A TCEQ hearing request coupled with your comment submissions is needed ASAP. After you have made up your mind you can go to the website link below to add you comment and request hearing participation.
The comment website below collects your full name, address, and phone number, the TCEQ ID number (WQ0001309000), you need to provide why the permit comment is important to you, and asks for your position on that ID number item. Your comment needs be requesting a hearing on TCEQ preliminary decision.
Your reply information will get a notice of a hearing. Your preamble needs to read something like this:
Office of the Chief Clerk (MC 105)
Texas Commission on Environmental Quality
P.O. Box 13087
Austin, Texas 78711-3087
Re: TCEQ Wastewater Discharge Permit Number WQ0001309000 Big Brown Power Company LLC and Luminant Generation Company LLC. Also listed as TPDES Permit No. 00001309000
Four key points to include in your own words if you agree:
1. Calavaras and Braunig, lakes which are much further south and west of Fairfield also serve as power plant cooling and public recreation lakes and have even experienced worse drought conditions without suffering similar decimating fish kills. Presumably having low enough nutrient levels alone is accomplishing this. A qualified biologist would need to name the nutrient and/or oxygen quantity addition needed to offset the natural dissolved oxygen low swing events and prevent killing more fish. The extreme tested experiences at Calavarus and Braunig and the early life of Lake Fairfield all prove power plant lakes need not annually kill most of the aquatic life.
2. Stop the Lake Fairfield fish kills! LGC's current lake composition management system is causing this fish killing problem, therefore LGC needs a waste water permit structured to make and manage the necessary changes. LGC needs to prevent these fish killing low oxygen swings. TPWD believes nutrient addition control will prevent these fish killing DO low swings and suggests a natural treatment method. Another source of low nutrient make up water could also be sought. A more costly lake blow down system or a man-made oxygen addition might also suffice, but would have to be 100% dependable. There may be other methods, but some combination of the above has worked at Calavarus and Braunig and the early life of Lake Fairfield as well.
3. We laymen understand the Diural Dissolved Oxygen (DO) level should be managed to not drop below what TPWD specialist should affirm is the minimum level. LGC together with TPWD needs to decide what the exact minimum required Dissolved Oxygen needs to be. LGC needs to find a solution and afford the changes. Then LGC needs to design and build a dependable system that gets it done. TPWD mentions both 3 mg/l and 5 mg/l DO level in their comment letter.
4. LGC's lack of nutrient control resulted in what TPWD values as $6,200,000 worth of dead fish stock. After the nutrient and/or oxygen addition is under control LGC needs to replace that dead stock in as near a size and count as possible. To restore the Fairfield lake jewel as quickly as practical it needs to be restocked with a significant amount of adult size fish. Aquatic food farms already raise Red Drum, Large Mouth Bass, Catfish, and the various pan fish species that can all be purchased.
If you have seen enough information, here or in the attachments and you agree then you need to file your own comments something like the above here: (you will need to fill in the TCEQ number WQ0001309000) and make you desires and requirements known here.
http://www10.tceq.state.tx.us/epic/ecmnts/index.cfm?fuseaction=per.p3,
Be sure to put in text in your comment something like this: Barring an acceptable Luminant Generating Company rewrite of this permit application and a subsequent acceptable TCEQ decision I am requesting a contested case hearing near Fairfield with TPWD staff in presence with a meeting period spanning over at least one Saturday so the impacted sportsmen can attend.
Until 10 days ago I thought LGC owned the lake, they do not it is a public water body. LGC is permitted to use it as if it were a once through use, which is fiction in reality.
They recirculate the lake and with the current natural inflow LGC heat discharge from just the current two units evaporates all the natural inflow plus needs more from the Trinity River.
There is TPWD scientist proof what is happening in this lake. Here is part of what TPWD sent to the TCEQ:
In response to the fish kills, TPWD staff intensified their investigations and water quality monitoring, and began coordinating with TCEQ Surface Water Quality Monitoring (SWQM) staff in Waco, who initiated quarterly monitoring at Fairfield Lake in November 2005. TPWDs monitoring efforts included special studies on instantaneous and diel dissolved oxygen prior to and during fish kills (technical report:
http://www.tpwd.state.tx.us/publications/pwdpubs/media/pwd_rp_v3400_1565a.pdf). In addition to the recent special studies, TPWD Inland Fisheries routinely surveys the fish community (survey report:
http://www.tpwd.state.tx.us/publications/pwdpubs/lake_survey/pwd_rp_t3200_1290/).
Both fish kill and fishery survey data support that legal size game fish are nearly absent from the fish community and forage species such as bluegill have been impacted as well (Figure 5 - 10). The fishery survey data shows a clear decline in fish abundance and size distribution from 2000 2011. The impact has been so great that on September 21, 2011, TPWD suspended fish stockings until water quality improves (news release:
http://www.tpwd.state.tx.us/newsmedia/releases/?req=20110921c).
Fairfield Lake and the nearby Trinity River are listed as concerns for high nutrient levels in TCEQs 2010 Water Quality Inventory. Both water bodies have phosphorus and chlorophyll-a means that exceed the TCEQ screening levels for nutrient concerns (Tables 2 and 3). The chlorophyll-a values at Fairfield Lake (Figure 11) suggest it is one of the most eutrophic reservoirs in Texas. TPWD and TCEQ data indicate high nutrient levels, in combination with the higher water temperatures from power plant discharges, fuel algal blooms in the reservoir. These algal blooms can produce extreme swings in daily dissolved oxygen concentrations, eventually leading to a drastic drop in dissolved oxygen. Diel dissolved oxygen data collected as part of fish kill investigations in 2009, 2010 and 2011 show extreme daily swings in dissolved oxygen and extended periods when dissolved oxygen is below concentrations supportive of aquatic life (Figure 12). Over time there also appears to be a trend of low dissolved oxygen and fish kills occurring earlier each subsequent year, and daily swings becoming more extreme.
