4. BOD permit limits: The mill already operates under the most restrictive BOD permit limits of any bleached kraft papermill in the South.
5. Compliance with current standards: Even with this multimillion-dollar commitment to reduce effluents and emissions and make the Angelina River cleaner, the Lufkin Mill will not be able to meet the water quality standards that currently apply to the proposed new segment of the river. The Sam Rayburn Reservoir will retain its current high aquatic life use designation.
6. The river cannot comply: The fact is, the river itself cannot comply. Even if you remove discharges from the Lufkin Mill altogether, this naturally occurring waterway could not meet the existing non-science-based default classification.
7. Science-based standards: It is not reasonable to hold the Lufkin Mill to a standard the river itself cannot meet, much less a standard not based on sound science.
8. High aquatic life: High aquatic life does not survive upstream of the paper mill. High aquatic life cannot survive in the Attoyac Bayou, the reference stream used in our studies to support this change in designation.
Nature sets the conditions that make these streams in East Texas so sluggish and dense. The organic material absorbs much of the available oxygen in the water. The low oxygen levels in these streams are less desirable to high aquatic life. With or without a paper mill, this part of the river can support only intermediate aquatic life.
9. Upper Angelina is a bayou: The Attoyac is called a bayou because that is the nature of that stream. Scientific studies have shown the same conditions exist in the Upper Angelina River.
10. The 1998 fish kill at Sam Rayburn Reservoir: The 1998 fish kill has been extensively studied by many state agencies, particularly Parks & Wildlife. Parks & Wildlife has determined that the likely cause of the fish kill was the largemouth bass virus. This virus also hit nine other Southern states and was probably caused by high temperatures and low lake levels.
Four times a year, minnows are put in straight 100 percent effluent from the Lufkin Mill for two days to test for effluent toxicity. The fish have always survived the test. Based on all we know, Donohue's operations had nothing to do with the Sam Rayburn Reservoir fish kill.
11. Bass recovery: Just look at the results of recent bass tournaments. Sam Rayburn Reservoir is producing quantities of fish of normal and championship size. At a recent B.A.S.S. Tournament, it was reported that more than 3,000 fish were caught. The winner caught 15 fish with a total weight of 55 lbs. We also learned of a recent trophy bass from Sam Rayburn Reservoir that weighed 13.77 lbs.
Thank you for the opportunity to respond to and clarify important parts of the record.
Seth Kursman
Vice President
Government Affairs and Communications
Donohue
Houston
