Loretta,

 

Here is the comments regarding GP Crossett.

 

 

-----Original Message-----
From: SubraCom@aol.com [mailto:SubraCom@aol.com]
Sent: Friday, February 26, 2010 10:44 AM
To: Water Draft Permit Comments
Subject: Georgia-Pacific Crossett Paper Operations

 

                  Louisiana Environmental Action Network
                  P. O. Box 66323
                  Baton Rouge, LA 70896
                  225-928-1315
                  LEAN007@aol.com

Date:  February 26, 2010
    
To:  Loretta Reiber, P. E.
Permits Branch
Water Division
Arkansas Department of Environmental Quality
5301 Northshore Dr.
North Little Rock, AR 72118-5317
Water-Draft-Permit-Comment@adeq.state.ar.us

From:  Marylee Orr
          Louisiana Environmental Action Network
          Wilma Subra, LEAN Technical Advisor
       
Re. Georgia-Pacific, LLC
Crossett Paper Operations
Discharge Permit Number AR0001210
AFIN 02-00013


     The Georgia-Pacific, LLC,  Crossett Paper Operation has applied for a renewal of their wastewater discharge permit.

Renewal of Waste Water Permit

     The Crossett Paper Operation is a major industrial source for the discharge of wastewater.  The wastewater is discharged into Mossy Lake which flows into Coffee Creek and then into the Ouachita River.

     The receiving stream is classified for:
-primary and secondary contact recreation
-raw water source for domestic  use (public and private)
-industrial water supply
-agricultural water supply
-propagation of desirable species of fish and other aquatic
  life

     The Crossett facility is designed to discharge 45 million gallons of wastewater per day from the following:
-paper mill
-plywood plant
-studmill
-sanitary wastewater
-landfill leachate
-site stormwater
-chemical plant
-building products
-truck wash and  backwash wastewater
-treated effluent from the City of Crossett


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    The sludge from the wastewater treatment process is placed in the facilities north landfill or combined with ash, sand, and grit for use as fill material for the sludge pond closure.  The combination  of sludge with ash, sand, and grit for use as fill material for the sludge pond closure presents an area of concern.  The dioxins and furans levels in the sludge could  serve as a source of  dioxins and furans that could migrate into the environmental from the sludge pond.

Outfall 001 - located immediately downstream of the aerated lagoon and discharging into Mossy Lake

     Outfall 001 will be allowed to discharge conventional and toxic pollutants through the outfall into Mossy Lake.  The concentrations of the conventional and toxic pollutants are limited by the limits established in the wastewater permit.

     The wastewater discharged through Outfall 001 will be  allowed to contain up to:
24,155.4 pounds per day of Biochemical Oxygen Demand
37,720 pounds per day of Total Suspended Solids
2,193.04 pounds per day of Adsorbable Organic Halogens
0.00034  pounds per day  of Dieldrin
8.42 pounds per day of recoverable Copper
0.026 pounds per day of recoverable Mercury
75.21 pounds per day of recoverable Zinc

     Dioxin is required to be analyzed in the waste water once per quarter and the value reported as 2,3,7,8-TCDD.
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No discharge limits have been set for 2,3,7,8-TCDD in the effluent.  The only requirement is for the concentration of 2,3,7,8,-TCDD to be reported.  The lack of discharge limits for 2,3,7,8-TCDD in outfall 001 in not appropriate.   The Arkansas Department of Environmental Quality must establish effluent limitations for 2,3,7,8-TCDD in Outfall 001.

     Dioxins and Furans are required to be analyzed for in internal outfalls 101,102, and 103.  The effluent limits for 2,3,7,8-TCDD for all three internal outfalls is <10 pg/l and the effluent limits for 2,3,7,8-TCDF are 31.9 pg/l for the daily maximum discharge limit.  However, these discharge limits should not be used as a reason for not establishing effluent limitations for 2,3,7,8-TCDD in Outfall 001.

     Phosphorous and nitrates as nitrogen are required to be monitored in Outfall 001.  However, the values only have to be reported.  Outfall 001 lacks discharge limitations for phosphorous and nitrates as nitrogen.  The Arkansas Department of Environmental Quality must establish limitations for phosphorous and nitrates as nitrogen in Outfall 001.

Stream Monitoring Station 002 - at the transition from Mossy Lake to Coffee Creek

     SMS 002 has mass loading Biochemical Oxygen Demand criteria that is approximately one-third of the limits for Outfall 001.  The mass loading Total Suspended Solids
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criteria is approximately half of the limit for Outfall 001.  However, the mass loading for dieldrin, copper, mercury, and  zinc are the same for the instream segment as for Outfall 001.  The Biochemical Oxygen Demand and Total Suspended Solids mass loading values should be the same for Outfall 001 as for SMS 002. 

Adsorbable Organic Halogens

     The Adsorbable Organic Halogen mass loading values allowed to be discharged have increased from the previous permit.  The monthly average increased from 2,146 pounds per day to 2,193.04 pounds per day and the daily maximum increased from  3,276 pounds per day to 3,299.97 pounds per day.   Such in increase in mass loading is not acceptable. 

Anti-backsliding

     The anti-backsliding requirements state that the final effluent limitations for reissuance of permits must be as stringent as those in the previous permit.  The increase in mass loading criteria for Absorbable Organic Halogens is in violation of the Anti-backsliding provision.

Best Management Practices

     The terms of the draft permit requires the submittal of a report on an annual basis of the Best Management Practices
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monitoring results, action level exceedances and corrective actions taken to respond to any exceedances.  Exceedances are not violations of the permit.

     Submittal of the report on an annual basis is not sufficient for ADEQ to identify and track exceedances.  The reporting frequency should be at a minimum on a quarterly basis.  In addition, ADEQ should define exceedances of conditions of the Best Management Practices as permit violations.

Compliance History

     According to the fact sheet prepared by the Arkansas Department of Environmental Quality,  the Discharge Monitoring Reports from December 2003 through  December 2008 only reported one exceedance which was  a typo error.  However, according to individuals and groups living and recreating on/in the waters downstream from the Crossett facility, the water quality is being severely negatively impacted by the discharge from the Crossett facility.   The Arkansas Department of Environmental Quality must evaluate the impacts of the Crossett facility effluent on the waters downstream from the facility and determine the extent of negative impacts as a result of the Crossett discharge.  The resulting negative impacts must be addressed as a part of the effluent limitations established in this draft wastewater permit.

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     LEAN would like to request that a public hearing be held on this permit in order to give community members  in Arkansas and  Louisiana an opportunity to express their concerns and issue to the ADEQ.

     LEAN  reserves the right to rely on all public comments submitted in this matter.  LEAN respectfully request a written response to all comments and written notice of any additional or final actions on the permit application and permit.  

     


 














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