CHAIRMAN. WELLS
oNo
•AN ANTONIO
PEARCE JOHNSON
AUSTIN
JAMES U. CROSS
EXECUTIVE DIRECTOR
JOHN H. REAGAN BUILDING
AUSTIN, TEXAS 78701
COMMISSIONER:
BOB BURLESOF
TEMPLE
JOEK.FULTO
LUB8OCK
MAX L. THONM
DALLAS
March 13, 1972
Mr. Ed Coker
Division of Planning Coordination
Executive Department
Capitol Station
Austin, Texas 78711 RECEIVED
MAR 14 Wl
Dear Mr. Coker: DJV. Of Plan. COOrtL
Re: Draft Environmental
Impact Statement for
Wastewater Facilities
at Red Oak, Texas
We have reviewed the draft environmental impact statement for construction of
wastewater facilities at Red Oak, Texas, and are only in partial agreement with
the assessment presented. Specifically, we do not agree with statements con-
cerning the impact on fish in Red Oak Creek or statements concerning the assim-
ilative capacity of the stream.
Red Oak Creek is an intermittent stream and will provide little or no dilution
of wastes during the dry season. During that period, it is likely that solids
will accumulate in slack water areas and the diurnal oxygen fluctuation will be
exaggerated .
It is also misleading to assume that BOD5 of the effluent will indicate the
ultimate oxygen demand. The nitrogenous oxygen demand, not included in BOD^,
will exert a demand possibly as great as the BODc. Additionally, chlorine
residual in the stream can combine with ammonia from the waste discharge to
form chloramines which are toxic to fish in very low concentrations.
The net result of the interaction of these factors will be to produce a segment
of stream which fish and other aquatic life will avoid, at least in conditions
of low stream flow. Therefore, the assessment of the impact statement which
indicates the only effect on fish will be a minimal size increase is misleading.
It is probable that the environmental impact will be small, and as an interim
plan, we do not disagree with the need for the facility. We would not, however,
-------
Mr. Ed Coker
March 13, 1972
Page 2
like to see the assessment based on the assumption that there will be no degra-
dation of the stream when, in fact, degradation will occur.
We appreciate having had the opportunity to comment on this draft statement.
Sincerely,
s u.
ecutive Director
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TEXAS FOREST SERVICE
File-
College Station, Texas 778*4-3
March 1, 1972
Arthur W. Busch
Regional Administrator
Environmental Protection Agency
1600 Patterson, Suite 1100
Dallas, Texas 75201
Dear Mr. Busch:
This agency finds no objection to the contents of your
draft of an environmental impact statement for construction
of wastewater facilities, Red Oak, Texas. This is in response
to your circular letter of February 25th.
Very truly yours,
Paul R. Kramer, Director
Mason C.. Cloud
MC/co
-------
TRINITY RIVER AUTHORITY OF TEXAS
JOHN M. SCOTT
PMMIOENT
A. C. SPENCER
•EN H. CARPENTER
CHAIRMAN
EXKCUTIVB COMMITTH
DAVID H. BRUNE
MAMA«m
GEORGE D. JANNINO
AMIBYANT
QINKRAL MANAOKII
ALBERT E. HAUL
PROJECT*
CONSTRUCTION MANAOIR
JAMES L. STRAWS
PMOJICTB
DCVCLOPMINT MANAaCR
7O1 OATEWAY PLAZA • 8723 AVENUE E EAST
P. O. BOX 8708
ARLINGTON. TEXAS 76OI !
TELEPHONE: (AREA CODE 817) 268-3181
March 28, 1972
Mr. Arthur W, Busch
Regional Administrator
Environmental Protection Agency
Region VI
1600 Patterson, Suite 1100
Dallas, Texas 75201
Dear Mr, Busch:
In response to your letter of February 25, 1972, we have reviewed
the draft of the environmental statement prepared by your staff
for construction of wastewater facilities for the City of Red Oak,
Texas.
We generally concur with the environmental statement and offer no
suggested additions or modifications to the draft.
Thank you for providing the Authority with the opportunity to
review the draft of this environmental statement.
Sincerely,
James L. Strawn
Development Manager
JLS:db
MAR 30$%
APR 1 0 1972
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
P. 0. Box 648
Temple, Texas 76501
Mr. Arthur W. Busch
Regional Administrator
Environmental Protection Agency
1600 Patterson, Suite 1100
Dallas, Texas 75201
March 27, 1972
Dear Mr. Busch:
We have completed our review of the draft environmental statement
on a complete wastewater treatment system for the City of Red Oak,
Ellis County, Texas, dated February 25, 1972.
The statement adequately describes the effect of the proposed
project on land use and management and upstream water resources.
We appreciate the opportunity to review and comment on this statement.
Sincerely,
fervationist
APR 3 1S72
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
Region 3
517 Gold Avenue S.W.
Albuquerque, Hew Mexico 87101
1940
April 7, 1972
Environmental Protection Agency
Region VI
1600 Fetterson, Suite 1100
Dallas, Texas 75201
L
Gentlemen:
We have reviewed the draft environmental statement for the
proposed waste-water treatment facilities to be located near
Red Oak, Texas.
The statement is well prepared end all items wherein the Forest
Service can lend expertise have been adequately considered. We
have no suggested revisions or additions.
We appreciate the opportunity to review this well prepared
statement.
Sincerely,
WM. D. HURST
Regional Forester
APR
APR 10 1972
-------
DEPARTMENT OF THE ARMY
FORT WORTH DISTRICT, CORPS OF ENGINEERS
P. O. BOX 17300
FORT WORTH, TEXAS 76102
SWFED-PR
27 March 1972
Mr. Arthur W. Busch
Regional Administrator
Environmental Protection Agency
1600 Patterson, Suite 1100
Dallas, Texas 75201
Dear Mr. Busch:
As requested by your letter, the draft environmental statement for the
proposed wastewater facilities, Red Oak, Texas., has been reviewed by the
Fort Worth District, U. S. Army Corps of Engineers.
We concur with the basic text of the draft environmental statement.
However, the following comments are offered to assist you in the revision
of this environmental statement.
a. Section I, "Description of the Proposed Action", could be strength-
ened by including additional material covering the hydrologic aspects of
the study area. The flora and fauna of the study area could be discussed
in more detail.
b. Section V, page 29, paragraph 1. Although productivity, in terms
of biomass, may indeed be increased, there will be dramatic changes in
the nature of the organisms present. Algae will flourish, especially
filamentous forms, blue greens, etc. Sport fishes, where present now,
will disappear and be replaced by those more tolerant to low oxygen levels
which will be occurring as the nutrient levels increase. Bottom sediments
will trap nutrients which will be present for quite some time after the
release of sewage effluent ceases. This length of time will depend on
the scouring action of the natural flows of the stream.
c. Section VII, page 31, Response to Comment 5. The previous com-
ment, b., is also applicable to Comment 5. Also the response to this
comment is somewhat deceptive because it fails to point out that quality
MAR 28
-------
SWFED-PR 27 March 1972
Mr. Arthur W. Busch
of stream organisms is more important than quantity. The discharge of
effluent into the creek would create a very productive body of water,
yet the desirability of fish harvested from the creek would be question-
able.
Thank you for the opportunity to review and comment on this statement.
It is hoped these comments will be helpful in preparing the final
environmental statement.
Sincerely yours,
D. L. ORENDOKFF
Chief, Engineering Division
-------
DEPARTMENT OF HEALTH, EDUCATION. AND WELFARE
REGIONAL OFFICE
1114 COMMERCE STREET
DALLAS. TEXAS 75202 OFFICE OF
March 24, 1972 THE REGIONAL DIRECTOR
Our Reference: EI# 0272-107
Mr. Arthur W. Busch
Regional Administrator
Environmental Protection Agency Re: Construction of Wastewater
1600 Patterson, Suite 1100 Facilities, Red Oak, Texas
Dallas, Texas 75201 WPC-TEX-533
Dear Mr. Busch:
Pursuant to your request, we have reviewed the Environmental
Impact Statement for the above project proposal in accordance
with Section 102(2) (C) of P. L. 91-190, and the Council on
Environmental Quality Guidelines of April 23, 1971.
Environmental health program responsibilities and standards of
the Department of Health, Education, and Welfare include those
vested with the United States Public Health Service and the
Facilities Engineering and Construction Agency. The U. S. Public
Health Service has those programs of the Federal Food and Drug
Administration, which include the National Institute of Occu-
pational Safety and Health and the Bureau of Community Environ-
mental Management (housing, injury control, recreational health
and insect and rodent control).
Accordingly, our review of the Draft Environmental Statement for
the project discerns no adverse health effects that might be of
significance where our program responsibilities and standards
pertain, provided that appropriate guides are followed in concert
with state, county, and local environmental health laws and
regulations.
We therefore have no objection to the authorization of this project
insofar as our interests and responsibilities are concerned.
£ery truly yours,
/WT(y
/j/. Stephens
/'Environmental Impacl
Coordinator
ORD-EI-l
-------
IN REPLY HtrtH TO:
United States Department of the Interior
BUREAU OF OUTDOOR RECREATION
MID-CONTINENT REGION
BUILDING 41, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
APR 4 1972
D6427 EIS
Wastewater Treatment
Red Oak, Texas
Mr. Arthur W. Busch
Regional Administrator
Environmental Protection Agenc
Region VI
1600 Patterson, Suite 1100
Dallas, Texas 75201
Dear Mr. Busch:
We have reviewed the draft environmental impact statement for the
proposed wastewater treatment facilities to be located near Red Oak,
Texas as requested in your letter of February 25, 1972. Our comments
are based entirely on the environmental impact data that you provided
without the benefit of an on-site inspection.
We wish to compliment you on the general quality of the draft state-
ment. The narrative is well written and makes clear what is intended
and the general effects that the project work will have on the
environment. We also feel that a sincere effort was made here to
thoroughly explore all possible solutions to the sewage problem at
Red Oak. There are, however, several specific comments we wish to
offer.
We recommend that the word "beneficially" be dropped from the last
sentence on page 12. Population growth is not always beneficial to
an area. The growth of Red Oak with its close proximity to Dallas
could represent a continuation of undesirable urban sprawl.
On page 14 it is indicated that no current detailed data exists on
the assimilative capacity of Red Oak Creek. It would seem logical
that such data should be obtained before proceeding with construction
of the project.
On page 19 we suggest the sentence "...they can require the city to
upgrade facilities to produce a less harmful effluent" be changed to
read "they will require the city to upgrade the facilities to produce
a less harmful effluent."
APR 1 0 1972
-------
Mr. Busch
Page 2
The statement is unclear as to the exact location of the treatment
facilities in relation to the receiving tributary. Mention is made of
possible flood conditions in the area. If the facilities lie in the
flood plain of the tributary, the statement should include discussion
of measures taken to protect plant operations from flooding.
On page 32 it is indicated that opponents of the project believe the
treatment facilities could create odor and pollution problems down-
stream. As evidence, they cite existing problems at similar plants
in Ferris, Forreston, and Lancaster, Texas. We are pleased that the
final statement will include a review of these other facilities. In
lieu of current recreation use on Red Oak Creek, objectionable odor
or pollution could create undesirable conditions from a recreation
standpoint.
The alternative of irrigating a privately owned golf course with the
treated effluent would seem wise from a recreation standpoint. This,
of course, is assuming that the vegetation will not be harmed by the
effluent. The suggestion that the contract between the owner of the
golf course and the city contain a clause allowing him to discontinue
irrigation if necessary is an excellent solution to this possible
problem.
The statement does not include discussion of possible design alterna-
tives for the wastewater facilities. Such alternatives should be
included in order to assure that the most aesthetically advantageous
design is selected.
Our comments should be regarded as those of the Mid-Continent Regional
Office of the Bureau and not the official position of the Bureau of
Outdoor Recreation or the Department of the Interior.
Thank you for affording us the opportunity to comment.
Sincerely yours,
Maurice D. Arnold
Regional Director
cc: BOR, Washington
Attn: Division of Resource
Area Studies
-------
March 27, 1972
ENVIRONMENTAL PROTECTION AGENCY
Gentlemen)
My name is C.E.Spain, Jr. and I am president of the Red Oak Creek Landowners
Association, Ellis County.
We have had members at every meeting in regard to the Red Oak sewage problem
and we have spent a great amount of money trying to prevent the pollution
of Red Oak Crook. I am sure that this is a surprise to you, since no mention
of our organization is included in your report- a fact which does not surprise
us since throughout this affair wo have been treated as second class citizens
with no rights whatever*
In your report as in every report regarding this matter, you explain that
the city of Red Oak cannot go to the Trinity River Authority Sewage System
because of lack of money. This is based on the fact that Red Oak has about
600 citizens. On the other hand, their need is based en a projected popu-
lation of 2000 in the near future. No city or business can base its ability
to expand on its present finances, Any city,in so doing, will find its facil-
ities always behind the times.
Secondly, you state that no damage to Red Oak Creek is expected from the eff-
luent being dumped into it. Why isn't it expectedt Have you looked at any of
the creeks where sewage has boon dumped for a number of years? I do not
believe that this statement is believed by anyone, including the people who
made the statement*
My opinion of the report is that it is a poor cover-up for the failure of the
ENVIRONMENTAL PROTECTION AGENCY to live up to its job of protecting the envir-
onment. If this is a sample of ymor work, I personally begrudge every tax
dollar that is spent by your Ageney*
O.E. Spain, Jr.-President,
Red Oak Creek Landowners
Association
Rte. I
Wakahaehie, Texas
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7 . / f 7
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-------
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^^/t^x-V-lx«-^< "4}l~l—
@^^@&<&Jt^
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Saute # 3
Wtaahachie, i'exas Y5l6$
March 28, 1972
Environment Protection Agency:
As a landowner along Red Oak Greek, i want to protest your recent
decision concerning the Red Oak Sewage Plant. One has only to look at
similar situations such as Ten Mile Creok before the Trinity River Disposible
Pl--nt v;a:; installed near Ferris. The Creek was once used by many :eo le in
the Dallas area, but was soon so polluted that no one used it nor the area
(land) surroundtNt this cre.ik. Red Oak Greek is one of the few creeks in this
aroa on which there is sufficient recreational area and clean unpolluted
water. *v .. ee sons learned to swim in this crbek some lf> years ago and
even today fish and swim in it. Boy Scouts from Palmer, Dallas, and Lancaster
come to my property at least 1^ times during the year for two to four day
outings on the creek. If this creek is polluted, you will have had a part
in depriving these young men from the opportunity of enjoying the ait-doors.
Also, many church and civic groups come to this creek to enjoy the clean
environment fo'.ind along this creek, I personally feel that you are making
a mistake when you allow a city to dump into an unpolluted creek when for
only about a dollar a person more, the city could link up with a sewage pipe
system (Trinity River Project-Ferris,Texas) and save thereselven money at
the same time. Red Oak is growing so fast that a sewage plant such as the
one planned for Red Oak Greek will be out-dated in lesn that three years.
Please use com.1 .ion sense and deny them the ri^ht to dump in our creek.
-------
Box 12
Palmer, Texas 7!>l52
March 23, 1972
Environmental Protection Agency
Dallas, Texas
G/o G.E. Spain - J^ockette, Texas
Sirs:
I hope and :xay that you will not be misled and deceived into beli ving
th."t dumping any type of sewage (treated or raw) into Re.'" Oak Greek -all do
anything but harm the creek and the land aro'.md this beautiful creek.
Ify father raised me on a farm near this creek and I am now living in a
mobile home situated abouted a 100 yards from the creek. I urn High School
Principal at Palmer Higi School and I know that the majority o? our students
defend U'-on this Greek for out-door recreation. Please!!!!!! Help save this
Recreation area for our youth by denting Red Oak the right to dump their
o
waste in our creek. They can easily go to a pined sewage? line running to
the Trinity River through Ferris this will only cost a small amount -compared
to the damage and eventual destruction of this beautiful creek. Thank you
for your cooperation.
Binqierel/,
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Red Oak, Texas. Varch 31, 1972
*'r. C. 13. Spain, Jr.
Chairman Red Oak, Creek Landowners Assn.,
Dear Vr. Spain:
As a landoimer and living *ithin the
adjacent Units of '^e Red Oak Greek area I wish to make
a few comments re-^ardin? the recent decision of t^e '••:. P. A
giving th city of Red Oak permission to d'aini) the effluent
into Red Oa> creek.
This eo^m-ini '".y 'an esi^blislied in the year
and t1- e <~ener-'t : ons since that date V;ve enjoyed benefits of
rvL'-ir a 'Ure ntcoan of ™r.ter n which many hundreds of kids
hare »ssd tne many sirimming holes for their pleasure.
if the order is allowed to stand many cattle
raisers *ill be forced to seek sources o *»ater s'".pvly other
trian the "tainted fnter" of Ked Oak Creek.
1 am enclosing a clip-ping t-ken fron the Dill as
•;e^s of Varch 30, 197?, regarding clean -rater, The TTo-~e of
Representatives in Washing-feom parsed a bill a^rorin- -$?4 billion
dollars amin^ at cleaning »p the nation's -o^ter nys.
It simply doer, not ma'-re ..*:ood sense to pollute
a fine stream like Ked Oak creek and then spend nntold amotmt
of money to correct it a fe^ yearn later.
Jfloa'-e letr, v'eep o~ir clean ^ater clean instead of
"iaV.in;r it iinsofe for man or beast to drin>l:.
I am a"aint nollntinr any clean strean >fbere
ever it nirht b-~).
Please make ;t clear to the 15. P. A.
desire to reconrider their action and "rive ~s a fair break
in the matter of -rater pollution.
rpmrs verj7 flfepilj JL
11
Be!
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Billion
Approved for
Clean Water
WASHINGTON (AP) - The House
Wednesday passed a $24.6-billion water.
pollution-control bill aimed at cleaning
up the nation's waterways, perhaps by
1981. The vote was 378 to 14.
The measure, believed to be the
largest single nondefense authorization
ever approved by the House, now goes
before a joint conference of the House
and Senate Public Works Committees to
iron out differences between the House
version and one passed last November
by the Senate.
Rep. John A. Blatnik, D-Mlnn.,
chairman of the House Public Wptte
ConnoTtrar that wrote the bffl,»aif "as
.soon as possible after the Easter T*
cess, we hope to proceed to conference
with the Senate in order to expedite
final enactment bfleglsjmtlon that ip
enable America to restore and pre-
serve the integrity of her waters.** .
A spokesman for the Environmental
Policy Center said it was "a fraud on
the public to pass a dirty-water Mil ifl
a clean-water wrapping." Y
Significant differences between, 4fc
House and Senate versions are expected
to delay for some time agreement Be-
tween conferees.
The House bill calls for $18.3
billion to be spent from fiscal J9JHJ
to 1975 for the federal share of con-
structing sewage-treatment works and,
for the first time, sewage-collection sys-
tems. The total called for by the Senate
is only $14 billion. ;:.
The House bill calls also for the
best available technology to purify
wastes discharged into waterways.
After Congress received the study,-It
would decide whether to impose a 1981
deadline for utilizing the best means
available.
The Senate bill rigidly adopts the
1981 deadline and calls also for all dis-
charges into waterways to end by 1985.
The House, in contrast, considers 1865
to be a national goal, not a governmen-
tal policy.
In addition, the House bill would
abloshi the 1899 Refuse Act permit sys-
tem requiring industries to receive a
permit before discharging wastes into
navigable waterway. The permit sys-
tem would be replaced by a federal-
state permit system in which stale
would issue permits to industries com-
plying with federal guidelines.
The Senate version also establishes
a federal-state permit system but re-
tains the 1899 Refuse Act system which
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Red Oak, Texas
March 28, 1972
Dear Sirs:
I am writing in regard to the proposed sewage
system in Red Oak, Texas. This proposal is under your
consideration at this time.
I am nineteen years old and have lived in Red Oak
all my life. My family own a farm along the banks of
Red Oak Creek. This creek has been a special place
to me as long as I can remember. Summer after summer
my family and many friends have used this cree>k for
recreational purposes* Each Fourth of July our church
groups spend much of the week end on our farm. At other
times, during the year, we have other parties or Just a
picnic. It seems that never a week goes by without there
being a picnic or a camp along the creek banks.
I have enjoyed many an enjoyable hour along Red Oak
Creek and I sure hate to see it polluted. I hate to
think of giving up the beautiful memories of walking a-
long the banks of the creek looking into the clear waters
at the many fish that swim freely. Many mornings I have
risen well before the sun an made my way to the banks
of Red Oak Creek to find a nice spot to hunt squirrels.
I have hunted or fished the banks of this creek as
far back as I can remember. My father and his father did
the same. I would truly like to think that my children
could do the same and not worry about getting sick from
the waste materials that might get put in there by the
city of Red Oak.
Many of the world's paradises have been destroyed
and some have been preserved. I don't think that this
cr ek should be preserved but just left alone. The wonders
of the world are left alone and they are not hurting any-
body and people are able to enjoy them. I think this creek
is a wonder of God and think that it should be left alone.
Not polluted but to be enjoyed by everyone.
Yours truly,
Jary
"A concerned citizen"
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Red Oak, Texas
March 30, 1972
Dear Sirs:
After reading the impact statement on the proposed
Red Oak Creek Sewage System, I was very disappointed in
the reversing of your decision to utilize the discharge
waters on the Red Oak Golf Course. Also removing the
stipulation of having the city of Red Oak to join the
TRA by the year 197f. In all the meetings, concerning the
project, these two items were emphasized by your agency.
I realize this was contrary to what the Texas Quality
Board had already agreed to, and a permit was granted
before downstream land owners were advised or consulted.
At all of the Texas Quality Board meetings, they stipu-
lated that when they made a decision it was beyond question
by any individual or any other agency. I appreciated
the original stand the SPA took regarding everyone's views,
but in the final analysis I interpreted the impact state-
ment as EPA yielding to the Texas Quality Board almost
entirely. I have great reapect for those members on the
TQWB, but for the past (twenty) 20 years I have had to
pass by the city of Lancaster's disposal pland and would
almost gag by sewage gas odors and observed the discolor-
ationof the water downstream and the disappearing of all
game and catfish that were present before Lancaster dis-
charged into Ten Mile Creek. Also, I cross the Trinity
River twice daily and it is a duplication of Ten Mile Creel.
I am also aware that there has bean a Texas Quality Board
that has been in existence for a number of years. I am
thankful that Lancaster has joined the TRA and think this
is the most practical, feasible and economical solution for
the city of Red Oak. If the state water board will permit
conditions, as I mentioned above, to exist and if EPA, which
is apparently going to condone what the TQB dictates, then
when can we ever begin to start on this mammouth problem of
pollution. Can we search our hearts and consciences and
truthfully say this is the price we have to pay for progress
and let it stop there?
May I ask what rights or resources I have as a citizen
and a downstream land owner in case the city does pollute
Red Oak Creek? Is there anyone beside EPA or TQWB that could
be contacted that would be of any assistance in this matter?
I hope and pray that I never have to contact anyone on the
above mentioned subject. However, if the city of Red Oak runs
affluent in the creek, such as Cedar Hill, Lancaster and Ferris
prior to joining the TRA, then I would feel justified in con-
tacting the director of EPA or president of United Sftases.
Re
ernon G. Coffe
-------
Palmer, Texas
March 30, 1972
Environmental Protection Agency
1600 Patterson, Suite 1100
Dallas, Texas 75201
Gentlemen:
After reading your recent report concerning the problems of Red Oak,
Texas and the use of Red Oak Creek to carry the effluent from their
proposed sewage system, it would seem that we, th» landowners along
the creek, have again been sold out, and have nothing to say about
this matter,.
When your agency entered the picture, we had hopes that we were
going to be helped in preventing the pollution of a stream which is
used by many for recreation, as well as providing water for cattle
and various other uses.
Your report states that the effluent from the Red Oak sewage system
would improve the quality of the water. However, we have talked to
people who are in this kind of work and they say it is impossible
to control the amount of elfluent which would go into the creek,
especially in the overflow season. Therefore, it most definitely would
be a pollution and environmental problem, and certainly the value of
the land along the creek would be lowered considerably.
It seems that the rural people of this country are a forgotten
people, with no protection of any kind, and that this matter has,
due to the fact that this is election year, become a political foot-
ball. We are tax paying citizens, but can do nothing to protect our
own property against this threat.
Since cleaning up our environment and ridding the streams of pollu-
tion is your field of endeavor, it would seem that you, of all people
would not endorse this project.
We sincerely hope and ask that you studj this matter extensively, and
consider the far reaching results of letting yet another stream
become polluted.
Sincerely,
X£
C. R. Farrar
Mrs. C. R. Farrar
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March 24, 1972
To the ENVIRONMENTAL PROTECTION AGENCY
I am a member of the Red Oak Creed Landowners Association (Bills County).
I have lived my entire life on this Red Oak Creek and I own my hone on its
banks. I pay taxes to Midstream on this Creek. Let me state to you, I
owe the city of Red Oak nothing in regard to having their sewage dumped on
me and also on my neighbors. Red Oak oity has many $ 50,000 new homes,
not to mention the numerous $ 25,000 structures. They hare a thriving
new bank. Apparently, they are second-rate in having no regard to their
neighbors downstream. Have they led the Environmental Protection Agency
to believe that they cannot afford to pay their own obligation? They
can go to Trinity River Authority Disposal System. Why is the E.P.A
letting the city of Red Oak defeat the purpose of the S.P.A. and also
the purpose of the Trinity River Authority?
Raymond C. Humposies
Rte. I
Waxahactyie, Texas
-------
March 28, 1972
Environmental Protection Agency
Dallas, Texas
Dear Sirs:
My home is on Red Oak Creek and the homesite was chosen because of the
beauty and the white rock bottom of the creek in our particular area.
This has made our location one of the best for good family fun, swimming,
and picnicking.
We are concerned to learn that dispite our efforts to preserve this creek,
a Federal grant will permit its pollution by the effluent from the proposed
Red Oak sewage system. What has happened to the agency that was set up to
clean up the creeks and rivers? This one will not have to be cleaned up
later if it is not allowed to become polluted now. Is this the agency
that is now financing the pollution of our water ways?
Very truly yours,
V,
MR. AND MRS. CHARLES L. PRUDE & FAMILY
Route 1
Palmer, Texas 75152
/
cc: General William D. Ruckelshaus
Washington, D.C. 20204
-------
March 28, 1972
Environmental Protection Agency
Dallas, Texas
Dear Sirs:
I have recently purchased a homesite in the Red Oak Creek area. It has been
brought to my attention by the people in the community of the existing situation
in regard to the proposed sewage system by the city of Red Oak. VSy wife and I
were very disturbed to find the whole community involved in a protest to prevent
the pollution of the creek. I find myself very much in sympathy with the cause.
In the past my children have enjoyed swimming and fishing in this creek and I
fully expected to give this same privilege to my grandchildren. We are very
disturbed to find the creek will be unsuitable for recreational purposes if this
effluent is allowed to enter the creek. This is a pollution free creek at this
point and we are astonished and confused to learn that the agency which was set
up and designed to protect our environment and clean up the polluted creeks and
rivers has totally disregarded the pleas of the landowners to protect one of the
few remaining pollution free creeks.
We want to register our opposition to the pollution of the creek by the effluent
from the sewage system.
Very truly yours,
Ronald Whitehead
Gladys Whitehead
Route 1
Palmer, Texas 75152
cc: General William D. Ruckelshaus
Washington, D. C. 20204
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Cedarhurst Drive
Dallas, Texas 75233
March 25. 1972
The Environmental Protection Agency
Dallas, Texas
Dear Sir:
I am amazed that you, the Environmental Protection Agency,
have completely disregarded and refuted the numerous protests
that the landowners on Red Oak Creek have made over the pos-
sible releasing of treated sewage in Red Oak Creek.
The term we hear is "economically unfeasible" on every consi-
deration of their disposing of their sewage with the exception
of dumping their effluent in Red Oak Creek which solves their
problem with the least expense to them but totally without
regard or consideration for landowners whose deed lines center
the creek.
Some b2 acres, approximately 1/2 mile in length, which centers
Red Oak Creek to the south has been in the family sirce 1911.
Our water supply comes from a 35 foot well with a 10. foot basin
of water which is some 200 yards from the creek. The well has
a 6 foot wall but when the creek overflows there is some seepage
of water. Do you tell me that the effluent from Red Oak sew-
age plant will not effect my well, but instead Improve my water?
Real Estate people say the value of property on Red Oak Creek
will definately decrease in value when it becomes a carrier of
treated effluent. Will my legal rights not be abused by the
city of Red Oak, the state of Texas and the Federal Government
by decreasing the value of my property and depriving me of
recreational facilities of the creek that I have enjoyed in
the past?
My property on Red Oak Creek is very near and dear to me and
there is much hostility within me to think that the Federal
Government would approve a grant that would put sewage in one
of our very few remaining unpolluted streams when there are
other alternatives for the city of Red Oak.
Yours truly,
&1S4£y^ ^
Evelyn Farrar Byrd
-------
March 21, 1972
TO WHOM IT MAY CONCERN:
Even though I live in Red Oak, Texas and know that we need the new
sewage system and will benifit from it. I am against the way the
Dallas Environmental Protection Agency agrees to dispose of the
sewage in the Red Oak Creek.
My Mother lives in Rockett, Texas, only four houses from the Red
Oak Creek, where the sewage will be dumped. I feel sorry for her
and the people living in this community. I stand to inherit this
property, where my Mother lives, and may move to the town of Rockett
to live, therefore I have an interest.
1 hope you will please give this matter more consideration and look
into this situation fully, before you decide to let them dump this
sewage in the Red Oak Creek. I feel sure there are other ways of
disposing of this sewage, as other towns and communities have other
facilities. Please re-consider this matter.
Yours truly,
Virginia Runnels
206 N. Hillside
Red Oak, Texas
Donald'Runnels
206 N. Hillside
Red Oak, Texas
-------
March 24, 1972
TO WHOM IT MAY CONCERN:
This letter is written in protest of any effluent or
sewage being put into Red Oak Creek other than natural
rainfall and elements.
The property along the drainage of this creek is owned
by property owners who pay taxes on same to the center
of running stream if owned on one side. Also the pro-
perty in which I am interested has a well that could
draw seepage water from this creek as it is located
about three hundred yards from the stream of water on
creek level and is the only source of water for the
home.
I was born and raised on the stream and have used it
for recreation and helped maintain its upkeep for over
fifty years and I protest any changes in condition of
waste being disposed of in this stream.
Yours trul
J. R. Farrar
115 W University
Waxahachie, Texas 75165
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March 25, 1972
ENVIRONMENTAL PROTECTION AGENCY
I have lived my entire life on the banks of Red Oak Creek, Ellis County,
in the community of Roekett which is located three miles downstream from
the City of Red Oak, Texas.
Why should my home and my community be down-graded because the city of
Red fiak desires to take the cheap route for sewage disposal? They are
no poverty stricken people. Did the delegates from the Environmental
Protection Agency really drive through the town to see the new homes,
the new churches, the new bank, etc.? Numerous new homes and a major
gasoline station are under construction this very day.
I resent your recommendation to allow the City of Red Oak to take a
cheap alternative at my expense and at the expense of my community*
Clara Parrar
Route I
Waxahachie, Texas
75165
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LIFE INSURANCE COMPANY
March 21, 1972
PRESIDENT AND
CHAIRMAN OF THE BOARD
I SO O DAVIS BUiLDING
DALLAS, TEXAS 75202
Dallas Environmental
Protection Agency
Gentlemen:
I am a property owner affected by the discharge
of the flowing into Red Oak Creek, the creek passing
directly through my property. Cattle and other
livestock currently drink out of the creek waters.
Additional uses of the waters, outside of drinking
purposes, are for fishing, recreation, camping,
picnicking, public rest and play areas.
In the past, water supply lines from Rockett Water
Supply Corporation have burst during heavy rains,
thus allowing the potable waters to the customers
and users of the Rockett Water Supply to be mixed
with sewage effluent.
The discharge of effluent, without limitation, into
the Red Oak Creek will destroy all present uses of
the creek.
Your consideration of all the factors surrounding
the Red Oak Sewage problem should definitely dictate
against the use of Red Oak Creek as a sewage disposal
facility.
truly yours ,
ALR:mc
Arnold L. Reed
-------
Rusk, Texas
March 17, 1972
TO WHOM IT MAY CONCERN:
I am an heir at law of A.C. (Ike) Prude, Jr. and own an interest in the Prude
Homestead Farm through which Red Oak Creek flows. It has come to my attention
that the discharge from the proposed Red Oak Sewerage Plant is to be dumped
into Red Oak Creek.
My plans for the future are that I would like to build my retirement home on my
Father's Homestead Tract. I know from other experiences that if the sewerage
discharge from a sewerage is dumped into Red Oak Creek that it will not only
destroy the natural beauty of this creek and in my opinion will kill all fish
and Vegetation along the creek. A portion of our land is subject to overflow
from Red Oak Creek from time to time and this will mean that the sewerage
discharge from the Sewerage Plant will overflow our bottom land along Red Oak
Creek. The history of these sewerage plants is that they operator waits until
a heavy rain comes and then cleans out the sewerage plant by dumping every-
thing into the creek. Please protect my property from this injustice.
Respectfully,
Marguerjte Prude Tolar
P.O. Box 264
Rusk, Texas 75785
-------
March 27, 1972
General wHliaa D. Raekelihaus
Consumer Protection Midi fcnrironeental Health Serrloea
Dopart»»at of Health, Masatioa and Welfare
200 C Street S¥
Washington, D.C. 20204
DMT General Ruckeleheus t
Attached la a oopy of your laat ooi-reepo*d4nee to us regarding tho proposed
Rod Oak sewage system and it'a pollution of Rod Oak Crook, however, in view
of roeont developments, we a* laadewmore on Rod Oak Creek, want to register
farther opealtlcn to the polluttoa of Rod Oak Orook by this system and tho
torn of Rod Oak.
Tho roport from IPA in Dallas admlta that tho erook io virtually pollution
free at thia point, howoror, IPA piano to oupport tho plan to drain tho
offlnont from tho ayaton into tho orook. In viow of all tho publicity
toward eloaning up our air and wator rooourooa, wo aro at a looo to undor*
atand why a furthor of fort waa not or ha* not boon awtfo to work out aaothor
oolmtion to tho probloji,
Anothor point that haa failod to roooivo any oonoidoration is tho fact that
aoa* of tho wator ovpply pipoo for tho Roekott Vator Supply Corporation erooa
tho erook. In tho pact ooow of th« pipoo hare boon brokon during hoavy raina.
If tho orook ia poUvtod, aoaw of thio offluont win bo induofd into tho wator
ayotoa ahould a broak ooour. Wh«n thio oyotoa wao oonotruotod, it is ay nndor-
standing that tho aupply pipoa eovld not bo laid within a oortain •aaim of
foot of a oowago drain or lino, howovor, our objoctlon to tho offluont in tho
erook boeauao of our wator pipoo has boon ignorod.
Tho diaohargo of tho offluont to anothor otroaa in tho aroa vaa Bontionod in
tho roport, howoror, this waa di»*iss«d aa pooing tho aaao probla* u tho uoo
of Rod Oak Crook. But in via* of tho indication fro* V& that tho offluont will
be such that it will enhance tho quality of tho orook water and bo ouoh an
advantage, perhaf* thio ootald bo ajmlrtand furthor. ferhapa tho people on one
of tho other creeks would wolooBS au«h an aaditioa to their eajiomitd1nga« WB
DON'T WART ITI
At tho rate tho town of Rod Oak io growing, wo fool owe tho eyeteB will not
handle the need and tho orook will bo damaged oven
In view of all tho publicity amde in your najao for clean air and pure wator,
we felt you ahould bo ajado aware of tho situation at thiakpoint. Can any
thing else be doaotT
Tory truly youra,
* *
and Mrs. Edward L. Frudo and ir.vaad Mra. Loo frude
R 1 Box 49 Route 1
Palnor, Texas 75152 Palawjr, Texaa
oo : Snvironaontal Protection Agency
Dallas, T«
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ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20242
Water Programs /j(Jg g
Mr. C.E. Spain, Jr., President
Red Oak Creek Landowners Association
Route 1
Waxahachie, Texas 75165
Dear Mr. Spain:
Mr. Kuekelshaus has asked that I bring you up to date on the latest
developments concerning the Rod Oak Creek sewage treatment alternative
proposals. We are aware of your organization's opposition to the
discharge of sewage effluent to Red Oak Creek. You will therefore
be gratified to know that our Regional Office has recommended the
following conditions be incorporated in the construction grant now
being processed for Red Oak.
1. fan amended waste control order shall be obtained from the TWQB.
2. Effluent from the treatment facility constructed by this project
shall be retained or reused with no discharge to Red Oak Creek or
"i ts tr ibu tar \ e s.
3. Effluent from said facility shall be chlorinated as required
to protect the public health in accordance with the requirements of
the Texas State Department of Health and the TWQB.
4. A plan for the implementation of a connection to the Ten Mile
Creek Regional Sewerage System should be submitted at the time
of the completed expansion of this facility in 1978.
The region has further recommended that the irrigation of the golf
course with effluent from the modified treatment system is the most
desirable alternative to the solution of Red Oak's pollution difficulties.
Wo look forward to the successful implementation of this project
mid thank you for the concerted effort and interest of the citizens
of Red Oak.
Sincerely yours,
Deputy Assistant Administrator
for Water Programs
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VIRGINIA E. DUFF
ATTORNEY AT I-AW
FERRIS. TEXAS 78I2B
March 28, 1972
Environmental Protection Agency
Region VI
1600 Patterson,Suite 1100
Dallas, Texas 75201
Gentlemen:
As a resident of Ellis County within the proximity of five miles of
Red Oak Creek for the past forty years, I wish to express my objections to
the discharge into Red Oak Creek of the effluent from a sewage treatment
plant to be located south of the City of Red Oak.
My objections are based on the many uses of the Creek which have been
outlined in detail to you at the previous Hearings, such uses as irrigation,
picnic area, fishing, cattle watering and residential purposes.
Red Oak Creek is one of the most beautiful creeks in our area and
hundreds of pioneers and their descendants have been baptized in its
beautiful white-rock-bottom swimming holes.
I am no chemist or water engineer and can offer no expert testimony
on the damage to be done by the proposal to discharge the effluent into a
stream which leads to the Creek, but I would like for you to take into
consideration from past experience when similar plans have been executed
if they have been successful and have their waters and odors been satis-
factory to the extent that it would be desireable to you to reside on its
banks and enjoy the water as these landowners have been enjoying for these
many years.
Trusting that your decision will be in favor of the landowners along
Red Oak Creek who are fighting so hard to preserve that which is so valuable
and dear to them.
Yours very truly,
ny" ' ' i
Virginia E. Duff
cc: Gen. Wm. D. Ruckelshaus
Consumer P * E Health Service
Department of **°lath, Education & Welfare
?OO n st. S^
-------
March 28, 1972
Environmental Protection Agency
Dallas, Texas
Dear Sirs:
In this day of all this talk about clean air and pollution free streams,
I want to go on record as opposing the discharge of the effluent from the
proposed City of Red Oak Sewage Plant emptying into Red Oak Creek. Not
only would it detur recreation, devalue the property, it would be a step
backward in our effort to keep our streams clean.
Our Commissioners Court passed a resolution, number 4377 dated June 23, 1970,
opposing the pollution of the streams in Ellis County and this order has never
been recended. Attached is a copy of the resolution for your records..
A new sewage plant less than three years old just like the one proposed for
the City of Red Oak is now polluting Grove Creek southeast of Palmer, Texas.
This is enough evidence for me to believe this plant would do the same for
Red Oak Creek.
Very truly yours,
ick Risinger
"County Commissioner
of Ellis County, Precinct I
Palmer, Texas 75152
cc: General William D. Ruckelshaus
Washington, D. C. 20204
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MKIUTI23 OP TIIE COi-ttllS SIGNERS COURT
BL'LXS COUNTY, TEXAS, TUESDAY, JUKS 23, 1970
IN RE': WASTE CONTROL IN TIIE DEAR CREEK AND THE RED OAK CREEK WATERSHED
ORDER it A 37 7
Itotion by Conuuiooionar Ricingor, seconded by Coir^nisrjioner Halcton,
tliat the following resolution ba adopted by the Ellis County Commissioners
Court:
WHEREAS, various* parties are ranking applications to flew oowaga
into the Bear Creek and tho Hod Oak Creek Waternhed arid, WHEREAS, cuch
pl.ctns will pollute tho crooka in the Watershed;
NOW, THEREFORE, 132 I? RESOLVED, the Ellis County Commissioners
Court opposes the granting of such applications and requests eaici parties
ba required to connect to the Trinity River Authority sewage disposal
nyotem,
All thoce in favor say "Ayo." All those opposed, "No." Motion
carried and it so ordered,
(Certified copy to Mr. Paul Barry)
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