United States Region 6
Environmental Protection 1201 Elm Street
Agency Dallas, TX 75270 May, 1980
Enforcement
Environmental Final
Impact Statement
Bleached Kraft Market Pulp Mill
Near Bon Wier, Texas
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906R80104
Final Environmental Impact Statement
on the Issuance of an NPDES
New Source Permit for
Kirby Forest Industries, Inc. Pulp Mill
Near Bon Weir, Texas
May 1980
U.S. Environmental Protection Agency
Region 6
Dallas, Texas
Approved By:
AdTene Harrison
Regional Administrator
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EXECUTIVE SUMMARY
ENVIRONMENTAL IMPACT STATEMENT
The following Executive Summary for the Environmental Impact Statement
on the Kirby bleached kraft market pulp mill should replace that which
appeared in the Draft EIS.
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EXECUTIVE SUMMARY
A. Problems and Issues
The United States Environmental Protection Agency (EPA) is considering
the issuance of a New Source National Pollutant Discharge Elimination System
(NPDES) permit for a treated wastewater discharge from the proposed Kirby
Forest Industries, Inc. (KFI) pulp mill into the Sabine River. The Applicant,
KFI, proposes to construct a 650 tons/day bleached kraft market pulp mill (with
possible expansion to 1,000 tons/day; see Section 3.1.1.2 of DEIS) on a site
1*5 miles west of Bon Wier in Newton County, Texas. Pursuant to the National
Environmental Policy Act of 1969 (PL 91-190 or NEPA), the EPA has prepared
this Environmental Impact Statement (EIS) to evaluate the potential impacts
of the proposed Federal'action on the human environment. The main issues
evaluated in this EIS are:
• The impacts of the treated wastewater discharge on the assimilative
capacity and dissolved oxygen (DO) concentrations in the Sabine
River below Bon Wier;
• The impacts (primary, secondary, and cumulative) of emission of
particulates, sulfur dioxide, and odor on soils, vegetation, and
the public health and welfare;
• The impacts of converting 150 acres of forest land to an industrial
use;
• The impacts of harvesting 32,500 acres of pine and hardwood forests
to supply pulpwood to the mill;
• The impacts on the cultural resources of the project area;
• The impacts on prime and unique farmlands in the area;
• The impacts on the Big Thicket National Preserve;
• The impacts on wetlands in the project area; and
• The impacts on rare and endangered species in the project area.
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B. Environmental Setting
For the purpose of determining environmental impacts caused by the con-
struction and operation of the proposed KFI mill, the influence region has
been defined as Newton County, Texas and Beauregard Parish, Louisiana which
are separated by the Sabine River, the major waterway in the area. Newton
County is essentially rural in character. More than 90% of the land in the
County is forested and the timber and wood products industry represents the
major commercial land use of the area. The area supports a population of
approximately 12,100 persons.
Beauregard Parish, bordering the Sabine River on the east, is commercial-
ly undeveloped, its larger population (27,241 persons) reflecting the presence
of a stronger economic base than found in Newton County. The production of
wood and paper products is the Parish's major industry.
The total employed labor force in the influence region during 1970 was
9,487 persons, with 31% employed in the field of government and services and
24% in manufacturing. This predominantly blue collar working force is ex-
periencing an unemployment rate of approximately 6.5%. Median family income
of persons in the influence region ($6,940 in Beauregard Parish, $5,819 in
Newton County) is generally lower than that of their respective states and
regions. More than 20% of the total families in the region had incomes less
than poverty level during 1970.
Biological characteristics of the Sabine River in the vicinity of Bon
Wier are .determined in part by the operation of the Sabine River Authority's
Toledo Bend Dam. The effects of the dam (including changes in discharge timing
and volume, temperature, and other factors) on the ecology of the Sabine
River are not fully known, but recent studies by the Texas Parks and Wild-
life Department (TPWD, in preparation) and the US Fish and Wildlife Service
(USFWS 1978) indicate that the River in this area supports a diverse fish
population. No long-term data are available for other aquatic organisms,
however. An additional factor which affects the ecology of the River in
this area is the effluent from the Boise Southern mill, which is discharged
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above Bon Wier at Anacoco Bayou. This plant will soon be expanded to approx-
imately three times its current size. Therefore, in evaluating potential
impacts of kraft mill effluents on the River's ecology, future discharges
from both KFI and Boise Southern plants should be considered.
In accordance with Texas and Louisiana water quality criteria, the
lower segment of the Sabine River is classified for contact and non-contact
recreation, fish and wildlife propagation, and domestic water supply. Data
gathered from below Toledo Bend Dam indicate that water quality standards
are generally met. Existing point sources represent a greater potential for
water quality standards violations than does surface runoff because the major-
ity of the land in the lower Sabine River basin is forested. Reported depres-
sions of DO in Bayou Anacoco and the Sabine River just below their confluence
have been attributed to wastewater discharged upstream in the Bayou (URS/
Forrest and Cotton, Inc. 1973).
Fresh, potable groundwater from the Chicot, Evangeline, and Jasper
Aquifers is abundant and of relatively good quality. The Jasper Aquifer
supplies most of the potable water for the Bon Wier area. Groundwater re-
charge of the aquifer in the Lower Sabine basin has been estimated at 500 mgd
by the Texas Department of Water Resources. Total withdrawal by all area
users is estimated at 100 mgd.
All of the proposed site is located in the EPA's Air Quality Control
Region (AQCR) 106 and the Texas Air Control Board (TACB) Region 10. These
regions have been designated as a Class II Prevention of Significant Deter-
ioration (PSD) area. AQCR 106 has been determined to be in attainment with
National Ambient Air Quality Standards (NAAQS), except for certain sub-areas
not in attainment for hydrocarbons and oxidants. Oxidants are regulated by
NAAQS, whereas designations for hydrocarbons are actually guidelines which
are in support of the oxidant standards. The closest non-attainment area
for hydrocarbons and oxidants is Beauregard Parish, Louisiana, approximately
4 miles east of the site. Ambient air quality data for the proposed site are
very limited; however, data available from surrounding areas indicate that
air pollutant concentrations are significantly below NAAQS, except in the
non-attainment areas for hydrocarbons and oxidants.
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Neither Texas nor Newton County has promulgated noise regulations. No
complaints have been recorded to date, however.
No existing cultural resources were identified in the vicinity of the
mill site, a finding verified by the Texas Historical Commission.
C. Alternatives Evaluated
In addition to the economic benefits to be derived from corporate expan-
sion, KFI has determined that it can function more efficiently and approach
total utilization of its raw materials by the construction and operation of
a pulp mill.
The two alternatives originally evaluated included: 1) a 650 tpd bleached
kraft market pulp mill, and 2) the no action alternative (the no-build option,
which would result from a decision by KFI not to build or from denial of the
permit by either EPA or the Corps of Engineers). Because of a several month
delay in the project caused by the need for additional study of the impacts
of the 650 tpd mill, KFI determined that it would be in its best interest to
request EPA to evaluate potential cumulative impacts of the 1,000 tpd plant.
These impacts have been analyzed and are included in the final EIS (see
Section 5.8 of FEIS).
D. The Proposed Project
As a result of a site selection process, the proposed site west of Bon
Wier was chosen. Among other considerations, the availability of abundant
potable water, wastewater assimilative capacity, and raw materials led to
its selection. About 150 acres of the 500 acre site will be utilized for
initial construction activities.
The proposed project is a 650 tons/day bleached kraft market pulp mill
(with possible expansion to 1,000 tons/day; see Section 3.1.1.2 of DEIS). Two
process alternatives are proposed with final selection to be made during the
detailed design stage. Alternative One is a conventional five-stage bleach-
ing process with chemical recovery and reuse. Alternative Two adds oxygen
delignification to the bleaching sequence as the only modification.
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A variety of chemicals will be consumed by the mill for production of
pulp and treatment of water and wastewater. In addition, approximately
286,650 cords of pine wood and 109,200 cords of hardwood chips will be
utilized annually to produce about 650 tons of pulp. Process wastewater and
contaminated stormwater will be treated in a secondary biological treatment
system. Sanitary wastes will be segregated and treated by a package extended
aeration plant and chlorinated. Effluent from both systems will be combined
following treatment and discharged into the Sabine River through a 30-inch
diameter gravity pipeline in the vicinity of River Mile 88 (Figure 3). The 650
tpd mill will discharge approximately 17 million gallons per day (irigd) of treated
effluent containing 3,445 pounds of BOD5, 3,380 pounds of TSS, and 78,000 to
227,500 pounds of color. Potable and process water will be groundwater from
the Jasper Aquifer which has an estimated recharge of 500 mgd. The total
water requirement of about 25 mgd can be adequately supplied from this source
which presently provides 100 mgd to all area users.
Air emissions will be controlled by the latest state-of-the-art air
pollution abatement equipment. New Source Performance Standards will be
the basis for design of air pollution abatement equipment. About 115,000
pounds per day of solid wastes will be generated in the form of sludge,
grit dregs, screenings, ash, and trash and garbage. A combination of treat-
ment, reduction, and disposal methods including sludge lagoons, incineration,
and landfilling will be utilized to manage these wastes.
E. Impacts of Proposed Project
The proposed project will have a minimal impact on the geology, topo-
graphy, and soils of the region. Some minor erosion and siltation as a
result of site preparation activities are anticipated; however, mitigation
of these short-term impacts will be achieved by adequate site design and
construction management procedures.
Mathematical modeling of the Sabine River performed during the develop-
ment of this document indicates that water quality standards (for both Texas
and Louisiana) for the River will not be violated as a result of the proposed
17 mgd treated wastewater discharge even though there will be some increase
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in stream temperature and concentrations of chlorides and sulfates. Under
the most extreme low-flow (worst-case) conditions the model of the River
predicted no concentration of dissolved oxygen below 5.0 mg/1. Additional
water quality modeling was also conducted to evaluate the cumulative impacts
of the 1,000 tons/day KFI mill in conjuction with the.Boise Southern dis-
charge (Appendix 1 of FEIS). The model predicted that water quality stan-
dards would not be violated under any of the conditions tested (including
combined discharges of the KFI and Boise Southern plants under worst-case
conditions). Therefore, the River would have more than adequate assimila-
tive capacity to receive the daily waste load under average flow conditions.
It is predicted that the discharge from the 650 tpd mill will increase the
color of the River from 62 to 73 PCU under two-thirds average flow conditions,
and from 137 to 246 PCU under low-flow conditions. The 1,000 tpd KFI mill
effluent will elevate color levels in the River to a maximum of about 227 PCU
under worst^case conditions and about 9 PCU during average flow (Appendix 1
of FEIS). Although color is primarily an aesthetic characteristic, the poten-
tial for reduction in produtivity due to decreased light penetration during
periods of extremely low flow cannot be completely discounted. However, since
these flow conditions are rare, typical impacts of color increases caused by
the mill will be minimal.
With the exception of odors caused by reduced sulfur and other organic
compounds, the impacts of emissions from the mill on air quality will not be
significant. Because of improved emission control the 1,000 tpd plant will
not exceed TACB standards even under worst-case conditions. However, predicted
3
typical concentrations (60 g/m ) of total reduced sulfur (TRS) produced by
the 650 tpd plant at the mill site are considerably higher than odor thresh-
3
olds, and worst-case concentrations (310 g/m ) of hydrogen sulfide (H2S) due
to mill emissions would exceed Texas Air Control Board standards at the mill's
property line. These TRS emissions (including H?S) are predicted (Sirrine
1977a) to be caused almost entirely by ground-level fugitive sources that
will be effectively controlled. The Big Thicket National Preserve should
not be affected by the proposed mill.
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The proposed mill site and effluent pipeline corridor currently support
second growth forests which are typical of this region of east Texas. Even
though a fairly diverse wildlife community inhabits the site, none of the
species was found to be unusual or uncommon. Construction impacts will re-
sult in the loss of 150 acres of wildlife habitat at the mill site. Although
these 150 acres of second growth forest will be cleared for mill construction,
this is not a significant loss of timber resources or wildlife habitat; there-
fore, no significant adverse impacts are anticipated. The mill will require
wood as follows:
Cords/yr
650 tpd Mill
286,650
109,200
395,850
Expanded Mill-1,000
441,000
168,000
609,000
tpd
Pine (chips)
Hardwood (chips)
Total
No pine will be harvested directly for use in the proposed pulp mill,
since all pinewood consumed will be in the form of chips generated in exist-
ing Kirby-owned plywood and sawmills. Therefore, no direct increase in pine-
wood harvest will be produced by the proposed mill. The mill will produce
an indirect increase of about 10.3% of the total 1977 pine harvest in south-
east Texas. However, pinewood harvest in this area will not exceed growth
because of increasing growth stock and rapidly advancing silviculture tech-
nology. Both the 650 and 1,000 tpd mills will produce direct increases of
hardwood harvest in southeast Texas of 77,200 and 136,000 cords/year, respec-
tively (current hardwood harvest is about 32,000 cords/year, or 44.3% of
growth). However, hardwood harvest will not exceed growth in southeast Texas.
Since there were no cultural or historical resources identified in the
project area, there will be no anticipated impacts on these resources.
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Established land use patterns should not change as a result of the con-
struction and operation of the mill. The influence region is expected to
realize a population increase of about 354 persons as a result of the mill's
operation. Unemployment in the influence region would be temporarily re-
duced by about 1,000 new jobs resulting from mill construction. It is esti-
mated that construction workers residing in the influence region would have
a total family income of $3 to $4 million annually, most of which will be
spent locally. During both construction and operation of the mill, demand
for public services and facilities is not expected to exceed existing capa-
cities. The mill should not cause any adverse secondary impacts on the other
socioeconomic and demographic characteristics of the region.
F. Comments Requested
The Draft EIS has been made available to the following Federal, state,
and local interests for review and comment:
Advisory Council on Historic Preservation
US Department of Agriculture
US Department of Commerce
US Department of Energy
US Department of Housing and Urban Development
US Department of Health, Education and Welfare
US Department of Interior
US Department of Transportation
US Corps of Engineers
International Boundary and Water Commission
Federal Energy Administration
Federal Power Commission
Economic Development Administration
Environmental Protection Agency
viii
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ............... ...... ..... ±
TABLE OF CONTENTS .......................... lx
1.0 INTRODUCTION . . ............. . ..... ..... 13
2.0 REASONS FOR THE PROPOSED ACTION .............. . . 1?
3.0 ALTERNATIVES .................. ........ 19
4.0 DESCRIPTION OF PROPOSED ACTION ...... ........... 29
5.0 IMPACTS OF THE PROPOSED PROJECT ON THE ENVIRONMENT . . ..... 35
6.0 COORDINATION ...... .................... 63
BIBLIOGRAPHY ............................ 65
APPENDICES (DEIS) .......................... 73
7.0 RESPONSE TO PUBLIC COMMENTS RECEIVED ON DRAFT EIS ....... 77
APPENDICES (FEIS) .............. ...... ...... 131
1. WATER QUALITY MODELING OF BAYOU ANACOCO AND SABINE RIVER
(1,000 TON/DAY PLANT) .................... 133
2. TABLES ACCOMPANYING AIR QUALITY ANALYSIS (SECTION 5.8 of DEIS) 171
3 . BIOLOGICAL ASSESSMENT OF FEDERALLY LISTED ENDANGERED AND
THREATENED SPECIES IN THE VICINITY OF THE PROPOSED KIRBY
BLEACHED PULP KRAFT MILL NEAR BON WIER, TEXAS ...... . 179
4. NPDES PERMIT
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1.0 INTRODUCTION
The following list presents page changes in this section of the Draft
Environmental Impact Statement:
Page 1
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1.0 INTRODUCTION
1.1 NEPA/EPA REQUIREMENTS
In 1969, Public Law 91-190, the National Environmental Policy Act (NEPA),
was adopted establishing national environmental policies and goals for eval-
uation of impacts. The provisions of NEPA stipulate that major Federal ac-
t
tions which significantly affect the quality of the human environment be
accompanied by a detailed statement, prepared by the responsible Official,
evaluating the impacts of the proposed action. The Environmental Impact State-
ment (EIS) procedure has developed as a result of this stipulation.
The Federal Water Pollution Control Act, as amended in 1977 (FWPCA,
PL 92-500, as amended by PL 95-217), requires under Section 511(c) that the
provisions of NEPA apply to the issuance of a National Pollutant Discharge
Elimination System (NPDES) permit under Section 402 for the discharge of any
potential pollutant to the waters of the United States by a New Source as
defined in Section 306. The US Environmental Protection Agency (EPA) has
under consideration the issuance of a New Source NPDES permit to Kirby Forest .
Industries, Inc. (KFI) of Houston, Texas, for discharge, of the treated waste-
water from a proposed 650 tons/day (with possible expansion to 1,000 tons/
day;, see Section 3.1.1.2 of the DEIS) bleached kraft market pulp mill to the
Sabine River in the vicinity of Bon Wier, Texas. The EPA has determined that
the issuance of a New Source NPDES permit to. KFI would represent a major
Federal action which could have a significant effect on the quality of the
human environment. Pursuant to the requirements of NEPA, and its authority
under the FWPCA, EPA issued a Notice of Intent (NOI) to prepare an EIS on
June 20, 1978. As a result, EPA published the Draft Environmental Impact
Statement (DEIS) for coordination and review on June 19, 1979. This Final EIS
CFEIS), along with the DEIS, fulfills EPA's responsibilities under NEPA and
the Federal Water Pollution Control Act. The Final EIS contains only those
pages that have required modifications or additions plus the comment letters
received during the public comment period and USEPA's responses to these
comments. The reader is referred to the Draft EIS for a full analysis of
the environmental issues associated with this project.
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It should be noted that all page changes, except for responses to and
letters from the various agencies on the Draft EIS (Section 7.0), have been
paginated as in the Draft EIS. Any additional required pages have been fol-
lowed by a letter designation (la, Ib, Ic). Each text change or addition is
indicated with a line in the left margin. Page numbers for the Final EIS
are indicated in the upper right hand corner.
Section 5.8 has been added to the Final EIS.in order to summarize the
cumulative impacts of the 1,000 tons/day mill.
1.2 THE PROPOSED NEW SOURCE
On October 3, 1977, KFI submitted an application to EPA for an NPDES
permit in accordance with the FWPCA, as amended, for a treated wastewater
discharge from a new bleached kraft market pulp mill. The mill, to be located
in Newton County, Texas (about 1.5 miles west of Bon Wier on Texas Route 363)
la
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2.0 REASONS FOR THE PROPOSED ACTION
This section remains unchanged from the Draft Environmental Impact
Statement.
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3.0 ALTERNATIVES
The following list presents page changes in this section of the Draft
Environmental Impact Statement:
Page 9
11
14
15
23
24
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Effluent from process and sanitary waste streams will be handled
separately in systems designed to meet requirements of the State of Texas
and EPA. Design effluent values employing the Best Available Control Tech-
nology Economically Achievable (BACTEA) are based upon 1983 effluent guide-
lines. The strength of the process wastewater, and thus the required level
of treatment, will be determined when the selection of the bleaching pro-
cess is made. In either case, the wastewater streams will have to be treated
to a sufficient degree in order to meet New Source Performance Standards.
3.1.1.5 Discharge Method and Location
Process and sanitary wastewater effluents will be combined and discharged
into the Sabine River via. a thirty-inch diameter pipeline. The use of an open
ditch from the mill site to the river was considered but rejected in favor of
a buried pipeline because of lower maintenance and operation costs.
The location of the discharge point into the Sabine River will be deter-
mined during the final design phase based in part on engineering and environ-
mental constraints. Both the discharge point and pipeline right-of-way will
be constructed to comply with the Nationwide Permit concept.
3.1.1.6 Residuals Disposal
i
The sources and quantities of all solid wastes to be generated by the
proposed mill are discussed and listed in Section 4.0. KFI proposes to dis-
pose of solid wastes, including sludges from pulping and wastewater treat-
ment processes, in an approved on-site sanitary landfill. All State rules
and regulations for disposal of solid wastes will be observed.
3.1.2 Environmental Impact Analysis of Applicant's Alternative
The following sections summarize the primary, secondary, unavoidable,
irreversible, irretrievable, and short- and long-term environmental impacts,
as well as appropriate mitigative measures of the proposed project as pre-
sented in detail in Section 5.0. Where pertinent, the distinction between
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effluent line would have a more direct impact on surface waters since it
will be built adjacent to Davis Creek and the Sabine River. Both of these
construction activities are expected to have some minor primary, short-term
impacts which are unavoidable but will be controlled by engineering design,
silt dams, and land-conserving construction practices.
Since all stormwater that falls on the mill site once the operation of
the facility begins will be processed through the wastewater treatment sys-
tems, the only surface water to be affected by the operation of the mill
will be the Sabine River. Mathematical modeling of the Sabine River from
Bayou Anacoco to Ruliff, Texas, indicated that water quality standards for
the River will not be violated as a result of the proposed discharge under
average or base flow conditions. Base flow conditions are low flows estab-
lished by the Texas Department of Water Resources about which Texas Water
Quality Standards must be met as an annual arithmetic mean. Base flow is
387.1 cfs at the Bon Wier gage.
The primary impact on water quality at the point of mixing under base
flow conditions will be an increase of less than 1° C in stream temperature
and an increase in stream chloride and sulfate concentrations from 30 mg/1
to 50.3 mg/1 and from 20 mg/1 to 28.9 mg/1, respectively. Texas water quali-
ty standards of 120 mg/1 for chlorides and 60 mg/1 for sulfates will not be
exceeded. DO concentrations in the River between Bayou Anacoco and Ruliff
were projected for several varying flow conditions using a simplified mathe-
matical model. Under base flow conditions, the model predicts no DO concen-
tration below 5.0 mg/1 as a result of the discharge. Because of the small
quantity of disinfected sanitary wastewater in comparison to process waste-
water, the bacterial content of the wastewater will be required by the permit
to be below the 200 coliform/100 ml level which is the standard commonly
applied to domestic discharges. Therefore, there will be no adverse impact
on the River.
Color values in the Sabine River could rise from an existing mean value
of 62 PCU (Platinum Cobalt Units) to a mean value of 73 PCU under two-thirds
average flow conditions (4,563 cfs). During low-flow conditions (Case 2,
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see Section 5.2), mean values could Increase from 137 to 246 PCU. Changes
in biological productivity in the River upstream of the proposed discharge
appear to have occurred after an upstream discharge of highly colored waste-
waters began but these changes cannot be directly related to color. The
River in the vicinity of the proposed discharge could become highly colored
and thus have an adverse impact on aesthetics during low-flow conditions.
This primary impact should not constitute a long-term or significant impact.
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in such a manner as not to cause a nuisance, and in accordance with TACB
Rule 101.
3.1.2.4 Sound Quality
During mill construction activities only daytime ambient sound levels
will be affected (Table 16). These anticipated project-related daytime
sound level increases would be insignificant and should not cause any long-
term adverse impacts. The increase in nighttime sound levels during the
operation of the mill (Table 17) at Fawil and the nearest residence (Figure
14) would be significant and could interfere with sleep and annoy residents
especially during warm weather. The day/night equivalent sound levels at all
three noise sensitive locations (Figure 14) during both construction and
operation of the mill would be in compliance with the EPA "identified level"
requisite to protect the public health and welfare (Section 5.4).
3.1.2.5 Biology
Aquatic Biota
Run-off control practices (Section 4.5.3) will be utilized so that there
should be no significant short- or long-term impacts on aquatic biota due to
mill construction. Any runoff which might occur during the pipeline con-
struction phase could be expected to have only local short-term impacts on
the aquatic life of the Sabine River. The proposed wastewater treatment faci-
lities should prevent violations of water quality standards due to the
effluent, even at low river flows. However, localized reductions in dissolved
oxygen or sporadic toxicity (caused by periodic spills) of kraft mill efflu-
ent (KME) could produce minor impacts on benthic invertebrates, fish, and
plant life in the immediate vicinity of the discharge plume (EPA 1979).
Sublethal physiological effects of treated KME on aquatic organisms could
also occur as a result of low level toxicity and increased color levels, but
these will be minor impacts.
Terrestrial Landscape Types
The proposed mill site currently supports second growth forests which
are typical pinewoods of this region of East Texas. The 150 acres that would
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be irreversibly committed for mill construction would constitute an unavoid-
able adverse impact. However, because of the large quantity of this renew-
able resource, this community is considered an insignificant loss of timber
resources and wildlife habitat and should not affect the short- or long-term
prbductivity of the area.
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Terrestrial Animals
A fairly diverse wildlife community inhabits the site but none of the
species found during the 1978 EPA survey was unusual or uncommon in the Bon
Wier area. Construction and operation of the mill should not have any sig-
nificant short-term or long-term or irreversible impacts on these species.
Endangered Species
Certain species of Federal and State-listed endangered and/or threatened
species of animals are known to inhabit the area. However, impacts of the
proposed project on these species have been determined not to be significant.
Noteworthy Biological Resources
Noteworthy biological resources are defined as any outstanding or highly
valued biological features such as unique wilderness areas, stands of relict
or first growth forest, or trees of unusual size. Such resources also
include wetlands or known occurrence of endangered and threatened species.
Noteworthy biological resources present in the study area include certain
endangered and threatened species and wetlands. Impacts of the proposed pro-
ject on these resources are not expected to be significant (Sections 5.5.1 and
5.5.2).
Timber Resources
KFI's proposed mill will be located in the Southeast Region of Texas and
will result in an additional indirect harvest for the expanded mill of approx-
imately 366,030 cords of pine from this region.
Texas Forest Service projections for the Southeast Region indicate that
no significant effect on pine pulpwood inventory and growth patterns will
result from the proposed mill. In fact, the projections include an average
12.86 MM cu ft/yr of pine harvest set aside for industrial expansions for
the period 1975-1984. This average allocation of 12.86 MM cu ft/yr will
satisfy KFI's needs for the expanded mill in 2.3 years on a cumulative basis.
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3.3 ALTERNATIVES AVAILABLE TO OTHER PERMITTING AGENCIES
i i .. •
The placement of a discharge structure at either,of the proposed dis-
charge points on the Sabine River, as shown in Figure 3, will require a per-
mit from the COE pursuant to Section 10'of the River and Harbor Act of 1899.
In addition, if the COE determines that wetlands are located on the mill site
or that either of the alternative effluent line corridors cross wetlands, a
permit pursuant to Section 404 of the FWPCA, as amended, will be required.
3.3.1 Issuance of COE Permits
The COE must issue both a Section 10 and a Section 404 permit for the
proposed project.
Issuance of the Section 404 permit will proceed under the "Nationwide
Permit" concept for the placement of dredged or fill material as backfill or
bedding for an effluent line. KFI will proceed under the "Nationwide Permit"
concept and they need not formally submit a Section 404 permit application.
The following conditions need to be satisfied for a " Nationwide Permit'1- to
, be applicable (42 FR 13-8:37146-37147, July 19, 1977:
a. "That the discharge will not be located in the proximity of a public
water supply intake."
b. "That the discharge will not occur in areas of concentrated shell-
fish production."
c. "That the discharge will not destroy a threatened or endangered
. species as identified under the Endangered Species Act, or endanger
the critical habitat of such species."
d. "That the discharge will not disrupt the movement of those species
of aquatic life indigenous to the waterbody."
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e. "That the discharge will consist of suitable material free from
toxic pollutants in other than trace quantities."
f. "That the fill created by the discharge will be properly main-
tained to prevent erosion and other non-point sources of pollution."
g. "That the discharge will not occur in a component of the National
Wild and Scenic River System or in a component of State wild and
scenic river system."
3.3.2 Denial of COE Permits
The COE can deny either or both of the required permits. Denial of a
Section 404 permit would require the redesign and rerouting of the effluent
transportation and disposal system to avoid any impact on wetlands, while
the denial of a Section 10 permit would totally preclude the construction of
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4.0 DESCRIPTION OF.THE PROPOSED ACTION
The following list presents the page changes in this section of the
Draft Environmental Impact Statement:
Page 29
32
44
12
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biological systems. The use of oxygen in the bleaching process does have
limitations, however. Some grades of pulp require more chlorine than others,
precluding the use of oxygen. The use of oxygen also requires additional
evaporator, boiler, and pulp washing capacities.
4.3 RAW MATERIAL REQUIREMENTS
The primary raw materials used in the pulp-making process are wood,
chemicals for cooking and bleaching liquors, papermaking additives, and
water. In addition, small quantities of materials such as cotton, linen,
hemp, and flax are used for specialty products; however, the quantities of
these materials are minuscule in comparison to the tonnage of wood used.
4.3.1 Process Wood
I The equivalent of 286,650 cords of pine and 109,200 cords of hardwood
|chips will be required annually by the mill to produce 650 tons/day of pulp.
Of the 422,000 cords, 348,000 will be pine and 74,000 hardwoods. An addition-
's
al 70,000 cords of hogged wood will be required to supplement bark and chip
screenings for power boiler fuel. Hogged wood or wastewood will consist of
cull logs, tree tops, and limbs which are not presently used for pulp produc-
tion. It is anticipated that all hogged wood will come from company owned
or leased land.
All of the mill's pinewood requirements will be supplied from existing
KFI sawmills and plywood mills. The expanded mill will require a total of
168,000 cords of hardwoods to be harvested, 83% of which will come from
Texas. All of the wood will be supplied from within a 100-mile radius of
the mill site. Wood will be delivered by rail or by truck in the form of
chips. A two to three week supply will be maintained at the mill.
4.3.2 Chemicals
The estimated quantities of chemicals to be used at the proposed mill
are shown in Table 1. Most of the chlorine will be utilized in the bleach-
-------
Figure 5 Layout of proposed Kirby Forest Industries Mill, Bon Wier, Texas (Sirrine 1977a).
-------
ing process with small amounts being used for disinfection of potable water
and sanitary wastewaters. The other chemicals will be used in the prepara-
tion of the cooling liquors and in the bleaching process. Unless new pulp-
ing and bleaching techniques are developed, the use of these chemicals will
vary depending upon the demands of the paper market for particular grades of
pulp.
-------
Under average operational conditions, the mill is expected to discharge
17 mgd of treated effluent containing 3,445 pounds of 6005, 3,380 pounds of
TSS, and 227,000 pounds of color (Sirrine 1978) (Appendix 1). Several waste-
water management alternatives and combinations were evaluated to achieve the
required effluent limitations. EPA has identified the best available tech-
nology economically achievable (BATEA) for this type of mill as biological
oxidation with nutrient addition. As a result, the air activated sludge
system was chosen, consisting of screens, aerated grit chamber, equalization
basin,, primary clarification, aerobic biological reactors, secondary clarifi-
••••'"' 'l
cation, and solids handling. During the detailed design phase of the project,
the biological wastewater treatment mode will be selected. If the air acti-
vated sludge process is selected, the system will have to achieve 91.5% and
96.3% removal efficiencies for BOD and TSS respectively. However, the oxygen
activated sludge system would have to remove 88.8% of the BOD and 96.3% of
the TSS to achieve the same effluent quality.
4.5.3 Storm Water Management
Erosion control for storm water runoff during construction will be prac-
ticed throughout the mill. Storm water runoff from the woodyard will be col-
lected in a holding pond where the suspended solids will be allowed to settle.
The decant will then be channeled to natural drainage ditches. Storm water
runoff from the general mill site will be controlled in the same manner with
as many holding ponds as necessary. Where necessary, earthen dikes will be
used to channel runoff away from the site. Dirt roads and exposed soils will
be graded to drain storm water to drainage ditches.
4.5.4 Solid Waste Disposal
Several major categories of solid waste generation at the mill were
Identified. The wastewater treatment process will produce waste biological
and suspended solids, grit, and screenings. Ash and inert solids will be
produced by the power boilers, and grit and dregs from the recausticizing
process. Administrative and supply operations at the mill will produce trash
and garbage.
15
-------
It is proposed that grit and screenings produced by the wastewater treat-
ment process, grit and dregs produced by the recausticizing process, and trash
and garbage be disposed of in an on-site landfill. Waste biological solids,
ash, and inerts will be discharged into a solids retention basin.
16
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5.0 IMPACTS OF THE PROPOSED PROJECT ON THE ENVIRONMENT
The following list presents the page changes in this section of the
Draft Environmental Impact Statement:
Page 59
65
69
90
106
107
108
109
110
111
115
117
119
122
123
17
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released from the bottom of Toledo Bend Reservoir during the summer may
contain only 2 to 4 mg/1 of dissolved oxygen (DO), as well as concentrations
of hydrogen sulfide (I^S) , biochemical oxygen demand (BOD), and chemical
oxygen demand (COD) of 1.8, 4, and 20 mg/1 respectively (Shampine 1971).
Concentrations of iron (Fe) and manganese (Mn) of 1 and 2 mg/1, respectively,
are also found in these oxygen deficient bottom water releases, but these con-
centrations do not persist in the Sabine River for a great distance down-
stream. By the time the pulse reaches Bon Wier, natural reaeration raises
the DO to State standards, precipitates the metals, and strips the H2S.
The salinity difference between the River water and the estuarine
waters of Sabine Lake creates a density stratification or salt wedge in the
lower portion of the River. During low flow periods, this salt water intru-
sion has "occasionally reached water intakes in the Old River on the Louisi-
and side but has never reached" the Sabine River Authority's pumping station
about 20 miles north of Orange, Texas (SRA 1979).
The potential for water quality standard violations resulting from
runoff is very small. The low intensity of land use within the basin is
evident from the estimate that greater than 90% of the land area is forested.
This, in combination with sandy soils and minimal topographic relief, reduces
runoff to approximately 25% of the total precipitation (Gattis, Barber, and
Parker 1976).
Existing point sources of wastewater present a greater potential for
water quality standard violations than does runoff. The 22 mgd Boise Southern
discharge is more significant in terms of its impact on the Sabine River
than the 1.5 mgd Leesville discharge due to its relative magnitude and proxi-
mity to the Bon Wier area. Boise Southern discharges into Bayou Anacoco
15.7 miles upstream of the confluence with the Sabine River.
According to reports by URS/Forrest and Cotton, Inc. (1973) and J.E.
Sirrine Company (1977), instances of severe dissolved oxygen depletion were
observed in Bayou Anacoco and the Sabine River below the Bayou during the
early 1970's. These DO depressions, attributed to the discharge from Boise
18
-------
flow at Rosepine on Bayou Anacoco correlates with a flow in the Sabine River,
at Bon Wier, of 4,520 cfs, which is about 67% of the average annual flow.
The effect of the KFI discharge on DO in the River under base flow
conditions was simulated in Case 2. In this case it was assumed that KFI
' !
would be discharging its full waste load and that Boise Southern would be
discharging half of its present permitted load. This set of conditions was
selected to simulate a critical low flow situation. Actually, flow on the
Bayou at Rosepine would probably not be sufficient for Boise Southern to be
discharging much, if any, of its normal waste load during a period of sus-
tained base flow on the River.
Even under the critical circumstances analyzed in Cases 1 and 2, the
model indicated that there would be no violation of DO standards in the
Sabine River as a result of the proposed KFI discharge (Figures 10 and 11).
Because average flow on the Sabine River is greater than that modeled without
violation in Case 1, a DO analysis was not performed for the average flow
conditions. A more complete discussion of the modeling is included in TSD
Section 2.
The discharge should have an insignificant impact on the suitability of
the River for other uses recommended by the State of Texas. The bacterial
content of the effluent should not be of concern because most of it will be
process water in combination with a small volume of disinfected effluent
from the mill's sanitary facilities.
There are no known drinking water intakes between Bon Wier and Orange
and the only significant water withdrawal is the SRA's pumping station located
2 miles south of Deweyville, Texas, and approximately 50 miles south of the
proposed discharge. Except for the highly colored and aesthetically unappeal-
ing appearance of the River around the effluent outfall, the Sabine River
should continue to be of acceptable quality for contact and non-contact
recreation, and fish and wildlife propagation.
The significance of an increase in color has to be evaluated on a case
by case basis since neither Texas nor Louisiana have water quality standards
19
-------
• color retards sunlight transmission and may interfere with photo-
synthesis, thereby reducing the productivity of the aquatic com-
munity;
• color has effects upon downstream municipal and industrial water
users, such as higher water treatment costs, difficulties with
water treatment, and a multitude of industrial process operating
problems;
• color bodies complex with metal ions, such as iron and copper,
forming tar-like residues which remove the metals from the stock
available to stream organisms for normal metabolism, and the com-
plexes can have direct inhibitory effects on some of the lower
scale of organisms in the aquatic community and thereby reduce the
productivity of the receiving water;
• color derived from lignin, as in the case of paper mill waste, is
an indicator of the presence of potentially inhibitory compounds
and in addition may have direct inhibitory effects upon some of the
lower scale organisms in the food chain;
• color in receiving waters may affect fish movements and fish
productivity;
• color bodies exert a long-term BOD (from 20-60 days up to 100 days)
not measured by the BOD5 test. They are, however, measured as
BODU.*
Ultimate BOD or BODU is the biological oxygen demand that would be
exerted by biological decomposition of a waste if the reaction were
allowed to proceed to completion.
Problems with water quality and with the productivity of the River have
been reported by observers familiar with the River (Appendix 9, Van Conner's
letter), but these problems cannot be directly attributed to the color of the
water. Based on the one-time EPA 1978 field survey and a comparison with
data of previous years, bottom scour from the hydroelectric dam releases also
appears to be a factor affecting benthic productivity. However, fish popula-
tions in the area appear to be normal based on recent studies (TPWD, in
preparation; USFWS 1978) . Nevertheless, the potential for reductions in
productivity due to decreased light penetration or avoidance of highly colored
areas by fish under worst-case low-flow conditions cannot be completely
discounted.
20
-------
In summary, it can be concluded that under low flow conditions, the .
proposed KFI discharge may cause a large increase in the color of the Sabine
River,. However, this should not constitute a long-term, significant adverse
impact on water quality. .
21
-------
Based on these predictions, if 25% (by weight) of emitted TRS were
assumed to be H_S, the worst-case property line concentration of H_S would
exceed the TACB H.S standard for land not used for residential, commercial,
or business purposes (Table 15). The worst-case property line concentra-
3 3
tion of H.S of 310 yg/m would exceed the 180 yg/m TACB standard by approxi-
mately 70%. However, to obtain a construction and operating permit the mill
must be designed to meet all TACB standards in order for the facility to be
consistent with the Texas Air Pollution Implementation Plan.
The predicted worst-case TRS level at Highway 363 (460 yg/m ) is sig-
nificantly greater than odor threshold levels of emitted reduced sulfur com-
3
pounds (Table 15), and the predicted typical-case TRS concentration (12 yg/m )
is of the same magnitude as the odor threshold levels. Consequent odors may
usually be expected at Highway 363 when the wind is from the southern quadrant
(approximately 25% of the time). Based on predicted TRS concentrations at
the Sabine River, odors may be expected there approximately 4% of the time
(Odors may occur there when the wind is from the southwest through northwest
quadrant, the wind speed is less than 10 ft/sec, and the atmospheric stabi-
lity is neutral or stable).
Impact on the Air Quality of the Big Thicket National Preserve
Operation of the proposed mill will not have a significant effect on the
air quality of the Big Thicket National Preserve. According to dispersion
modeling, Class I PSD increments for SO- and TSP will not be exceeded at dis-
tances greater than approximately 20 miles from the mill. The mill will be
more than 27 miles from the Preserve. Therefore, even though the predominant
wind direction is from east to west, toward the Preserve, the distance of
the mill from the Preserve would be too great for significant S02 and TSP
concentrations to occur. The impact of emissions on atmospheric visibility in
the Preserve, however, would be attributable to both direct particulate
emissions and to conversion of a portion of the emitted SO. to particulate
sulfate during transport in the atmosphere. (Conversion of SO. is potentially
significant here, but not closer to the mill, because of the long atmospheric
transport time required for emissions to reach the Preserve.) However, if all
emitted SO- were converted to particulate sulfate (which is highly unlikely),
22
-------
the total TSP impact at the Preserve would not exceed the Class I increment.
Thus, sulfate formation will degrade neither the quality of the Preserve's
air not its atmospheric visibility as protected by the Class I increments.
-------
Table 20. A comparison of fish species. collected during
recent surveys of the Sabine River and Quicksand Creek.
Longnose gar
Threadfln shad
.River carpsucker
Spotted sucker
Silvery minnow
Golden shiner
Pallid shiner
Emerald shiner
Ghost shiner
Red shiner
Sabine shiner
Weed shiner
Blacktail shiner
Mimic shiner
Pugnose minnow
Suckermouth minnow
Bullhead minnow
Blue catfish
Channel catfish
Freckled madtora
Suttkus
& Gunning1
1969
2
1
1
43
2
28
1
11
447
63
43
191
34
19
1
246
51
Blackspotted topminnow
Mosquitoflsh
Pirate perch
2
. River River
Mile 92 Mile 88
Suttkus Van EPA EPA
& Gunning2 Conner Survey4 Survey5
1970 1961-1971 1978 1978
1
13 *
26
205 ** 6
27 *
8
41 *
621 **
186 ** 9
134 **
1605 ** 250 5
118 **
18 *
274 **
1
24 *
1 1
1
1 24
Quicksand
Creek
EPA
Survey**
1978
4
15
17
1
14
1
4
-------
Table 20. Fish species (continued).
River
:Mile 92
Suttkus & Suttkus & Van EPA i
Gunning^- Gunning Conner Survey
1969 1970 1961-1971 1978
River Quicksand
Mile 88 Creek
EPA c
Survey"
1978
EPA
Survey*
1978
Striped mullet 2
Brook silverside 1
Green sunfish
Orangespotted sunfish 2
Bluegill
Longear sunfish 7
Redear sunfish 2
Spotted bass 7
Largemcuth bass 1
White crappie 5
Black crappie
Western sand darter
Scaly sand darter 7
Bluntnose darter
Cypress; darter
Dusky darter 5
4
2
1
18
2
26
2
1
6
31
4
12
**
**
11
**
3
2
2
1
Hogchoker 1
Total Species 28 31 9
Total Fish 1226 3414 293
13
66
1,, Suttkus and Gunning 1969. Collections were made at 7 stations on Bayou
Anacoco and 7 stations on the Sabine River. The data presented in
column "1" were collected at RM 92 just upstream from the AT&SF Railroad
Bridge (Figure 5.8). A 10 foot seine was used for 3 hours.
2,, Suttkus and Gunning 1977. As above.
3. Dr. Van Conner has conducted several surveys on this section of the Sabine
River and was a consultant on the 1978 EPA sponsored survey (Appendix 10).
Species marked with one asterisk were "common;" species marked with double
asterisk were "abundant" in previous surveys by Dr. Conner.
25
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Table 20. Fish species (continued).
4. EPA 1978 survey. A thirty-foot seine was used for three hours at the
Railroad Bridge Station.
5. River Mile 88 at proposed discharge point. Only one school of shiners
was observed here. Seining efforts would not have been productive and
none were carried out.
6. Quicksand Creek. The first 100 yards of this creek were seined for one
hour.
26
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weekly basis during summer, benthic organisms may become stranded above the
high water line, become desiccated, and die. The absence of normal seasonal
water levels also prevents aquatic macrophytes, and invertebrates that may
be associated with them, from becoming established.
The rapidly changing flows appear to have altered the composition of
benthic substrates in the River to some degree (Conner, Appendix 9 of DEIS).
Few gravel bars were observed during the 1978 survey, and those observed
were partially covered with sand. Rapidly changing flows probably produce
a pattern of alternating erosion and deposition. The constant covering and
exposing of the gravel beds may discourage the establishment of benthic
macroinvertebrates.
Fish species richness and relative abundance were lower than those
reported in previous studies. Suttkus and Gunning (1970) noted that the
red shiner was the most abundant fish at a location north of the Railroad
Bridge (Figure 15) during the July 1969 survey (Table 20). In July 1970,
134 weed shiners, 118 mimic shiners, and 274 bullhead minnows were collected
at the same location. None of the above species was found in October 1978.
The location north of the Railroad Bridge (Figure 15) was fished with a 10-
foot: seine for three hours during the 1969 and 1970 surveys. A 30-foot
seine was used for three hours in 1978, and less than 10% of the 1970 catch
was collected.
Differences in fish abundance and diversity observed in the 1978 EPA
study and previous studies could be related to large seasonal or between-
year variations.in fish distribution which commonly occur. These differences
could have been heightened by a one-time sampling effort. Conner (Appendix
9 of DEIS) indicated that the low diversity and abundance of fish observed
during the October 1978 survey could have been caused by the "highly disturbed"
nature of the River. However, he concluded that only additional sampling
could confirm this hypothesis. Subsequent studies by the TPUD in this por-
tion of the River have shown that diverse fish populations exist in the area
(Appendix 3 of the FEIS).
During the 1978 EPA.survey the Sabine River just upstream from Bayou
Anacoco was clear, low in turbidity, and had a Secchi disc reading of over
2?
-------
6 feet. The Bayou water was fairly clear but was colored very dark
brown, and gave off a distinct odor. Although the Secchi disc could still
be read at a depth of 16 inches, this reading is not definitive because the
disc was on bottom at that point.
26
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During the 1978 survey, fish were more abundant in the uncolored and
slightly turbid water of Quicksand Creek than in the brown water of the
River. Many species previously recorded in the Sabine River—weed shiner,
mimic shiner, pugnose minnow, and bullhead minnow—were only collected from
Quicksand Creek in 1978.
Aquatic Birds
There are many resident species of aquatic birds in the project area,
but most birds are migratory. A list of resident birds which are associated
with the river habitat is provided in Table 20a. In addition to these
species, numerous ducks, geese, and other birds use the River as a flight
path during autumn. Aquatic birds should normally play an important role
in the ecology of the Sabine River. The almost complete absence of aquatic
birds on the River during the October 1978 survey can probably be attributed
to the reduced fish population at the time of sampling.
Local farm ponds were observed to support wading bird (little blue
heron, great egret) and migrating shorebird (solitary sandpiper, greater
yellowlegs, piping plover) populations; however, the River was nearly .
deserted. Only one spotted sandpiper and one great blue heron were observed
during the October 1978 EPA field studies.
Wood ducks, the only waterfowl commonly nesting in the Bon Wier area,
were observed on Bayou Anacoco. Since the River is not suitable habitat for
wood ducks, and most are found in the tributary streams and ox bow lakes,
the discharge from the proposed mill should not impact breeding waterfowl
populations.
29
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Table 20a. Birds which are associated with the aquatic
habitats of the Sabine River.
Common Name
Wood duck
Mallard
Green-winged teal
Hooded merganser
Solitary sandpiper
Belted kingfisher
Bank swallow
Water pipit
Killdeer
Scientific Name
Aix sponsa
Anas platyrhynchos
Anas crecca
Lophodytes cucullatus
Bartramia longicauda
Meaceryle alcyon
Riparia riparia
Authus spinoletta
Charadrius vociferus
Source: Brazda and Lark 1978.
30
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Aquatic Mammals
Two species of aquatic mammals, the river otter (Lutra canadensis) and
the American beaver (Castor canadensis), are known to inhabit the Sabine
River (Brazda and Lark 1978). Neither was observed during the October 1978
survey, probably because of the very low water levels.
Aquatic Reptiles
Several species of aquatic reptiles are known to inhabit the Sabine
River (Brazda and Lark 1978). These include the green water snake, diamond-
back water snake, water snake, Sabine map turtle, Mississippi mud turtle,
common snapping turtle, and the American alligator. The dominant reptile
observed in 1969 and 1970 (Suttkus and Gunning 1969, 1970) was the smooth
soft-shelled turtle, which feeds on shrimp and crayfish. In the 1978 sur-
vey only one individual was observed. The false map turtle and the razor-
backed musk turtle were the most abundant reptiles observed during the 1978
survey. \
Other Noteworthy Biological Resources
In 1969 the Texas State Legislature directed the Texas Parks and Wild-
life Department (TPWD) to determine the feasibility of establishing a "scenic
waterways" system. In 1972, the 62nd Legislature directed the TPWD to iden-
tify candidate rivers and to "present a reasonable course of action by which
a waterway system could be established." The study, which TPWD published in
1973, defines the stretch of the Sabine River from Toledo Bend Dam or Orange
as a scenic river (Belisle and Josselet 1973). Paragraph III of the "findings"
chapter of the study also lists several rivers, including this section of the
Sabine, that "should be given high priority for preservation consideration."
This section of the River will also be listed as a recommended scenic water-
way in the 1980 Texas Outdoor Recreation Plan (in preparation).
31
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5.5.1.2 Impacts on Aquatic Ecosystems
Construction Impacts
Since the proposed site is about 4 miles from the Sabine River, no
construction runoff is anticipated. Davis Creek is about half a mile from
the site, but if accepted siltation and runoff control practices are
utilized, the Creek should not be significantly affected. Construction of
the discharge structure may cause some siltation in the River, but the
effects on aquatic animals should be localized and of short duration.
Operation Impacts
Wastewater discharges from the proposed mill should not cause a viola-
tion of Texas water quality criteria even under worst-case conditions. No
wastes will be discharged in toxic quantities although sporadic variations
in KME toxicity could occur due to periodic spills (EPA 1979). Therefore,
potential toxic impacts of KME from the proposed mill could occasionally
occur. These would be of short duration and localized around the immediate
area of the discharge plume, however, and are only expected to produce minor
impacts on aquatic life. Sublethal effects of treated KME, including physio-
logical effects on fish, benthic invertebrates, and algae, could also occur
(EPA 1979) as a result of discharge of very low amounts of toxic materials
and elevated color levels, but these are expected to be only minor impacts.
5.5.2 Terrestrial Habitats and Biota
5.5.2.1 Existing Environment
Much of the land in the assessment area was in agricultural production
until the 1930's (Gibson et al. 1977). Most of the trees on the mill site
were less than 50 feet tall, although several black gum trees were estimated
to be over 80 feet tall. Most of the forest land along the pipeline right-
of-way is managed for lumber and pulp products.
32
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Forest management practices limit natural succession on land that will
be affected by the proposed mill. Naturally occurring upland forests of
this area are dominated by longleaf and loblolly pine with common associates
being oaks and other hardwoods. The natural ecosystem was fire-maintained
(Dan Lay, TPW, personal communication); however, current silvicultural manage-
ment practicds preclude the presence of ground fires on newly cleared lands
and, as a consequence, fire-resistant longleaf pine seedlings cannot compete
with the faster growing loblolly pine.
33
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flooding by a stream. Watson (1975), who described a similar plant community
in the Neches River drainage area, called such poorly drained upland areas
"baygalls." The edges of the plant site conform fairly well to her descrip-
tion.
Vegetation of the Pipeline Right-of-Way
The pipeline transect will cross approximately 4 miles of changing,
forested landscape between the plant site and the Sabine River. The width
of the right-of-way has not been finalized, but it is expected to be 25 or
100 feet. The exact route has not been determined, but it was possible to
identify representative vegetation at several points that will be near or
within the final right-of-way.
The transect will cross a mature bottomland forest. Dominant species
in this forest were water oak, willow oak, swamp chestnut oak, and black gum
with sweet gum, white oak, overcup oak, and beech as common associates.
Scattered bald cypress trees were observed in the streambed or on shore.
Specified wetland areas have not been determined since the final discharge
.pipeline route is not known; however, since KFI will proceed under the Nation-
wide permit concept, no significant impacts on wetlands are expected
(Section 3.3.1).
Terrestrial Animals
During the July 1978 EPA survey, reptiles observed included the fence
lizard, box turtle, black racer, and cottonmoUth. Amphibians encountered
included the squirrel tree frog, green tree frog, northern cricket frog,
southern leapord frog, green frog, and pickerel frog; no salamanders were
found. Several deer were sighted, along with armadillos, opossums, cotton-
tail rabbits, raccoons, and gray squirrels. No small mammal trapping was
undertaken. A complete list of species observed is given in Table 22. These
are considered to be animals that are typical of this area.
A bird survey was conducted on the proposed site from 5:45 am to
9:45 am on July 11, 1978. All birds seen or heard while walking over a
-------
50-acre rectangular transect were counted (Table 23). Because several birds
heard were calling from some distance, the area sampled probably equalled
70 acres. Also counted were birds whose presence was indicated by tracks
and/or feathers (cattle egret, screech owl).
A total of 122 individuals and 29 species were counted during the survey
(Table 23). Dominant species recorded were cardinal (18), Carolina wren (13),
white-eyed vireo (130), and pine warbler (12). A density of 1.74 birds/acre
was found during 1978 which compares well with Debetaz (1978) who reported
1.92/acre of breeding birds in a similar area nearby. Although the breeding
season was ending, one active hooded warbler nest was found. The results of
this single study are merely indicative of the avifauna present and should
not be considered definitive. Most birds in the study area are forest inhabi-
tants; few grassland or urban species are present. Most are either summer
or winter migrants (Sirrine 1977a) which time their migration to coincide with
periods of plant and insect abundance. Some migrants would be expected to
breed in winter on the project site, whereas resident birds breed and nest
in pine forests and bottomland areas. Resident birds are either predatory
(hawks, owls), insectivorous (woodpecker, nuthatch, warbler), or ominivorous
(quail, turkey, bluejay). Migrants are usually almost exclusively insecti-
vorous.
Endangered Species
During the July 1978 EPA site survey, special efforts were made to
locate and identify endangered animals and plants. Similar efforts were
made when terrestrial studies were conducted previously for KFI's environ-
mental assessment (Sirrine 1977) . No endangered or threatened species were
found on the proposed mill site in either survey.
Plants
Table 24 lists the endangered species of plants which may be found in
Newton County, Texas. This list was excerpted from the "Texas List," com-
piled by the Rare Plant Study Center of the University of Texas at Austin.
35
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This list comprises the "Texas List" of endangered plants and it includes
plants on the Federal list. However, Table 24 contains only those species
which might be found in Newton County, Texas.
Four endangered species—sedge, weak rush, sword-leaf panic grass, and
minor nutrush—are wetland inhabitants. As no wetlands occur on the proposed
site, these species will not be affected by mill construction or operation.
These species are fairly widespread and somewhat common outside of Texas
(Radford et al. 1968). The pyramid magnolia, a swamp-dwelling species, was
not found on the mill site.
36
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Table 24. Endangered species which could occur
near proposed KFI mill, Bon Wier, Texas.
Common Name
Plants: Atlantic sedge
Digital sedge
Yellow lady's slipper
Purple bluet
Weak rush
Pyramid magnolia
Sword-leaf panic grass
Tall rattlesnake root
Barbed rattlesnake root
Bloodroot
Texas sunnybell
Minor nutrush
Eared goldenrod
Oval lady's tresses
Silky camellia
Slender gayfeather
Animals: Eastern cougar
Red wolf
Houston toad
Bald eagle
Peregrine falcon
Eskimo curlew
Interior least tern
Ivory-billed woodpecker
American alligator
Red-cockaded woodpecker
Paddlefish
Blue sucker
Scientific Name
Carex atlantica
Carex digitalis
Cypripedium calceolus
Hedyotis purpurea
Juncos debilis
Magnolia pyramidata
Panicum ensifolium
Prenanthes altissima
Prenanthes barbata
Sanguinaria canadensis
Schoenolirion texanum
Scleria minor
Solidago auriculata
Spiranthes ovalis
Stewartia malcodendron
Liatris tenuis
Felis concolor
Canis niger
Bufo houstonensis
Haliaeetus leutocephalus
Falco peregrinus
Numenius borealis
Sterna albifrons
Campephilus principalis
Alligator mississippiensis
Picoides borealis
Polyodon spathula
Cycleptus elongatus
Source: Texas Parks and Wildlife Code. 1977. Regulations for taking,
possessing, transporting, exporting, processing, selling, or
offering for sale, or shipping endangered species. Section
127.30.09.001-.006. Austin TX, 1 p.
37
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paper mills. The proposed pulp mill will utilize all of KFI's pulpwood
harvest and all wastewood not needed for fuel or particle-board production
(Sirrine 1977b). KFI has no multi-year pulpwood sales contracts and the
company has no plans for continuing to supply non-company paper mills after
the proposed mill becomes operational (By phone, J.R. Woods, KFI, 1978).
In the early 1950's, KFI began an intensive program of pine cultivation.
The first of these "pine plantations" is now mature and the amount of har-
vestable wood per acre exceeds yields from natural stands. Consequently,
KFI has been able to increase their annual allowable cut per acre by 205%
over the last 25 years. Improved forestry practices, such as genetic
research and fertilization, will continue to increase the forest yield in
the future (KFI 1978).
In 1977 KFI harvested 130,000 cords of round-wood pulp stock. An
additional 90,000 cords were sold as chips and wood waste (By letter, J.B.
Webster, KFI, 1978a). The proposed mill at Bon Wier will require 422,000
cords of process wood annually, a 92% increase over the 1977 harvest, but
only 156,000 cords will be cut as round-wood. The rest will be made of chips
and sawdust. A third lumber/plywood plant is under construction which will
further increase KFI's demand for saw-timber, but will also increase the
supply of chips and sawdust.
In 1977, 93.3% of the annual pine growth in the southeast section of
Texas was harvested. Harvest trends from 1975-1977 follow:
HARVEST TRENDS
Growth Harvest Harvest as Per-
Year Species Group (Million cubic feet) cent of Growth
1975 Pine 299,0 234.7 75.5
1976 Pine 301.8 269.2 89.2
1977 Pine 303.6 283.2 93.3
Texas Forest Service TRASK Program for Southeast Texas, College Station, TX.
-------
Preceding 1977, a considerable amount of plant expansion and new
plant construction occurred in Texas. This has slowed considerably.
KFI's proposed mill's wood requirements of 23.4 million cubic feet per year
is approximately 0.4% of the standing inventory in 1975. The projected
consumption should not cause harvest to exceed growth since advances in
silvicultural practices will result in growth rates considerably greater
than in the past.
5.5.2.2 Impacts on Terrestrial Ecosystems
Construction
Plants
Approximately 150 acres of second growth pinewood-hardwood forest will
be cleared for construction of the proposed mill. This is an irretrievable
loss of habitat and timber production, but the mill site and pipeline cor-
ridor vegetation was not found to be unique to either the assessment area
or the influence region. Plant communities do not represent a "noteworthy
biological resource" and the construction of the mill will not threaten the
overall plant community of the assessment area or influence region.
Initially, all hardwood will be removed and pine seedlings encouraged.
Should pine production prove to be low, the site might be clear-cut and
replanted. Therefore, many and perhaps all of the trees on the site will
be cut, even if the mill is not constructed.
Land cleared during construction will be replanted as soon as possible
to prevent soil erosion, and any construction or access road rights-of-way
will be cut with tree conservation in mind. KFI has agreed to route the
pipeline around existing wetlands. If the pipeline must be constructed across
a wetland, KFI will proceed under the Nationwide Permit concept, which will
minimize impacts on wetland values and functions (Section 3.3.1).
39
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Animals
The forest removed for construction represents a loss of habitat for
terrestrial animals and these species will have to suffer impacts of the
limited capacity of adjacent areas. No rare, endangered, or uncommon
species of vertebrates were observed in the assessment area.
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5.8 CUMULATIVE IMPACTS OF PROPOSED MILL
In July 1979, EPA issued the draft EIS (DEIS) on Kirby Forest Industries
(KFI) proposed bleached kraft market pulp mill to be located near Bon Wier,
Texas. The facility was proposed to have an initial capacity of 650 tons/
day (tpd) with provision for future expansion to 1,000 tpd as described in
the DEIS. Comments on the DEIS required that additional analyses be per-
formed in order to draft adequate responses as determined by EPA. When it
was determined that additional work would be required which would result in
delaying the issuance of the final EIS (FEIS) for several months, KFI deter-
mined it to be in its best Interest to request EPA to evaluate the potential
cumulative impacts of its facility at the future projected 1,000 tpd capacity
rather than 650 tpd.
Subsequently EPA determined that there would be cumulative impacts only
in the following areas which should be addressed in the FEIS:
• Water Quality
• Air Quality
• Wood Resources
• Aquatic and Terrestrial Biology
The following sections present the anticipated impacts as a result of the
mill's daily production being increased from 650 to 1,000 tpd. From the
inception of the project the proposed layout of the mill was planned to
produce 1,000 tpd. The original plot plan included provisions for all the
equipment necessary to increase pulp production from 650 to 1,000 tpd with-
out requiring the utilization of additional lands.
5.8.1 Water Quality
Cumulative impacts of discharges from both the 650 and 1,000 tpd on
the water quality of the Sabine River were determined using mathematical
water quality modeling techniques (Appendix 1 of FEIS, Section 2.1 of the
DEIS Technical Support Document). Parameters examined included dissolved
-------
oxygen, BOD , chloride, sulfate, and color. The area modeled included Bayou
Anacoco from Rosepine to its mouth and a portion of the Sabine River from
Bayou Anacoco to Ruliff. Existing water quality data were employed in this
analysis and in the model calibration effort. It was determined that dis-
posal of kraft mill effluents will have a relatively minor impact on existing
water quality in Bayou Anacoco and the Sabine River, and that water quality
standards should not be violated. Under worst case low-flow conditions the
KFI mill is expected to increase color levels in the River by Til PCU
(Appendix 1 of FEIS). However, this will be a relatively uncommon occurrence,
and under average flow the color levels of the River will be elevated by
only 9 PCU.
The Boise Southern mill will only increase color levels of the River
by approximately 9 PCU under average conditions and by 227 PCU under worst-
case conditions (Appendix 1 of FEIS). The overall cumulative impacts of
discharges from the KFI and Boise Southern mills on color levels of the River
will therefore be minor, except under extreme low-flow conditions.
5.8.2 Air Quality
With the exception of odors caused by reduced sulfur and other compounds,
.the primary unavoidable adverse impact of emissions from the 1,000 tons/day
mill on air quality will not be significant. The National Ambient Air
Quality Standards (NAAQS), established to protect the public health and wel-
fare with an adequate margin of safety, will not be exceeded (Table 1,
Appendix 2 of FEIS).
Prevention of Significant Deterioration (PSD) requirements have been
established by EPA to prevent deterioration of the ambient air quality to
levels approaching the NAAQS in areas that have ambient air quality better
than the standards. PSD requirements are discussed further in Section
5.3.1.3 of the DEIS. Increases in ambient concentrations of sulfur dioxide
and particulate matter caused by emissions from the 1,000 or 650 tpd mill
will be less than 17% of the PSD Class II increments and will not exceed
the TACB regulations regarding increases in ambient pollutant concentrations.
Thus, there should be no significant secondary short- or long-term impacts
on the air quality of the area.
-------
In addition, the operation of the mill will not have a significant
impact on the air quality of the Big Thicket National Preserve. Dispersion
modeling has indicated that even though the predominate wind direction is
toward the Preserve, the distance from the mill to the Preserve in compari-
son with quantity of emissions is too great for significant impacts to
occur. Even though no air quality standards will be violated, there would
be a slight malodor associated with the operation of the mill which will have
a negative aesthetic impact.
Major plant emission sources and their respective emission control sys-
tems were discussed in the DEIS. Some uncertainty remains regarding the
plant power boiler, since the Applicant has not determined whether the
boiler will utilize wood or coal as the basic fuel. The maximum emission
rates for either boiler fuel are listed in Table 2 (Appendix 2 of FEIS)
along with emissions data for other plant units. Table 3 (Appendix 2 of
FEIS) provides the physical characteristics of all emission sources. The
proposed 1,000 tpd plant will meet the more restrictive of either EPA or
TACB emission regulations (Appendices 1 and 2 of DEIS).
Using the modeling techniques described in the original DEIS, the maxi-
mum predicted ambient levels of SO- and TSP including plant impacts are
expected to be approximately 10% and 50% of National Ambient Standards for
SO- and TSP, respectively (natural background TSP levels in the area account
for most of the current ambient levels). Plant impacts on ambient NO., CO,
NMHC, and 0_ concentrations will be insignificant. A comparison of predicted
plant impacts and PSD requirements is provided in Table 4 (Appendix 2 of
FEIS). A similar comparison of ambient air quality levels and NAAQS is pro-
vided in Table 1 (Appendix 2 of FEIS).
A summary of predicted TRS and H.S ground level concentrations which
result from plant operations is provided in Table 5 (Appendix 2 of FEIS) .
Assuming that 25% of the total TRS emissions are H^S, the calculated impact
at Highway 363 of 146 migrograms per cubic meter is approximately 81% of the
TACB standard. Impacts calculated in the vicinity of the Sabine River indi-
cate that some odor will occur when winds blow from the southwest, west, or
northwest.
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5.8.3 Wood Resources
Operation of the proposed 650 or 1,000 tons/day mill will not require
any direct increases in the harvest of pine-pulpwood. The mill will utilize
waste chips generated in KFI's existing plywood plants, so that there would
be no cumulative impacts of the mill on existing pinewood resources in the
influence region (i.e., this harvest would occur whether or not the proposed
mill were built). KFI will have to increase its hardwood harvesting from
32,000 to 109,000 cords/year for the 650 tons/day plant to meet the require-
ments of the new mill. The 1,000 tons/day plant would increase hardwood
harvest to 168,000 cords/year. However, this will not cause harvest to exceed
growth in southeastern Texas.
5.8.4 Aquatic and Terrestrial Biology
No air or water quality standards will be violated due to the operation of
the expanded KFI mill alone, or in combination with the expanded Boise Southern
plant. Elevated color levels will be produced by the KFI mill under extreme
low flow conditions, but color levels under average flows will increase only
slightly. Therefore, no significant cumulative air and water quality related
impacts are predicted as a result of operation of the 1,000 tpd KFI mill.
Also, since no direct increase in pine-pulpwood harvest will occur as a
result of the expanded mill, no cumulative ecological impacts on wildlife
are expected. The increased hardwood harvest (from 32,000 to 168,000 cords/
yr) which would result from the operation of the 1,000 tpd mill will
increase the percentage of hardwood growth removed from the influence region
(currently 44.3% of total hardwood growth is being harvested). However,
since harvest will not exceed growth, impacts of increased hardwood removal
will not have significant impacts on terrestrial wildlife.
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6.0 COORDINATION
This section remains unchanged from the Draft Environmental Impact
Statement.
-------
BIBLIOGRAPHY
The following list presents the page changes in this section of the
Draft Environmental Impact Statement:
Page 154
155
156
157
158
159
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BIBLIOGRAPHY
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-------
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f
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. 1975c. Population and economic base study.
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Wildlife, 9 July 1978.
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kraft mill effluents, a manageable problem. TAPPI 60(9):135-137.
-------
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expenditures and operating costs for 1976, Special report ho. 77-06.
New York NY, 9 p.
National Industrial Pollution Control Council. 1971. Wood products, Sub- •
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Potter, F. 1979. Letter, Floyd Potter, Texas Parks and Wildlife Department,
20 August 1978.
Radford, Albert E., Harry E. Ahles, and C. Ritchie Bell. 1968. Manual of
the vascular flora of the Carolinas. University of North Carolina Press,
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Regional Planning Division, Deep East Texas Council of Governments/Economic
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Texas Region. Jasper TX, 76 p.
Reid, George I< 1961. Ecology of inland waters and estuaries. Reinhold
Publishing Co., New York NY, p. 101.
Sabine River Authority of Texas. No date. Information packet. Variously.
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and Bayou Anacoco, Louisiana and Texas. Sabine River Compact Administra-
tion. Baton Rouge LA, 36 p.
Sinclair, Ralph M. 1971. Annotated bibliography on the exotic bivalve
Corbicula in North America, 1900-1971. US Environmental Protection
Agency, Water Quality Office, Cincinnati OH.
J.E. Sirrine Co. No date. Proposed plot plan. 1 sheet.
. 1977a and 1977b. Environmental assessment for proposed
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TX.
. 1978. Environmental assessment for proposed 650 tons per
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Sabine River. New Orleans LA, 33 p.
. 1970. Biological survey of the Sabine River. New Orleans
LA, 18 p.
49 .
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Swift, L.K. 1976. An engineering approach to pulp mill odorous emission
containment. Technical Association of the Pulp and Paper Industry
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1978b. Statweide monitoring network, Selective data
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50
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51
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52
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53
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APPENDICES (DEIS)
The following list presents the page changes in this section of the
Draft Environmental Impact Statement:
Pages A-ll
A-12
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Appendix 1
US-EPA New Source Performance Standards
As applied to Proposed KFI Mill Bon Wier, Texas
Wood Residue and Oil-Fired Boilers - Promulgated (40 CFR 60:D)
• Particulate Matter - 0.18 g/10 cal (0.1 lb/10 Btu)
24.0 kg/hr (53 Ib/hr) @ 133,500 cal/hr (530X106Btu/hr) heat input
• Visible Emmissions - 20%
• Sulfur Dioxide - 1.4 g/10 cal (0.8 lb/106 Btu)
187 kg/hr (424 Ib/hr) @ 133,500 cal/hr (530X106Btu/hr) heat input
• Nitrogen Oxides - 0.54 g/106cal (0.3 lb/106 Btu)
72.1 kg/hr (159 Ib/hr) @ 133,500 cal/hr (530X106fitu/hr) heat input
Kraft Pulp Mills - Proposed (40 CFR 60:BB)
• Particulate Matter
Recovery Furnace - 0.11 g/dry normal cubic meter (0.044
grains/dry standard cubic foot) or (45.5 kg/hr)
(100 Ib/hr)
Lime Kiln - 0.30 g/dry normal cubic meter (0.13 grains/dry
standard cubic foot) or (24 kg/hr)
(52 Ib/hr)
Smelt Tank - 0.15 kg/metric ton (0.3 Ib/short ton) of air
dried pulp or 9.7 kg/hr (21.5 Ib/hr)
• Opacity - 35% for recovery furnace
• Total Reduced Sulfur (TRS)
Digester system, brown stock washer system, multi-effect
evaporator system, condensate stripper system, recovery furnace,
and lime kiln - 5 ppm TRS
Smelt dissolving tank - 0.0084 kg/metric ton (0.0168 Ib/short ton)
of air dried pulp or 0.55 kg/hr (1.21 Ib/hr) TRS
SOURCE: J.E. Sirrine Company. 1977a. Environmental assessment for proposed
1000 ton per day bleached kraft market pulp mill. Houston, Texas,
Volume 1.
55
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Rule 23
Rule 103
Rule 105.1
Rule 201.06
Appendix 2
Texas Air Control Board Emission Regulations
As Applied to Proposed KFI Mill Bon Wier, Texas
- Comply with New Source Performance Standards promulgated by the
EPA.
- Visible emissions limited to 20% opacity for any 5 minutes.
- Particulate matter emissions.
Kiln @ 1560 actual cubic meters/minute
(55,100 actual cubic feet/minute (acfm)
Smelt tank @ 1210 actual cubic meters/minute
(42,800 acfm)
Recovery furnace @ 8700 actual cubic
meters/minute (308,000 acfm)
Power boiler @ 4984 actual cubic meters/
minute (176,000 acfm)
19 kg/hr
(41.8 Ib/hr)
23.6 kg/hr
(35.7 Ib/hr)
54.8 kg/hr
(121 Ib/hr)
66.9 kg/hr
(85.8 Ib/hr)
- Sulfur dioxide emissions from a liquid fuel-fired steam
generator are limited to 440 ppm by volume.
Regulation 6 - Proposed facility must comply with
• Rules and regulations of Texas Air Control Board
• Consideration of Best Available Control Technology
• New Source Performance Standards
SOURCE: J.E. Sirrine Company, 1977a. Environmental assessment for proposed
1000 ton per day bleached kraft market pulp mill. Houston, Texas,
Volume 1.
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7.0 RESPONSE TO PUBLIC COMMENTS RECEIVED ON DRAFT .EIS
This section has been added to the Environmental Impact Statement in
order to respond to the comments received during the public review period.
Included are the comment letters from the interested agencies, groups, and
individuals and EPA's responses to these comments. The questions and comments
contained in these letters have been answered either in the response following
the letters and/or in the text changes preceding this section.
57
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in
oo
UNITED STATES COftS' GUARD
^"-'"' ' • . J50-) 58r-2Sei
16475
1 0 JUL '§79
Environmental Protection Aaency
Reaion 6
1201 Elm Street
Dallas, TX 75270
Dear Sirs:
In response to your request for a review of your draft impact statement
for the "Issuance of an NPDES New Source Permit for Kirby Forest
Industries, Inc., Pulp Mill Near Bon Wier, Texas," no objections or
comments are felt necessary. Your draft EIS appears complete and will
not significantly impact on Coast Guard programs or areas of respon-
sibility as documented.
Sincerely,
Response to Comments from the US Department of Transportation
United States' Coast Guard
Comment noted. No response is required by USEPA.
P.C. GOLDEN
Lieutenant, U.S. Coast Guard
Environmental Assessment Officer
By direction of the Commander,
Eighth Coast Guard District
Copy: COMDT (G-WEP-7)
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rKC.1-1.:
iexas ro-e:"_ ie-vice,
!iat >.- Si-r.'. : 7/I"/"-•
Dan- lint: 8/13/79
SUB
,BIECT. Bleached Kraft Market. 1'ulp Mill, lion «clr^ Texas Kuft-r: K)S_9-07-010
We have reviewed the cited docun-ent ,';nd our cor.ini-nts ;is to thy arlequacv of troatnent of
environmental effects of concern ;ire r.hown below:
Cli.^k fX) j"lL:_t-:-'J1_';!'i:
NI-IIO ' ! !.nr:nii'ii' i-nr li';;--!1.
1. Additional spt-clfir i-f forts uhlrh shoulil !>'• .i:;:;i':'.s.'.J:
2. AJuitional alit.-riut.jves which should he
3. Better or more appropriate rcrasiirt-s and :•' .inslanls whi'-l:
sho-.ild he used to evaluate onvironmont.nl i'fl"-r-ls:
A. . Additional control measures which should In1 :i|>pli"-cl to
roduce adverse environmental effects or to .-ivoid or
minimize the irreversible or irretrievable rnnuiiitment
of resources:
5. Our assessment of how serious the environmental
Iron this project might be, using the best alternative
and control measures:
6. We identify issues which require-further discussion or
resolution:
it.iiiiiants wlii '•!:
of l.-r-ts:
be :i|>pl ii'd to
Lo .-ivoid or
ie commit men t
imental damage
st alternative
discussion or
Response to Comments from Texas Forest Service
Comment noted. No response is required by USEPA.
E>^j This agency concurs with the implement a I inn of this projrrt.
P llhis agency does not wish to comment on the subject d.u-nment hyr.uise
'
F.nclosure(s)
_
and Title of Reviewing Official
Mason C. Cloud, Head, Forest Environment Dept.
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Advisor'
Council ^r
Historic
Preservation
1522 K Street N\V
Wasnmgion D.C.
20UU5
July IB, 19';-
Mr. Clir.tor. B. Spctts
Regional EIS Coordinator, Region 6
Environmental Protection Agency
1201 Elm Street
Dallas, Texas 'T5270
Dear Mr. Spotts:
This is to acknowledge receipt of the draft environmental
statement for a Kev Source National Pollutant Discharge
Elimination System permit to discharge vastewater into
the Sabine River from a Bleached Kraft Market Pulp Mill
near Bon Wier, in Kevton County, Texas on July 12, 1979-
We regret that we will be unable to review and comment or.
this document in a timely manner pursuant to Section
102(2)(C) of the National Environmental Policy Act of
1969.
Nevertheless, the Environmental Protection Agency is
reminded that, if the proposed undertaking will affect
properties included in or eligible for inclusion in the
National Register of Historic Places, it is required by
Section 106 of the National Historic Preservation Act of
1966 (l6 U.S.C. Sec. l»70f, as amended, 90 Stat. 1320) to
afford the Council an opportunity to comment on the
undertaking prior to the approval of the expenditure of
any Federal funds or prior to the issuance of any license.
The Council's regulations, "Protection of Historic and
Cultural Properties" (36 CFR Part 800.U) detail the steps
an agency is to follow in requesting Council comment.
Generally, the Council considers environmental evaluations
to be adequate when they contain evidence of compliance
with Section 106 of the National Historic Preservation
Act, as amended. The environmental documentation must
demonstrate that either of the following conditions
exists:
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i. K:: proj-ertlsr included ir; or that nay be eligible
for inclusion ir. the National Register are located wit'nir:
the area of envirorjssntfcl impact . ani the undertaking
will no*, affect any such property. In mar-ing thif determinaticr..
the Council requires:
—evidence that the agency has consulted the latest
editior, of the National Register (Federal Register,
February 6, 1979, anc its monthly supplementsi;
—evidence of an effort to ensure the identification of
properties eligible for inclusion in the national Register,
including evidence of contact with the State Historic
Preservation Officer, whose comments should be included
in the final environmental statement.
2. Properties included in or that may be eligible
for inclusion in the National Register are located within
the area of environmental Impact, and the undertaking
will or will not affect any such property. Ir. cases
where there will be an effect, the final environmental
statement should contain evidence of compliance with
Section 106 of the National Historic Preservation Act
through the Council's regulations, "Protection of Historic
and Cultural Properties".
Should you have any questions, please call Jane King at
(303) 23U-U9U6, an FTS number.
Sincerely,
Louis S. Wall™
Chief, Western Divis
of Project Review
Response to Comments from the Council on Historic Preservation
1. Section 5.6 and Appendix 8 of the DEIS discuss the htstorical and
archaeological impacts of the project. No significant impacts are ex-
pected. This Is supported by comments from the State of Texas Historic
Preservation Officer and from consultation wtth the latest revision of
the National Register.
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WAPORA, INC.
ATLANTA OFFICE
Response to Mr, George Mullins
1. Section 5.3.1.4 of the DEIS discusses impacts of the proposed project on
air quality. Section 5.8 of the FEIS discusses potential cumulative air
quality impacts of the 1,000 tpd plant. Both the 650 and 1,000 tpd plants
are required to meet TACB limits and the National Ambient Air Quality
Standards (NAAQS). The 1,000 tpd mill will use at most only 17Z of the
PSD Class II Increment for the area.
The proposed mill will be designed to Implement the best available control
technology for TRS emissions. Due to the low odor threshold value of TRS
compounds, no mill can be absolutely odor free. The proposed Kirby mill
should meet the lowest achievable odor potential and cause minimal nuisance
problems to the surrounding areas.
2. Both the 650 and 1,000 ton/day plants will meet all water quality standards.
Section 5.2.2 of the DEIS and Appendix 1 of the FEIS discuss the potential
impacts of the mill on water quality. The 1,000 ton/day mill will increase
the color of the river to about 227 PCU under worst-case conditions, but
only by 9 PCU under average flow. Impacts of the mill discharge on river
fisheries are not expected to be significant (Appendix 3 of FEIS).
3. Impacts of the proposed mill on population, employment, and taxes are
discussed in Section 5.7 of the DEIS. The mill is expected to approx-
imately double the tax base of Newton County, and increase the tax base of
the Newton Independence School district to an assessed value of more than
$85 million.
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JU, :. - J979
Mr. Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
The Draft Environmental Impact Statement for Bleached Kraft Market
Pulp Mill, near Bon Wier, Texas has been reviewed. Following are
our comments:
®| 1. Discussion of the net energies involved in alternate transpor-
I tation of the feed stock would be of value.
2. Has any consideration been given to using the wastes and
hog wood to generate producer gas or some other low BTU
gas to offset the 95,000 BBL of fuel oil needed for the
lime kiln?
3. Can the steam generating boiler using wood wastes and other
forestry products use the solid domestic wastes from the
local communities?
4. Are there any plans to recycle the ash from the boiler to
the forest lands?
Sincerely,
j. Dan RamBo
Regional Representative
Responses to Comments from US Department of Energy
1. Section 4.3.1 of the DEIS discussed available transportation in the project
and regional area. Water and air transportation are unavailable. Rail
and truck service will be the primary means of delivery of feed stock.
Rail service will be of secondary use because of the local transient
nature and the required flexibility needed to harvest the nearby forests.
Rail traffic in the immediate area may be doubled (Section 5.7.5.9 of the
DEIS) to two trains per day. Truck traffic is expected to be increased
due to the delivery in excess of 1,000 cords of wood per day. Highway
maintenance and design has been determined to accommodate this usage.
Truck harvesting will be utilized up to a 100 mile radius. Depending on
the size of the truck, 5, 10, or 20 cords can be transported per load. A
railcar averages 20 cords per load.
2. The average consumption of fuel oil in the lime kiln is 250 bbl/d and it
is expected to be the primary fossil fuel user in the mill. Installation
of a pilot or R & D type wood waste producer gas process to compliment the
small fuel oil use was not considered.
3. The boiler capacity is sized to economically and safely provide the necessary
. steam requirements of the mill. The design of the boiler will meet fuel
requirements using existing material balances. Utilization of existing
small, sporadic solid wastes from local communities Is not considered
economical because of the varied sources of waste and the unmanageable
logistics involved in the collection, transportation, classification, and
disposal of non-fuel wastes.
4. No plans have been made to recycle ash from the boiler to forestland.
Boiler wastes will be landfllled.
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LONE STAR CHAPTER
July 30, 1979
RE: Kirby Lumber Industries, Inc.
Bleached Kraft Market Pulp Mill
Bon Wier, Texas
AUG 6 1979
WAPORA, INC.
ATLANTA OFFICE
Mr. Clinton B. Spotts
Regional E1S Coordinator EPA Region 6
1201 Elm Street
Dallas, Texas
Clinton:
The Sierra Club opposes the proposed plant's location and dis-
charge into the Sabine River for the following reasons.
Sabine River is dammed by Toledo Bend Dam just a few miles up
stream from the proposed site. Toledo Bend Dam has resulted in
cleaning water and providing a large body of water to the extent
that the America Bald Eagle is now nesting around the lake. The
eagles often feed in the river area below the dam and in the area
of the proposed site. The reduction of food in the waters of the
Sabine River would certainly have adverse affects on the American
Bald Eagle. As high as seven eagles have been seen feeding below
Toledo Bend Dam at one time. This problem is not assessed in the
impact statement.
The site is on the north edge of the coastal prairies which is
extremely flat. This location is very similar to the location of
the East Texas Pulp and Paper Mill located on the Neches River,
southwest of the proposed site some 40 miles. The Neches is
dammed by Sam Rayburn Dam and Dam B, and is located on the north
edge of the flat coastal prairie. The two plants, the East Tex
and the proposed plant, are similarly located 4n similar rivers
with similar operations. Experience gained from one is the basis
used for the other.
The waters of the Sabine River in recent years have cleaned to a
considerable extent because of Toledo Bend Dam.. Trees, aquatic
vegetation and sport fish have regenerated. Water sports on the
river have increased tremendously. ^-?5"~
RICHARD N. EVANS. CHAIRMAN
III GOODHUE BLDG. BEAUMONT. TEXAS 77701
Responses to Comments, from Sierra Club-Lone Star Chapter
1. Effluent of the proposed mill is expected to be discharged approximately
55 river miles downstream of the Toledo Bend Reservoir dam. The mill Is
located approximately 33 land miles from the dam.
The mill Is not expected- to have significant impacts on bald eagles.
Potential Impacts of the proposed mill on.wintering eagle populations
which are known to exist in the Sabine River basin are discussed 'in the
Section 7 assessment (Appendix 3 of the FEIS).
2. Reference was made to the Temple-Eastex pulp and paper mill at Evadale,
Texas, and Its operation compared to the proposed KFI mill. The KFI mill
is designed to incorporate the latest environmental controls and is ex-
pected to be significantly "cleaner" than the older Temple-Eastex mill.
Experience factors of the Temple-Eastex mill would have to be tempered on
a case-by-case basis prior to their application to the KFI project.
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PAGE TWO
If the proposed plant is allowed, the waters turn black and carry
strong long lasting odors which are offensive. In the Neches
River, sport fish were killed out and eggs would not hatch.
Nearly 100% of all sport fishing on the Neches River ceased below
the discharge point of East Texas Pulp and Paper Mill and the
same will happen on the Sabine. Plus this discharge will kill or
destroy the fish habitat necessary for the American Bald Eagle.
In these blackened water, 90% of all water sports cease. It is
simply not desirable to water ski or even be around water with
such an odor.
With the advent of Toledo Bend Dam, the Sabine River has a con-
trolled flow which has causing it to silt considerably. During
the past five years the areas of the Sabine River below the pro-
posed site have flooded extensively and frequently. The tonnage
of solid waste dumped into the river at the point will cause
silting up of the river and contribute to more flooding. All of
this silt must later be moved at the tax payers expense.
Studies of this area demonstrate the air clears very poorly. In
fact if all areas in the United States 48 states are classified,
the proposed site area ranks in the bottom 25% in air clearing
ability. The offensive odors of the plant will be with someone
1007. of the time. During six months of the year the offensive
plume of odor from the proposed plant will lace the air over The
Big Thicket National Preserve and The Beaumont to Lake Charles
complex where over a million people live.
Last of all, the waters of the Neches and Sabine Rivers join at
the head of Sabine Lake and feed it their filth and blackened
waters 365 days a year. Sabine Lake is regenerating to some
extent and in season is heavily used for fishing, swimming,
sailing, etc. A resort hotel is now being built on its shores.
It would not be desirable to turn these waters darker and destroy
these activities.
Sincerely,
SIERRA
.Richard N. Evans
Legal Chairman
Lone Star Chapter
3. Potential Impacts of the proposed mill's effluent on fish habitat necessary
to support the bald eagle are not predicted to be significant (Appendix 3
of the FEIS).
4. All solid wastes will be disposed of by landfill. The total suspended
solids concentration of the mill effluent is estimated to be 31 mg/1
(avg.) and 58 mg/1 (max.) at a flow rate of 20.1 cfs (avg.) and 30.9 cfs
(max.). At an average flow rate of 6,446 cfs, natural levels of suspended
solids in the Sabine River equal 20.6 mg/1 (avg) and 68 mg/1 (max). The
mill effluent is therefore not expected to contribute significantly to
excessive silting in the river.
5. Section 5.3 of the DEIS thoroughly evaluated the existing air quality and
mill impact on air quality. Pasquill stability class data indicates that
the weather in the influence region is neutral or unstable more than 62%
of the time, slightly stable 11Z of the time and stable 26Z of the time.
These data were used in extensive air dispersion analyses which indicated
compliance with both National Ambient Air Quality Standards and PSD criteria.
In addition, an odor analysis completed for TACB indicates that although
the mill will not be odor free, the type of emission controls are expected
to minimize odor impacts. In particular, comparison of odorous emissions
from older mills is Inappropriate because of the absence of odor controls
in existing mills. Odor dispersion analysis does not indicate the lacing
of odorous emissions of the proposed mill over the Big Thicket National
Preserve and Beaumont/Lake Charles complex. An old mill may emit up to 15
Ibs. of TRS/ton of production whereas a new mill with odor controls can
maintain less than 1.0 Ib. of TRS/ton of production. These conclusions
apply to both the 650 and 1,000 ton/day mills (Section 5.8 of the FEIS;
Section 5.3 of the DEIS).
PROJ20B8
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DEEP EAST TEXAS
COUNCIL OF GOVERNMENTS
ECONOMIC DEVELOPMENT DISTRICT
P.O. Drawer 1170 P.O. Bo» 1423
272 East Lamar Street 222 South 2nd Si
Jasper Texas 75951 Lulxin, Taxai 75901
Phone (713) 384-5704 Phone (713) 634-2247
DATE:"" September 7, 1979
FROH: Lavlna Gibson, A-9S Coordinator
jO: Environmental Protection Agency
Region 6
1201 Elm Street
Dallas, Texas 75270
Attn: Clinton B. Spotts
PO Bo.681
2800 Woden Road
NKogdochM. Ton 75961
Phone (713) S6&0482
SUBJECT: Kirby Forest Industries 79-DET-119
"New Source National Pollutant Discharge Elimination System Permit"
The Deep East Texas Council of Governments' A-95 Application Review
Committee met August 23, 1979 and made the following recommendation
on the above reference project:
IK] favorable review [~~| unfavorable review Q tabled
Qy consistent with Regional Planning goals and objectives.
I X| Review and Comment Evaluation Form attached.
The Board of Directors subsequently approved and adopted the recom-
mendation of the A-95 Application Review Committee.
If I can be of further assistance, please contact me at the above
Jasper address or telephone number.
Thank you.
4H lauti offomuMiTf mnora
DETCOGCountinSemd: Angelina • Houston • Jacpw • Nacogdoches • Newton . Polk . Sibine • SanAuguttine i
SanJacinto • Shelby • Trinity • Tyler
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.L1CAJ" SAXL/APPrXS:.' Z:-i:~. f-.T. !'E?.SO:.'-'"HC^E 1-T^E:.:
Environmental Protectior. Ajiency
Region 6
1201 Elm Street
Dallas, Texas 7527.0
E.I.S. Coordinator: Clinton B. Spotts
2. PROJECT DESCRIPTION AND.OBJECTIVES:
Kirby Forest Industries, Inc. applied to the U. S. Environmental Protection Agency
(EPA), Region 6, for a New Source National Pollutant Discharge Elimination System
(NPDES) permit to discharge wastewater into the Sablne Riber from a Bleached Kraft
Market Pulp Mill near Bon Wier, in Newton County, Texas. EPA determined the issuance
of this permit'to be "a major Federal action significantly affecting the quality of
the human environment," and has prepared the attached Environmental Impact Statement
(EIS).
3. FUNDINGl | or LOAN INSURING) [AGENCY: Not Applicable - Comments Only
LOAN LJ or GRANT! 1 COST: FEDERAL $ STATE $
LOCAL $ (CASH| | or IN-KIND] |) TOTAL PROJECT COST: $_
4. PROJECT IMPACT AREA:
Newton County
(Primarily, vicinity of Bon Wier)
5. EVALUATION CRITERIA AND REVIEW DATA (Refer to attached page number) : PACE 0
a. Persons contacted for comments/infonnation/issues 3
b. Compatibility with state, regional, local plans/objectives 3
c. Availability/use of energy, communication, water, disposal systems 3
d. Design, implementation, completion, inspection, evaluation 3
e. Project beneficiaries/minority inclusions/employment . 3
f. Environmental, historical, archaeological and esthetic concerns
g.- Natural resource and .land -use impacts. ^
h. Traffic and transportation impacts *
i. Open space and recreation impacts .-• f ^
j. Previous project evaluation (previous or continuation project)
PAGE 1^ of * PAGES
ITEM NO. 11 ON AGENDA, NEW BUSINESS
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..TAFF COM'-ZNTS AKD RECOMMENDATIONS:
79-I)i:7-: 1~
While this document (Environmental Impact Statement) prepared bv E.P.A. does net
require an A-95 review, the staff has acquired a limited number of these documents
and submitted them to various A-95 and Natural Resources Committee members so that
comments may be submitted as a regional body. The E.l.S. is very technical and
the staff will rely heavily on comments received, which, so far, have been favorable
to issuance of the permit to Kirby Forest Industries, Inc., Pulp Mill.
(See site maps (2) and letter attached.)
STAFF REVIEW STATEMENT AND SIGNATURE OF REVIEWERS:
REVIEW BASIS: Review criteria contained herein represent summaries of positive and/
or negative viewpoints and/or information data from those parties with interest,
involvement or expertise in project or effects of the project. Statements may in-
clude staff comments and recommendations for the consideration of .the Applications
Review Committee.
Floyd Herbert
- STAFF REVIEWER
8. APPLICATIONS REVIEW COMMITTEE'S COMMENTS ON PROJECT:
The A-95 Application Review Committee's comments were favorable in regard to the
Kirby Forest Industries application for a permit to discharge wastewater into the
TI Sabine River from a Bleached Kraft Market Pulp Mill near Bon Wier, and recommended
" approval by the Board of Directors as being consistent with regional planning goals
and objectives.
9. RECOMMENDED ACTION ON APPLICATION:
_ Approval without comment
X Approval with comment
No action taken
Other (Explain) :
10. CERTIFICATION : The application described herein was reviewed by the Deep East Texas
Council of Governments/Economic Development District at its regular month meeting on
August 23, _ ' , 19 79 , at which meeting the above-described action was taken on
the project.
SIGNED:
SIGNED:
-W. R. ."Bill" BOWLIN - DETCOG PRESIDENT
"ROTCE" GARRETT .- A-r95 REVIEW .COMtTTiEE CHAIEMN
PAGE 2 of A PAGES
ITEM NO. 11 ON AGENDA, NFA) BUSINESS
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;.". I ;:. :. ^:;. I'
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See Stnff Comments - Itui: (,.
5g. NATURAL RESOURCE AND LAND USE IMPACTS:
See Staff Comments - Item 6.
5h. TRAFFIC AND TRANSPORTATION IMPACTS:
See Staff Comments - Item 6.
5i. OPEN SPACE AND RECREATION IMPACTS:
See Staff Comments - Item 6.
5j. PREVIOUS PROJECT EVALUATION (previous or continuation project);
See Staff Comments - Item 6.
PAGE _< of U PAGES
ITEM NO. 11 ON AGENDA, NEW BUSINESS
Responses to Comments from Deep East Texas Council of Governments
No response required by USEPA.
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/ •'. ••• \
DEPARTMENT Or H j.SING AND URBAN DEVELOPMENT
FT. WORTH REGIONAL OFFICE
1100 COMMERCE STREET
DALLAS. TEXAS 76202 NEW ZIP CODE
REGION VI
September 21, 1979
Mr. Clinton B. Spotts -
Regional EIS Coordinator
Environmental Protection Agency
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
The Draft Environmental Impact Statement for the proposed Bleached
Kraft Market Pulp Mill near Bon Wier, Texas, has been reviewed in
the Department of Housing and Urban Development's Dallas Area Office
and Dallas Regional Office and the following comments are applicable:
1. Cross-Reference to Incoming Inquiry.
The proposed action is to issue a New Source National Pollutant
Discharge Elimination System (NPDES) permit for a treated waste-
water discharge from the proposed Kirby Forest Industries, Inc.
(KFI) pulpmill into the Sabine River. The applicant, KFI, proposes
to construct a 650 ton/day bleached Kraft market pulp mill on a
site one and a half miles west of Bon Wier in Newton County, Texas.
2. HUD Comments on the Statement.
©
a. EPA's alternative of "Denial of the Permit" (paragraph 3.2.2)
does not give adequate assessment of the alternative.
Specifically the impacts resulting from denial are noted as
(1) economic loss, (2) loss of pulp to the national market, and
(3) loss of potential jobs and secondary services. What is
lacking is the weighing of these losses against the potential
losses that might arise because of the environmental impacts.
b. The site is located in a flood prone area and the impact of
flood waters overrunning a vastewater lagoon should be discussed,
including cost to correct the impact.
c. The Land Resources of Texas maps indicate that the soils have
moderate aquifer potential and high to low infiltration
characteristics. The data presented therein states that problems
can be expected with light and heavy construction, filling for
development, devegetation and drainage of wetlands. It also
states that surface and shallow subsurface disposal of untreated
liquid wastes and solid vastes could create serious contamination
problems. What would be the cost of correcting this impact?
Responses to Comments from US Department of Housing and Urban Development
1. Socioeconomic impacts resulting from denial of the permit would be equiva-
lent to the no action alternative. These impacts are discussed in Section
3.1.4.7 of the DEIS.
2. The flood hazard area of the proposed KFI site is described in Section
5.2.1.2 and shown In Figure 9 of the DEIS. Although limited portions of
the site are within the flood hazard area, they are to be graded to an
elevation above flood level during site preparation. In some instances
present elevations will be maintained to allow adequate stormwater runoff
but no facilities are planned for these areas.
Wastewater from the proposed mill Is to be treated in an activated sludge
type treatment facility, not a lagoon. A three acre polishing pond may be
constructed following the activated sludge system to allow for additional
settling of fine solids and natural aeration. The effluent from the pond
would be discharged to the Sabine River through the proposed outfall line.
Elevations of the pond are not specifically known but, if built, the top
of the pond levee will be above the FEMA flood hazard elevation. Should
the pond flood, however, the effect on the river should be minimal because
the wastewater is to be adequately treated before reaching the pond.
3. Soil limitations on the proposed site have been taken into account in the
development plans for the mill. Soil borings performed near the site
Indicated adequate conditions to support shallow spread footings designed
2
for a bearing capacity of 3000 to 4000 Ib/ft (Sirrine 1977a). However,
heavy critical equipment foundations will generally require pile supports
to remain stable. Other potential impacts on soils due to construction of
the mill are addressed in Section 5.1.8 of the DEIS.
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2.
HUD's interests as related to recreational and potable water
resources necessarily raise the issue of cumioulate impacts of
discharges into the Sabine River system (to include its tribu-
taries). It appears that a 20/20 ppm BOD/TSS would be In-
compatible with EPA requiremets for domestic STP's which normally
allow 10/10 ppm BOD/TSS effluent qualities. We are apprehensive
of the potential accrued impact from all sources on localities
below the project area, and recommend that the cummulative impacts
be recognized and discussed including mitigating measures and
their cost.
3. HUD Comment on the Proposal.
HUD does not oppose this proposed project, but does recommend that
maximum effort be made to minimize any adverse impact.
Sincerely,
Victor J. Hancock
Environmental Clearance Officer
The project is designed such that there will be no discharge of untreated
liquid wastes. Should the polishing pond be constructed, its bottom will
he evaluated to determine if excessive infiltration will occur (usually in
excess of 1 x 10~ cm/sec). If excessive infiltration is predicted to
occur, a synthetic lining or impermeable clay blanket will be used to line
the pond. Installed cost Is estimated at $0.75 per sq. ft.
Solid waste to be disposed of on-site is expected to be comprised of
inert, non-toxic wood ashes, grit and dregs from the causticizing process,
grit and screenings from the wastewater treatment process, and wood
trimmings. Disposal of these wastes in a properly designed and operated
sanitary landfill will be required subject to the Sections of RCRA dealing
with nonhazardous waste. Wastewater treatment plant solids are non-toxic
and will be disposed of in retention basins.
4. The comparision of domestic STP's with industrial effluent standards is
inconsistent with EPA's effluent guidelines and standards. Extensive
studies and promulgated regulations have been established by EPA for each
major industry, including pulp and paper (40 CFR 430), which have es-
tablished effluent limitations. These limitations were based on NSPS,
BPCTCA and BATEA, and now BACT and BCPCT. These standards were estab-
lished as technically achievable guidelines as applied to each type of
Industry regulated and its associated waste. Each industry has its own
characteristic wastes and treatability potential. As long as receiving
stream water quality standards are met, the degree of treatment required
is regulated by the effluent guidelines.
. As discussed In the DEIS and Section 5.8 of the FEIS, downstream water
quality impacts were determined to be well within water quality standards
and no significant adverse, accrued impact on downstream localities below
the project is expected. Specific parameters investigated included dis-
solved oxygen, BOD, chlorides, sulfates, color, and total dissolved solids.
-------
o 720
123.14
Unned States Department of the Interior
BURIAL! OF RECLAMATION
SOUTHWEST REGION
HERRING PLAZA BOX H-4377
AMARJLLO. TEXAS 79101 •'.
AUG ? 1979
Mrs. Adlene Harrison
Regional Administrator
Environmental Protection Agency
Attn: Mr. Clinton B. Spotts, Regional E1S Coordinator
1201 Elm Street
Dallas, TX 75270
Dear Mrs. Harrison:
We have reviewed your draft environmental statement on the proposed
Kirby Forest Industries processing plant to be located near Bon Weir,
Texas. We have no specific comments to offer.
The Bureau of Reclamation is currently investigating a dam and
reservoir site on the Sabine River at river mile 101.9. This poten-
tial reservoir would be multipurpose, but the primary purpose would
be to provide a municipal and industrial water supply source for the
upper Texas-Gulf Coast area. As the Kirby Forest Industries waste-
water discharge point is 13 to 15 miles below the proposed dam sice,
it should have no effect on our studies.
Thank you for the opportunity to review your draft statement.
Sincerely,
ACTING FOR
Robert H. Weimer
Regional Director
cc: Texas Reclamation Representative, Austin, TX
Response to Comments from US Department of Interior - Bureau of
Reclamation
1. No impact is expected on the proposed KFI mill as a result of the reser-
voir at river mile 101.9 as long as adequate flow is maintained in the
Sabine River to assimilate KFI's wastewater effluent. However, the dis-
charge from Boise Southern's paper mill into Bayou Anacoco which enters
the Sabine River near river mile 105 may have an impact on the quality of
water in the reservoir for other uses. Because the Boise Southern Mill is
expected to increase its waste discharge in the future, it is recommended
that this be taken into account in the planning of the reservoir.
-------
COMMISSION
REAGAN MOUCTON CHAIRMAN
DE'.VHT C GREER
CHARLES E SiMONS
STATE DEPARTMENT OF HIGHWAYS
AND PUBLIC TRANSPORTATION
ATVI iv TKXAS mini
August 3, 1979
f.GINEER OI^ECT
L L DcBERK*
D8-E 854
Draft Environmental Statement
Bleached Kraft Market Pulp Mill
Near Bon Wier, Texas
Mr. Ward Goessling
Economic and Natural Resources
Governor's Budget and Planning Office
411 West 13th Street
Austin, Texas 78701
Dear Sir:
Thank you for your memorandum dated July 17, 1979, providing an opportunity
to comment on the above captioned draft statement.
The proposed construction of the pulp mill on a site one and a half miles
west of Bon Wier in Newton County will not adversely affect the State highway
system.
In accordance with the Department's current Utility Accommodation Policy, it
will be necessary to secure permits for all pipe lines crossing or located
within State highway right of way.
Sincerely yours,
B. L. DeBerry
Engineer-Director ^_-,
Response to Comments from State Department of Highways and Public .
Transportation
1. Comment noted. EPA concurs that permits for all pipelines crossing
or located within State Highway rights-of-way must be secured by
the applicant.
,
R. L. Lewis, Chief Engineer
of Highway Design
-------
17.01
75270
*
Response to Comments from Mr. Eugene ^
1. Impacts on the "environment of the people" (socioeconomlc impacts) were
fully addressed in Section 5.7 of the DEIS.
2. The proposed mill will be designed to implement the best available control
technology for TRS emissions. Due to the low odor threshold value of TRS
compounds, no mill can be absolutely odor free. The proposed Kirby mill
should meet the lowest achievable odor potential and cause minimal, if
any, nuisance problems to the surrounding areas.
-------
:>.::. i.i r-. ,-.,.
i.i~£ fc iJ. T tic
C P T"ML" "P«s.rPi.€
J- I I:
777
7x
-------
General
Land Office
AUSTIN. TEXAS 78701
BOB ARMSTRONG. COMMISSIONER
Environmental Management
1700 North Congress
Austin, Texas
Telephone: (513) 475-6902
August 7, 1979
Mr. Ward Goessling
Economic and Natural Resources
Governor's Office of Budget and Planning
Executive Office Building
411 West 13th Street
Austin, Texas 78701
RE: Kirby Forest Industries, Inc.
Bleached Kraft Pulp Mill
Draft Environmental Impact Statement
Dear Mr. Goessling:
The General Land Office, Environmental Management Program, has reviewed the
DEIS for Kirby Forest Industries'proposed bleached kraft pulp mill near Bon
Weir, Texas. Based on this review, we have the following comments to offer
relevant to potential environmental impacts of the project.
The most significant impact of the proposed pulp mill will be on the water
quality of the Sabine River. The DEIS states that no water quality standards
are expected to be exceeded as a result of the project. Not all parameters of
concern are covered by the standards, however, and the actual quality of water
may not be reflected in established standards. The standards being applied in
this case are determined as annual arithmetic means. The real value of any one
parameter may vary considerably from one time to another, yet not exceed the
annually derived standard.
In the case of dissolved oxygen, the document cites modeling results which indi-
cate that no dissolved oxygen levels below 5 mg/1 should occur. It is not
clear whether this represents an instantaneous figure or is simply an average
over some time interval generated by the model. Levels of dissolved oxygen
below 5 mg/1 can have adverse effects on aquatic organisms if they occur over
larger areas or for extended periods of time. Low dissolved oxygen coinciding
with high temperatures, toxic substances or other sources of stress may be
particularly unfavorable. The estimation of impacts in the DEIS could possibly
be enhanced by a discussion of the combined effects of those interrelated water
quality parameters to be altered as a result of plant operation.
Response to Comments from General Land Office - State of Texas
1. All effluents from the 650 and 1,000 ton/day plants will meet State and
Federal discharge limitations, and will not result in violation of any
water quality standards. This was confirmed by additional modeling of
cumulative impacts of the proposed 1,000 tpd mill (Appendix 1 of the
FEIS). Modelling was conducted under both worst-case and average con-
ditions.
Water quality standards in use today are in part based upon broad cate-
gorizations of specific compounds. Identification and regulation of
specific compounds is a burdensome, if not impractical, task except for
known specific toxic compounds that by necessity require special attention.
The literature illustrates that specific pulp and paper mill effluent
pollutants such as unsaturated fatty acids, resin acids, volatiles and
bleach plant wastes are effectively removed by conventional waste treat-
ment systems. In many instances, concentrations of specific compounds are
below detection limits.
2. Evaluations of dissolved oxygen profiles were based on the classical
Streeter-Phelps dissolved oxygen sag analysis. This technique for eval-
uating the impact of waste waters upon streams is widely recognized as an
appropriate method, and both the EPA and TDWR concur with Its use.
Dissolved oxygen profiles are determined as a function of time and distance
from a given discharge point and tend to represent real time values. A
recognized procedure in the analysis is to assume steady-state conditions
of the stream, waste flow, and pollutant conditions. Modelling conducted
(using these techniques) on the 1,000 ton/day plant alone and in conjunc-
tion with the expanded Boise-Southern plant indicated that even under
extreme worst-case conditions no violation of any water quality standards
would occur (Appendix 1 of the FEIS). The mill could produce periodic
accidental chemical spills which would be toxic to aquatic life (EPA 1979)
but such spills are not common and will have a minor overall impact. The
mill will also have sublethal impacts on aquatic life produced by discharge
of low concentrations of toxic substances in the effluent, and by elevated
-------
There exists no applicable standard for that aspect of the Sabine River waters
expected to change the most. According to the DEIS, the color of the river water
will be increased from 62 to 73 platinum-cobalt units at two-thirds of average
flow and from 137 - 246 PCU at low flow. This alteration in water color could
represent a significant impact. The DEIS acknowledges many of the potential
problems associated with such an increase but regards the impacts as neither
long-term nor significant. The specific chemical derivation of the color is
not clear, so properties of specific components are not detailed.
The California State Water Resources Control Board has reported (1963) that
100 PUC is perhaps an upper limit to acceptable water color for domestic water
supply. Excessive color in water can limit its application to industrial uses,
also. The Technical Association of the Pulp and Paper Industry has recommended
a specification of 25 PUC for process water for bleached kraft pulp mills. It
should be noted that this leve'l is currently exceeded in the Sabine, partly as
asresultof the Boise Southern paper mill which effects the river downstream of
Bayou Anacoco. The KFI plant will utilize groundwater for its process require-
ments. The effect of the proposed discharge might well be to preclude many
municipal and industrial water uses downstream due to excessive levels of many
of the plant wastes. The existing water quality standards are intended to
maintain the Sabine River waters at levels suitable for contact and non-contact
recreation, fish and wildlife propagation, and domestic water supply. While
standards for some parameters have not been promulgated, there is certainly
some question as to whether the above water uses are consistent with the likely
water quality impacts of this facility.
The project in question will also have noticeable effects on the air quality of
the area. The biggest concern here is for emission of reduced sulfur, especially
H^S, and associated odors. The DEIS states that the H2$ concentration at the
plant property line could violate the TACB standard for land not used for resi-
dential, commercial or business purposes. The expected total reduced sulfur
concentrations are significantly greater than the odor thresholds for these
compounds in the plant area. These impacts could have effects on future land
uses in the area, especially recreation activities in the vicinity of the plant
and the Sabine River.
The DEIS (p. 91) states that means for controlling fugitive reduced sulfur emissions
have not been specified. Potential mitigative control measures are listed, however.
The incorporation of such measures should be discussed in greater detail and
considered as alternatives to the present project design. The same applies to
control measures for wastewaters. The potential impacts on Sabine River waters
warrant serious consideration of mitigative features as project alternatives.
Thank you for the opportunity to comment on this draft document. We hope our
response is of some assistance in the preparation of a final impact statement that
addresses the concerns of interested parties.
Sincerely,
Stepheti Hi nick
Approved:
Hike Hightower, Program Manager/Director
color levels. Such effects could be somewhat heightened, for example,
under worst case 7-day, 10-year low flow conditions but since such-con-
ditions are rare the overall impact of the mill effluent will be minor.
3. Two classes of color-contributing color bodies have been identified. The
first are high molecular weight, acid-insoluble bodies and the second are
low molecular weight, acid-soluble bodies. The acid-insoluble bodies have
molecular weights from 400 to 30,000 and contain a high proportion of
carboxyl groups conjugated with an aromatic ring. The acid-soluble bodies
have non-conjugated carboxyl groups, apparently associated with carbohydrate
material. Most color bodies are lignin-like in character, apparently
consisting of lignins degraded to varying degrees, and are negatively
charged. ;
Aerial investigation of the river Indicated that substantial natural
coloration of the river-results from forest water runoff and tributary
discharges. This is evident from a review of the following USGS water
quality data:
Color Levels (PCU)*
average
maximum
minimum
Burkeville (above mill) 48
Bon Wier(above mill) 59
Ruliff (below mill) 154
240 0
220 5
223 75
For period between 1968 and 1972
Discharges of the KFI effluent to the Sabine River by either the 650 or
1,000 ton/day plants will not result In excessive coloration of the river
since high color levels associated with 7-day, 10-hour low flows will only
rarely occur. Color elevation under average flow conditions will be very
small (Section 5.2 of DEIS; Section 5.8 of FEIS).
-------
Discussions with EPA, the Texas Department of Water Resources, and the
Sablne River Authority Indicate that maintenance of promulgated water
quality standards will not significantly preclude the use of the river by
municipalities and Industries. However, the elevated color produced by
both the Kirby mill and the expanded Boise Southern mill could preclude
recreational use of parts of the river to an unknown extent during low-flow
conditions.
4. An odor Analysis completed'for the Texas Air Control Board Indicated that
although the mill will.not be odor free, the types of emission controls
are expected to minimize odor impacts. Dispersion analysis indicates that
the odor threshold for H S may on occasion be exceeded at a distance of
approximately one mile from the plant.
• Comparing the KFI mill with an existing older mill's odor emissions is in-
appropriate because of the absence of odor controls in the existing mill.
Controls for fugitive and point source TRS emissions such as the collection
and incineration of low volume "- high concentration and high volume - low
concentration odor emissions is included in the design of the project.
Typically, low volume pulp digester and turpentine emissions are collected
and routed to the lime kiln and burned as combustion air. High volume
sources such as brown stock washer emissions are planned to be routed to a
boiler and used as combustion air. Odor compounds composed of H S and
total reduced sulfur (TRS) . when burned are converted to SO . Because the
total amounts of H S and TRS are small, the resultant increase in SO
emissions will be insignificant. An old mill may emit up to 15 Ibs. of
TRS per ton of production whereas a new mill with odor controls can main-
tain less than 1.0 Ib. TRS/ton product.
-------
Offnf Ituiir.jt,,; — 411 WrU l.lth Sli^rt — AiKlin. 'I r\.i\ '.H'C'i
srj\Tj:_a,EA HI NT. I ten's E
i'PLICAXT: Bleached Kraft Market Pulp Mill. Bon Keir. TX.u M'.MUKH
L'UOKT AN'n I'l.ANNiS'O OKKICK fONT.uri': I'IKINK: .">'<•<: I":".
CO M M K NTS
Response to Comments from Texas Department of Community Affairs-
Local Government Services Division
In our review of the Draft Environmental Impact Statement
for the Kirby Forest Industries, Inc., Pulp Mill we do not
identify any issues that have not been addressed in the
statement.
Even though there will be short term adverse impacts
due to construction and some increased emissions to the
atmosphere and discharge into the area water, the report
indicates that these will be minimal. The 1,000 new jobs
during construction and addition of 260 new jobs as a result
of mill operation will be a significant impact on the
area economy.
Comments noted. No response required by USEPA.
riutn Cuitiliir'.iM^ Ki-vii-w (Signal nit')
i«-iu'V Tt-xa* In'p.irlnent of Comm\mlty Affn
„ GLJ-
.Titli- Local Government
Services Div.
. |>3,,. 8/7/79
-------
SWGED-E
DEPARTMENT OF THE ARMY
GAIVESTON DISTRICT,. .CORPS Of ENGINEERS
P.O.'BOX 1229
GAtVESTON, TEXAS 77553
i- AUS 1S?t
Ms. Adiene Harrison
Regional Administrator (6A)
Environmental Protection Agency
1201 Elm Street
Dallas, Texas 75270
Dear Ms. Harrison:
This is in response to your letter dated 3 July 1979, which provided a
copy of the Draft Environmental Impact Statement on Bleached Kraft
Market Pulp Mill near Bon Weir, Texas, for our reviev and comments.
The project will not affect any Corps of Engineers' project; therefore,
we have no comment. A copy of the final environmental impact statement
is requested when completed.
Sincerely,
'JAMES M. SILLER
Colonel, Corps of Engineers
District Engineer
Response to Comments from Department of the Army - Calves ton
District Corps of Engineers
Comment noted. No response required by USEPA.
-------
/fSv, United States
fiyj; Department of
^3&>/ Agriculture
Soil
Conservation
Service
P. 0. Box 648
Temple, TX
76501
August 10, 1979
Mr. Clinton B. Spotts • "~
Regional EIS Coordinator (6)
Environmental Protection Agency
1201 Elm Street
Dallas, TX 75270
Dear Mr. Spotts:
We have reviewed the Draft Environmental Impact Statement on the Issuance
of an NPDES Source Permit for Kirby Forest Industries, Inc. Pulp Mill Near
Eon Wier, Texas and feel that the statement adequately reflects the Impacts
this project will have on the soil, water, and plant resources. The erosion
control measures planned should tend to keep soil erosion and sediment at a
mininrum.
We appreciate the opportunity of reviewing this statement.
Sincerely,
Response to Comments from US Department of Agriculture - Soil
Conservation Service
Comment noted. No response required by USEPA.
George C. Marks
State Conservationist
-------
xr
Texas Department of Health
Raymond T. Moon-. M.IA
G>mmisiioncr
Philip W.Mallor>,M.D. .
Dcpuly Commissioner
1100 West 49ihSlrcci
Austin, Texas 7S756
458-7111
August 14, 1979
Members o! the Doarc!
Rohcrl 0. Morcion, Chairman
Witlurr. |. Fora". Vicr-Crisirmji
Rodcric M. Belt, Sccrciarv
Johnnie M. Brnson
H. I'.uwne Brown
S«le> Hi nurd Marie li,,,,-n.tyt;
Ramlro Casso
Chants MHX Cole
Francis A. Conic)
Ben M. Durr
William |. tduardt
Ravmond C. Carrm
Bob 0. Glaze
Bldncli.ird T. Hollins
Laurjncc N. Nitkcy
|oc N. Pvlc
Rkl.jfd W. Rac>dalc
K.i
-------
Mr. Goessling
Page Two
August 14, 1979
We appreciate the opportunity to rcviaw and contnent on the public and environmental
health implications of the proposed Bleached Kraft Market Pulp Mill.
Sincerely,
G. R. Herzik, r, E.
Deputy Commissioner for Environmental
and Consumer Health Protection
RLJ/re
ccs: Public Health Region 10
Bureau of State Health Planning
and Resource Development, TDH
Response to Comments from Texas Department of Health
Comment noted. No response required by USEPA.
-------
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
626 FEDERAL OFFICE BUILDING
AUSTIN. TEXAS 78701
Texas - Draft EIS for Bleached Kraft
Market Pulp Mill Near Bon Wier,
Newton County, Texas
August 15, 1979
IN MPIY arm 10
HB-TX
Mr. Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency, Region 6
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
We have reviewed the subject document and have no comments to
offer. It is our understanding that the State Department of
Highways and Public Transportation is reviewing the document
and will provide appropriate comments on the impact of the
action on the highway environment.
Sincerelvoyeurs,
., E. Inabinet
/ District Engineer
Response to Comments from US Department of Transportation - Federal
Highway Administration
Comment noted. No response required by USEPA.
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TL.\.*N I'i.i'AU'iv.; M (ii \\ATI.i: Kl><»UU.:.-
TEXAS WATEK DEVELOPMENT BOARD -''--'ji *>'-- 'I IIXA1; XV.M I K COMMISSION
A. I.. ll!iiil..C-u:::i..n. li '\'--'
ft..
'
Mihciii T. I'oM'.
(;«nEi' V.1. M>fii-»l.i'
film 1 . li.iu.x
*•"•»••"' .......
August 16, 1979
Mr. Paul T. Wrotenbery, Director
Governor's Budget 4 Planning Office
Executive Office Building
All West 13th Street
Austin, Texas 78701
Re: U.S. Environmental Protection Agency (EPA) — Draft Environmental Impact
Statement (DEIS) on the Proposed Issuance of a National Pollutant Discharge
Elimination System (NPDES) New Source Discharge Permit for Kirby Forest
Industries, Incorporated Pulp Mill Near Bon Weir, Newton County, Texas.
(May 1979.)
Dear Mr. Wrotenbery:
In reply to your July 17 memorandum, the staff of the Texas Department of
Water Resources (TDWR) has reviewed the referenced DEIS, relative to application
submitted to the Region VI Office of EPA by the Kirby Forest Industries,
Inc., of Houston, Texas for a NPDES permit to discharge into the Sabine
River, the wastewater from the proposed 650-ton per day Bleached Kraft
Market Pulp Mill, located on an approximate 500-acre site, 1.5 miles west
of the city of Bon Weir, in Newton County, Texas. This mill construction
project includes the construction of a 30-inch diameter, 4-mile long,
gravity pipeline to, and associated outfall structure at, River Mile 88.6
(tentatively) of the Sabine River, to discharge approximately 17 million
gallons per day (mgd) of treated process and sanitary wastewaters. EPA has
determined that the proposed facility constitutes a "new source" of pollutants,
as defined in Section 306 of the Clean Water Act of 1977. The proposed
project will involve an estimated initial capital investment of $200 million,
a peak employment of 1,000 persons during construction, and an ultimate
employment of 260 persons in the operational stage. Plans tentatively
provide for the start of construction in early 1981, and the start of mill
operations in 1983.
TDWR notes the following essential background data and factors, as a necessary
preface to the staff review comments to be made hereinafter:
1. On January 8, 1979, TDWR Issued to the applicant, Kirby Forest
Industries, Inc., State of Texas Permit No. 02106, pursuant to
Chapter 26 of the Texas Water Code, authorizing the applicant
"...to dispose of wastes from the Bon Weir Pulp Mill... to the
Sabine River (Segment 0503) in the Sabine River Basin." TDWR's
records show that the said permit authorizes the following
average daily discharge limitations: BODj... 3,445 Ibs. per day;
P.O. Box 13087 Capitol Sution • Auitin. Tcxu 78711 • Atcj Code 512/475-3187
-------
Mr. Paul 1. Wrottnbery
August 16, 1979
Page 2
TSS...3.770 Ibs. per day. The said permit provides lor the
discharging of treated effluents not to exceed an average of 13
mgd, and a maximum of 20 mgd, at the outfall at River Mile 88.6
of the Sabine River (Long. 93°37'15" - Lat. 30°42'15")- TDWR
records also Indicate that the applicant submitted a comprehen-
sive environmental assesf-.ent report on the proposed industrial
facility project, which also forms the basis of the referenced
EPA DEIS under-review (J.E. Sirrine Company. Environmental
Assessment for Proposed 650 Ton Per Day Bleached Kraft Market
Pulp Mill, prepared for Kirby Forest Industries, Inc., Houston,
Texas, and submitted to EPA, Region VI, Dallas, Texas. 2 Volumes.
September 9, 1977.) The scope and findings of TDWR's verification
analysis of the potential impacts of the proposed project on the
water quality of the Sabine River Segment 0503, are shown in the
TDWR Interoffice Memorandum dated August 4, 1978, included as
Appendix No. 1 of the referenced DEIS.
2. On June 25, 1979, TDWR approved the permittee's request that his
Permit No\ 02106 be temporarily suspended until October 1, 1982,
because construction of the proposed facility will not be started
prior to early 1981, and the facility will not be ready for
operations prior to 1983.
3. The applicant has determined that the total water requirement for
the proposed 650-ton per day pulp mill will range from 10 to 25
ragd. Because of substantial water quality and economic advantages,
the applicant plans to use ground water from the Jasper Aquifer
rather than surface water from the Sabine River. Hence, no water
rights issues or limitations are involved. (DEIS: section
4.3.3, page 34.)
it. The applicant has determined that the sanitary and process waste-
water will be controlled through separate sewerage and treatment
facilities systems (DEIS: section 4.5.2, pages 42-43). The
sanitary wastewater load, based on an equivalent population of
260 persons, will be treated in a 10,000-gpd extended aeration
treatment plant. The biological treatment method to be used for
the process wastewater (i.e., air-activated sludge process versus
oxygen-activated sludge process) will be determined during the
detailed facility design phase of the project. (DEIS: section
4.5.2.2, page 44.)
5. Future plans call for the expansion of the proposed pulp mill
from 650 tons per day to 1,000 tons per day. (DEIS: 3.1.1.2,
page 7.)
6. The applicant has presented two process alternatives: (a) a
conventional fiverstage bleaching process, and (b) a five-stage
bleaching process with pure oxygen delignification added. The
final decision on which process alternative will be adopted is to
-------
Hr. t-aui 7. Wrctenbery
August Ifc, 1979
Page 3
be naee later, during the final design phase of the facility,
based on an overall evaluation of economics, market requirements,
availability of equipment, and environmental requirements.
(DEIS: section 3.1.1.3, page 8, and section 4.2, pages 2G-32.)
7. The applicant has presented two alternate points of discharge for
the traated wastes (i.e., either River Mile 88.6 or Hiver Mile
86.6). The final decision on which discharge point will be selected
will be determined during the final facility design phase of the
project, based on economic, engineering, and environmental consid-
erations. (DEIS: Figure 3, page 27, and section 4.6, page 45.)
TDWR offers the following staff review comments, relative to water resources
matters within our statutory purview and interest:
1. DEIS; section 3.2.2. page 22, and section 3.3, page's 23 and 24.
TDWR assumes that both the EPA and the Corps of Engineers — in
connection with their current and pending processing actions for
the issuance of permits under Section 402 of the Clean Water Act
of 1977 (NPDES Permit for new source pollutant discharge), Section
404 of the Clean Water Act of 1977 (permit for discharge of
dredge or fill materials into navigable waters of the United
States), and Section 10 of the River and Harbor Act of 1899 (non-
impedance of navigation) — will formally request TDWR's certifica-
tion regarding the compatibility of the proposed pulp mill project
with State of Texas water quality standards. Incident to the
preparation of the said certification, TDWR will consider impacts
of the "open-ended" factors described In items 2 through 7, above
insofar as they might affect the final volume and composition of
the wastes to be generated by the proposed industrial facility,
and the impact on the water quality of the receiving stream.
Thus, depending on the final capacity of the milljthe method
finally to be adopted for the treatment of process wastes, and
the location finally to be selected for the discharge point, TDWR
will address the basic questions as to whether we would recommend
authorizing a proportional Increase in the already permitted
waste loading, commensurate with the Increasing of the mill
capacity from 650 tons per day to 1,000 tons per day.
2. DEIS: sections 5.7.6 and 5.7.7. pages 151-152.
TDHR concurs In the favorable evaluation made In the DEIS (pages
151-152) and in the associated source document (I.e., section
4.2.8 of J.E. Sirrlne Company's Environmental Assessment (vol.
1) — see background item 1 above) regarding the mutual compati-
bility of the proposed pulp mill project with other existing or
potential water or water-related projects in the area of influence
Response to Comments from Texas Department of Water Resourc
1. Comment noted. No response required by USEPA.
2. Comment noted. No response required by USEPA.
-------
Mr. Paul T. Krotenbery
August 16, 1979
Page 4 .
^
(i.e., the 362,800-acre foot Bor. Weir Reservoir; the- 1,600,000-
acre-foot Lake Fork Reservoir; and the Blue Kills Nuclear Electric
Generating Station).
TDKR appreciated the opportunity of participating in the interagency review
and coordination process relative to the water resource aspects of the
proposed industrial project, pursuant to the National Environmental Policy
Act of 1969, and the Clean Water Act of 1977. Please advise if we can be
of further assistance.
Sincerely,
larvey Davis
Executive Director
-------
JOHN L.BLAIR
Chairman
CHARLES R.JAYNES
Vice Chairman
BILL STEWART. P. E.
Executive Dircctoi
August 21, 1979
ei23SHl:AL "".llf BOl'iLV
AUSTIN TtXAS 7b75t
512(«-. 5711
WILLIAM N.ALLAN'
FRED HARTMAN
0 JACK KILIAN.M. D.
OTTO R. KUNZE.Ph. D.. P. t.
. FRANK H.LEWIS
WILLIAM D. PARISH
Mr. Ward C. Goessling, Jr.
Budget and Planning Office
Office of the Governor
411 West 13th Street
Austin, Texas 78701
Subject: Draft Environmental Impact Statement for Kirby
Forest Industries, Inc., Bleached Kraft Pulp
Mill near Bon Wier in Newton County, Texas
Dear Mr. Goessling:
In order to receive a construction and an operating permit,
the proposed facility must be designed and operated to
comply with all Texas Air Control Board rules and regula-
tions including hydrogen sulfide emission limits. If it
meets these requirements, it will be consistent with the
Texas Air Pollution Implementation Plan. If not, it may
not be built and operated. The statement (page 90) needs
to be revised to recognize this.
Thank you for the opportunity to review this document.
we can be of further assistance, please contact me.
Sincerely you^,s,
"
If
Roge_r R. Wallis, Deputy Director
Standards and Regulations Program.
cc: Mr. Howard Baker, Regional Supervisor, Beaumont
Response to Comments from Texas Air Control Board
1. The 650 tons/day mill, as presently designed, would exceed the
TACB standards. However, based on modelling of the 1,000 ton/day
mill, it was estimated that the TACB standards would not be exceeded
(Section 5.8 of FEIS) due to improved emission controls. Appropriate
changes in the executive summary and on page 90 of the DEIS have been
made to reflect these differences, and to clarify that the mill must
meet TACB standards in order to obtain a construction and operating
permit.
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'=. >.•'.;:
PARKS AND WII_DI_IFE DEPART
PERRV R.BASS
Chairman. POM Woith
JOE K,FULTON
Vica-Chairman. Luuboch
PEARCE JOHNSON
Austin
CMAR'.LS D. TRAVIS
EXEC.U1!VE Dilution
4200 Smilh School Road
Austin. Tti>d» 787fld
. £DV.'t\ L CO/
; Dj.Ua;
W. B. OSBORN'.JP
Santa Elena
August 22, 1979
Mr. Ward C. Goessling, Jr.
Economic and Natural Resources Section
Governor's Budget and Planning Office
Executive Office Building
411 West 13th Street
Austin, Texas 78701
Re: Bleached Kraft Market Pulp Mill, Bon Wier, Texas
Dear Mr. Goessling:
The above-referenced document has been reviewed and compared to
information contained within an application to the Texas Department
of Water Resources for a waste discharge permit.
In addition to those species of fish listed on page 106 of the draft
environmental impact statement, Department records show that a paddlefish
(Polyodon spathula) was taken by a fisherman below Toledo Bend Dam and
several blue suckers (Cycleptus elongatus) were collected by Department
personnel from the Sabine River drainage about five years ago. The
paddlefish is listed by the Department as an endangered species in
Rule 127.30.09.001-.006, attached, and the blue sucker is listed by the
Department as a protected nongame species in Rule 127.70.12.001-.008,
attached.
Thank you for the opportunity to comment on this document.
Sincewly,
Response to Comments from Texas Parks and Wildlife Department
1. The paddlefish was included in the list of endangered species
on page 119 of the DEIS. The blue sucker has been added to this
list in response to the comment. In addition, two blue suckers were
collected in the vicinity of Bon Wier during a 1979 TPWD survey (TPWD
in preparation) (R. Helton, TPWD, personal Communication).
CDT:LER:lmw
Attachments
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United States Department of the Interior
OFFICE OF THE SECRETARY (
SOUTHWEST REGION
POST OFFICE BOX 2MKK
ALBUQUERQUE. NEW MEXICO H710:i
ER-79/634
AUG 2 7 1979
Mr. Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency
1201 Elm Street
Dallas, Texas 75270 '
Dear Mr. Spotts:
This responds to Regional Administrator Adlene Harrison's July 3, 1979,
notice requesting comments from interested agencies and the public on the
Draft Environmental Impact Statement for the proposed Bleached Kraft Market
Pulp Mill, Sabine River, Newton County, Texas. The following comments are
provided for your consideration.
Known mineral resources in Newton County include petroleum, natural gas,
and peat. Although no conflict is anticipated between the proposed project
and any mineral resource development, we suggest that subsequent versions
of this document briefly discuss mineral resources of the area and the
effects of the proposed project upon them.
The statement should indicate the types Ce.g., public-supply, private,
industrial, agricultural, and irrigation) and distribution of wells that
may be appreciably affected by the withdrawals of ground water for plant
use. Also needed are suggestions, where appropriate, for mitigation of
impacts such as increased pumping costs, replacement of wells, and alter-
ations such as changes in pump settings or installations of different
pumps.
Sections of the draft environmental impact statement (DEIS) are deficient
with respect to the fish .and wildlife resources of Newton County and the
Sabine River. Throughout the DEIS generalized statements are used to
assess environmental impacts. Without adequate project specifications
and biological information, descriptions of environmental impacts expected
to occur as a result of project construction are speculative. The technical
shortcomings of this report often hinder analysis of project effects on
fish and wildlife resources.
SPECIFIC COMMENTS
Page ii, Executive Summary - Environmental Setting - The section which
indicates that the Sabine River flow at Bon Wier is almost entirely con-
trolled by discharges from Toledo Bend Dam should be amended to identify
Response to Comments from United States Department of Interior
1. A complete description of the flow characteristics of the Sabine River
was provided in Section 5.2.1.1 of the DEIS, and included a breakdown
of mean monthly and mean annual flow data (Table 8 of DEIS). The
water quality modelling analysis which was conducted for both the 650
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all other factors that control water flov. The statement that data
gathered from below Toledo Bend Dam indicate that water quality standards
are generally met should be supported either by a list of actual data or
the source from which it was taken.
Page v, First Paragraph, Executive Summary - The Proposed Project - The
DEIS does not provide specific data regarding the location of sludge
lagoons, incinerators and land fills. It also does not address future
land fill and lagoon needs and extent to which each method will be used.
In addition, the statement only addresses these methods as possibilities.
The DEIS should address only those methods of waste treatment to be used.
Page 8, Section 3.1.1.4. Emission Control and Waste Reduction - The term
"sufficiently" as used in this section does not provide a base from which
to compare Federal and State air criteria listed in Appendices 5 and 6.
Page 9. Section 3.1.1.4. Emission Control and Haste Reduction - The lack
of facility specifications regarding waste water treatment does not pro-
vide adequate data to assess impacts.
Page 9,.Section 3.1.1.5, Discharge Method and Location - The statement
"Both the discharge point and pipeline right-of-way will be aligned to
avoid Cemphasis added) wetlands after the Corps of Engineers (COE) wet-
lands location determination is made" is in apparent contradiction with
the intent expressed by the COE letter to EPA dated October 10, 1978.
That letter informs EPA that any wetland crossing by the subject pipeline
is permitted under a nationwide permit as cited in C.F.R. 323.4-3. The
DEIS should reference this interagency letter, clearly identify adverse
impacts to the wetland habitat and its use, address the habitat's re-
covery potential and address alternate, more environmentally acceptable
routes.
Page 10, Section 3.1.2.1, Geology - The statements that topographic im-
pacts "should be minimal as long as careful consideration is given to
maintenance of natural drainage patterns and erosion control" and that
erosion and sedimentation problems "will be prevented by proper design
and installation of storm water drainage features" are based on possibil-
ities. The DEIS should provide a determination of impacts based on
specifications of the proposed project, not on speculation. The state-
ment that "because of the vast amount of forest land in the region", the
conversion of 150 acres of forest to an industrial site "will have a
negligible impact on forest resources" does not provide a data base from
which to make such a determination. The DEIS should provide the number
of acres of forest land remaining, the cumulative losses of such habitat
and the potential future losses due to an expanding industry or secondary
development in and around the plant site.
Page 10. Section 3.1.2.2. Hydrology - Surface Waters - It Is assumed that
the mathematical modeling of water quality on the Sahine River ere average
values along certain reaches or cross-sections. If so, some expression on
and 1,000 ton/day mills (Section 5.2.2 of DEIS; Appendix 1 of FEIS) in-
dicated that all water quality standards will be met. This conclusion
applies to operation of the KFI mill alone or in conjunction with the
expanded Boise Southern plant.
2. Information on the location of the landfills has been included on a re-
vised Figure 5 (page 29) of the DEIS. No new treatment lagoons will be
required since the existing system will meet all projected volume re-
quirements. No sludge lagoons will be employed In the proposed mill,
since sludge generated in the pulping process will be dewatered in clari-
fiers and recycled back Into the processing boiler. The proposed waste
treatment method will consist of air activated sludge processing (oxygen
activated sludge may also be used). An appropriate change has been made
on page 44 of the DEIS to clarify that air-actIvated sludge will be the
preferred treatment scheme.
3. An appropriate change has been made in the text to clarify the statement
regarding air quality criteria. A detailed analysis of air impacts as
they relate to air quality standards is presented In Section 5.3.2 of the
DEIS. Cumulative Impacts of the 1,000 tpd plant are discussed in Section
5.8 of the FEIS.
4. No detailed information on specific wastewater treatment methods Is currently
available, but all effluents must meet relevant water quality standards in
order for the NPDES permit to be issued.
5. Appropriate changes have been made In the DEIS (page 9; pages 23-25, and
page 123) to clarify that KFI will proceed under the Nationwide Permit.
The Corps of Engineers' response to EPA's request for supplemental infor-
mation (by letter from the COE to EPA, dated October 10, 1978) was that
the effluent pipeline between the plant and the river would be included
under the Nationwide Permit concept, assuming that the seven conditions
listed in CFR 123.4-3(b) concerning discharge of dredged material were
met. The letter also specified that a Section 10 permit would be required
for construction of the outfall pipe. Since all seven criteria listed in
CFR 323.4-3(b) will be met, KFI can proceed under the Nationwide Permit
Concept.
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the dynamics of river flow should be presented and the behavior of mill
wastewater plume should be presented. Also, water quality within the
plume zone and its changes downstream should be presented. The effects
of the relatively concentrated mill wastewater on fish and fauna should
also be addressed as well as any aesthetics intrusion. Perhaps a com-
parison of values between the right and left banks would be helpful.
Nowhere in the report is there addressed the possibility of mill waste-
water intruding into the shallower aquifers which others downstream may
be using as their sole source of water.
Page 11. Top of Page. Section 3.1.2.2. Hydrology - Surface Haters - The .
DEIS did not Identify the engineering designs that would mitigate surface
water impacts. This material should be included.
Page 11, Second Paragraph, Section 3.1.2.2. Hydrology - Surface Haters -
The statement, "domestic discharges should result in no adverse impact
on the river" (emphasis added), is too generalized. The DEIS should
identify impacts within the river system that would be expected to occur
should the effluent coliform count reach 200/100 ml.
Mathematical modeling of the Sabine River form Bayou Anacoco to Ruliff is
stated to indicate that water-quality standards for the river will) not be
violated as a result of the proposed discharge under average or base flow
conditions. Hovever, it is not clear whether the model included increases
in chloride concentration in the lower part of the river that would result
from the upstream migration of a saltwater wedge during low flow periods
(page 59).
Page 11. Third Paragraph, Section 3.1.2.2. Hydrology - Surface Haters -
Regarding the impacts due to highly colored water, the DEIS should pro-
vide river low flow rates and the percentage of time that low flow rates
occur. It should also identify contingency plans that would prevent un-
treated wastewaters from entering the river should the treatment system
fail.
Page 12, Section 3.1.2.2, Hydrology - Ground Hater - The DEIS should
quantify the recharge capacity loss of the Jasper Aquifer before asserting
insignificant impacts. The discussion of ground-water occurrence and
impacts should include aquifer characteristics used in calculating de-
clines in the piezometric surface.
Page 14, Section 3.1.2.5, Biology - Aquatic Biota - The DEIS fails to
clearly identify "Run-off control practices" that would produce "no
significant short and long-term impacts on aquatic biota . . . ." Also,
it fails to define the term "very low" regarding aquatic populations.
Although aquatic samples were apparently taken in October 1978, dates and
locations for the survey were not provided.
I Page 14. Section 3.1.2.5. Biology - Terrestrial Landscape Types - Comments
6. Stormwater runoff during the construction phase of the project is expected
to produce increased erosion. Channelization of Stormwater to natural
drainage, confinement of construction vehicles and machinery to specific
construction gates, roads and routes, and grading of areas to control
erosion is planned. Pollutants other than silt are not to be comingled
with Stormwater. Some spillage of paint, oil, and lubrication from vehicles
and machinery, etc. will occur, but is not expected to be significant.
7. The conversion of 150 acres of forest at the plant site represents only
approximately 0.015% of the total forested area in the influence region
(page 131 of the DEIS). Secondary impacts on forest areas in the project
area are discussed in Section 5.7.1.5 of the DEIS, and were not determined
to be significant.
8. Certain impacts o.n aquatic organisms could occur in the immediate vicinity
of the discharge pipe as a result of the effluent. Such impacts could
include elimination of benthic invertebrates and sublethal effects on fish
(avoidance behavior primarily). However, these Impacts would be highly
localized. Hater quality modelling of both the 650 and 1,000 ton/day
mills was conducted to determine downstream patterns of water quality
during operation of both KFI and Boise Southern mills (Appendix 1 of the
FEIS; Section 5.2.2 of the DEIS). The analysis showed that no water
quality standards would be violated. Potential aquatic impacts of dis-
charges from the KFI and Boise Southern mills are discussed in Appendix 3
and in Section 5.8 of the FEIS.
9. Studies conducted by the Texas Water Development Board (THDB 1967) con-
cerning groundwater conditions in the project area show that recharge of
aquifers in the area is mainly the result of direct Infiltration of rain-
fall. Small amounts of artificial recharge such as Infiltration of Irriga-
tion water, industrial wastewater and sewage occur in local isolated areas
in Jasper and Newton Counties but are not significant.
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(17)
(18)
(19)
provided for Section 3.1.2.1, page 10, regarding loss of forest lands
are applicable to this section.
Page 15, Section 3.1.2.5, Biology - Terrestrial Animals - The DEIS should
identify wildlife communities and discuss the rationale of how population
stress caused by displaced individuals would not adversely impact wild-
life resources in the influenced region. The DEIS failed to cite data
presented In Tables 22 and 23.
Page 15. Section 31.12.5. Biology - Endangered Species - The DEIS does
not adequately discuss the basis on which a "no affect" decision was
reached, and whether or not a formal Section 7 consultation with the
U. S. Fish and Wildlife Service was considered.
Page 15. Section 3.1.2.5. Biology - Noteworthy Biological Resources - The
DEIS does not define "Noteworthy Biological Resources."This definition
would help clarify this section.
Pages 23-24. Section 3.3. Alternatives Available to Other Permitting
Agencies - The DEIS discussion regarding issuance of COE permits is not
correct. , Information provided initially states that both a COE permit
pursuant to Section 10 of the River and Harbor Act of 1899 and one pur-
suant to Section 404 of the Federal Water Pollution Control Act (Clean
Water Act of 1977) will be required. Subsequent information insufficiently
explains the mandates of the COE "nationwide permit" for pipelines crossing
Section 404 areas. In addition, the section justifying compliance with
five (a, b, d, e, g) of the eight nationwide permit conditions Incorrectly
equates "discharge" (See Section 323.4-3.b., of C.F.R. Vol. 42, No. 138,
July 19, 1977) with "effluent" rather than "dredged material" generated
from the construction of the pipeline trench. The DEIS should consider
environmental impacts incurred from pipelaying activities across wetlands
in terms of fill and of restoration.
Page 44. Section 4.5.3. Storm Water Management - The DEIS does not ade-
quately discuss the methodCs) by which storm waters would be collected,
nor does It discuss procedures for storm water collection In the event
of a significant storm such as a hurricane.
Page 44. Section 4.5.4. Solid Waste Disposal - The DEIS does not Include
data showing that possible leachate components will not contaminate ground
water supplies.
Page 70. Section 5.2.2.2, Effects of Operation on Groundwater - The text
should include calculated or estimated water-level declines for the full
life of the project (presumably at least 30. years) at appropriate dis-
tances from the plant and at both, the minimum and maximum withdrawal rates
(10 mgd and 25 mgd). The values given In the draft statement appear to be
for the lower withdrawal rate (10 mgdl over a period of one year (page 70),
(94} I Page 75. Section 5.3.1.3. Regulations - Attainment Status - The DEIS states
\fry | a 1 1 a .
(20)
The lower Sablne River valley receives an excess of rainfall but only
about 25Z of it enters streams as direct runoff. The rest either evapo-
rates or enters the groundwater table as recharge. Since the present
recharge In the basin (500 mgd) far exceeds the withdrawals, there Is a
constant natural discharge from shallow groundwater aquifers back into
streams and rivers as springs and seeps. The withdrawal of ever in-
creasing amounts of groundwater for projects such as the KFI mill may
eventually lead to a balance between recharge and artificial withdrawals.
This would reduce or eliminate many of the natural discharges and reduce
groundwater recharge of the Sablne River. However, hydraulic gradients
In the vicinity of the river will continue to direct surface elevation
groundwater to the river.
The surface aquifer (Chlcot) Is not used In the Bon Wler area by any
significant consumers. Rather, its primary users are on the coast near
Orange where it and the Evangeline aquifer supply much of the water for
all uses. Because of the great distance between the source of mill waste
and the users and the tremendous dilution available both in the river and
in the groundwater, the chance for contamination of these aquifers by the
mill waste is therefore very small.
10. The comment Is noted, and an appropriate change has been made on page 11
of the DEIS to clarify the meaning of this statement. The engineering
design and method of construction of the outfall structure have not been
decided upon; however, mitlgatlve measures which may be utilized in
construction of the outfall Include: (1) maintenance and protection of
native vegetation; (2) use of mulches, nettings, or blankets for soil
stabilization; (3) construction coordination to expose the smallest area
for a minimum period of time; (4) scheduling of clearing and grading
during the dry season to minimize erosion (as feasible); (5) management
of surface runoff by diversion ditches. Impoundments, and dikes; (6)
traffic control for construction and earth hauling equipment; (7) seeding
areas with high erosion potential; (8) protection of stock piles of
previously excavated soil; (9) proper compaction of fills; and (10)
roughing graded slopes by scarification of the soil perpendicular to
runoff.
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that non-methane hydrocarbons (NMHC) emissions at the project site would
be "well below 100 tons/yr" and is therefore not subject to any offset
regulations. Regulations pursuant to the 1977 Clean Air Amendments, how-
ever, state that an offset is required at levels above SO tons/year.
Because KMHC emissions for the project site are not properly quantified,
the conclusion presented in the DEIS may not be justifiable. This should
be clarified.
Page 108. Section 5.5.1. Biology - Aquatic Habitat and Biota - Fish -
Discussion - In analyzing the reasons for low fish populations found
during the 1978 samples taken and those taken in 1969 and 1950, the DEIS
failed to compare the continuity between the different sampling programs.
In addition, the DEIS does not clarify the basis on which a one tine
sampling program could determine the cause of low fish populations. We
agree that water released from Toledo Bend Dam does not produce conditions
conducive to natural riverine populations. However, we believe, as Dr.
Conner does (Appendix 9), that a more extensive fish study would provide
a substantiated basis from which to assess fisheries Impact. In light of
the proposed increased discharges from the Boise Southern Mill and the
proposed Kirby Forest Industries (KFI) discharges, a more extensive fish
study would be necessary prior to asserting impacts, the DEIS should
discuss in detail fisheries impacts Imposed by water quality changes
resulting from the KFI and Boise Southern discharges.
Page 109. Section 5.5.1. Biology - Aquatic Habitat and Biota - Fish -
Conclusion - The DEIS does not provide a conclusion based on all of the
projected water quality changes addressed in Section 5.2. This section
should enumerate Impacts to the fisheries resource of the Sabine River
based on environmental changes brought about by current and proposed
water and wastewater discharges.
Page 109. Section 5.5.1. Biology - Aquatic Habitat and Biota -•Aquatic
Birds - The DEIS does not adequately assess impacts to aquatic birds. It
Is unrealistic to base impact statements on a one-month. (October 1978).
bird survey. This section should discuss In detail, Impacts to aquatic
birds by water and air quality changes resulting from the KFI and Boise
Southern dishcarges and emissions. Also, the DEIS did not address im-
pacts to migratory birds and waterfowl.
Page 110. Section 5.5.1. Biology - Aquatic Habitat and Biota - Mammals
and Reptiles - The DEIS, as in the previous section, does not provide
sufficient data to assess impacts on any of these populations.
Page 111, Section 5.5.1.2. Impacts on Aquatic Ecosystem - Operation
Impacts - The DEIS does not adequately consider possible distributional
changes of aquatic communities resulting from proposed additional dis-
charges. It falls to address environmental impacts based on a sampling
program that encompasses the seasonal water level variations resulting
from the operation of Toledo Bend Dam. Also, no reference has been made
of the 1979 Stream Evaluation Study for the State of Texas. This
11. The comment is noted, and an appropriate change made on page 11 of the
DEIS to clarify the'meaning of the coliform standard.
12. Comments made by the Sabine River Authority (see SRA comments) Indicate
that although salt water has "occasionally reached water intakes in the
Old River on the Louisiana side it has never reached the SRA pumping
station and is not expected to at any time In the future." A change
has been made on page 59 of the DEIS to reflect this fact.
13. Base flow Is of greater Importance in assessing water quality violations
than statistical low flows because it is the flow established by TDWR
above which Texas Water Quality Standards must be met as an annual arithmetic
mean (See Section 5.2.1.1 of the DEIS). For purposes of comparison,
however, the following USGS low flow statistics (USGS 1978b) for the Bon
Wier gage may be'useful:
Base flow
1 day 10 year
3 day 10 year
7 day 10 year
14 day 10 year
30 day 10 year
14 day 5 year
30 day 100 year
387.1 cfs
252.9 cfs
259.9 cfs
281.3 cfs
301.7 cfs
467.6 cfs
374.8 cfs
390.3 cfs
The wastewater treatment plant will be required to have multiple units
for each process so a complete failure of the system would be highly
unlikely. Standard provisions such as a standby power source and an
on-site Inventory of spare parts will also be maintained to reduce the
down time of any damaged units. If a polishing pond' is constructed, It
may also be possible to use it as an emergency storage reservoir for
partially treated wastewater. Any such emergency or standby .provisions
must be considered by KFI at the time of facilities design in accordance
with the requirements, of TDWR.
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cooperative study, in which the U. S. Fish and Wildlife Service, several
State agencies, and the Environmental Protection Agency participated,
classifies the Bon Wier area of the Sabine River as "Value Class I -
highest valued fishery resource." By project definition, the Sabine River
has (1) "documented occurrence (legally defined) of State or Federally
chartered endangered species", (2) "documented present occurrence of a
State or Federally chartered threatened species", (3) "habitat maintaining
outstanding populations of species of high Interest as defined by the State
to include self-sustaining wild populations that maintain a hiph yield or
represent a unique aesthetic, scientific, economic, educational, or rec-
reational value", and (4) "very low or essentially no potential for
restoration or reclamation of the habitat to its present species composition
and population levels, no alternate resource could be introduced that would
be as highly valued; no acceptable options are available to compensate for
the loss of this habitat at this time". The DEIS presents neither an ade-
quate survey of the aquatic ecosystem nor an adequate discussion regarding
adverse Impacts to that ecosystem.
Page 111. Section 5.5.2.1. Existing Environment - The DEIS should provide a
more specific description of the existing environment, including floral and
faunal distribution maps.
Page 115. Section 5.5.2.1, Existing Environment - Vegetation of the Pipe-
line Right-of-Way - Certain assessments of environmental Impacts are based
on unclear project specifications. As previously stated, the lack of per-
tinent data has hindered analysis of permit requirements as well as analysis
of recommendations intended to mitigate losses.
Page 115-116. Section 5.5.2.1, Existing Environment - Terrestrial Animals -
The DEIS does not clearly establish the fact that a onetime sampling program
produces only indications of existing populations. This should be clarified.
Pages 117-121. Section 5.5.2.1. Existing Environment - Endangered Species -
Plants - Animals - The DEIS does not present sufficient survey data to con-
clude the proposed action will not impact threatened or endangered species.
Our review indicates it may have an effect upon threatened or endangered
species. Therefore, we request you enter Into formal Section J consultation
with the Regional Director, U. S. Fish and Wildlife Service, F. 0. Box 1306,
Albuquerque, New Mexico 87103, as provided by the Endangered Species Act of
1973 as amended and the January 4, 1978, regulations governing Section 7
consultation. The consultation will address the impacts of your action on
the threatened/endangered species. If you need further assistance in regard
to the consultation process, we suggest you contact the Service's Endangered
Species Specialist at the Austin Area Office,.300 E. 8th Street, Room G-121,
Austin, Texas 78701 (FTS 734-54381 or the Regional Office (FTS 4J4-39J2).
Page 123. Section 5.5.2.2. Impacts on Terrestrial Ecosystems - Plants -
The. DEIS provides no definition of "tree conservation". Also, the width.
of the pipeline right-of-way should be presented.
14. Section 5.2.1.1 of the DEIS discusses the recharge capacity of the project
area groundwaters. This information is supplemented by studies by the
Texas Water Development Board (TWDB 1967). The aquifers of interest are
recharged at a rate of 500 MGD with a present withdrawal rate of 90 MCD.
All of the aquifer* In the vicinity of the proposed mill are fully charged.
The Chlcot Aquifer is recharged primarily from local precipitation and
•treaaflov. The Evangellne receives its primary recharge from precipita-
tion and streaaflov on Its outcrop and In some places from the overlying
Chlcot. The Jaaper Aquifer receives recharge from precipitation and
streamflow on its outcrop. Recharge is abundant and is not considered to
be a limiting factor to the amount of water which can be withdrawn from
wells under practical conditions.
The Jasper Aquifer (which has a thickness in excess of 2,000 feet) Is
expected to be the well water source. Pumping level elevations after the
cone of depression has reached steady-state end at a pumping rate of 25
MGD, indicate an estimated average draw-down of 170 feet (Guyton et al.
1977). Adding a contingency of 50 feet as possible future decline in
water levels caused by outside pumping, a future estimated average pump-
ing level of about ISO feet below land surface may be computed.
15. Storm water runoff during the construction phase of the project Is ex-
pected to produce Increased erosion. Channelization of stormwater to
natural drainage, confinement of construction vehicles and machinery to
specific construction gates, roads and routes, and grading of areas to
•control erosion Is planned. Pollutants other than silt are not to be
commingled with stormwater. Some spillage of paint, oil, and lubrication
from vehicles and machinery, etc. will occur, but Is not expected to be
significant.
Dates, locations and results of aquatic sampling conducted in association
with preparation of the DEIS are described In Section 5.5.
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Page 124. Section 5.5.2.2, Impacts OR Terrestrial Ecosystems - Animals -
The statement that "no rare, endangered, or uncommon species of verte-
brates were observed In the assessment area".may be correct. However,
the DEIS should explain that the survey conducted on a one time basis
should not be considered as indicative of distributional patterns of
species listed on Table 24.
Page 124-125, Section 5.5.2.2. Impacts on Terrestrial Ecosystems -
Operation - The DEIS should have addressed impacts of non-methane hydro
carbon (NMHC) to plants and animals. Also, this section reveals that
KFI will require 92 percent more process wood, thereby increasing tree
harvest. To meet demands extensive silviculture will be implemented,
thus decreasing the diversity of forest lands. The DEIS did not addres
impacts of decreased forest land diversity on terrestrial species.
We appreciate the opportunity to comment on this statement.
Sincerely,
ayroond P. Churan
Regional Environmental Officer
16. The total amount of forested land which would be eliminated for the mill
site represents approximately 0.015% of the total forested area in the
Influence region (page 131 of the DEIS). Secondary impacts of the project
on forest areas are discussed In Section 5.7.1.5 of the DEIS, and were
determined to be Insignificant.
17. .Section 5.5.2 of the DEIS discusses impacts on terrestrial animals.
Terrestrial habitats on the Bon Wier property are not unique and are
continuous with extensive and similar habitats off the property. Hence,
no terrestrial animal should be limited in abundance or reproductive
potential by habitat unavailability. Wildlife on the project site would
be forced to migrate into adjoining habitats and compete to some extent
with existing populations, however.
18. A formal Section.7 consultation between USEPA and USFWS has been under-
taken to determine potential Impacts on Federally listed species. Please
refer to the biological assessment (Appendix 3 of the FEIS) prepared as
the basis of the consultation for results of this analysis.
In order to determine the impacts on state listed species, the most
recent State list of endangered and threatened organisms which could
occur In Newton County has been obtained (Table 1). Of the species
listed In Table 1 only the eastern big-eared bat, Louisiana pine snake,
Louisiana milk snake and Texas horned lizard could occur on the project
site. The pine snake is usually associated with long-leaf pine forests,
and would more likely be found in the extreme northeastern section of the
property, although.it could occur In other .parts of the site and project
area as well. The ranges of the mole salamander and southeastern bat are
to the west of the project s,lte. (Davis 1974 and Thomas 1974; both In
Sirrlne 1977a) but they could possibly occur here.
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Table 1.
5 1. Species of threatened or endangered wildlife
which may be present in the project area.
(Source - Potter 1979).
Species
•Red wolf
•••Southern Bald Eagle
•••Artie peregrine falcon
•Eskimo curlew
•Interior least tern
**Red-cockaded woodpecker
•••American alligator
•Paddleflsh
•••Bat, Rafinesque's big-eared
•••Bat, southeastern
•Egret, reddish
•••Ibis, white-faced
•••Kite, swallow-tailed
•••Osprey
•••Wood Stork
••Least tern
••Texas horned lizard'
•••Snake, Louisiana milk
***Snake, Louisiana pine
••Salamander, mole
•••Darter, river
••Darter, western sand
••Blue sucker
Scientific Name Status
Canls rufua E
Haliaectus 1. leucocephalus E
Falco peregrinus tundrlus E
Numenius borealis E
Sterna alblfrons athalassos • E
Dendrocopos borealis E
Alligator mlssissiplensls E
Polyodon spathula E
Plecotus rafinesquli T '
Myotis austrorlparlus mumfordi T
Dichromanassa r_. rufescens T
Plegadis chlhi T
Elanoides £. forflcatus T
Pandion hallaetus carollnensis T
Mycteria amerlcana T
Sterna alblfrons antillarum T
Phrynosoma cornutum T
Lampropeltls trlangulum gentllls T
Pituophls melanoleucus ruthveni T
Ambystoma talpoideum T
Hadropterus shumardi T
Ammocrypta clara T
Cycleptus elongatus T
•possible occurence in Newton County
••probable occurence in Newton County
•••confirmed occurence in Newton County
E • Endangered
T - Threatened
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Other threatened or endangered species which are on the State list and
could potentially occur in the project area would include the wood, stork
(confirmed for Newton County), white-faced ibis (confirmed for Newton
County), swallow-tail kite (confirmed for Newton County), reddish egret
("possible" occurrence in Newton County), the western sand darter ("probable"
occurrence in Newton County), and the blue sucker ("possible presence").
Several blue suckers were collected by TPWD in the Sabine River drainage
'5 years ago (TPWD 1979) and 2 were collected in a 1979 TPWD study (TPWD
in preparation). A school of blue suckers were also observed near Bon
Wier during the TPWD study (R. Helton, personal communication). A paddle-
fish was caught by a fisherman below Toledo Bend Dan (see response to
TPWD comments). Paddleflsh are known to possibly occur in Newton County
(Table I).
Elimination of terrestrial vegetation on the plant site will cause a
small reduction in the amount of habitat available for the eastern big-
eared bat, Louisiana pine snake, and Louisiana milk snake. However,
abundant similar habitat Is present in surrounding areas. Also, since
the amount of forest affected by the site represents only 0.015% of the
total amount of forestland in the influence region. Impacts of the elimi-
nation of terrestrial vegetation on these species will be slight.
No Impacts on species of State listed terrestrial wildlife are expected
as a result of pine harvest since no direct increases in pine pulpwood
will be required by the mill. The increased hardwood harvest which is
projected is not expected to have Impacts on State listed species either,
'since harvest will not exceed growth (hardwood harvest is currently equal
to 44.3% of growth in Southeastern Texas).
Since plant discharges will meet all State and Federal water quality
requirements, no significant impacts on State listed species are pro-
jected to occur due to mill emissions. Elevated color levels In the
Sabine River under worst-case, low-flow conditions could produce be-
havioral avoidance patterns or other sublethal impacts on aquatic species,
but such flow conditions are rare. The mill will produce only a small
increase in color under average conditions (Section 5.2.2 of DEIS; Section
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5.8 of FEIS) and therefore will normally have a very minor effect on
endangered or threatened aquatic species. This statement Is true for
both the KPI mill alone or operating simultaneously with the expanded
Boise Southern mill (Section 1 of FEIS).
19. The comnent has been noted, and a change made on page IS of the DEIS In
order to clarify the terminology employed. -
20. Comnent has been noted and appropriate changes In the DEIS (pp 9, 23-25,
115, and 123) were made In order t» clarify the permit requirements, and
definition of permit terminology. Only minimal Impacts to wetlands will
occur since KFI will 'proceed under the Nationwide Permit concept If the
discharge pipeline possibly affects such areas (Section 3.3.1 of DEIS).
21. Contaminated stormvater Is that which passes through raw materials or
comes In contact with process units and results In polluted water (usually
TOC In excess of 70 mg/1 and oil and grease In excess of 15 mg/1). In
order not to oversize plant sewers excessively, uncontamlnated stormwater
would be allowed to drain naturally. Contaminated stormwater would drain
into process sewers and be treated In the waste treatment plant. Treat-
ment plants are typically sized to treat a 10-year, 24 hour duration
rainfall. For the Bon Wler area this rainfall Is approximately 7.5
Inches/24 hours (US Soil Conservation Service 1961). Peak plant storm-
water runoff Is estimated to be 7,000 gpm.
22. The solid wastes to be disposed of In'the on-slte land fill consist of
biological solids, inert solids, grit and screenings from the wastewater
treatment process, dregs and grit from the recaustlctzing process, and
general plant debris. According to the Texas Department of Water Re-
sources waste evaluation and classification guidelines (TDWR 1976) these
wastes, with possibly the exception of biological solids, are expected to
be classified as Class III, I.e.*,' essentially Inert and Insoluble Industrial
solid waste. The biological solids are-associated with the waste treatment
plant and will either be discharged to a lined pond (whose bottom permeability
will be
boiler.
will be less than 1 x 10~ cm/sec) or dewatered and burned in the power
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23. Please refer to response number 14 (USD01) for comment on groundwater
uses.
24. The comment with respect to Section' 5.3.1.3 of the DEIS is incorrect.
Before offsets are to occur in non-attainment areas, potential emissions
must exceed 100 ton/year for the source to be a major emitter. If the
allowable emissions are less than SO ton/year, then a source need only
comply with SIP requirements. NMHC potential emissions of the proposed
plant are below 20 ton/year.
25. The comparisons of fish populations in this portion of the Sabine River
were based on Table 20 (pp 106-107 of the DEIS). The comparisons were
made between the 1978 EPA survey of October 1978 and previous studies,
including those of Dr. Conner between 1969 and 1971, and those of Suttkus
and Gunning (1969, 1970). The 1978 EPA study was conducted because a
survey of the literature indicated that very little biological data were
available for this part of the Sabine River other than the studies of
Drs. Suttkus and Gunning and Dr. Conner. A change has been made in
Table 20 to explain the results of Conners' studies, which are summarized
in Appendix 9 of the DEIS. Species in Table 20 labelled with an asterisk
were considered by Dr. Conner to have been "common" in this portion of
Sabine during 1969-1971, whereas those labelled with a double asterisk
were judged to be "abundant" (and probably "ecological dominants"; Conner,
Appendix 9). Dr. Conner concluded that the species richness and diver-
sity of the fish populations of this part of the Sabine had been "...con-
spicuously reduced", "....temporarily at least..." but could offer no
explanation for this situation without additional long-term observations.
He also stated that the results were surprising because the extremely low
level of the river should have "facilitated the use of fine-mesh seines"
(Conner, Appendix 9 of the DEIS).
During the period following the submittal of the DEIS, the TPWD completed
a study of fish abundance and diversity In the stretch of the River
. between Orange, Texas and Toledo Bend Dam (TPWD in preparation). This
study, as well as the results of the 1978 Stream Evaluation Study for the
State of Texas (USFWS 1978), are discussed in the Section 7 biological
-------
assessment (Appendix 3 of the FEIS). They indicate that a diverse fish
population exists in the Bon Wier area. Potential impacts of KME on fish
populations are also discussed In the assessment, and were determined to
be only ninor.
26. Potential Impacts of the discharges from both the Kirby and Boise Southern
mills on fisheries resources and endangered species are discussed in the
Section 7 biological assessment (Appendix 3 of the FEIS). Potential
Impacts of color associated with discharges of Kraft Mill Effluent are
discussed In the DEIS (pages 68-69; 111), the Technical Support Document,
and in the Section 7 biological assessment. None of the impacts of the
mill discharges on the aquatic ecology of the River are predicted to be
significant.
27. The comment has .been noted, and appropriate changes made in the description
of the existing communities on pages 109 (aquatic birds) and 117 (terres-
tial birds) of the DEIS; impacts to bird populations are discussed on
page 125 of the DEIS, and are not expected to be significant.
28. The comment has been noted and appropriate changes made on page 110 of
the DEIS to clarify the nature of existing mammal and reptile populations.
29. The comment has been noted and an appropriate change on page 111 of the
text of the DEIS made to clarify impacts of the proposed mill on aquatic
communities. These impacts are also discussed in Section 7 biological
assessment (Appendix 3 of the FEIS). The assessment Includes a dis-
cussion of the results of the 1978 Texas Stream Evaluation Survey and the
more recent study by TPWD near Bon Wier.
30. Comment noted. No response required by USEPA.
31. Comment noted. No response required by USEPA.
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32. Fish and wildlife assessments were also conducted by University of Houston
and Rice University professors as part of the Environmental Assessment.
Appropriate changes have been made on pages 69 and 108 of the DEIS to
clarify that conclusions made concerning results of the 1978 EPA Survey
were based on a one-time sampling effort.
33. EPA Region VI has entered Into a formal Section 7 consultation with
USFWS, and has completed a biological assessment to be used in the con-
sultation (Appendix 3).
34. The comment has been noted. The width of the pipeline right-of-way (30
feet) is given on page 115 of the DEIS. Conservation practices would
Include routing the pipeline to avoid unusually large trees (or stands of
unusual trees) and selective cutting.
35. No significant Impacts on State or Federally listed species are predicted
(see response number 18 above). Please refer to Appendix 3 of the FEIS
for a discussion of potential impacts on Federally listed endangered
species.
36. Impacts of harvesting have been clarified on pages vi, vli, 122 and 123
of the DEIS. There will be no actual increase in current harvesting
levels of pinewood caused by the pulp mill itself. The indirect increases
In pinewood harvest which will occur will be caused by the demand for
wood by KFI's plywood and saw mills. The proposed pulp mill will utilize
waste chips from these facilities. If the pulp mill were not built,
pinewood harvest levels would still Increase due to demand from KFI's
plywood and sawmills and waste chips would be sold to other paper companies.
Hardwood harvest on KFI's holdings will Increase directly by 136,000
cords/year as a result of demand generated by the mill. However, because
KFI employs modern conservation and forest management practices (including
close coordination with state and Federal agencies) and because hardwood
harvest will not exceed growth. Impacts of this Increase will be minimal.
Only-normal quantities of total hydrocarbon emissions are expected from
the lime kiln and wood fired boiler stationary sources. These emissions
are dwarfed when compared with the estimated 2.6 Ib/hr per 100 acres of
volatile hydrocarbons emitted from pine forest.
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/*
x>f <0
BBIDE RIVER RI1THORITY
of /
August 30, 1979
Mr. Clinton B. Spotts
Regional EIS Coordinator
EPA, Region 6
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
Please find attached our comments on the Environmental Impact
Statement for the Kirby Bleached Kraft Market Pulp Hill near
Bon Wier, Texas.
He appreciate this opportunity for imput in the review process.
Please include our agency on your mailing list for copies of the
final EIS.
Please contact me if you have any questions concerning the comments
submitted.
Sincerely,
L} otdJl J*.
David S. Parsons
Technical Division Manager
DSP:pns
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.COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR KIRBY FOREST INDUSTRIES BLEACHED KRAFT
PULP MILL NEAR BON WIER, TEXAS
For purposes of discussion, the sections of the Kirby Forest Industries EIS
of particular concern to the Sabine River Authority of Texas (SRA) can be
considered under the following subject areas:
(1) Effects of the proposed discharge upon stream water quality;
(a) Based on the evidence at hand, it appears that the assimilative
capacity of the river will be adequate to handle wastewater
loading from the proposed discharge. Math modeling data indicate
that no violations of existing stream standards should result.
(b) Although generally considered to be an aesthetic problem, the
increased color levels expected to occur downstream from the
proposed discharge during low-flow periods cannot be completely
discounted in terms of potential impacts. A primary concern of •
the SRA is related to potential effects of increasing stream color
levels in the lower Sabine River upon existing and future downstream
water uses.
(c) Instream chemical and biological monitoring by the SRA is planned
in order to document the effects of the proposed discharge upon
stream water quality. Sampling will be done above and below the
discharge point both before and after construction of the plant.
(2) Existing biological condition of the Sabine River near Bon Wier:
(a) Several statements* made in the text of EIS indicating the existence
of a state of low or reduced biological productivity in the Sabine
River near Bon Wier are essentially unsubstantiated by actual data
and should either be excluded or highly qualified in the text.
(b) Conclusions attributing the previously mentioned reduced biological
productivity to fluctuations in discharge volumes from Toledo Bend
Reservoir are therefore very questionable.
(c) It is felt that the highly subjective nature of this information
should be pointed out in order to discourage its repetition in other
future reports.
(3) other statements noted to be specifically inaccurate or questionable;
(a) pp. 58, line 12-14: this statement concerning salt water intrusion
to the Sabine River Authority pumping station is incorrect as it
appears in the EIS and also in the referenced publication. Although
salt water has occasionally reached water intakes in the Old River on
the Louisiana side it has never reached the SRA pumping station and,
based on existing stream channel alignments, is not expected to at
any time in the future.
(p.ii, line 21-26; p.14, line 19-22; p.69, line 29-30; p.109, line 7-11)
Response to Comments from Sabine River Authority
1. Comment noted. No response required by USEPA.
2. Comment noted. Potential impacts of the proposed mill on downstream water
uses have been discussed in the response to comments received from the
General Land Office.
3. Comment noted. No response required by USEPA.
4. The statements on pages 14, 69, and 109 have been modified to clarify the
status of biological productivity in the Sabine River, based on more
recent data (TPWD in preparation) (see Appendix 3 of the FE1S).
5. The comment has been noted, and an appropriate change made on page 58 of
the DEIS to correct the statement concerning salt water intrusion.
-------
(b) pp. 59, line 13 and p. 65, lines 24-25: the use of the word
"irrigation" in reference to the SRA pumping plant north of Orange
is both inaccurate and misleading and should be deleted. Only a
very small percentage of water distributed through the SRA canal
system is used for irrigation purposes. The principal use at the
present time is for industrial purposes.
(c) p. 110, lines 23-24: the statement that "the River's appearance
does not warrant its inclusion in this system" seems both presumptuous
and, based on the actual field time spent in the October, 1978 survey,
somewhat questionable.
6. The comment has been noted, and the word "irrigation" eliminated from the
relevant sentences on pages 59 and 65.
7. The comment has been noted, and an appropriate change made on page 110 of
the DEIS.
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T;ec.'icr.al EIS Coordinator (rASAF;
U. S. Environmental Protection
Agency
1201 Elir. Street _
Dallas, Texas 75270
Dear Mr. Spotts:
This Is in reply to your .-V.ieust 24 letter which requested a review of
Federally listed and proposed species which were discussed in the Draft
Environmental Impact Statement for the Bleached Kraft Market Pulp Mill.
This proposed rail! will be located near Bon Weir, Texas.
Your Draft Environmental Impact Statement listed a number of species
protected by the Endangered Species Act. Only three of these would
be Hkely to occur within the project area. These are the red cock-
aded woodpecker (Dfcndrocopos borealis), American alligator (Alligator
mississippiensis), and bald eagle (Hallaeetus leucocephalus). Your
comments and reference to the 1977 study by Sirrine and July, 1978
EPA survey allude that these species probably do not occur at the
project site. However, no data was presented which would allow a
reader to come to a similar conclusion. Further, if a listed species
is found to occur in the project area, it is important to provide
sufficient information and discussion which would reveal if the pro-
ject may or may not affect that species. That type of conclusion is
then used as a basis in determining-whether formal consultation is
required. That is, a may affect determination requires formal con-
sultation.
No plants which are Federally listed or proposed for listing are known
to occur in Newton County. Presumably the 16 plants listed in the
Draft Environmental Impact Statement are protected only by state law.
One Federally proposed species, the plain pocketbopk pearly mussel
(Lainpstlis satura), was not included in your discussion. This species
occurs in the Sibine, Trinity, and San Jacinto river systems.. Certain
types of chemical discharges are known to have a detrimental impact
upon fresh water mussels.
Response to Comments from US Department of the Interior Fish and Wildlife
Service
1. Formal Section 7 consultation between USEFA and USFWS has been initiated,
and a biological assessment prepared on the potential impacts of the
proposed project on the red-cockaded woodpecker, bald eagle, American
alligator, and plain pocketbook pearly mussel (Appendix 3 of the FE1S).
Save Energy and You Serve America!
1 1979
ATLANTA OFFICE
-------
in the rerr.^inaer c-: tni<- jener.
Upon receipt of the Fish and Wildlife Service's species list, the
"s-dtraZ agency authorizinc:. funding, or carrying out the construct ior.
action is required to conduct 2 biological assessment for the purpose
of identifying listed species vhich are likely to be affected by such
action. Proposed species are included on the list even though they do
not have legal protection under the Act. Their inclusion recognizes
that they may be listed anytime and have the portent to cause delays or
modifications to the proposed action. In light of this, we recommend
that those species be included in the biological assessment .
The biological assessment shall be completed within 180 days after
receipt of the species list, unless it is mutually agreed to extend this
period. The biological assessment should include: 1) the results of a
comprehensive survey; 2) results of any studies undertaken to determine
the nature and extent of any impacts on identified species; 3) considera-
tion of the cumulative effects upon the species or its critical habitat;
4) study methods used; 5) difficulties encountered in obtaining data and
completing the proposed study; 6) conclusions including recommendations
as to further studies, and 7) any other relevant information.
For purposes of providing interim guidance, the Fish and Wildlife Service
considers construction projects to be any action conducted or contracted
by the Federal agency designed primarily to result In the building or
erection of man-made structures, such as dams, buildings, roads, pipe-
lines, and the like. This includes consideration of major Federal
actions such as permits, grants, licenses, or other forms of Federal
authorization or approval which may result in construction and which
significantly affect the quality of the human environment. In addition,
other actions that have the potential of becoming or are controversial,
may be considered as construction.
If the biological assessment reveals that the proposed project may
affect listed species, the formal consultation process shall be ini-
tiated by writing to the Regional Director, Region 2, U.S. Fish and
Wildlife Service, P. 0. Box 1306, Albuquerque, New Mexico 87103. If
no affect is evident, there is no need for further consultation. We
would, however, appreciate^the opportunity to review your biological
assessment.
-------
__._.. ..
i5Cj-;6B-J&7i; "T: -T--3972;.
Sincerely yours,
^7**"4CY /4W^
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APPENDICES (FEIS)
111
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APPENDIX 1
WATER QUALITY MODELING OF BAYOU ANACOCO
AND SABINE RIVER (1,000 TON/DAY PLANT)
112
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CONTENTS
LIST OF TABLES ii
LIST OF FIGURES iii
I. SUMMARY AND CONCLUSIONS
A. Introduction
B. Water Quality Data Analysis
C. Water Quality Modeling Studies . .
D. Conclusions from Modeling
II. SUMMARY OF AVAILABLE DATA
A. US Geological Survey Surface Water Records
B. USEPA STORE! Data Files
C. Sabine River Authority ,
III. METHOD OF ANALYSIS
A. Steady-State Modeling
B. Steps of Analysis ....
IV. DEVELOPMENT OF GENERAL MODEL PARAMETERS
A. Hydraulic Geometry
B. Freshwater Flow
C. Time-of-Travel
D. Temperature
V. WASTEWATER LOADS
VI. APPLICATION OF MODEL TO THE DISSOLVED OXYGEN SYSTEMS
A. Development of Dissolved Oxygen Model Parameters
1. Reaeration Coefficient (K)
2. BOD Deoxygenation Rate (Ka)
3. Dissolved Oxygen Saturation Level (C )
s
B. Verification of BOD/DO Model
1. Bayou Anacoco
2. The Sabine River
3. Comparison Between Model Calculation and Observed
Data
4. Model Sensitivity Analysis
VII. MODEL PROJECTIONS
A. Simulation Scenarios for BOD /DO
B. Results of BOD/DO Simulations ...
C. Application of Model to Color, Chlori.de, and Sulfate
REFERENCES
113
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LIST OF TABLES
IV-1. Average Values of Exponents in Hydraulic Geometry Relationships
for the Sabine River
V-l. Effluent Characteristics of the Boise Southern Paper Mill
VI-1. Results of Model Verification for BOD /DO in Bayou Anacoco,
June 6, 1972
VI-2. Results of Model Verification for BOD /DO in the Sabine River,
June 6, 1972
VI-3. Results of Model Sensitivity Analysis (DO Concentration) for
Deoxygenation Coefficient and Reaeration Coefficient
VI-4. Results of Model Sensitivity Analysis (DO Concentration) for
BOD /BODC Ratio
u 5
VII-1. Simulation Runs for BOD/DO in Bayou Anacoco and the Sabine
River .,
VII-2. Simulation Scenarios for Chloride, Sulfate, and Color Levels
in Bayou Anacoco and the Sabine River
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LIST OF FIGURES
II-l. USGS Gaging Station Location Map
III-l. Observed Temperature, BOD,., Dissolved Oxygen, and Color
Levels in Bayou Anacoco at Rosepine
III-2. Observed Temperature, BOD , Dissolved Oxygen, Chloride,
Sulfate, and Color Levels in Bayou Anacoco at Knight ..
IV-1. Average Depth of Flow vs. Stream Flow - Sabine River below
Toledo Bend Reservior (River Miles 92.7 to 146.0)
IV-2. Average Depth of Flow vs. Stream Flow - Sabine River below
Toledo Bend (River Miles 32.6 to 92.7)
IV-3. Discharge Distance Relationship for Bayou Anacoco, La.
IV-4. Travel Time-Distance Curves for Bayou Anacoco, La
VI-1. Deoxygenation Coefficient (K,) as a Function of Depth
VI-2. BOD /DO Model Verification
VII-1. Projected BOD and Dissolved Oxygen Levels in Bayou Anacoco
and the Sabine River (Run Number 1)
VII-2. Projected BOD and Dissolved Oxygen Levels in Bayou Anacoco
and the Sabine River (Run Number 2)
VI1-3. Projected BOD and Dissolved Oxygen Levels in Bayou
Anacoco and the Sabine River (Run Number 3)
VII-4. Projected BOD and Dissolved Oxygen Levels in Bayou
Anacoco and the Sabine River (Run Number 4)
VI1-5. Projected BOD and Dissolved Oxygen Levels in Bayou
Anacoco and the Sabine River (Run Number 5)
VII-6. Projected BOD,, and Dissolved Oxygen Levels in Bayou
Anacoco and the Sabine River (Run Number 6)
VII-7. Calculated Color, Chloride, and Sulfate Levels in the
Sabine River under the 7-Day, 10-Year Low Flow Conditions.
115
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WATER QUALITY MODELING OF "BAYOU ANACOCO
AND SABINE RIVER
I. SUMMARY AND CONCLUSIONS
A. Introduction
The present study is directed toward evaluating the cumulative impacts of
wastewater discharges from the Boise Southern and Kirby Forest Industries
paper mills on the water quality of Bayou Anacoco and the Sabine River. A
steady-state water quality model of Bayou Anacoco from Rosepine to its mouth
and a portion of the Sabine River from Bayou Anacoco to Ruliff was prepared to
assist in this evaluation. Existing water quality data were employed in this
analysis and in the model calibration effort. It has been determined that
disposal of effluents from these paper mills will have a relatively minor
impact on existing water quality in Bayou Anacoco and the Sabine River.
This section summarizes the results and conclusions of the water quality
studies for the Boise Southern and Kirby paper mills. Subsequent sections
describe in detail the analyses upon which the results are based.
B. Water Quality Data Analysis
Water quality data employed in evaluating study area characteristics and
in developing the analysis framework were derived principally from information
provided by the US Geological Survey and USEPA. This includes data relevant
to the seasonal variability of temperature, discharge, chloride, color,
sulfate, and dissolved oxygen in Bayou Anacoco and the Sabine River. Addi-
tional data were made available from the Sabine River Authority.
The existing water quality in Bayou Anacoco is indicative of a moderately
stressed system. Dissolved oxygen levels of the Bayou are depressed as a
result of the discharge from the Boise Southern paper mill. Water quality in
the Sabine River is relatively good in the portion studied. Dissolved oxygen
levels are generally at or near saturation in the Sabine River.
C. Water Quality Modeling Studies
A steady-state water quality model of Bayou Anacoco and the Sabine River
was prepared and tested. The model is one-dimensional along the longitudinal
direction of the river. The transport system was developed using the results
of the time-of-travel study conducted by the US Geological Survey. Reaction
coefficients such as deoxygenation and reaeration rates were derived from
literature values and empirical formulas. Subsequent model verification and
model sensitivity analysis validated the coefficient values.
A series of simulation scenarios combining different river flows, river
temperatures, and BOD,, loading rates from the paper mills was developed to
analyze the worst-case conditions for dissolved oxygen in the Sabine River.
Due to the complicated nature of the NPDES permit for the expanded Boise
Southern paper mill, allowable BOD loading rates associated with different
ambient temperature and flow conditions were derived for use in the calcu-
lation. For the proposed Kirby paper mill on the Sabine River, the designed
maximum daily BOD discharge rate was used in the model projection.
116
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The responses of BOD and dissolved oxygen in Bayou Anacoco and the
Sabine River were simulated by the verified model. Other water quality
constituents such as chloride, sulfate, and color were also calculated under
the worst-case conditions.
D. Conclusions
1. The modeling results indicate that the most significant cumu-
lative impact in terms of dissolved oxygen levels in the Sabine
River would not occur under the 7-day, 10-year low flow condi-
tions. Instead, the worst-case condition would result under a
slightly higher flow which allows the maximum discharge of BOD
from the Boise Southern paper mill.
2. Under the 7-day 10-year low flow conditions, the cumulative
impact would be predominated by the wastewater discharge from
the proposed Kirby paper mill into the Sabine River because
the BOD loading from the Kirby plant is much greater than
that from the expanded Boise Southern plant. This result is
based on the assumption that Boise Southern fully complies
with its NPDES permit to discharge into Bayou Anacoco.
3. The minimum concentration of dissolved oxygen in the Sabine River
predicted by the model is 6.0 mg/1 which is above the Texas Water
Quality Standard of 5.0 mg/1. Under this circumstance, the
cumulative impact of the paper mill discharges would be rela-
tively minor in terms of dissolved oxygen depression. That is,
the resulting profile of dissolved oxygen levels is only slightly
different from the current conditions in the Sabine River.
4. The maximum color level calculated by the model for the Sabine
River under the 7-day 10-year low flow conditions is about 227
PCU, considerably higher than the natural background level of 30
PCU. However, color levels of the river will normally be elevated
by only 9 PCU under average flow.
5. Chloride concentration in the Sabine River would reach 71 mg/1 as
a result of maximum wastewater discharges from both paper mills.
This peak concentration is still below the Texas Water Quality
Standard of 120 mg/1.
6. Sulfate concentration in the Sabine River would reach 38 mg/1
according to the model calculation. This level is below the
Texas Water Quality Standard of 60 mg/1.
II. SUMMARY OF AVAILABLE DATA
The water quality data gathered from various sources duririg this modeling
study were used to (1) evaluate model parameters, (2) provide input" to the
model (i.e., boundary conditions and loadings), and (3) verify the model. A
discussion of the data derived from various sources is presented in this
section. _ '_.. *?'
117
-------
A. US Geological Survey Surface Water Records
Records of daily flows of streams were obtained from the US Geological
Survey water resources data publications (USGS 1975-1979). The official
continuous gaging stations in the study area are shown in Figure II-l. They
are Burkeville, Bon Wier, and Ruliff on the Sabine River and Rosepine and
Knight in Bayou Anacoco. In addition to the daily average flow records, flow
statistics such as 7-day, 10-year low flow calculations were also obtained
from USGS. Data on water quality of Bayou Anacoco and the Sabine River were
obtained from USGS Surface Water resources data publications (USGS 1975-1979).
B. USEPA STORET Data Files
STORET data retrieval was conducted to obtain historical water quality
data collected at a number of stations since 1969. Water quality parameters
include temperature, flow, BOD , DO, color, chloride, sulfate, and nutrients.
Data were available for stations at Burkeville, Bon Weir, Ruliff, Knight, and
Rosepine.
C. Sabine River Authority
Three sampling stations have been used by the Sabine River Authority to
collect quarterly data from 1978 and 1979 on the above water quality para-
meters. These stations are located in the Sabine River at S.H. 12 near
Ruliff, Texas, U.S. 190 east of Bon Wier, Texas and in Anacoco Bayou at S.H.
Ill, southwest of Knight, Louisiana.
III. METHOD OF ANALYSIS
A. Steady-State Modeling
A steady-state modeling framework- was used in this study to evaluate
water quality problems at or near equilibrium conditions. In general, the
time-dependent behavior of the river flow in Bayou Anacoco and the Sabine
River is characterized by increased flow in spring and a prolonged drop to
reduced steady flow during the summer and early fall. It is during this
latter period that water quality is usually poorest as minimum dilution and
high temperature occur simultaneously. The analysis and projection of water
quality under these conditions are the most accurate since a steady-state is
frequently attained and water quality is at a minimum. All loadings of point
and non-point origin will be assumed to be reasonably constant within the time
scale of the model.
B. Steps of Analysis
The development of the water quality model of the Sabine River consists
of the following steps:
• Selecting the appropriate software package (computer code) which,
in mathematical terms, defines the relationships between a parti-
cular water quality constituent and the factors which affect it,
such as flow, biochemical reactions, and direct waste discharges.
118
-------
Burkevi1le
Proposed Kirby Paper Mill
Existing Boise
Paper Mi 11
-( / Legend:
• USGS Gaging Station
A Paper Mi 11
o 2 4
9 nma
IT- I USGS Gaging Station Location Map
119
-------
• Evaluating the modeling parameters such as hydraulic geometry,
reaction rates, and direct waste discharges.
• Testing the model by comparing the computed distribution of water
quality constituents against the observed data in different por-
tions of the stream.
• Making final adjustments of the model parameters such that a con-
sistent set of coefficients yields reasonable agreement between
the computed distributions and observed data.
A general computer program (STREAM) suitable for one-dimensional dis-
tribution of non-conservative substances was selected for this study. The
basic principle behind this computer program is that of the conservation of
mass which can be expressed as:
A
x
In Eq. 1, Q is the stream flow in the longitudinal direction, A is the
longitudinal Across-sectional area, C represents the concentration of any water
quality constituent under consideration, and S represents all sources and
sinks of this constituent as well as all biological or physical reactions that
occur within the system.
IV. DEVELOPMENT OF GENERAL MODEL PARAMETERS
In this modeling analysis, the model is available in a general form
(i.e., computer code). The purpose of the model development is to adapt the
general model to Bayou Anacoco and the Sabine River. This process calls for a
site-specific application of water quality mass balance equations which relate
waste inputs to resulting water quality and includes specific numerical values
for physical and kinetic interactions. Some of these numerical parameters are
specific to the individual water quality constituents being analyzed. Para-
meters such as reaeration coefficients and oxidation rates fall into this
category and are discussed in later sections of this report. Other parameters'
such as hydraulic geometry, time-of-travel and temperature are general to all
water quality constituents and are developed and evaluated separately from
specific water quality constituents. This section develops these parameters.
A. Hydraulic Geometry
The physical parameters of hydraulic geometry include width, depth, and
velocity in different reaches of the Sabine River. A time-of-travel study by
the US Geological Survey (Shampine 1971) aided the development of the ve-
locity-flow and average depth-flow relations for the portion of the Sabine
River under study. These relationships take the form of power functions with
flow as the independent variable. Thus,
H = aQb
d
u = cQ
120
-------
where H is stream depth and u is stream velocity. Values of "c" and "d" for
use as input to the computer model are listed in Table IV-1 and were developed
over a range of flows representative of those daily stream flows ranging from
200 cfs to 4,000 cfs between Ruliff and Burkeville.
Table IV-1. Average Values of Exponents in Hydraulic Geometry Relations
for the Sabine River
Velocity = cQ
From River Mile
to
River Mile
"c"
32.6
37.0
44.3
56.5
61.0
78.0
86.0
92.7
98.5
102.5
37.0
44.3
56.5
61.0
78.0
86.0
92.7
98.5
102.5
116.4
0.432
1.666
0.879
2.945
2.070
9.55
1.255
0.495
0.0427
0.625
0.491
0.368
0.410
0.301
0.322
0.154
0.374
0.489
0.787
0.495
The average depth-flow relations of the Sabine River derived in a
modeling report by URS/Forrest and Cotton, Inc. (1973) were used for this
study and are summarized in Figures IV-1 and IV-2.
Hydraulic geometry information for Bayou Anacoco was obtained from the
NPDES permit study conducted by USEPA. They are expressed as the following
exponential functions of flow:
H
u
0.308Q
0.036Q1
0.444
0.604
where H is depth in ft, Q is flow in cfs, and u is velocity in ft/sec.
B. Freshwater Flow
In this mathematical model, movement of water quality constituents
through the stream is achieved through advective flow. The flow in the Sabine
River is a combination of tributary flow, runoff flow, and wastewater flow.
In the steady-state dry weather analysis, runoff flow is not included as the
river system is assumed free of storm effects.
121
-------
15.0
100
6 7 S 9 1.000
1 1 RIVER MILES
1-93.5 - 102.5
129.0 - 132.1
—92.7 - 93.5
—'IIS.4 - 121.0
'102.5 - 115.4
;—132. I - 116.0
"121.0 - 129.0
STREAM FLOW (CFS)
Figure iv-i. AVERAGE DEPTH OF FLOW VS. STREAM FLOW
SABINE RIVER BELOW TOLEDO BEND RESERVOIR
(RIVER MILES 92.7 TO IH6.0)
-------
C-
LU
O
cc
UJ
>
10.
9
8
7
G
5
100
56789 1,000
STREAM FLOW (CFS)
RIVER MILES
74.0-76.0
ts.o-ue.c
— 32.G-45.0
86.0-02.7
76.0-66.0
iJ8.0-7-,.0
Figure iv-2.
AVERAGE DEPTH OF FLOW VS. STREAM
SABiNE RIVER BELOW TOLEDO BEND
FLOW
(RIVER MILES 32.6 TO 92.7)
-------
Five major tributaries join the Sabine River below Bayou Anacoco and are
listed below with their locations by river mile.
Major Tributaries of the Sabine River in the Modeling Area
Tributary Confluence with Sabine River
(River Miles)
Big Cypress Creek 41.1
Nichols Creek • 48.4
Big Cow Greek 71.9
Old Bivens Branch 80.9
Bayou Anacoco —• 105.4
The river flows were obtained from the US Geological Survey records and in-
corporated with the data from gaging stations on the main stem of the Sabine
River to establish the flow pattern used in the model. The river flows and
drainage areas at Burkeville and Bon Wier were first obtained from the US
Geological Survey records. The river flow per unit drainage area between
Burkeville and Bon Wier was then calculated and used to derive the incre-
menting flow at various locations between these two stations. The same pro-
cedure was used to derive the flows along the river between Bon Wier and
Ruliff. By means of these incremental flow calculations, the flows from major
tributaries were properly incorporated.
Flows at various locations in Bayou Anacoco were derived using the flow-
distance relationship derived by the US Geological Survey (Shampine 1971') as
shown in Figure IV-3. For example, Figure IV-3 indicates that a flow of 150
cfs at Rosepine is associated with a flow of 200 cfs at Knight.
Only two wastewater discharges of significance to modeling presently
occur in. the study reach of the Sabine River. The Leesville, Louisiana,
sewage treatement plant and the Boise Southern Company paper mill, with
typical discharges of 1.5 mgd and 40 mgd respectively, could noticeably affect
Sabine River water quality under low-flow conditions. Both of these effluents
flow into Bayou Anacoco.
C. Timer-of-Travel
<
Time-of-travel in the Sabine River was calculated from flow, velocity,
and distance in each reach as shown in Table IV-1. An extensive program of
data collection and analysis was conducted by the US Geological Survey
(Shampine 1971) to determine the water-particle movement in Bayou Anacoco. The
results presented in that report were used to estimate the travel time.
Figure IV-3 shows the discharge-distance curves for Bayou Anacoco adopted
from the US Geological Survey study. These curves illustrate the flows for
any location within the Bayou. Next, the travel time-distance curves for
Bayou Anacoco are shown in Figure IV-4, based on the flow at Knight.
-------
15 10
RIVER MILES ABOVE MOUTH
LA
Figure IV-3. Discharge-distance relationship for Bayou Anacoco, LA.
125
-------
25
RIVER MILES ABOVE MOUTH
Figure IV-4. TRAVELTIME-DISTANCE CURVES FOR BAYOU ANACOCO, LA.
126
-------
D. Temperature
BOD oxidation rates, reaeration rate, and dissolved oxygen saturation
concentrations are temperature dependent. Temperature data are available at
many locations in the river from various data sources. These data were used
in making temperature assignments to each model segment for simulation runs.
V. WASTEWATER LOADS
The plant discharge records of the Boise Southern paper mill for 1979
were obtained in order to derive the BOD loading needed in the calculation.
Table V-l shows the effluent characteristics of the Boise Southern plant in
terms of monthly averages for BOD , total suspended solids, pH, and flow in
1979.
Table V-l. Effluent Characteristics of the Boise Southern Paper Mill
(Monthly Averages in 1979)
Jan.
Feb.
Mar.
Apr.
May
June
KITH (ma 7l ^ ____ -
TCC fmo/1 ^ ' •
r»H _______________
-la 7
— 81 S
7 fl
on i Q
69.0
114.5
7.9
16.31
53.4
99.6
7.8
19.11
23.3
82.5
7.7
24.05
27.0
65.6
7.7
20.55
25.7
45.1
7.8
21.98
July
Aug.
Sep.
Oct.
Nov.
Dec.
riH __„___. ______ .
176
Afi 1
7 7
77 7fi
OQ Q
*^Q ?
7 7
1 7 9 A
76 S
77 -i
7 Q
70 A7
71 7
7-1 a
7 Q
i S 07
oy, q
70 q
7 Q
in 7fi
Afi 7
77 Q
/ / > j
7 8
nSft
VI. APPLICATION OF MODEL TO THE DISSOLVED OXYGEN SYSTEMS
The concentration of dissolved oxygen in Bayou Anacoco and the Sabine
River is a function of the rate of oxygen consumption and the rate of oxygen
replenishment. Factors affecting oxygen consumption in streams include oxi-
dation of carbonaceous materials, increased levels of nitrogenous BOD, and
oxygen demand from benthic needs. The nitrogenous BOD was assumed to be
negligible because pulp and paper mill wastewater are traditionally deficient
in nitrogen. In a controlled nutrient addition system, ammonia nitrogen in
the effluent ranges from 0 mg/1 to less than 1 mg/1. It was assumed that
oxygen demands from benthic muds are not significant and can be neglected in
the analysis. The most important factor affecting oxygen replenishment in
Bayou Anacoco and the Sabine River is transfer of oxygen into the stream
12?
-------
through surface reaeration. Other oxygen sources and sinks such as photo-
synthetic production and respiration by algal cells are not significant
(Shampine 1979).
A. Development of Dissolved Oxygen Model Parameters
The dissolved oxygen concentrations in Bayou Anacoco and the Sabine river
are calculated using the following equations derived from Eq. 1.
0 = - - I -\- «,L + WT (2)
0 = - _ (__ V KdL - KaD = W (3)
A Vdx/
D.O. = C - D ' (4)
i S
In Eq. 2, Q is the average stream flow in each reach; A is the average channel
cross-sectional area; L is the ultimate carbonaceous BOD; K is the BOD decay
rate in the water column; W is the loading of BOD; K Is the reaeration
coefficient; W is the loading of dissolved oxygen deficit; D.O. is the dis-
solved oxygen concentration; and C is the dissolved oxygen saturation level.
s
Solutions of Eqs. 2 and 3 are:
L = L e ~Kd (£) (5)
(6)
Equation 6 is commonly known as the Streeter-Phelps Equation.
Before it is possible to calculate a dissolved oxygen profile, all of the
input parameters in Eqs. 5 and 6 must be defined for each modeled reach.
Physical parameters were discussed in earlier sections of this report. The
remaining input parameters are discussed in the following paragraphs.
(1) Reaeration Coefficients (K .
_ a)
The reaeration coefficient is the rate at which oxygen is transferred
into the water column. Numerous investigators have shown the rate of oxygen
transfer (K ) to be a function of stream velocity and depth. The equation
chosen to calculate the reaeration coefficient for this study is the O'Connor-
Dobbins (1956) equation. The reaeration formula is written as in Eq. 7.
Ka(20°C) = KL(20°C) . | (7)
128
-------
In Eq. 7, K is the surface transfer rate, A is surface area, and V is volunv .
In their work, O'Connor and Dobbins have shown that:
KT (20°C) = (DT U/H) (8)
Li Lt
4 2
where D is the diffusivity of oxygen in water (=0.81 x 10 ft /hr @ 20°C), U
is velocity in ft/sec and H is water depth in ft. (K to the base e has the
unit ft/day). Combining Eqs. 7 and 8 yields:
Ka(20°C) = 130J/H)15 . | = 13
This equation was applied to obtain the reaeration coefficients at 20°C. For
temperature correction of the reaeration coefficient, Eq. 10 is used to make
this correction.
K = K (20°C) 9 (T~20) (10)
a a
where 9 is 1.024 and T is temperature in °C.
(2) BOD. Deoxygenation Rate (K,)
3 _ d
The overall decay phenomena as observed in Bayou Anacoco and the Sabine
River reflect the "disappearance" of BOD from the overlying water column due
to a combination of both settling and biological oxidation. A correlation has
been crudely developed for the deoxygenation coefficient K and average depth,
H. The rational behind this correlation lies in the fact that the greater the
ratio of wetted perimeter to cross-section, which is equivalent to small
depth, the greater the contact with the biological film in stream bed, which
is the most important factor in natural oxidative processes. Data surveys,
reported in literature, are plotted in Figure VI-1. Although bed conditions
were not always described with great precision, Figure VI-1 can be used as a
guide to derive the initial estimate of K which is subject to adjustment in
the model verification analysis.
The BOD deoxygenation rate is temperature dependent. This dependency is
described by the following equation:
_
K = K (20°C) . 9 (11)
d d
where 9 is 1.047.
The ultimate BOD to BOD ratio cannot be estimated due to the lack of
pertinent data. In this analysis, a range from 1.0 to 2.0 was first used to
reproduce the available data and to simulate the DO levels under various
129
-------
4.0
O
o
O
CM
<
O
i.o
O.I
0.05
Unstable,Sandy Channel
Highly Treated Effluent
with Nitrification
-Stable,Rocky Bed
Moderate Treatment
Some Ammonia
1.0
10.
DEPTH IN FEET
100.
LEGEND
©Shallow Streams (l-3Ft.)
0 Medium Streams (3-15 Ft)
A Deep Rivers (> 15 Ft)
Figure Vl-1.
DEOXYGENATION COEFFICIENT (Kd) AS
A FUNCTION OF DEPTH
130
-------
projected conditions. This range is consistent with the range reported for
paper and pulp wastes.
(3) Dissolved Oxygen Saturation Level (C .
s;
Equation 6 calculates the depression in dissolved oxygen below a
naturally occurring dissolved oxygen saturation concentration. The actual
dissolved oxygen concentration is then calculated by subtracting the dissolved
oxygen deficit from this naturally occurring dissolved oxygen saturation con-
centration.
The dissolved oxygen saturation concentration which is a function of
temperature can be calculated using the following equation:
Cs = 14.652 - 0.41022T + 0.007991 T2 - 0.000077774T3 (12)
B. Verification of BOD/DO Model
(1) Bayou Anacoco
Equations 5 and 6 were used to reproduce the dissolved oxygen concen-
tration observed in Bayou Anacoco on June 6, 1972, (URS/Forrest and Cotton,
Inc. 1973). In this analysis, the time-of-travel was derived using the USGS
study results as described in Section IV. The BOD deoxygenation rate and
reaeration coefficient in Bayou Anacoco were determined based on the meth-
odology outlined in the preceding section. Specific BOD loading from the
Boise Southern paper mill was not available. In the calculation, the loading
was approximated using the monthly average BOD concentration and flow in June
as shown in Table V-l. The results of the calculations are summarized in
Table VI-1.
Table VI-1. Results of Model Verification for BOD/DO in Bayou Anacoco,
June 6, 1972
Miles from
the mouth
16
14
12
10
8
6
4
2
0
Cumulative
Time-of -travel
(day)
0
0.19
0.42
0.69
0.96
1.19
1.44
1.67
1.92
BOD
(mg/1)
12.0
11.0
10.0
8.9
7.9
7.2
6.5
5.9
5.3
DO deficit
(mg/1)
1.30
1.96
2.34
2.45
2.37
2.24
2.07
1.90
1.73
DO
(mg/1)
6.80
6.14
5.76
5.65
5.73
5.86
6.03
6.20
6.37
131
-------
Temperature = 27°C
Flow at Rosepine = 23 cfs; flow at Knight = 89 cfs
Flow from Boise Southern = 35 cfs; BODC loading = 4,750 Ib/day
K = 0.43 day ; K = 2.36 day"
Q Q.
(2) The Sabine River
BOD /B
OD,
1.5
The most complete study on dissolved oxygen profiles is the survey con-
ducted by URS/Forrest and Cotton, Inc. on June 6, 1972. Dissolved oxygen
concentration was measured in the Sabine River from immediately upstream of
the entrance of Bayou Anacoco to Bon Wier. These data were used to verify the
model.
The BOD and DO concentrations at the mouth of Bayou Anacoco which were
calculated and presented in the previous section were used as input to the
Sabine River model. River flow and water temperature were assigned to the
model along the river based on the USGS surface water records. The results of
BOD and DO calculation are shown in Table VI-2.
Table VI-2.
Results of Model Verification for BOD/DO in the Sabine River,
June 6, 1972
Miles from
the Mouth
105.4
104.0
103.0
102.0
101.0
100.0
99.0
98.0
97.0
96.0
95.0
94.0
93.0
92.0
Cummulative
Time-of-travel
(day)
0
0.024
0.048
0.073
0.102
0.132
0.162
0.193
0.226
0.258
0.291
0.323
0.356
0.390
K K
d a
(day"1) (day"1)
0.41
0.43
0.43
0.41
0.41
0.43
0.43
0.43
0.43
0.43
0.43
0.41
0.41
0.41
0.84
1.05
1.05
0.47
0.47
1.05
1.05
1.05
1.05
1.05
1.05
0.84
0.84
0.84
BOD
(mg/I)
1.43
1.40
1.38
1.37
1.35
1.33
1.32
1.31
1.30
1.28
1.26
1.24
1.23
1.21
DO
Deficit
(mg/1)
0.92
0.93
0.94
0.99
1.01
0.95
0.95
0.96
0.96
0.96
0.97
0.97
1.02
1.02
DO
(mg/1)
7.18
7.17
7.16
7.11
7.09
7.15
7.15
7.14
7.14
7.13
7.13
7.08
7.08
6.87
(3) Comparison Between Model Calculation and Observed Data
Figure VI-2 shows the comparison between model calculations and observed
data for both Bayou Anacoco and the Sabine River. The calculated DO profiles
match the observed data reasonably well. The BOD calculation compares favor-
ably with the observed concentration in Bayou Anacoco. The ultimate BOD to
5-day BOD ratio of 1.5 was used in the analysis. Subsequent model sensitivity
analysis further validated this ratio. The Bayou Anacoco and Sabine River
model was considered verified for BOD and DO. Its methodology used to derive
the model parameters was therefore validated.
132
-------
90
IY\ ices FRom /nouTH
V1-Z
-------
(4) Model Sensitivity Analysis
In the calibration and verification of the BOD/DO model, parameters were
used which yielded a reasonable reproduction of observed BOD and DO concen-
trations. Some of these input parameters such as velocities and time-of-
travel were directly derived from hydrologic studies. Other model parameters
such as BOD deoxygenation rate, reaeration coefficient, and BOD / BOD ratio
were approximated using empirical formulas. The purpose of this analysis is
to test the sensitivity of the model to these input parameters.
The BOD deoxygenation rate and reaeration coefficient were approximated
based on the depth in Bayou Anacoco. A range of depths was used to yield a
range of deoxygenation rates and reaeration coefficient values. The model was
run to test the sensitivity of these variations. The results are shown in
Table VI-3. Variation of these model parameters generated appreciable dif-
ferences in the DO levels in the Bayou. Comparison with the model verifi-
cation results in Table VI-1 suggests that the verification run best re-
produces the data. The sensitivity analysis therefore substantiates the model
verification.
Another parameter addressed in the model sensitivity analysis is the
ultimate BOD to 5-day BOD ratio. A value of 1.0 has been used by EPA (NPDES
Permit, 1979) and a value of 2.0 has been reported in the literature for paper
mill waste. The model was run to generate results of the ratios of 1.0 and
2.0, respectively. A comparison of these results with the verification is
shown in Table VI-4. The model ratio of 1.5 yields results which best match
the data.
Table VI-3. Results of Model Sensitivity Analysis (DO Concentration) for
Deoxygenation Coefficient and Reaeration Coefficient
Mile Point Kd=0.43 day"1 Kd=0'51 d3?"* Kd=0.39 day'1
K =2.36 day"1 K =4.49 day"1 K =1.53 day"1
B. 3. 3
16
14
12
10
8
6
4
2
0
6.80
6.14
5.76
5.65
5.73
5.86
6.03
6.20
6.37
6.80
5.80
5.89
6.02
6.24
6.63
6.79
6.95
6.80
5.65
4.76
4.23
4.04
4.06
4.18
4.36
4.59
134
-------
Table VI-4. Results of Model Sensitivity Analysis (DO Concentration)
for BOD /BODC Ratio
u 5
Mile Point
16
14
12
10
8
6
4
2
0
BOD /
6.80
6.14
5.76
5.65
5.73
5.86
6.03
6.20
6.37
BOD /
5~ *
6.80
6.51
6.38
6.38
6.47
6.58
6.71
6.82
6.94
BOD /
BOD"=2.0
6.80
5.76
5.14
4.92
4.98
5.14
5.36
5.57
5.80
VII. MODEL PROJECTION
A. Simulation Scenarios for BOD /DO
The first step in model projection analysis is to develop a set of
scenarios associated with the critical conditions in Bayou Anacoco and the
Sabine River. Earlier data analysis of flow and temperature provided input to
the derivation of the simulation runs. In addition, the NPDES permit for the
Boise Southern paper mill and the designed effluent characteristics for the
proposed Kirby Industry paper mill (with 1,000 tons/day production) were
incorporated. The simulation runs associated with various hydrologic and BOD
loading conditions are summarized in Table VII-1.
The 7-day, 10-year low flow was used to define critical low-flow hydro-
logical conditions. This term is defined as the lowest average flow that
occurs for a consecutive 7-day period at a recurrence interval of 10 years.
That is, over a long period of time, the average time interval between 7-day
low flow of this severity will be 10 years. The US Geological Survey has
compiled a comprehensive data base and determined the 7-day, 10-year low flows
at Rosepine and Burkeville to be 9 cfs and 90 cfs, respectively, (see Table
VII-1). These flows were used in Runs 1 and 2. Flows at Rosepine, as shown in
Runs 3 and 4, are the minimum flow required for Boise Southern to discharge
the maximum allowable BOD loading (34,350 Ib/day) associated with tempera-
tures of 29°C and 15°C, respectively. Flows at Burkeville were obtained
through correlation between flows at Rosepine and flows at Burkeville. Flows
in Run No. 5 are the same as those in Run No. 4. Flows in Run No. 6 are
selected between flows in Runs 3 and 4 in order to cover a whole range of flow
conditions.
Temperatures of 29°C and 15°C were assigned to different flow conditions
in order to generate various combinations of hydrologic conditions. They
represent the high and low extremes of temperatures in the receiving water.
135
-------
Table
Simulation Runs for BOD/DO in Bayou Anacoco
and the Sabine River
Background Water Quality Wastewater Discharge
Run No. Receiving Water Flow
(cfs)
1
2
3
4
5
6
Bayou Anacoco
Sabine River
Bayou Anacoco
Sabine River
Bayou Anacoco
Sabine River
Bayou Anacoco
Sabine River
Bayou Anacoco
Sabine River
Bayou Anacoco
Sabine River
9*
90*
9
90
736+
9,160
276@
3,800
276
3,800
544
7.500
Temp
29
29
15
15
29
29
15
15
29
29
29
29
BOD5
(mg/1)
2.0
1.5
2.0
1.5
2.0
1.5
2.0
1.5
2.0
1.5
2.0
1.5
D.O.
(mg/1)
6.8
6.8
8.8
8.8
6.8
6.8
8.8
8.8
6.8
6.8
6.8
6.8
Flow BOD5
(cfs) (///Day)
44
35
44
35
44
35
44
35
44
35
44
35
1
10
3
10
34
10
34
10
34
10
34
10
,500
,300
,500
,300
,350
,300
,350
,300
,350
.300
,350
,300
D.O.
(mg/1)
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
Source
Boise
Kirby
Boise
Kirby
Boise
Kirby
Boise
Kirby
Boise
Kirby
Boise
Kirby
Southern
Southern
Southern
Southern
Southern
Southern
* The 7-day, 10-year low flows at Rosepine and Burkeville are 9cfs and 90 cfs, respectively.
+ Minimum flow at Rosepine required to receive the maximum 8005 discharge from Boise Southern
at 29°C.
@ Minimum flow at Rosepine required to receive the maximum BOD^ discharge from Boise Southern.
-------
The NPDES permit for the Boise Southern paper mill was used to derive the
allowable BOD loadings for Runs 1 and 2. A maximum daily BOD loading of
34,350 Ib/day was used in Runs 3 to 6 to depict worst-case conditions. A
maximum daily BOD loading of 10,300 Ib/day associated with 1,000 tons/day
productions at the proposed Kirby Industry paper mill was used for all con-
ditions in order to generate the worst-case conditions for cumulative impact
on the Sabine River.
The background water quality in Bayou Anacoco and the Sabine River was
derived from existing data (Section II of this report).
B. Results of BOD/DO Simulations
The results of Runs 1 and 2 are presented in Figures VII-1 and VII-2.
The predicated BOD and DO profiles are plotted along Bayou Anacoco and the
Sabine River. Also shown is the 5.0 mg/1 DO standard for comparison with the
calculated DO levels in the Sabine River. The BOD concentration is slightly
higher in-Bayou Anacoco than in the Sabine River. In general, DO levels are
above the standard in the Sabine River. The impact of the BOD discharge from
Boise Southern provides moderate depression of DO in Bayou Anacoco and this
depression disappears in the Sabine River. Wastewater from the proposed Kirby
Industry paper mill reduces the DO concentration by up to 0.5 mg/1 in the
Sabine River.
The results from simulation runs 3 to 6 are shown in Figures VII-3 to
VII-6. Runs 3, 4, and 6 yield a constant low DO of 6 mg/1 in the Sabine
River, which is above the water quality standard level. The sole impact of
the proposed Kirby discharge on the DO concentration in the Sabine River is
insignificant under the flow conditions associated with Run Nos. 3 to 6. On
the other hand, DO levels downstream from the Boise Southern discharge show
consistent violation of the 5.0 mg/1 limit in Bayou Anacoco.
C. Application of Model to Color, Chloride, and Sulfate
Water quality constituents such as color, chloride, and sulfate were
simulated as conservative substances using a similar modeling technique.
Because temperature is not a factor in these calculations, only the river flow
is considered when deriving the projected downstream levels of these para-
meters. Therefore, the 7-day 10-year low flow condition was used for the
simulation of conservative substances for worst-case conditions. Table VII-2
presents the background water quality conditions and paper mill effluent
characteristics in terms of color, chloride, and sulfate used in the model
projection. The background concentrations were obtained from Figures VII-1 to
VII-4. The designed effluent characteristics for the proposed Kirby paper
mill were used to generate the loadings from the paper mill discharge. Waste-
water loadings of color, chloride, and sulfate from the Boise Southern plant
were approximated in accordance with the BOD loading required by the NPDES
permit.
The results of the simulation are presented in Figure VII-7. The
cumulative impact of the wastewater discharges will be to raise the color
level of the Sabine River to 227 PCU. Based on the loading rate used for
Boise Southern, the maximum color level due to the Boise Southern discharge
alone is only 20 PCU. The color level slowly decreases to 186 PCU at Ruliff.
137
-------
Table VII-2. Simulation Scenarios for Chloride, Sulfate, and Color
Levels in Bayou Anacoco and the Sabine River.
Background Levels
Wastewater Discharge
Receiving Water
Flow Chloride Sulfate Color
(cfs) (mg/1) (mg/1) (PCU)
*
Bayou Anacoco 9 8.8 5.2 50
Sabine River 90* 30.0 15.0 30
*
based on the following flows:
Run No.
Bayou Anacoco
Rosepine
Boise Southern
Mouth
Sabine River
Burkeville
Bayou Anacoco
Kirby
Ruliff
142 3 4&5 6
9 736 276 544
30 756 295 564
70 800 335 605
90 9,160 3,800 7,500
270 11,752 4,524 8,299
300 12,087 4,699 8,483
429 12,636 5,604 9,830
Flow Chloride Sulfate Color Source
(cfs) (mg/1) (mg/1) (PCU)
44 192 330 972 B. Southern
35 400 175 1,800 Kirby
-------
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-------
Table VII-2.
Simulation Scenarios for Chloride, Sulfate, and Color
Levels in Bayou Anacoco and the Sabine River
Background Levels
Wastewater Discharge
rge
Receiving Water Flow Chloride Sulfate Color FlowChlorideSultateColor
(cfs) (mg/1) (mg/1) (PCU) (cfs) (mg/1) (mg/1) (PCU)
bouro
Bayou Anacoco 9* 8.8 5.2 50 44 192 330 972 B. Sout
Sabine River 90* 30.0 15.0 30 35 400 175 1,800 Kirby
* The 7-day 10-year low flows at Rosepine and Burkeville are 9 cfs and 90 cfs, respectively.
-------
500
400
300 4
200
100.
COLOR (pcu)
Flow at Burkeville = 90 cfs
227
186
140
120.
100
80
60
40
20 J
CHLORIDE (mg/1)
71.2
Flow at Burkeville = 90 cfs
Water Quality Standards 120 mg/1
64.6
60.
50.
40.
30.
20.
10.
0
SULFATE (mg/1) Flow at Burkeville = 90 cfs
vTexas Water Quality Standards 60 mg/1
37.8
(U M
Jj ni
-. Tj 5 .e •> co
o u •* A- a ...
g§ *£§ S § 51 11
IS1! g^SI 3S 4?« ^"
CQ ^ ^ ? ^ ^ O pQ ^*
• i • • i •
1 II 1 | 1
110 100 90 80 70 60 50
34.1
CO
co
.8-
CL , 0) vw
O M ^
O i-l
00 i-l
•H 3
1*4 >**
i •
1
40 3(
River Miles from Mouth
Figure VII-7. Calculated color, chloride and sulfate levels in the
Sabine River under 7-day 10-year low flow.
146
-------
The result of chloride simulation indicates that the maximum chloride
concentration in the Sabine River reaches 71 mg/1 as a result of both waste-
water discharges from the Boise Southern and the proposed Kirby Forest
Industries mill. This level is well below the Texas Water Quality Standards
(120 mg/1).
The sulfate concentration in the Sabine River increases from 15 mg/1 to
22 mg/1 downstream from the junction of Bayou Anacoco and the Sabine River.
Additional increases due to the proposed Kirby discharge make the maximum
concentration in the Sabine River equal to 37.8 mg/1. Both peaks are below
the 60 mg/1 level of the Texas Water Quality Standards. Significant dilution
from the background non-point source runoff further reduces the sulfate con-
centration. . .
-------
References
O'Connor, D.J. and W.E. Dobbins. 1956. The mechanism of reaeration in
natural streams. J. San. Eng. Div. (ASCE) SA6, 1115-1115-30.
Shampine, W.J. 1971. Selected hydrologic characteristics of the Sabine River
and Bayou Anacoco, Louisiana and Texas. Prepared by US Geological
Survey, Louisiana District in cooperation with Sabine River Compact
Administration, 34 p.
URS/Forrest and Cotton, Inc. 1973. Mathematical model of stream water
quality, Sabine River, Texas and Louisiana. Report to Sabine River
Authority of Texas. 99 p.
USEPA. 1979. Authorization to discharge under NPDES Permit No. LA0007927.
11 p.
US Geological Survey. 1975-1979. Water resources data for Texas. Water year
1975-1979. US Geological Survey Water Reports.
-------
APPENDIX 2
TABLES ACCOMPANING AIR QUALITY ANALYSIS (SECTION 5.8 OF FEIS)
-------
Table 1. Maximum predicted ambient air contaminant concentrations and national
ambient air quality standards, proposed KFI Mill, Bon Wier, Texas.
Concentration, ug/m"
Pollutant and
Averaging Time Background ( 1 )
so2
3-hour 19
24-hour 19
Annual 1
TSP
24-hour 72
Annual 35
CO
1-hour 118
8-hour 122
Annual 0
°3
1-hour
1-hour
NMHC
6-9 a.m.
Pb
3-month
Predicted Predicted
Increase Maximum
wood (coal) wood (coal)
13 (21.4) 32 (40.4)
7.7 (14.8) 26.7 (33.8)
1.1 ( 1.9) 2.1 ( 2.9)
3.6 ( 3.8) 75.6 (75.8)
<1 (<1 ) <36 (<36 )
11.5 ( 8.3) 129.5(126.3)
4.8 ( 3.4) 126.8(125.4)
<1 (<1 ) <1 (<1 )
Not modeled
Not modeled
Not modeled
Not modeled
Primary
365
80
260
75
40,000
10,000
100
240
240
160(3)
1.5
NAAQS
Secondary
1,300
150
60(2)
40,000
10,000
100
240
240
160(3)
1.5
(1) Based on monitoring data presented in Appendix 8.
(2) Guideline only.
SOURCE: J.E. Sirrine Company. 1977a. Environmental assessment for proposed 1000
ton per day bleached kraft market pulp mill. Volume 1. Houston TX.
150
-------
Table 2. Projected atmospheric emissions from proposed KFI mill, Bon Wier, TX.
Emission
Source
Lime Kiln
Smelt Tank
Recovery
Furnace (8)
Power
Boiler (9)
Digester;
Turpentine
Recovery ;
Fugitive
Totals
Control (1)
Caustic
Scrubbing
Caustic
Scrubbing
Noncontract
Furnace;
Wet-bottom
ESP
To be speci-
fied (10)
Incineration
in Lime Kiln
(ID
Total
Reduced
Sulfur (2)
kg/hr (Ib/hr)
1.6 ( 3.5)
0.54 ( 1.2)
2.77 ( 6.1)
-
~
7.6 (16.7)
12.51 (27.5)
Nonmethane N_
„ . , Hydrocarbon x
r./-, /o\ Particulates ~,T /c\ «« //:\
S02 (3) „. as CH^ (5) as N02 (6)
kg/hr (Ib/hr) kg/hr (Ib/hr) kg/hr (Ib/hr) kg/hr (Ib/hr)
39.3 ( 86.7) 18 ( 41.8) - 1.5 ( 3.3)
6.5 ( 14.4)
197 (434 ) 37.8 (83.4) - 30.7 ( 67.8)
43.5 ( 96.0) 19.6 ( 43.2) 1.3 (2.9) 58.8 (129.6)
— ™ •" •—
_ -
279.8 (616.7) 81.9 (182.8) 1.3 (2.9) 91 (200.7)
CO (7)
kg/hr (Ib/hr)
19.0 ( 42 )
-
37.5 ( 82.6)
43.5 ( 96 )
^
-
100 (220.6)
Notes for Table 1 follow on the next page
-------
Notes for Table 2.
1) Control devices will be selected and designed so that emissions do not
exceed EPA NSPS and TACB Emission Regulations
2) Point source reduced sulfur emissions will be controlled so as not to
exceed EPA proposed NSPS (40 CFR 60:BB). Fugitive emission estimates
are based on a paper by L.K. Swift (1976).
3) Over 60% of lime kiln potential S02 emissions are absorbed in lime and
removed via the grit system (Swift 1976). Recovery furnace S02 emis-
sions include 0.22 kg/hr per air dried metric ton (0.43 Ib/hr per air
dried short ton) of pulp plus 4.90 kg/hr (10.8 Ib/hr) from odorous gas
combustion (J.E. Sirrine Company 1977a: 3.6). Power boiler sulfur
emissions estimates are based on 0.05% sulfur (by weight) in the wood.
4) Particulate emissions estimates are based on EPA NSPS (40 CFR 60:BB:D).
5) Kiln hydrocarbon emission estimate is based on EPA emission factors
(Office of Air Quality Planning and Standards 1976: 10.1). Power
boiler emission estimate is based on field measurements of a similar
unit (J.E. Sirrine .Company 1977a).
6) NOX emission estimates are based on EPA emission factors (Office of
Air Quality Planning and Standards 1976: 1.6, 10.1).
7) Lime kiln and recovery furnace CO emission estimates were based on field
measurements (J. E. Sirrine Company 1977a: 3.6). Power boiler CO emis-
sion estimate was based on EPA emission factors (Office of Air Quality
Planning and Standards 1976: 1.6).
8) Recovery furnace heat input will be 235.5 x 109 cal/hr 935 x 10 Btu/
hr).
9) Power boiler heat input will be 133.5 x 109 cal/hr 530 x 106 Btu/hr).
10) Power boiler emissions will be controlled so as not to exceed EPA NSPS.
Control methods being considered by KRI are: mechanical collector,
electrostatic precipitator, or wet scrubber.
11) Control of fugitive emissions has not been specified by KFI. KFI will
incinerate fugitive emissions if required to do so by permit restric-
tions.
SOURCE: J. E. Sirrine Company. 1977a. Environmental assessment for pro-
posed 1,000 ton per day bleached draft market pulp mill. Volume
1. Houston TX.
152
-------
Table 3. Emission source physical characteristics for the proposed KFI mill.
Source
Stack
Height*
Meters
Diameter
Meters
K
Gas
Temp. Exit Velocity Moisture
Meters/Second Vol.
Lime Kiln
61.0
1.47
353
15.28
43.7
Smelt Tank
76.2
1.83
356
7.69
30
Recovery Furnace
76.2
3.2
478
18.07
20.8
Power Boiler
(Wood)
76.2
2.39
446
18.57
11.35
Power Boiler
(Coal)
76.2
2,62
446
18.72
11.35
Fugitive
3.0
300
* Stack heights for point sources were determined in accordance with method of Briggs
(1976) for prevention of plume downwash from existing nearby buildings.
* Fugitive sources are assumed to be spread evenly over process area (180 m square)
for purpose of dispersion modeling.
SOURCE: J.E. Sirrine Company. 1977a. Environmental Assessment for proposed 1000
ton per day bleached kraft market pulp mill. Volume 1. Houston TX.
153
-------
Table 4. Maximum predicted air contaminant concentration increases as a result
of emissions from proposed KFI Mill, Bon Wier, Texas, and corresponding
standards.
Distance to
Concentration, ug/m"
Pollutant and
Averaging Time
so2
3-hour
24-hour
Annual
TSP
1-hour
3-hour
5 -hour
24-hour
Annual
CO
1-hour
8-hour
Predicted' Cone.
From Source (mi)
2.5
3.1
1.2
N.A. (2)
N.A. (2)
N.A. (2)
1.9
1.2
1.9
1.2
Predicted
Increase
Wood (Coal)
13 (21.4)
7.7 (14.8)
1.1 ( 1.9)
(26.6)
(16.1)
(16.1)
3.6 ( 3.8)
<1 <<1 )
11.5 ( 8.3)
4.8 ( 3.4)
Federal
Standard (1)
512
91
29
-
-
-
37
19
40,000
10,000
Texas
Standard
,
-
-
"•
400
200
100
•
™
-
-
NO.
Annual
1.2
100
1-hour
Not modeled
Not modeled
240
240
NMHC
6-9 a.m. Not modeled
Not modeled
160 (4)
160 (3)
Pb
3-month
Not modeled
Not modeled
1.5
1.5
(1) Allowable Class II PSD Increments (Section 5.3.1.3). ;
(2) Not supplied in Applicant's data.
(3) Guideline only.
SOURCE: J.E. Sirrine Company. 1977a. Environmental assessment for proposed 1000
ton per day bleached kraft market pulp mill. Volume 1. Houston TX.
-------
Table 5. Predicted TRS and H2S ambient concentrations due to the proposed KFI
mill with odor thresholds for reduced sulfur compounds.
Location
Highway 363
TRS Concentration, ug/m (a)
Worst-Case Typical-Case
(c) (d)
584
18
H2S Concentration, ug/m3(.b) TACB H2S
Worst-Case
(c)
<146
Typical-Case Standard,
(d)
ug/m
3
<5
180(e)
Sabine River
West Wind
83
Not predicted
< 18
Not predicted 120(f)
Northwest or
Southwest Wind
50
Not predicted
< 10
Not predicted 120(f)
Odor Thresholds of Reduced Sulfur Compounds(g)
Compound
Odor Threshold
PPm
ug/m3
Hydrogen Sulfide
Methyl Mercaptan
Dimethyl Sulfide
Dimethyl Disulfide
0.0047
0.0021
0.0010
0.0056
6.5
4.1
2.5
22.0
Notes: (a) Predicted by dispersion modeling of emitted TRS.
(b) Assuming <25% (by weight) of TRS is H2S (Sirrine 1977a).
(c) Most limiting dispersion meteorology possible (atmospheric
stability class F and a 1 meter/second wind speed).
(d) Typical dispersion meteorology conditions (atmospheric stability
class C and a 5 meter/second wind speed).
(e) TACB ambient air standard for land not used for residential,
commercial, or business purposes.
(f) TACB ambient air standard for land used for residential, commercial,
or business purposes.
(g) From: J.E. Sirrine Company. 1977b. Environmental assessment for
proposed 1000 ton per day bleached kraft market pulp mill.
Volume 2. Houston TX.
155
-------
APPENDIX 3
BIOLOGICAL ASSESSMENT OF FEDERALLY LISTED ENDANGERED AND
THREATENED SPECIES IN THE* VICINITY OF THE PROPOSED KIRBY
BLEACHED PULP KRAFT MILL NEAR BON WIER, TEXAS
156
-------
WAPORA.Inc.
Environmental/Energy/Economic Studies
33O1 BUCKEYE ROAD, N.E.. SUITE 603, ATLANTA, GEORGIA 3O341
PHONE —(404) 456-0408
Project 622
March 1980
Biological Assessment of Federally
Listed Endangered and Threatened
Species in the Vicinity of the
Proposed Kirby Bleached Pulp Kraft
Mill Near Bon Wier, Texas
Submitted to:
USEPA Region VI
Dallas, TX
Submitted by:
Steven D. Bach, Ph.D.
Ecologist
Approved by:
Lawrence W. Olinger, PAEl
Director, Southern Region
AIH
157
•OLIO WASTC
WATIR
-------
TABLE OF CONTENTS
Table of Contents . i
/
1.0 INTRODUCTION, SUMMARY AND CONCLUSION 1
2.0 RESULTS OF A COMPREHENSIVE SURVEY OF THE STUDY AREA 3
2.1 Literature Review 3
2.1.1 Bald Eagle 3
2.1.2 Red-cockaded Woodpecker 7
2.1.3 American Alligator 12
2.1.4 Plain Pocketbook Pearly Mussel 13
2.1.5 Impacts of KME on Aquatic Communities 15
2.2 Results of the On-Site Survey 23
2.2.1 Bald Eagle 23
2.2.2 Red-cockaded Woodpecker 23
2.2.3 American Alligator 24
2.2.4 Plain Pocketbook Pearly Mussel 24
2.3 Coordination and Consultation 24
2.3.1 Bald Eagle 24
2.3.2 Red-cockaded Woodpecker 26
2.3.3 American Alligator 27
2.3.4 Plain Pocketbook Pearly Mussel 27
2.3.5 Status of the Sabine River Fisheries 28
3.0 NATURE AND EXTENT OF IMPACTS ON ENDANGERED SPECIES ,34
3.1 Bald Eagle . 34
3.2 Red-cockaded Woodpecker 35
3.3 American Alligator 36
3.4 Plain Pocketbook Pearly Mussel 36
4.0 POTENTIAL CUMULATIVE IMPACTS ON ENDANGERED SPECIES OR CRITICAL
HABITATS , 38
4.1 Bald Eagle . ; 38
4.2 Red-cockaded Woodpecker ..... 39
4.3 American Alligator and Plain Pocketbook Pearly Mussel .... 39
5.0 STUDY METHODS USED 40
6.0 DIFFICULTIES IN OBTAINING DATA AND COMPLETING STUDY 41
7.0 CONCLUSIONS OF THE NET EFFECTS OF PROPOSED PROJECT ON ENDANGERED
SPECIES 42
7.1 Bald Eagle 42
7.2 Red-cockaded Woodpecker 42
7.3 American Alligator 42
7.4 Plain Pocketbook Pearly Mussel 43
8.0 ADDITIONAL RELEVANT INFORMATION 44
9.0 LITERATURE CITED 45
APPENDIX 1
APPENDIX 2
158
-------
1.0 INTRODUCTION. SUMMARY AND CONCLUSIONS
This biological assessment has been developed to be used as the basis of
a formal Section 7 consultation between USEPA Region VI and the USFWS. The
purpose of the formal consultation is to determine the nature and extent of
the impacts of the proposed Kirby bleached kiraft mill on three endangered
species of animals which inhabit the project area (within a 50 mile radius
of the site). The species examined are the bald eagle (endangered), the Ameri-
can alligator (endangered), and the red-cockaded woodpecker (endangered). An
analysis of potential impacts of the mill on a proposed endangered mussel,
Lampsilis satura (the plain pocketbook pearly mussel) was also conducted, but
this species has since been dropped from the proposed list (see Section 8.0).
The assessment includes 1) a review of the literature concerning the above
species, 2) a summary of the results of the field survey, 3) results of con-
tracts made with various government agencies and experts, 4) a description
of the impacts of the proposed mill on these species, and 5) determination of
impacts of the proposed mill in combination with the expansion of the Boise-
• Southern paper mill located upstream of the KFI site.
Based on the results of the above analysis, the following conclusions
were reached concerning potential impacts on these species:
• Minor impacts on migratory wintering bald eagle populations could be
produced by sublethal effects of KME on fish distribution in the river.
These impacts will be lessened by the fact that wintering eagles con-
centrate around the Toledo Bend Dam and because wintering bald eagles
consume a variety of other foods besides fish. No impacts are pre-
dicted on nesting bald eagles in the project influence region.
• No impacts on the red-cockaded woodpecker are predicted as a result of
the construction and operation of the KFI mill since no increase in
pine-pulpwood harvest will result. Some minor impacts could occur as
a result of increased hardwood harvest, however. The proposed increased
159
-------
expansion by Boise Southern could potentially produce cumulative impacts
on the red-cockaded woodpecker, but nothing is known concerning Boises'
source of pine pulpwood or need for increased harvest.
No significant impacts on the American alligator are expected as a
result of construction and operation of the proposed mill.
Impacts on the plain pocketbook pearly mussel could result from sub-
lethal effects of KME on host fish distribution or mother mussel beds.
160
-------
2.0 RESULTS OF A COMPREHENSIVE SURVEY OF THE STUDY AREA
2.1 Literature Review
2.1.1 Bald Eagle (Haliaeetus leucocephalus) (Linneaus)
The bald eagle is currently listed by the Department of Interior as
endangered throughout the lower 48 States, except in Washington, Oregon,
Minnesota, Wisconsin, and Michigan where it is classified as threatened
(50 CFR 17.11 as amended 17 January 1978). This species occurs throughout
the continental United States.
Most bald eagles which occur in Texas and Louisiana are wintering migrants,
but nests are known to occur in several areas (usually coastal). Figures 1
and 2 summarize the known distribution of nesting territories of the bald
eagle in Texas and Louisiana. No nests are known to occur in Newton County,
although there is an unsubstantiated report that a nest exists along the
Sabine River south of Toledo Bend Dam (Bagley 1979).
Bald eagles are considered to be endangered because of recent declines
in their population caused by a variety of factors, including reduced repro-
ductive success, direct loss of feeding and nesting habitat caused by man's
activities, and human disturbance during nesting (USFWS 1979). Some are also
killed by hunters, destruction of nest trees, or by electrocution by power
lines (USFWS 1979).
161
-------
Figure 1. Texas counties in which active bald eagle nests have been
observed at least once since 1971 (from USFWS 1978).
i
i
i
i- ...
i
i •
i
i
1 u
1
(
1
•"
1
1
1
1
1
1 ~,
00.
«.
-
•OUT
MM
,.*
UM
1
ma
>ni-ni
MI
—
™—
noo
L
•Mtt
«MBd
««m
M
•nut
—
Off
m»
OHM
~
TCMMU
.
*~\
v _
*, "•"*"'•
•MW
— u
J\
L_
— »r~^-
MU» > *OO
1
l-LJ-.-^J ««
*"0(*IIO>™^ W-0
1
May 1978
Bald Eagle
Haliaeetus leucocephalus
\
Counties showing active nests,
used at least once since 1971.
Most bald eagles in Texas are
wintering migrants.
TEXAS
COUNTY OUTLINE MAP
STATE DEPARTMENT OF HIGHWAYS
AND PUBLIC TRANSPORTATION
TMNSPORTAIIOH PLANNING DIVISION
162
-------
RANGE MAP - LOUISIANA
BALD EAGLE NESTING TERRITORIES
Figure 2. Bald eagle nesting territory in Louisiana (from USFWS 1978a).
-------
Bald eagles prefer riparian habitats and are therefore usually found near
coastlines, rivers, or lakeshores. They nest near large bodies of water,
although they can nest far inland near marshes or ponds. The preferred nest
sites are in remote areas in the tops of large trees (dead or alive) but they
may utilize a variety of habitats for this purpose. Most nests are located
within about one-half mile of the nearest body of water, and the tree chosen
usually provides an open view of the surrounding area and a direct flight path
to water.
Bald eagles become territorial during the breeding season. Territorial
behavior begins approximately 2 to 3 months following egg laying, and studies
in Alaska have shown that territories range from 28 to 112 acres in size
(average 57 acres).
Following nesting, the birds are not as limited to shorelands, and they
may range over a variety of habitats while hunting their prey. Eagles con-
sume a variety of foods, including primarily small terrestrial vertebrates
(both living animals and carrion) and fish. If available, fish are preferred
to other forms of prey, and are taken selectively when present.
In the southern United States, bald eagles generally breed during winter.
During 1977-78, approximately 13 active nests were located in Louisiana
(USFWS 1979), and 7 in Texas (Potter 1978). Females do most of the nest build-
ing, in which from 1 to 4 eggs are laid, and young birds require 4 to 5
years to reach breeding age. Approximately 700 to 1,000 breeding pairs of
bald eagles are estimated to exist in the lower 48 States as of 1976 (USFWS
1979). Most bald eagles present in the study area are individuals which
-------
have migrated south into the area during winter.
Based on this literature review it can be concluded that it is certain
that bald eagles occur within the area of influence of the proposed Kirby
mill. Eagles would be most abundant along the Sabine River because this is
the major riparian habitat in the area, and would provide both food (fish)
and shelter. No eagles are known to nest along the river in the vicinity of
the mill.
2.1.2 Red-cockaded Woodpecker (Picoides borealis)
The red-cockaded woodpecker is currently listed as endangered throughout
its geographic range, which includes the southcentral and southeastern por-
tions of the United States (USFWS 1979). The known distribution of the red-
cockaded woodpecker in the Southeast up to 1978 is shown in Figure 3. The
IPWD (1978) and USFWS (1979) indicate that the red-cockaded woodpecker is
present in Newton County and several surrounding counties (Figure 3). The
gradual elimination of its preferred habitat (see below) has been the primary
cause for the species' gradual decline and current status on the Federal list.
The red-cockaded woodpecker nests only in cavities excavated in open
stands of pine trees (preferably longleaf pine, Pinus palustris) which are
infected with red-heart fungus disease (Forces). The woodpecker requires liv-
ing trees because they are resistent to ground fires which are common in this
type of plant community. Older trees are needed because long periods of time
are required for the red-heart disease to develop sufficiently to soften the inner
165
-------
Figure 3. Distribution of red-cockaded woodpecker in the
southeast United States (from Jackson 1971 in USFWS 1979) .
ON
m q
"t y-ii i*T^/-><'i .1
RED-COCKADED WOODPECKER DISTRIBUTION
RECORDS PRIOR TO I960
RECORDS I960 TO 1971
From Jackson, 1971
-------
parts of the tree enough to permit nest excavation. Nests take from several
months to several years to build (Jackson 1978). Several birds (up to 7 or 8)
may form a colony and excavate cavities in the same area, but within each colony
only one pair of birds usually breeds. Active cavities are usually marked by
sticky sap oozing from excavations surrounding the nest opening, which presum-
ably protects the nest from predators. Three to five eggs are laid during
i
spring, and the young are ready for independence within several weeks after the
juvenile stage (about 38 days after egg laying).
Red-cockaded woodpeckers feed primarily on insects, including ants, wood
boring insects, beetles, and grasshoppers. About 16% to 19% of their diet
includes wild fruit. The home range required to support a colony is very
large, and may vary from 100 to 200 acres. This is one of the main reasons
why preservation of this species is very difficult. Approximately 3,000 to
10,000 birds are estimated to currently exist in the United States (USFWS
1979).
Based on this review, it can be concluded that the project influence
region is located in an area which represents known .habitat for the red-
cockaded woodpecker. This area includes several counties in eastern Texas
and western Louisiana (Figure .3)•
167
-------
ON
00
U.S. FISH AND WILDLIFE SERVICE
REGION 4 ATLANTA, GA
RANGE. MAP
AMERICAN ALLIGATOR
Figure 4. Range map of the American Alligator in the
Southeast United States (USFWS 1979).
-------
March 1978
American Alligator
Alligator mississippiensis
M
•i f • . v < ma
-\-\.\ or
Range where the alligator"
is threatened
Range where the alligator
is endangered
TEXAS
COUNTY OUTLINE MAP
STATE DEPART WENT OF HIGHWAYS
AND PUBLIC TRANSPORTATION
TRANSPORTATION PIANN.XG DIVISION
Figure 5. Areas of Texas in which the American alligator is listed
as threatened or endangered (USFWS 1970).
169
-------
2.1.3 American Alligator (Alligator mlssissippiensis)
The American alligator is listed as endangered over most of its range,
except for certain areas in Louisiana and Texas where it is classified as
threatened. In Louisiana, it is listed as endangered in all areas except
Cameron, Vermillion, and Calcasieu Parishes (USFWS 1979) where it is listed
as threatened under the Endangered Species Act's "similarity of appearance"
provision (USFWS 1978). In Texas it is listed as endangered in Newton County
and several surrounding counties (Figure 4), and as threatened along most
coastal counties (Figure 5). Concern about the status of this species has
been the result of sharp reductions in populations during the late 1950fs
and 1960's caused largely by illegal poaching activities and, to a lesser
extent, elimination of habitat caused by development. The above differences
in classification are related to increases in alligator populations which
have occurred during the last several years" (especially in coastal counties)
largely as the result of conservation efforts by State and Federal agencies.
Alligators inhabit rivers, canals, swamps, lakes, bayous, and marshes.
They are predators which consume a variety of prey including mammals, other
reptiles, amphibians, birds, fish, and crustaceans. In the project area,
they would occur in lowland riparian forests and marshes along the Sabine
River and its tributaries. Biologists from TPWD and the Louisiana Fish and
Game Commission have indicated that alligators undoubtedly occur in the vici-
nity of Bon Wier, although no population estimates are currently available
specifically for that area (Section 2.3). Alligators mature generally in
approximately 6 to 7 years and make nest mounds out of grass during spring
or early summer. Females lay an average of 35 to 40 eggs and the young hatch
in about 9 weeks.
170
-------
Current populations of alligators in the United States have been esti-
mated to be about 734,384 individuals, 75% of which are in the area where
they would be considered to be listed as threatened. The current Louisiana
and Texas populations are estimated to be 200,682 and 26,784, respectively
(USFWS 1979). Because of recent increases in populations in many areas,
USFWS is considering the need for reclassification to a lower status, and this
is currently in progress in Louisiana (42. FR 6:2071-2077, 10 January 1977).
2.1.4 Plain Pocketbook Pearly Mussel (Lampsilis satura) (Lea 1852)
This moHusk is considered to be a close relative of a form of L^ ventri-
cosa (Barnes 1823) which inhabits the Red River and streams in northern
Louisiana and Arkansas (Stansbery 1978). Because it is a very rare species,
the geographical range of L. satura is not fully documented, but is believed
to include the area from the Calcasieu River in Louisiana west into Texas
(Stansbery 1978). Naiad moHusks as a group have experienced rapid recent
declines in abundance due to a variety of causes, including dam construction,
pollution, dredging, channelization, siltation, and direct harvesting by man.
Naiads are sensitive to many forms of pollutants since they are largely
sedentary organisms, and because, like most mollusks, they tend to concentrate
heavy metals,pesticides, and other chemicals in their body tissues. Because
of this, and because of their long life span (up to 20-40 years for some
species) and widespread distribution, naiads are considered to be good bio-
logical indicators of stream water quality.
171
-------
Several additional features of the biology of naiad mollusks must be
considered in order to evaluate impacts of the proposed Kirby mill. These
are as follows:
1) While naiads are generally collected as individual specimens, these
usually originate reproductively from mussel "beds," which are
colonies of mollusks. The beds are of critical importance in main-
taining populations within a given area, and destruction of such a
bed could result in the elimination of the species from the entire
area.
2) Naiad mollusks produce a larval stage which develops from the ferti-
lized egg and is released into the water column. This larval stage,
called a "glochidia," is usually parasitically dependent on a particular
species of native host fish for completion of the life cycle of the mol-
lusk. The glochidia encysts in the host fish gill tissue (usually) and
depending on the mollusk species, develops into the juvenile stage
after a week to several months. Juveniles break out of the cyst,
are released and drop to the bottom where they continue growing to
the adult stage. Most naiads can complete this life cycle on a
variety of species of fish but some require a particular fish species.
Therefore, "the problem of preserving threatened and endangered
naiads must include the need for preserving the native fish fauna,
including their natural migration and spawning patterns" (USFWS 1979).
Nothing is currently known about the host fish requirements of
Lampsilis satura, the species of concern in the proposed Kirby pro-
ject, although there is a diverse native fish population in the
Sabine River at the present time (Helton 1979).
In summary, to determine the impacts of porposed kraft mill on populations
of Lampsilis satura in the Sabine, the following must be considered:
• the relatively great sensitivity of naiad mollusks to a broad spectrum
of pollutants;
• the potential existence of "mother beds" of L. satura in the Sabine,
and the role they might play in maintaining populations; and
• the pattern of naiad reproduction which involves potential dependence
on a particular fish species.
172
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2.1.5 The Impact of Bleached Kraft Mill Effluent on Aquatic Communities
The purpose of this review is to briefly summarize the scientific litera-
ture concerning the effects of Kraft mill effluent (KME) on aquatic communities.
This review has been conducted in order to provide a basis for conclusions made
in section 3.0 concerning impacts on the bald eagle and plain pocketbook pearly
mussel which could potentially be caused by changes in the ecology of the
Sabine River produced by the proposed mill.
Impacts of kraft mill effluent on aquatic communties are caused by a com-
bination of factors including elevated BOD, discharge of suspended and dis-
solved solids changes in pH, increased color, and toxicity (USEPA 1979). Most
of the studies which have been conducted have concerned effects of KME on fish,
and much less is known concerning impacts on aquatic plants or invertebrates.
Acute Toxicity of KME
A summary of the literature concerning the acute toxicity of KME on aquatic
organisms is shown in Table 1. Untreated KME is highly toxic to aquatic organ-
isms, whereas treated effluent may be completely non-toxic even at full strength
(Seimetal. 1977; Tokar and Owens 1978). Toxicity of treated effluent varies
widely over time for several reasons (including periodic accidental spills or
dumping of spent chemicals) (USEPA 1979), and at least some sporadic toxic
effects of treated KME can be expected to occur at all discharge locations.
However, such effects would be highly localized and would occur very infrequently.
KME can also be toxic to fish food organisms. The few studies which have
been conducted have indicated that aquatic invertebrates are just as or slightly
173
-------
Table 1. Concentrations of pulp and paper mill effluents lethal to aquatic life (from USEPA 1979).
Effluent type
Kraft (KME)
Species
(S
Rainbow trout
"
Chi ook sa iwn
Coho salmon
n w
Perch
fiuppy
Oppossum shrimp
«i ii
Marine invertebrates
Daplmla ft Insect larvae
Insects and trout
Micro-crustaceans
96hrLC50
by volume)
< 15
15-50 ,
755 mg/1 (PBI)i'
26
> 100
< 15
4-24
> 100
7
40
> 100
18-32
24
4.5
4.7
2.6
3.7 (ave.)
"Toxic"
"
"Toxic"
Comments
Integrated newsprint
...
...
Untreated newsprint
Biotreated
___
Primary treatment
Secondary treatment and stabilized (SKME)
Primary treatment Hill A
Hill B
SKME non-chlorinated effluent
SKME chlorinated effluent
...
Primary treatment
Untreated 17°C
26CC
Clams, mussels, sea worms, zooplankton
tested (abstracted article, details not
available)
...
Sensitivity: Chironomus > trout > ganmarus
> mosquito
Slightly more resistant than salmonids
Reference
Loch ft MacLeod 1973
Loch ft Bryant 1972
Jacobs ft Grant 1974
Wilson 1975
Fahmy & Lush 1974
Loch ft MacLeod 1973
Sein et al. 1977
M "™" ™~" "
Tokar ft Owens 1968
M * M
Stiles 1977
MM
Cook et al. 1971
TokarT Owens 1968
Jacobs ft Grant 1974
M M N
Donnier 1972
Van Horn et al. 1949
Fahmy 6 Lush~T974
Litlntsev 1967
(Abstracted article— details not available)
Kraft-bleached
(BKHE)
Micro-crustaceans
Stonefly
Stonefly larvae
Phy topi ank ton
M
Rainbow trout
!• H
<* *'
Chinook and Coho salmon
Chinook salmon
Sockeye salmon
P ii
m ti
tf M
m h
Atlantic salmon
M tt
Guppy
Pontogawnarus
II
"Lethal"
"Toxic"
2.5
> 100
32
4-10
0.6
1.9-3.6
6.5
34-64
12-43
60% tests toxic 9
25% v/v
71 tests toxic 9
90S v/v
12-15
12-15
14
34-36
12
Sensitivity: Caimarus > Oaphnia > Cyclops
Lethal cone. 0.1 « 24 hr LC50 for guppy
Slightly more resistant than salmonids
Coccochloris sp. Untreated effluent
" Secondary treatment
...
Non-chlorinated effluent
Chlorinated effluent
Untreated
Secondary treatment
Demonstrated acclimation to toxicant
«•_
Biobasin treated
99 hr additional treatment
Untreated
Untreated.
Untreated
...
A crustacean
Wilson 197S
DeWitt 1963
Oimick ft Haydu 1952
Rainville et al. 1975
• N
Loch ft MacLeod 1973
Seppovaara 1973
N M
Holland et al. 1960
Loch ft MacLeod 1973
Howard ft Wai den 1965
Servizl et al. 1966
Gordon ftlervizi 1974
• MM
Howard ft Wai den 1974
Sprague i McLeese 1968
Betts ft Wilson 1966
Howard ft Walden 1974
Gazdziauskaite 1971a
-------
Table 1. Concentrations of pulp and paper mill effluents lethal to aquatic life (cont.).
Effluent type
Sulfite (SHE)
Sulflte (SWL)
Groundwood (WE)
Wood and debarking
leachates
Species
Pacific salmon
It H
Atlantic salmon
M II
H N
Pacific salmon
n H
Rainbow trout
i* M
H II
It n
Atlantic salmon
Pacific salmon
n H
Rainbow trout
Oaphnla
Gamma rus
Cyclops"
SnaM
Rainbow trout
M N
N I*
•» 1*
* *
• *
96hrLC50
(X by volume)
2
3-45
25-60
11-24
15
0.7-1.45
2,340 mg/1 (PBI)
3,000 "
0.18-0.29
1.1-3.5
8-12
2.500 mg/1 (PBI)
1-2
Varied
25
14-18
18-32 (72 hr)
> 100
> 100
0.2-4
0.2-2
9-45
\ 1
1.5-6
0.2-10
Comments
Untreated; Na and Ca base mills
Untreated Mg base
Untreated. Na base, high yield
Untreated, Na base, low yield
NHt base Including bleachery wastes
Neutral sulflte semi -chemical process
Aged 5 days
Samples limited to red liquors, NH, base
" " " Mg base
Main sewer
Mixed hardwood and softwood — maritime mill
Mixed wood species— many mills
Groundwood and some BKME effluent
H 1* M 1* It
M HUM II
1* . . * • • M
M MUM tf
Fir and spruce wood, nontoxic when bio-
treated 3 days
Pine, fir, and spruce wood, nontoxic if
treated > 5 days
Dense hardwoods
Estimated LCSO from X survival In 11
solution
Jackplne wood; > 5 day treatment required
to detoxify
Softwoods (bark leachates)
Reference
Rosehart et al. 1974
H ~~ ~~~ n
Wilson & Chappel 1973
(I If II
It H U
Rosehart et al. 1974
Kondo et aT.~T973
W11sonT977
Grande 1964
Wilson & Chappel 1973
M p M
Wilson 1972
Leach & Thakore 1974c
Howard & Leach 1973b
Wilson 1975
M ' H
M •
MM . -
M M
Howard & Leach 1973a
• M N
« « M
M MM
McKague 1975
Howard I Leach 1973a
Leach et.al. 1974
^/Concentration expressed as Pearl Benson Index, an index to the amount of Hgnln present.
-------
more sensitive to untreated KME but treatment of the effluent usually elimin-
ates this sensitivity (USEPA 1979).
Sublethal Impacts
Sublethal impacts are those which produce stress on an organism but do
not necessarily cause direct mortality. The importance of sublethal effects
is that they may reduce the organisms' chances of survival, thereby resulting
in indirect mortality or changes in the species composition of natural popu-
lations. A summary of sublethal effects caused by KME is provided in Table 2.
These effects include changes in respiration, circulation, metabolism,
morphology, growth, production, and abundance (Table 2). While the data are
highly variable, certain conclusions have been drawn concerning the results.
One general conclusion is that the threshold value for sublethal effects of
KME is often equal to about 1/10 of the 96-hour LC5Q concentration (USEPA 1979).
However, several sublethal responses were noted at lower concentrations of
KME. These included the cough response of rainbow trout, production of salmon
in laboratory streams, growth of sockeye salmon, and temperature tolerance of
coho salmon (USEPA 1979).
Studies of the effects of KME on fish in artificial streams have shown
that production may be reduced or actually increased depending on the degree
of treatment. Untreated KME is generally very toxic, whereas KME that receives
advanced treatment may actually stimulate production of fish and algae
(USEPA 1979). These studies point out the need for adequate KME treatment,
but also indicate that a potential exists for producing increased eutrophi-
cation in waters receiving treated KME.
176
-------
Table 2.- Sublethal effects of pulp and paper mill effluents on aquatic life (from USEPA 1979).
Threshold concentration
Effects
RESPIRATORY
Coughing response elevated
a u a
• a M
Ventilation volume Increased
Oxygen uptake Increased
M H M
n a ' «
CIRCULATORY
Arterial oxygen tension reduced
M N M • II
White blood cells reduced
Blood neutrophll count elevated
Hematocrlt reduced
Small lymphocytes decreased
NeutrophlUs Increased
Hematocrlt reduced
Blood values reduced
MM M
MM M
METABOLISM
Plasma glucose elevated
M M M
M • •
a a M
Body protein decreased
Muscle protein depressed
Liver glycogen depressed
H • M
Liver RNA decreased
Blood and muscle lactate Increased
Swimming ability reduced
a MM
Species
Rainbow trout
M M
Sockeye salmon
H M
M M
Pontogammarus
Salmonlds
Rainbow trout
Sockeye salmon
Coho salmon
H M
Sockeye salmon
Coho salmon
M M
M M
Rainbow trout
Carp
Pontogammarus
Coho salmon
M M
" "
Rainbow trout
II M
Coho salmon
Sparus
macrocephalus
Coho salmon
S_. macroceph-
alus
Coho salmon
N n
Pontogammarus
Effluent
type
KME
"
BKME
M
•
SME
SWL
BKME
H
KME
H
KME
N
"
n
SME
•
BKME
KME
M
BKME
M
"
• KME
BKME
KME
BKME
KME
SME
fraction of
96-hr LC50
0.0870.18
0.5*'
0.1-0.2
0.2
0.33
—
> 1.0
0.47
0.33
0.1
0.25
...
> 0.33
"
M
— .
0.8*/
0.1
0.0-0.3
.
0.1-0.25
M
0.1
...
0.1
...
0.25
0.1-0.2
X volume Comments
11 Immediate effect
Untreated; (treated no
effect)
Possible adaptation
Immediate effect
M M
12 LCSO Independent of life
stage
100
No adaptation
M M
2.4 21 day expos.
200 day expos.
1.5 8 week expos.
25 day expos.
12 day expos, (returned
to normal 1n 25 days)
25 day expos.
Abstracted article
M •
12-25 Increased respiratory
quotient
•
44 Fish also stressed by
swimming
200 day expos.
Increased for 12 days;
decreased In 25 days.
200 day expos.
MM H
MM M
3.2-6.2 12-24 hr. expos. In
river
MM* • M
II M M M M
200 day expos.
1 .8-9.0
12-25 Abstracted article
Reference
Walden et al. 1970
Schaumburg et^ al_. 1967
Davis 1973
N •
• H
Gazdzlauskalte 1971a.b
Williams et al. 1953
Davis 1973
« M
McLeay 1973
Howard ft HcLeay 1972
Webb ft Brett 1972
McLeay 1973
M M
Howard ft Walden 1967
Seppovaara 1973
M M
Gazdzlauskalte I971b
McLeay ft Brown 1975
Howard ft McLeay 1972
McLeay 1973
McLeay ft Brown 1974
U MM
Howard ft McLeay 1972
Fujlya 1961
Howard ft McLeay 1972
Fujlya 1961
Howard ft McLeay 1972
Howard 1975
Gazdzlauskalte 1971a.b
-------
Table 2. Sublethal effects of pulp and paper mill effluents on aquatic life (cont).
o>
Threshold concentration
Effects
BEHAVIOR
Avoidance
No avoidance
Drift Increased .
Orientation to current
Alarm response slowed
Unresponsive
Feeding reduced
M II
M M
N M
H li
No feeding
MORPHOLOGY. HISTOLOGY
Liver, kidney, Intestine
Liver
Opaque eyes
H M
Abnormalities Increased
H H
M M
GROWTH
Growth rate reduced
MM H
It * M
MM W
II • M
Species
Sockeye salmon
Atlantic salmon
H H
Chinook salmon
It li
Lobster
Snail
Salmonlds
Coho salmon t
Steel head
Gamma rus
Sockeye salmon
it it
Coho salmon
M . II
Chinook salmon
II M
Pontogammarus
Lobster
Salmonlds
Sparus
macrophalus
Chinook salmon
II M
M M
Oyster
Clams
Oyster
Sockeye salmon
H n
Chinook salmon
n . n
M n
Effluent
type
BKME
KME
li
KHE
BKME
KME ft GME
SUL
KME
li
BKME
li
KME
II
*
M
SHE
BKME
KME
KME
KME
N
• .
SWL
n
»
KME
BKME
KME
H
M
fraction of
96-hr LC50
0.8
0.37
0.0006
...
...
...
...
—
—
...
0.8
0.4
0.15
0.1-0.2
0.14-0.36
0.1-0.3
...
-..
...
-..
...
—
—
0.05-0.1
0.14-0:35
0.1-0.3
...
X volume
50
5-10
50
> 20
...
—
100
> 1
...
...
—
12-25
> 10
100
3.2-6.2
f
33*
n
6.6
6-12 mo/1
(PBI)?/
1-3 Pig/1
(PBI)
0.15-0.5
10-25
...
1.5
...
6
Garments
Bleachery wastes — not
whole effluent
Strong response
Vague response
Variable results
Bleachery wastes
Lowest level tested
Avoid low but not high
cone.
Variable results
Bleachery wastes
• M
Response lasted 2 wks.
Long term study
2 week expos.
LC50 Independent of life
stage
12-24 hr expos. In river
"Synthesized wastes"
7 day expos.
• M
• «
> 201 Increase 1n
abnormalities
MM M M
Mg base most toxic
(untreated effluent)
8 wk expos.
...
...
...
...
Reference
Servlzl et al_. 1966
Sprague & Drury 1969
H n n ii
Jones et al. 1956
D1m1ck~et~al . 1957
McLeese~T97ff
Wilson 1975
Dlmlck et ajk 1957
Galtsoff et al. 1947
Servlzl eI~aT7 1968
11 ™" ' "" ~ H
Davis 1973
M II
Ellis 1967
Tokar & Owens 1968
Gazdzlauskalte 1971a.b
Mcleese 1970
Williams et^jn. 1953
Fujlya 1961
Holland et^ al_. 1960
n M
H *
Woelke 1960
Noelke et al. 1970
1970. 1972
Webb & Brett 1972
Servlzl et al. 1966
Ellis 1917 ~
Tokar ft Owens 1968
Warren 1972
-------
Table 2. Sublethal effects of pulp and paper mill effluents on aquatic life (cont.).
Threshold concentration
Effects Species Effluent fraction of X volune Comments
type 96-hr LC50
GROWTH (cont) .
Growth rate reduced Chinook salmon KME 1 mg/1 BOD^
n -
Coho salmon
Pontoganroarus
Oyster larvae
U 1*
Coho salmon
M M
H H
Green algae S
Selena strum K
Senedesmus
Anabaena
Selena strum
Senedesmus
" Anabaena
Growth efficiency reduced Sockeye salmon
0.12-0.14
4.5 30 day expos, treated
effluent
0.6 30 day expos.
12-25
—
0.15-0.5 Untreated effluent
1.3 Treated effluent
0.1-0.2
0.1-0.25
> 0.25
E
E & 6ME
...
...
...
...
...
Several wk. exp.
70 day expos.
...
—
15 Abstracted article
25
50 i
50 '
50
SO
50
a green algae)
a green algae)
a blue-green algae)
a green algae)
a green algae)
a blue-green algae)
10-25 8 wk. expos.
Chinook salmon 0.06-0.12
0.4-0.9 12 day expos.
Reference
Borton 1970
Holland et al 1960
GazdzlauskYTte 197 la
Woelke et al. 1972
• ~~ "~~ N
Davis 1973
Howard S McLeay 1972
HcLeay & Brown 1974
Seppovaara ft Hynnlnen 1970
Wilson 1975
M
H
W
M
*
Webb & Brett 1972
Tokar & Owens 1968
PRODUCTION-ABUNDANCE
Production reduced
Production enhanced
Diversity change
Chinook salmon KME
Caddis larvae
Amphlpods
Fish food
organisms
Chinook salmon
Amphlpods
Snails
Insects
0.19 1.5
0.08
0.03 mg/1 BOD 1.5
0.75 mg/1 BOD 0.35
0.2
1.4
1. 5-3.0 ng/1 0.7-1.5
BOD
1.5 " • BOD 7.5
5
0.2-5
100
Lab streams; winter, Selm et_ al_. 1977
blotreated effluent
Lab streams (untreated Ellis 1967
effluent)
Lab streams (untreated Llchatowlch 1970
effluent)
Stream channel (prim. Warren et^ al_. 1974
treatment)
HUM M «
Outfall area (Cladocera Flllmonova 1968
and rotifers absent)
Lab streams (stabilized Llchatowlch 1970
effluent) Mill B
Lab streams (prim. ' "
treated effluent) Mill B
Lab streams (stabilized "
effluent) Mill A
Stream channels Warren e£ a1_. 1974
(treated effluent)
Stream channels (treated
and untreated effluent)
Stream channels (un- Warren et^ al_. 1974
treated effluent)
Treated effluent channel Shlreman 1975
j/test*d concentration, not a threshold value
-/Pearl Benson Index, an Index to the amount of Hgnln present
•/effluents were not acutely toxic, therefore effective concentrations were expressed as 5-day
-/.threshold concentration given as 0.5 of the 96-hr LCSO value for rainbow trout.
£/ " " " " 0.05 " " " " " " Chinook salmon.
BOD.
-------
Toxic Components of KME
The majority of the toxicity of unbleached KME is caused by several
natural resin-acids, whereas chlorinated compounds produce the majority of
toxic effects in bleached effluents (USEPA 1979) . Toxic components of KME
can be further divided into volatile and non-volatile components. Volatile
components include highly toxic l^S and methylmercaptans, but these largely
evaporate during the aeration stage of treatment. The non-volatile fractions,
including certain resin-acids and fatty acids, are the toxic component of
greatest significance to aquatic communities (Rogers 1973; Leach and Thakore
1974). In mills which utilize caustic bleaching, as the proposed mill would,
resin-acids, lignins, phenols, and stearic acid can become chlorinated (Leach
and Thakore 1974, 1975) and can account for the majority of the toxicity of
KME. These same studies have shown these compounds to be toxic at levels
below 1 mg/1.
Suspended solids, and especially wood fibers, are also present in KME,
and produce negative impacts on aquatic communities (Springer and Atalla 1974).
Woody fibers can be directly toxic to fish (USEPA 1979) but lethal amounts
are seldom released from pulp mills (Smith et al. 1965), and therefore do
not usually represent a significant environmental problem.
Other suspended and dissolved material is also discharged by kraft mills,
and these contribute to elevated BOD levels. They can also accumulate on
the bottom in sludge beds where they may cause elimination of the bottom
fauna and reduction of sediment oxygen levels (USEPA 1979). Dissolved solids
can also produce osmoregulatory stress (Tsai 1973).
180
-------
Impacts of Color
Color is one of the most noticeable components of KME. Its origins and
ecological effects are discussed on page 59 of the DEIS and in the Technical
Support Document. In general, color is expected to exert the following types
of impacts: 1) color reduces photosynthesis of phytoplankton and benthic
plants (Stone et al. 1974); 2) highly colored water can cause some fish to
avoid the area; 3) color can interfere with the reproductive cycle of certain
visually oriented fish; 4) by complexing with metal ions such as iron and
copper, residues may form which can inhibit metabolism of organisms low on
the aquatic food chain, thereby reducing productivity of the receiving waters;
and 5) color may exert a long term BOD (not measured by the BODs test) which
could affect aquatic communities. Very little detailed information is actually
available concerning the impacts of color on aquatic communities, however (USEPA 1976)
2.2 Results of the On-Site Survey
2.2.1 Bald Eagle
During the on-site survey of October 1978 no bald eagles or bald eagle
nests were observed on the proposed site or along the river corridor; The
bald eagle is known to have nested historically along the Sabine River but no
nests are currently known beyond 50 miles inland of the Texas coast (TPWD 1979).
2.2.2 Red-cockaded Woodpecker
A few large pine trees were observed on the proposed site which could pro-
vide potential nest sites for the red-cockaded woodpecker, but no nests or birds
were observed during the field survey. Since the species requires large stands
181
-------
of mature pine forest, construction of the mill would not eliminate a poten-
tial nesting site.
2.2.3 American Alligator
No alligators dr alligator nests were observed during the on-site visit.
Alligators are expected to occur along this part of the Sabine River, however
(Section 2.3).
2.2.4 Plain Pocketbook Pearly Mussel
Benthic samples were taken from five locations in the Sabine River
near the project site (Figure 15 of DEIS). A single specimen of L. satura
was collected at the AT & SF railroad bridge. This was the only specimen col-
lected during the study. It was sent to Dr. David Stansbery of Ohio State
University, who confirmed its identity.
2.3 Coordination and Consultation
A complete list of persons contacted during the assessment and their
affiliations is provided in Table 3. The following is a discussion of the
results of this effort.
2.3.1 Bald Eagle
Mr. Floyd Potter (TPWD) confirmed that up to two dozen or more bald
eagles had been sited along the length of the Sabine River during aerial
182
-------
Table 3. List of persons and organizations contacted
during the completion of this assessment.
Name Affiliation
Dr. David Stansbery Ohio State University
Dr. Arthur Clark Smithsonian Institute
Jerry Bentley USFWS1
Paul Seidensticker TPWD2
Kenneth Lantz LWFC3
Jerome Jackson Mississippi State University
Fredrick Bagley USFWS1
Fredrick Dunham LWFC3
Lawrence McNeiss LWFC3
Dr. Kenneth Stewart North Texas State University
Robert Bounds TPWD2
Ronald Josselet TPWD2
Floyd Potter TPWD2
Dr. Denwood Butler USFWS1
Dr. John Van Conner Louisiana State University
Gary Halveson USFWS1
Gary Henry USFWS1
Al Montgomery USFWS1
Richard Bailey USFWS1
Dr. William Kovalak University of Michigan
Thomas Turnipseed USFWS1
1. United States Fish and Wildlife Service
2. Texas Parks and Wildlife Department
3. Louisiana Wildlife and Fisheries Commission
183
-------
surveys conducted by his department. He stated that bald eagles could defin-
itely be expected to occur along the stretch of the Sabine near Bon Wier. He
also provided a performance report concerning the known occurrence of bald
eagle nests in Texas (Appendix 1) which is based on extensive aerial surveys.
Seven active nests were found in 1977 and 1978. No active nests have been
found over 50 miles from the coast, and no nests are known to occur in the
project area.
Mr. Fred Bagley of the USFWS (Jackson, Mississippi office) has conducted
aerial surveys of eagle populations along the Sabine River. He also reported
concentrations of bald eagles around the Toledo Bend Dam reservoir.
Mr. Kenneth Lantz of the Louisiana Wildlife and Fisheries Commission
stated that large populations of threadf in and gizzard shad occur seasonally
in a 10 to 15 mile stretch of the Sabine River below Todedo Bend Dam and in the
diversion canal which goes around the dam. They prefer the higher currents
found in these areas and are most abundant during migrating runs. These
populations are probably one of the main food sources for bald eagles in this
area*
2.3.2 Red-cockaded Woodpecker
Dr. Jerome Jackson (Mississippi State University) stated that the main
problem with protection of the red-cockaded woodpecker is the large amount of
mature undisturbed forest (100-200 acres) required by each nesting colony.
He also suggested that EPA review his article on the red-cockaded woodpecker
in a recent symposium (Jackson 1978).
-------
Mr. Frederick Dunham of the Louisiana Wildlife and Fisheries Commission
stated that there were no detailed studies of the distribution of the red-
cockaded woodpecker in the project area other than one study near Fort Polk.
He suggested that site-specific surveys should be conducted in order to deter-
mine if the species was nesting in a particular area prior to harvesting.
2.3.3 American Alligator
Mr. Larry McNeiss of the Louisiana Wildlife and Fisheries Commission
stated that the alligator is present in the area of the Sabine River near
Bon Wier and the proposed discharge point, although no field data on popula-
tion densities are available. Mr. Floyd Potter of the TPWD stated that this
species would occur in Newton County.
2.3.4 Plain Pocketbook Pearly Mussel
Dr. David Stansbery described Lampsilis satura (Lea 1852) as a close
relative of L. ventricosa (Barnes 1823). L. ventricosa occurs in "the Red
River and streams to the northeast in northern Louisiana and Arkansas."
Lampsilis satura is found "from the Calcasieu River of the Louisiana Gulf
Coast west into Texas." The distinctive taxonomic features of L. satura
are 1) a dark periostracum, 2) "lack of rays," and 3) "an atypical cardinal
tooth in the right valve" (Stansbery 1978). Dr. Stansbery has collected
this species from various parts of the Sabine River over the last several
years and stated that it is very rare. It occurs in a variety of substrate
185
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types ranging from sand to gravel, but does not prefer soft, fine-grained ooze.
It also seems to require at least some moving water and like most moHusks
it is sensitive to a broad spectrum of chemical pollutants. It would there-
fore probably be among the first of the organisms to be affected by KME.
Dr. Arthur Clark of the Smithsonian Institution stated that there are
several records for L. satura in this part of Texas and Louisiana. These
include: 1) one record from near Alexandria, Louisiana (collected by Hale),
2) a record from the Sabine River near Logansport, Louisiana (by Frierson in
1928), and 3) a record from the Sabine River in Smith County, Texas, by Askew
(also more than 50 years ago).
In summary, L. satura definitely occurs in the Sabine River basin. It
is a very rare but taxonomically valid species whose geographical distribution
has not been precisely delineated. Like most other naiad mollusks, it also
would be very sensitive to many forms of chemical or organic pollution,
including KME.
2.3.5 Status of the Sabine River Fisheries
Preliminary results of a recent TPWD study of the Sabine River Fisheries
have become available during the preparation of the FEIS. Because they relate
directly to the potential impacts on the bald eagle (i.e., prey availability)
and the plain pearly pocketbook mussel (i.e., host fish availability), these
results will briefly be discussed here.
186
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The TPWD study was conducted between August and December of 1979.
Mr. Randy Helton of TPWD has provided a list of species taken from around
the Bon Wier area of the Sabine River and its adjacent tributaries (Table A)
The following is a summary of the results of the study:
• A total of 42 species of fish were collected during the course of
the study from the area near Bon Wier. Considering that sampling
was not extensive (data here are only for the area near Bon Wier)
and that it was conducted over only a part of the year, this is a
relatively large number of species. For example, pre-impoundment
surveys conducted in the same approximate area of the Sabine by Lantz
•(1970) over a period of three years yielded a total of 6.5 fish species.
• The most abundant fish caught were shiners, sunfish, and mullet.
• A large number of blue suckers, listed as threatened by TPWD, were
observed near Bon Wier. Two were captured at this location.
The conclusion that can be drawn from the above data is that a relatively
abundant and diverse fish population exists in the Sabine River near Bon Wier.
These results are supported by the results of the 1978 USFWS Stream
Evaluation Survey (USFWS 1978). This study classified the section of the
Sabine River near Bon Wier as a "value class I - highest valued fishery
resource." This classification was based on a survey of unpublished data on
the river as well as the experience and professional judgement of State and
Federal agency biologists. According to the USFWS definition, this implies
that this part of the Sabine River has: 1) "documented occurrence (legally
defined) of State or Federally chartered threatened species,". 2) "documented
present occurence of a State or Federally chartered threatened species," 3)"habitat
maintaining outstanding populations of species of high interest as defined
by the State to include self-sustaining wild populations that maintain a
18?
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Table 4. Results of the Texas Parks and Wildlife Fish survey near Bon Weir,
Texas. Samples taken between August and December 1979) (from Helton 1979) .
Date
Species
No date Chestnut lamprey
Spotted gar
Longnose gar
Gizzard shad
Carp
Blacktail shiner
Blue sucker
Blacktail redhorse
Flathead catfish
Yellow bass
Spotted bass
Largemouth bass
Longear sunfish
Bluegill sunfish
Striped mullet
8 August 1979 Smallmouth buffalo
Longnose gar
Spotted gar
Yellow bass
Warmouth
Black crappie
White crappie
Spotted bass
Backtail shiner
Gizzard shad
Ladyfish
Bluegill
River carpsucker
Striped mullet
Blacktail Redhorse
Channel catfish
Channel catfish -
Black crappie
Largemouth bass
Spotted bass
Yellow bass
Ongear sunfish
Bluegill
Redear sunfish
Gizzard shad
Striped mullet
Ladyfish
Blacktail shiner
Longnose gar
Spotted gar
Location and
Type of Sampling
Electrofishlng boat
in Sabine R. at Bon
Weir bridge area
Number
Collected
Gill Net sampling in
Sabine R. at Bon Weir
15 August 1979
2
1
3
2
5
2
5
1
1
3
1
8
4
23
3
2
1
1
2
2
2
1
1
1
1
1
3
5
6
1
2
2
2
1
2
4
1
1
1
1
3
3
1
Weight(Ibs)
0.1
2.8
2.0
1.3
3.8
0.2
0.5
4.0
0.4
0.2
1.0
1.2
0.6
0.2
16.8
8.5
6.8
2.5
0.1
0.3
0.6
0.4
0.6
0.1
0.4
0.2
0.1
1.0
2.3
4.5
10.4
3.3
0.6
0.8
0.4
0.6
0.4
0.2
0.2
0.5
0.6
.3
,1
0.
0.
5.4
0.8
188
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Table 4. Results of the Texas Parks and Wildlife Fish survey (cont.)
Date
Species
no date Redfin shiner
Location and
Type of Sampling
Seine samples (trib-
utaries in Bon Weir
area)
Ironcolor shiner
Blacktail shiner
Blackstripe topminnow
Mosquitofish
Largemouth bass
Slough darter
Redfin shiner
Ironcolor shiner
Blacktail shiner
Redfin pickerel
Golden shiner
Pugnose minnow
Ironcolor
Blacktail shiner
Mosquitofish
Bluegill
Longear sunfish
Flier
Slough darter
Caney Creek
Number
Collected
10
29
70
1
3
1
2
27
21
50
Slaydon Creek (10
miles south of Bon Weir
Golden shiner
Ironcolor shiner
Blackstripe zopminnow
Slough darter
Davis Creek
Ribbon shiner
Ironcolor shiner
Blacktail shiner
Blackstripe Topminnow
Mosquitofish
Brook Silverside
Dempsey Creek
Redfin Pickeral
Golden shiner
Pugnose minnow
Ribbon shiner
Blackstripe topminnow
Mosquitofish
Brook silverside
Largemouth bass
Flier
Arch Creek
28
20
23
1
18
4
2
6
1
2
11
2
1
17
8
18
2
2
4
1
19
2
30
2
12
28
1
1
189
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Table 4. Results of the Texas Parks and Wildlife Fish survey (cont.)<
Species
Pugnose minnow
Location and
Type of Sampling
Number
Collected
Quicksand Creek
(different site than
previous one mentioned)
Ribbon shiner
Redfin shiner
Blacktail shiner
Silvery minnow
Blackstripe topminnow
Slough darter
Southern brook
lamprey
Back-Pack Electrofish-
ing Unit (only one
sample site in Bon
Weir area)
Redfin pickerel
Ironcolor shiner
Blacktail shiner
Pirate perch
Blackstripe topminnow
Largemouth bass
Warmouth
Green sunfish
Spotted sunfish
Bluegill
Longear sunfish
Dollar sunfish
Flier
Slough Darter
11
3
6
74
4
1
1
6
5
2
6
10
1
1
2
3
3
24
2
2
1
190
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high yield or represent a unique aesthetic, scientific, economic, educational,
or recreational value," and 4) "very low or essentially no potential for
restoration or reclamation of the habitat to its present species composition
and population levels, no alternate resource could be introduced that would
be as highly valued, no acceptable options are available to compensate for
the loss of this habitat at this time."
191
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3.0 NATURE AND EXTENT OF PROPOSED PROJECT ON ENDANGERED SPECIES
3.1 Bald Eagle
No impacts on the reproductive cycle of the bald eagle will occur as the
result of removal of vegetation from the site, since no nests or suitable
nest trees occur here. Harvesting operations could affect nests or potential
nest sites in some of Kirby's holdings which provide suitable habitat, but
these will be minimimal since Kirby employs a management program which includes
identification and preservation of any nests or potential nest trees on its
land. This program is briefly described in Appendix 2.
If changes in the river fisheries are produced by the effluent from the
proposed mill either through 1) "sporadic" (Section 2.1.5) occurence of toxic
effects or 2) avoidance of fish of the affected stretch of river due to elevated
color levels or other sublethal effects (Section 2.1.5), impacts on migrating
bald eagle populations could occur, since their food source would be reduced
or altered. Impacts of sporadic toxicity of KME on fish populations will have
only a very minor effect on bald eagles since the discharge point is over 50
miles downstream of the Toledo Bend Dam where the eagles concentrate (eagles
feed up and down the river, but tend to concentrate in an area 10 to 15 miles
below the dam and in the diversion canals that go around the dam). In addi-
tion, sporadic discharges would occur very infrequently and would be on an
extremely small scale, which implies that impacts on fish would be minimized.
Impacts of color avoidance would be minimized by the fact that bald eagles
concentrate primarily around the Toledo Bend Dam, but this arguement assumes
that the mill discharge will not affect the movement of fish populations within
the Sabine River. It is therefore possible that the proposed mill could have
192
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some impact on bald eagles in the area if shad or populations of other prey
fish species are affected in this manner. However, the potential for this
to occur is lessened by the fact that wintering bald eagles eat a variety of
other foods (Steenhoff 1976). They prefer fish, but waterfowl become an impor-
tant food source as winter progesses (Lish 1975, Spencer 1976). Eagles may
also feed on mammals or mammal carrion (Lish 1975). One study in Oklahoma
showed that remains of Canada geese and cottontail rabbits constituted 77%
of the volume of pelle-ts from wintering bald eagles. In summary, impacts of
the proposed mill on the bald eagle will be limited entirely to migrating
populations which do not nest in the region. Impacts which could occur include
primarily those caused by potential changes in fish distribution within the
Sabine River produced by sublethal effects of KME. These impacts will be
lessened by the fact that wintering eagles eat a variety of food and that the
birds tend to concentrate their feeding activities just below or around Toledo
Bend Dam.
3.2 Red-cockaded Woodpecker
Potential impacts of the proposed mill on the red-cockaded woodpecker
must be considered in relation to projected harvest trends and utilization
of harvested wood products. The proposed mill will require approximately
440,000 cords of residual chips/year to operate. This material will come
entirely from waste chips generated in three plywood plants and one saw mill
operated by KFI. Rather than sell residual chips from these sources to other
companies, KFI will utilize them as feedstock for the proposed mill. There-
fore, there will be no increase in pine harvest caused by the proposed mill.
Since there will be no increase in pine harvest attributable to the mill, no
193
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impacts on the red-cockaded .woodpecker will result. KFI does project an
increase in hardwood harvest (an increase of 136,000 cords/year) on its hold-
ings but this would have only minimal impacts on the red-cockaded woodpecker
since pine is its preferred habitat. Impacts of increased hardwood harvest
would be limited to potential disturbance of nesting colonies (none are known
to exist on Kirby land) (Appendix 2) or increased competition for nest trees
between red-cockaded woodpeckers and other hole nesting birds caused by hard-
wood removal. However, these would be only minor impacts. Any such impacts
which might occur to the red-cockaded woodpecker will also be minimized
because KFI employs a wildlife management program which includes measures to
ensure protection of the red-cockaded woodpecker (Appendix 2). This program
includes review of all harvesting plans to determine that no nests are pre-
sent in a particular area, periodic wildlife surveys, and coordination/con-
sultation with state and federal agencies. Appendix 2 outlines KFI's program
to protect endangered and threatened species.
3.3 American Alligator
No significant impacts of the mill on this species are predicted. If
fish avoid the area due to sublethal effects, this food source (one of many
on which the alligator depends) would be reduced however.
3.4 Plain Pocketbook Pearly Mussel
Impacts of KME on this species are predicted based on its known presence
in the vicinity of Bon Weir and the great sensitivity of mollusks in general
to a broad spectrum of chemical wastes. In addition, if host fish species
-------
avoid the area as a result of sublethal effects of KME on their behavior or
physiology, the life cycle of _L. satura could also be disturbed. Finally, if
a mother mussel bed is present in the vicinity of the discharge point and were
affected by the effluent, this could significantly affect the abundance of _L.
satura. However, no such beds were observed during the October 1978 field
survey.
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4.0 POTENTIAL CUMULATIVE IMPACTS ON ENDANGERED SPECIES OR CRITICAL HABITAT
4.1 Bald Eagle
The results of both air and water quality modeling completed as part of
this FEIS (USEPA in preparation) indicate that no air quality standards in
the study area or water quality standards in the Sabine River will be violated
as a result of the proposed Kirby mill alone or in combination with the expanded
Boise Southern mill on Bayou Anacoco. For air quality, these conclusions apply
to National Ambient Air Quality Standards (NAAQS) for air contamination by SCU,
total suspended particulates, CO and NC>2, as well as the Prevention of Signi-
ficant Deterioration (PSD) requirements for S02 and particulate matter (USEPA
in preparation). For water quality the conclusions apply for temperature,
discharge volume, chloride sulfate, color and dissolved oxygen (USEPA in pre-
paration) . Therefore, no significant cumulative impacts caused by discharge
of KME or air pollutants from both mills are expected with respect to those
parameters included in the air and water quality standards. The Kirby mill
will increase average color levels in the Sabine River by about 100 platinum
Cobalt units above that produced by Boise Southern, but the Boise discharge
will account for the majority of the overall color increase in the river accord-
ing to the water quality modeling results. Therefore, the impacts of the
proposed Kirby mill will not significantly add to any color avoidance impacts
on fish populations in the river, and subsequently, will not significantly
affect migrating bald eagle populations.
196
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4.2 Red-cockaded Woodpecker
Since no increases in pulpwood production are predicted as a result of
the proposed mill, no cumulative impacts on the red-cockaded woodpecker are
expected. However, if Boise Southern triples its output, significant impacts
could occur if its harvesting operations also triple. However, no information
is currently available concerning Boise's proposed source of new pulpwood to
meet its requirements for expansion, and therefore, cumulative impacts on
red-cockaded woodpecker habitat are not possible to predict at this time.
4.3 American Alligator and Plain Pocketbook Pearly Mussel
Since no water quality standards are predicted as a result of the com-
bined operation of the two mills, no significant impacts are expected on these
species.
197
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5.0 STUDY METHODS USED
The study methods used to prepare this assessment included: 1) a review
of the scientific literature concerning abundance and distribution of
threatened and endangered species in the study area, 2) an on-site survey,
and 3) personal contacts by phone or letter with State and Federal agencies,
college and university experts.
A complete search was also conducted on the effects of kraft mill wastes
on aquatic life, including algae, fish, and mussels. This search utilized
primarily DIALOG and NTIS data bases.
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6.0 DIFFICULTIES IN OBTAINING DATA AND COMPLETING STUDY
No detailed information on the abundance of L. satura in the Sabine
River was available, although its presence there was confirmed. Additional
data on its abundance and distribution and on the possible existence of beds
or colonies of this species would be very useful in assessing the impacts of
the proposed Kirby project (and Boise expansion) on this species.
No information was available on the detailed distribution of the red-
cockaded woodpecker within the parcels of land to be harvested by Kirby,
although these areas represent potential habitat since they are all within"
the known range of this species.
199
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7.0 CONCLUSIONS OF THE NET EFFECTS OF PROPOSED PROJECT ON ENDANGERED SPECIES
7.1 Bald Eagle
Potential impacts on this species will be minor, and will be limited
entirely to migrating populations which winter in the project area. These
impacts will consist of changes in food availability caused by sub-lethal effects
of KME on the river fisheries. However, such impacts are not considered to
be significant since wintering eagles consume a variety of foods and also because
the eagles in this area concentrate their feeding activities more than 50 miles
upstream of the proposed pulp mill site.
7.2 Red-cockaded Woodpecker
Since no increase in pine-pulpwood harvest is projected by KFI over that
projected for supplying its plywood and saw mills, no impacts on red-cockaded
woodpeckers are expected to result from construction and operation of the mill.
Some impacts could result from the expected increase in hardwood harvest which
would be produced by the mill, but these are considered minor.
Cumulative impacts on the red-cockaded woodpecker could be produced by
the expanded Boise Southern mill, but nothing is known concerning the source
of their pulpwood or Boises* need for increased harvest.
7.3 American Alligator
No significant impacts on this species are expected as a result of the
operation and construction of the mill.
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7.4 Plain Pocketbook Pearly Mussel
Impacts on this species could occur as a result of sublethal effects of
KME on host fish distribution or mussel colonies which could exist in the
river below the discharge point. These impacts would be of similar nature
for both the proposed KFI and Boise Southern mills.
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8.0 ADDITIONAL RELEVANT INFORMATION
During the preparation of this assessment, the plain pocketbook pearly
mussel (L. satura) was dropped from the list of proposed endangered species.
This action was listed in the Federal Register on December 10, 1979 - Volume 44
(238):70796-70797. Therefore, although potential impacts on this species are
included in the assessment as required by NEPA (i.e., response to comments on
DEIS), it is no longer required to consider L^ satura as part of the Section 7
consultation.
202
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9.0 LITERATURE CITED
Bagley, Fredrick. 1979. Personal communication, Frederick Bagley, Louisiana
Wildlife and Fisheries Commission.
Helton, Randolph. 1979. Personal communication, Randolph Helton, Texas Parks
and Wildlife Department.
Jackson, J.A. 1978. Analysis of the distribution and population status of
the red-cockaded woodpecker, pp. 101-111. In Odom, R.R. and L. Landers
(eds) Proceedings of the rare and endangered wildlife symposium, Geogia
Department of Natural Resources Technical Bulletin. WL-4.
Leach, J.M. and Thakore, A.N. 1973. Isolation of the toxic constituents of
kraft pulp mill effluents. CPAR Rep. No. 11-3, Canadian Forestry Service,
Ottawa, Ontario.
Leach, J.M. and Thakore, A.N. 1975. Identification of the toxic constituents
in kraft mill bleach plant effluents. CPAR Rep. No. 245-2, Canadian
Forestry Service, Ottawa, Ontario.
Lish, J.W. 1975. Status and ecology of bald eagles and nesting of golden
eagles in Oklahoma. Unpubl. M.S. Thesis, Oklahoma State Univiersity,
Stillwater, 98 pp.
Potter, Floyd. 1978. By letter, Floyd Potter, Texas Parks and Wildlife
Department, 20 August 1978.
Robinson, John. 1980. Personal communication, John Robinson, Kirby Forest
Industries, 22 Februay 1980.
Rogers, I.H. 1973. Isolation and chemical identification of toxic components
of kraft mill wastes. Pulp Paper Mag. Canada. 74:T303.
Seidensticker, Paul. 1979. Personal communication, Paul Seidensticker, Texas
Parks and Wildlife Department.
Seim, W.. Lictatowich, S., Ellis R., and Davis, J.E. 1977. Effects of kraft.
mill on production of juvenile salmon production in laboratory stream
communities. Water Research 11:189.
Smith, L.L., Kramer, R.H. 1964. Some effects of paper fibers on fish eggs
and small fish. Proc. 19th Ind. Waste Conf., Purdue University, Lafay-
ette, IN.
Spencer, Donald A. (ed.). 1976. Wintering of the migrant bald eagle in the
lower 48 states. Natl. Agr. Chem. Asso., Washington, DC 170 pp.
Springer, A.M. and Atalla, R.H. 1974. Cellulosic deposits in benthal environ-
ments: Occurrence, evaluation and decomposition. TAPPI. 1:120.
Stansberg, D. 1978. By letter, David Stansbery, Ohio State University, 23
October 1978.
203
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Steenhof, K. n.d. Management of wintering bald eagles. National Stream Alter-
ation Team, OBS. Columbia MO. 46 pp.
Stone, D., Griffing, T.C., and Knight, M.C. 1974. Biological monitoring of
the Fraser River near Prince George, B.C.- Pulp and Paper mag. Can.
75(c);100.
Texas Parks and Wildlife Department. 1979. Performance Report as required by
Federal Aid in Wildlife Restoration Act. Texas Federal Aid Project No.
W-103-R-8. Nongama Wildlife Investigations. Job No.30: Bald Eagle -
Osprey Survey. January 18, 1979.
Tokar, E.M. and Owens, E.L. 1968. The effects of unbleached kraft pulp mill
effluents on salmon. I. Growth, food consumption and swimming ability
of juvenile chinook salmon. Technical Bulletin No. 217, NCASI, New York NY.
Tsai, Chu-Fa. 1973. Water quality and fish life below sewage outfalls. Trans.
Am. Fish. Society. 102:281.
US Environmental Protection Agency (EPA). 1976. Development document for
effluent limitations guidelines (BPCTCA) for the bleached kraft, ground-
wood, sulfite, soda, deink, and non-integrated paper mills segment of
the pulp, paper, and paperboard mills point source category. 638 p.
1979. Toxicity of pulp and paper mill effluent - a litera-
ture review. USEPA report No. EPA 600/3-79-013.
• In preparation. Final Environmental Impact Statement for
proposed bleached kraft marketpulp mill near Bon Wier TX.
US Fish and Wildlife Service. 1978. Stream Evaluation Map for the state of
Texas. Office of Biological Services. Denver CO.
1979. Endangered and threatened species of the southeastern
United States. USFWS Atlanta Regional Office Publication.
204-
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ATTACHMENT TO BIOLOGICAL ASSESSMENT
TPWD Bald Eagle-Osprey Survey; Jan. 1979
205
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PERFORMANCE REPORT
As required by
FEDERAL AID IN WILDLIFE RESTORATION ACT
TEXAS
Federal Aid Project No. W-103-R-8
NONGAME WILDLIFE INVESTIGATIONS
Job No. 30: Bald Eagle-Osprey Survey
Program Leader: W. C. Brownlee
Charles D. Travis
Executive Director
Texas Parks and Wildlife Department
Austin, Texas
Jack K. Parsons Ted L. Clark, Director
P. R. Coordinator - Wildlife Division
January 18, 1979
206
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PERFORMANCE REPORT
State: Texas Project No: W-103-R-8
Project Title; Nongame Wildlife Investigations
Study Title: Nongame Investigations - Texas Fauna '
Period Covered; September 1, 1977 to August 31. 1978
Objective Number; 3 Job Number; 30
I. Objective:
To determine breeding population of southern bald eagles 1n Texas.
II. Background;
From 1972 to 1976, an extensive mall survey was conducted annually to
determine the winter concentrations of bald eagles (Haliaeetus leucoce-
phalus) in the state and to aid in locating active nests of the southern
bald eagle (IH. T_. leucocephalus). Two extensive aerial surveys of the
major drainage systems of East Texas were also conducted. However, no
active nests have been found more than fifty miles from the coast.
During years when extensiv? aerial surveys were not conducted, local
aerial surveys were completed in those counties having known active
nests. All known nests are between Refugio, Texas on the south and
Orange, Texas on the north, with nesting concentrations south of Houston
and southwest of Victoria in the Brazos and San Antonio-Guadalupe River
bottoms, respectively.
Although osprey (Pandion haliaetus) have historically nested in Texas,
no active nests have been observed by project personnel since this study
was Initiated in 1972.
, /
i
III. Procedures:
During January and February, aerial checks of each previously active -j
nest site of the southern bald eagle were made to determine presence of
adult eagles and nesting progress. During March 17-27, 1978, project per-
sonnel surveyed the current known nesting range by fixed wing aircraft to
check known nest sites for fledging young and to search for additional
nests. 8
i
IV. Findings: . . ^
The seven bald eagle nests active in 1977 were also active in 1978
(Table 1). However, five of the seven nests fledged nine young; the
sixth nest which had fledged one young in 1976, again had a female
20?
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.'. brooding on an empty nest as she did in 1977. The seventh nest which
had produced two young per year for several years, failed when the
adults left' the nest site during Incubation 1n early January. It is
unknown why the eagles abandoned this nest.
The aerial survey promulgated the location of a previously unknown
eagle nest in Brazoria County. The nest was in good condition but
seemingly Inactive. However, young could have fledged from the nest
before the late March survey.
Reports of an additional five bald eagle nests were investigated. Of
the five reports, one was a great horned owl (Bubo vlrginianus) nest;
two were wintering bald eagle roosts consisting of at least seven and
four birds, respectively, and two were secondhand reports which proved
to have no bald eagles in the areas. <
V. Recommendations:
This job should be continued, not only to closely monitor the active
nesting pairs of bald eagles, but to check additional reports received
each year. Future research efforts should be directed toward developing
a better understanding of the breeding biology of the southern bald
eagle in order to formulate management guidelines for'the subspecies.
It 1s also recommended that a banding and color-marking program be
- Initiated to determine the summer range of the eagles fledged in Texas
and to determine why so few of them return to nest.
Reports of osprey breeding activities should be investigated for the
purpose of confirmation, but no further research 1s recommended at this
time. If additional funds become available, consideration should be
given to Introducing osprey fledglings Into the aquatic habitat created
by the lake systems of East Texas.
VI. Prepared by; John C. Smith Approved by:
Date; January 18. 1979
Program Leader, Nongame jj
208
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APPENDIX 4
NPDES PERMIT
209
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Permit No. TX0074373
Application N". TX0074373
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the previsions of the Federal Water Pollution Control Act, as amended.
(33 U.S.C. 1251 et. seq;the "Act"),
Kirby Forest Industries, Incorporated
P. 0. Box 1514
Houston, Texas 77001
is authorized to discharge from a facility located at .
Near Bon Weir, Newton County, Texas
to receiving waters named •
Sabine River
> . ' ' '
in accordance with effluent limitations, monitoring requirements End other conditions set forth
in Parts I, II, and III hereof.
. This permit shall become effective on
This permit and the authorliation to discharge shall expire at midnight,
Signed this
"Diana uutton"
Director
Enforcement Division
E?A Perm J320-4 (10-73) ' 210
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A-1 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning 1-1-82 and lasting through expiration date
'the permittee is authorized to discharge from outfall(s) serial number(s) Q01.
Such discharges shall be limited and monitored by the permittee as specified below:
ro
Effluent Characteristic
Discharge Limitations
Monitoring Requirements
kg/day (Ibs/dny)
•
FloTr-m3/Day (MGD)
Biochemical Oxygen
Demand (5-day)
Total Suspended Solids
Chemical Oxygen Demand
Dairy Avg .
N/A
.1563(3445)
1710(3770)
Report
Daily Max
N/A -
3037(6695)
3155(6955)
Report
Other Units (Specify)
Daily Avg
Report
•
N/A
N/A
N/A
-
Daily Bin
Report
N/A
N/A
N/A
Measurement
Frequency
Continuous .
.
Daily
Daily
Daily
Sample
Type
Record
*
24-hr.
24-hr.
24-hr.
;
•
composite
composite
composite
The pH shall not be less than 5*0 standard units nor greater than 9.0 standard units and shall be monitored
I/day, grab. ,
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
At outfall 001.
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PARTI
Page 3 of 9
Permit No. TX0074373
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent limitations specified • for
discharges in accordance with the following schedule:
None.
2. No later than 14 calendar days following a date identified in the above schedule ci
compliance, the permittee shall submit either a report of progress or, in the case of
specific actions being required by identified dates, a written notice of compliance or
noncomplian'ce. In the latter case, the notice shall include the cause of noncompliance,
any remedial actions taken, and the probability of meeting the next scheduled
requirement.
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PART I
Papc 4 of 9
Permit No. TX0074373
C. MONITORING AND REPORTING
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume
and nature of the monitored discharge.
2. Reporting
Monitoring results obtained during the previous 3 months shall be summarized for
each month and reported on a Discharge Monitoring Report Form (EPA No. 3320-1),
postmarked no later than the 28th day of the month following the completed reporting
period. The first report is due on January 28, 1980 . Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the Regional
Administrator and the State at the following addresses:
• • . • ' * •
Director, Enforcement Division (6AEP) Executive Director .
U. S. Environmental Protection Agency Texas Department of Water Resources
Region VI P. 0. Box 13087
First International Bank Building Capitol Station
; 1201 Elm Street Austin, Texas 78711
Dallas, Texas 75270
* •• *
3. Definitions
a. The "daily average" discharge means the total discharge by weight during a calendar
- month divided by the number of days in the month that the production or
• commercial facility was operating. Where less than daily sampling is required by this
permit, the daily average discharge shall be determined by the summation of all the
measured daily discharges by weight divided by the number of days during the
calendar month when the measurements were made.
b.' The "daily maximum" discharge means the total discharge by weight during any
-calendar day.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to regulations published
pursuant to Section 304(g) of the Act, under which such procedures may be required.
5. Recording of Results .
For each measurement or sample taken pursuant to the requirements of this permit, the
permittee shall record the following information:
a. The exact place, date, and time of sampling;
b. 'The dates the analyses were performed;
c. The person(s) who performed the analyses;
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PART »
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Permit No. TX0074373
d. The analytical techniques or methods used; and
e. The results of all required analyses.
6. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more
frequently than required by this permit, using approved analytical methods as specified
above, the results of such monitoring shall be included in the calculation and reporting of
the values required in the Discharge Monitoring Report Form (EPA No. 3320-1;. Such
increased frequency shall also be indicated.
7. Records Retention .
•
All records and information resulting from the monitoring activities required by this
permit including all records of analyses performed and calibration and maintenance of
instrumentation and recordings from continuous monitoring instrumentation shall be
retained for a minimum of three (3) years, or longer if requested by the Regional
Administrator or the State water pollution control agency.
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PART II
Page 6 of 9
Permit No. TX0074373
A. MANAGEMENT REQUIREMENTS
. 1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this
permit. The discharge of any pollutant identified in this permit more frequently than or
at a level in excess of that authorized shall constitute a violation of the permit. Any
anticipated facility expansions, production increases, or process modifications which will
result in new, different, or increased discharges of pollutants must be reported by
submission of a new NPDES application or, if such changes will not violate the effluent
limitations specified in this permit, by notice to the permit issuing authority of such
changes. Following such notice, the permit may be modified to specify and limit any
pollutants not previously limited.
2. Noncompliance Notification
If, for any reason, the permittee does not comply with or will be unable to comply with
any daily maximum effluent limitation specified in this permit, the permittee shall
provide the Regional Administrator and the State with the following information, in
writing, within five (5) days of becoming aware of such condition:
a. A description of the discharge and cause of noncompliance; and
b. -The period of noncompliance, including exact dates and times; or, if not corrected,
the anticipated time the noncompliance is expected to continue, and steps being
taken to reduce, eliminate and prevent recurrence of the noncomplying discharge.
3. Facilities Operation •
The permittee shall at all times maintain in good working order and operate as efficiently
as possible all treatment or control facilities or systems installed or used by the permittee
to achieve compliance with the terms and conditions of this permit.
4. Adverse Impact . ' • ' • '
The permittee shall take all reasonable steps to minimize any adverse impact to navigable
• waters resulting from noncompliance with any effluent limitations specified in this
permit, including such accelerated or additional monitoring as necessary to determine the
nature and impact of the noncomplying discharge.
!
t
5. Bypassing " - •
^
Any diversion from or bypass of facilities necessary to maintain compliance with the
terms and conditions of this permit is prohibited, except (i) where unavoidable to prevent
loss of life or severe property damage, or (ii) where excessive storm drainage or runoff
would damage any facilities necessary for compliance with the effluent limitations and
prohibitions of this permit. The permittee shall promptly notify the Region?J
Administrator and the State in writing of each such diversion or bypass.
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PART II
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Permit No. TX0074373
6. Removed Substances
Solids, sludges, filter backwash, or othsr pollutants removed in the course of treatment or
control of wastewatcrs shall be disposed of in a manner such as to prevent any pollutant
from such materials from entering navigable waters.
7. Po0}er Failures
In order to maintain compliance with the effluent limitations and prohibitions of this
permit, the permittee shall either:
a. In accordance with the Schedule of Compliance contained in Part I, provide an
alternative power source sufficient to operate the wastewater control facilities;
or, if such alternative power source is not in existence, and no date for its implementation
appears in Part I,
b. Halt, reduce or otherwise control production and/or all discharges upon the
reduction, loss, or failure of the primary source of power to the wastewater control
facilities.
B. RESPONSIBILITIES
1. Right of Entry - ' •
The permittee shall allow the head of the State water pollution control agency, the
Regional Administrator, and/or their authorized representatives, upon the presentation of
credentials:
a. To enter upon the permittee's premises where an effluent source is located or in
which any records are required to be kept, under the terms and conditions of tins
permit; and
b. At reasonable times to have access to and copy any records required to be kept under
the terms and conditions of this permit; to inspect any monitoring equipment or
monitoring method required in this permit; and to sample any discharge of pollutants.
2. Transfer of Ownership or Control
•
In the event of any change in control or ownership of facilities from which the authorized
discharges emanate, the permittee shall notify the succeeding owner or controller of the
existence of this permit b% letter, a copy of which shall be forwarded to the Regional
Administrator and the State water pollution control agency.
3. Availability of Reports
Except for data dotermined to be confidential under Section 308 of the Act. all reports
prepared in accordance with the terms of this permit shall be available for public
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PART II
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Permit No. TX0074373
inspection at the offices of the State water pollution control agency and the Regional
Administrator. As required by the Act, effluent data ehall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of
criminal penalties as provided for in Section 309 of the Act.
4. Permit Modification ,
After notice and opportunity for a hearing, this permit may be modified, suspended, or
revoked in whole or in part during its term for cause including, but not limited to, the
following: .
'"•'• a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant
. facts; or
c. A change in any condition that requires either a temporary or permanent reduction or
elimination of the authorized discharge.
5. Toxic Pollutants
Notwithstanding Pert II, B-4 above, if a toxic effluent standard or prohibition (including
any schedule of compliance specified in such effluent standard or prohibition) is
established under Section 307(a) of the Act for a toxic pollutant which is present in the
discharge and such standard or prohibition is more stringent than any limitation for such
pollutant in this permit, this permit shall be revised or modified in accordance with the
toxic effluent standard or prohibition and the permittee so notified.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, A-5) and "Power
Failures" (Part II, A-7), nothing in this permit shall be construed to relieve the permittee
from civil or criminal penalties for noncompliance.
f ' *
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or penalties to .which the
permittee is or may be subject under Section 311 of the Act.
•
8. State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or penalties established pursuant
to any applicable State law or regulation under authority preserved by Section 510 of the
Act.
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PART II
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PermitNo.TX0074373
9. Property Rights
The issuance of this permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to" private property
or any invasion of personal rights, nor any infringement of Federal, State or local laws or
regulations.
10. Severability
The provisions of this permit are severable, and if any provision of this permit, or the
application of any provision of this permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this permit,
shall not be affected thereby.
PART III
OTHER REQUIREMENTS
"This permit shall be modified, or alternatively, revoked and reissued, to
comply with any applicable effluent standard or limitation issued or approved
under sections 301 (b) (2) (C), and (D), 304 (b) <2), and 307 (a) (2) of
the Clean Water Act, if the effluent standard or limitation so issued or
approved:
(1) Contains different conditions or is otherwise more stringent than
any effluent limitation in the permit; or
(2) Controls any pollutant not limited in the permit.
The permit as modified or reissued under this paragraph shall also contain
any other requirements of the Act then applicable."
NEPA CONDITIONS:
An on-the-ground cultural resource survey of the effluent pipeline corridor
shall be undertaken by a qualified archeologist prior to any construction.
Kirby Forest Industries shall provide the results, conclusions, and recom-
mendations of the Survey to the Texas State Historical Preservation Officer
(SHPO) and EPA. EPA shall follow the Advisory Council's procedures (36 CFR
part 800) in coordination with the SHPO to determine any affect of pipeline
construction on cultural properties.
If any potential cultural resources are observed during construction at the
plant site or pipeline site, the affected sources shall be preserved and both
the SHPO and EPA shall be notified so that the resource can be properly
identified and a determination made if it is eligible for nomination to the
National Register.
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