ill give it a go tomorrow.
im pretty slow so i might have to get some help when i do.

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. TPWD�s 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 TCEQ�s 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.�

Are you meaning Diurnal as in Daytime? Night (Nocturnal) DO drops are typically when fish kills will occur (or Night and Daylight hours during an extended periods of overcast conditions). At night algae switch from using CO2 and producing O2 (photosynthesis) to using O2 and producing CO2 (respiration). Also, when algae die off in mass events they decay, also feeding other microorganisms resulting in depleted DO. It also seems like having a large aeration system at the plant's outfall would eliminate anything that could be blamed on them.

Also, TPWD shows TXU being the controlling entity over Fairfield.

Another thing to consider would be to see who does the watershed testing for the area. It seems that there are too many non-point sources of excessive runoff occuring in this lake. You can't really blame this on one person/company. But you can plame the Texas Agencies for appearently not doing anything.

TPWD uses Diel. I have seen it elsewhere as Diural. The DO depleation happens overnight as you describe. We need comments at the hearing from guys with your apparent background. We do not have to solve the problems just get solid goals set for LGC to solve. Please file a comment and request for a hearing using the link content above and anything you can add. Time is off the essence the 30 day comment period is nearly expired. If you need anything in technical documentation email out of my profile.

The Corporate entity on the permit application shows a Big Brown entity and also Luminant Generating Company. TXU previously own the Big Brown Station, If TPWD has TXU on some documentation that is a slight error for the later years of these events.

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,

i put this in the comment section and submitted it.

Barring a Luminant Generating Company rewrite of this permit application and the TCEQ decision I am requesting a contested case hearing with TPWD staff in presence with a meeting period spanning over at least one Saturday so the impacted sportsmen can attend.


DID I DO IT RIGHT.




this is what i was shown.

Thank you for submitting your comments on this pending permit application.

You will receive an e-mail confirmation of your remarks that you can print for your records.

If you do not receive an e-mailed confirmation within 24 hours, we may not have received your comments. Please note, successful submittal of your electronic comments does not guarantee that your comments are timely filed. If you have any questions, call the Office of the Chief Clerk at 512-239-3300.

After re-reading the comments, 3 ppm and 5 ppm DO levels that TPWD are refering, below 5 ppm DO fish become stressed, below 3 ppm is when fish kills typically occur, although some can hand more and some can handle less.

Also, Luminant is part of Energy Future Holdings, which used to be TXU. TXU (well, the 3 companies that later became TXU) built the lake so I'm assuming they are still the controlling body of the lake.
http://www.luminant.com/about/Lum_History.pdf

Are there any test results for the water from this lake available?

where will this hearing or hearings most likely be held?

I'm instructed:

Texas granted TXU the right to impound flow from a water shed, but the water sources are not owned by any power company.
This makes it a public water body.
The life in the lake is owned by Texas.

The permit document has Big Brown and LGC as owners. It does not matter how many points, the lake worked OK for 20+ years before these fish kills started. The lake composition isn't being managed well today and the none water constituents are being concentrated as the water evaporates.

Yes the TPWD letter quotes water test results in their 18 page document. email me for a copy Millerd1_airmail_net@yahoo.com

No idea yet TCEQ or LGC or both will certainly control that event.

All large surface water lakes/reservoirs are State of Texas Property (that aren't exempted under stock tank laws). But the controlling authorites have responsibilites. City of Dallas is responsible for Lake Ray Hubbard, for example.

*edit*
Looking to see if there are statutes outlining these, but knowing the State of Texas......they're probably deeply buried somewhere.

The TPWD letter is the the hot link on the bottom of this page, the hot link to
my letter is above that.

I couldn't find the specific wording but here are a couple of exceprts from Texas Administration Code (TAC) 30 Chapter 307, Rule 307.4:

"(e) Nutrients. Nutrients from permitted discharges or other controllable sources must not cause excessive growth of aquatic vegetation that impairs an existing, designated, presumed, or attainable use. Site-specific nutrient criteria, nutrient permit limitations, or separate rules to control nutrients in individual watersheds are established where appropriate after notice and opportunity for public participation and proper hearing. Site-specific numeric criteria related to chlorophyll a are listed in Appendix F of �307.10 of this title.

(f) Temperature. Consistent with �307.1 of this title (relating to General Policy Statement) and in accordance with state water rights permits, temperature in industrial cooling lake impoundments and all other surface water in the state must be maintained so as to not interfere with the reasonable use of such waters. Numerical temperature criteria have not been specifically established for industrial cooling lake impoundments, which in most areas of the state contribute to water conservation and water quality objectives. The following temperature criteria, expressed as a maximum temperature differential (rise over ambient) are established except for industrial cooling impoundments, temperature elevations due to discharges of treated domestic (sanitary) effluent, and temperature elevations within designated mixing zones. The maximum temperature differentials are:

(1) freshwater streams: 5 degrees Fahrenheit (degrees F);

(2) freshwater lakes and impoundments: 3 degrees F; and

(3) tidal river reaches, bay, and gulf waters: 4 degrees F in fall, winter, and spring, and 1.5 degrees F in summer (June, July, and August).

(4) Additional temperature criteria (expressed as maximum temperatures) for classified segments are specified in Appendix A of �307.10 of this title."

"(h) Aquatic life uses and dissolved oxygen.

(1) Dissolved oxygen concentrations must be sufficient to support existing, designated, presumed, and attainable aquatic life uses. Aquatic-life use categories and corresponding dissolved oxygen criteria are described in �307.7(b)(3) of this title (relating to Site-Specific Uses and Criteria).

(2) Aquatic life use categories and dissolved oxygen criteria for classified segments are specified in Appendix A of �307.10 of this title. Aquatic life use categories and dissolved oxygen criteria for other specific water bodies are specified in Appendix D of �307.10 of this title. Where justified by sufficient site-specific information, dissolved oxygen criteria that differ from �307.7(b)(3) of this title may be adopted for a particular water body in �307.10 of this title.

(3) Perennial streams, rivers, lakes, bays, estuaries, and other appropriate perennial waters that are not specifically listed in Appendix A or D of �307.10 of this title are presumed to have a high aquatic life use and corresponding dissolved oxygen criteria. Applicable dissolved oxygen criteria are described in �307.7(b)(3)(A) of this title. Higher uses are protected where they are attainable.

(4) When water is present in the streambed of intermittent streams, a 24-hour dissolved oxygen mean of at least 2.0 mg/L and 24-hour minimum dissolved oxygen concentration of 1.5 mg/L must be maintained. Intermittent streams that are not specifically listed in Appendix A or D of �307.10 of this title are considered to have a minimal aquatic life use except as indicated below in this subsection. For intermittent streams with seasonal aquatic life uses, dissolved oxygen concentrations commensurate with the aquatic life uses must be maintained during the seasons when the aquatic life uses occur. Unclassified intermittent streams with perennial pools are presumed to have a limited aquatic life use and corresponding dissolved oxygen criteria. Higher uses are protected where they are attainable.

(i) Aquatic life uses and habitat. Vegetative and physical components of the aquatic environment must be maintained or mitigated to protect aquatic life uses. Procedures to protect habitat in permits for dredge and fill are specified in Federal Clean Water Act, �404 and in Chapter 279 of this title (relating to Water Quality Certification). "

Please pull the Ross (TPWD) letter from the link I provided and have a read of that scientific body of work. It has all the water test data I know is in the public domain.

How about some links to your content source so I can refer it to others, please include the referred to appendixs? to do hyperlinks Use the switch to full reply screen method below.

I'm not going to discourage your efforts but I think the TPWD folks should know these issues pretty well. This isn't their first rodeo. My teachings say the temperature rise is exempt for power stations. The permits only requires the measurement be reported and has no maximum. The Temp. rise at Fairfield is about 10 to 20 F in the height of the summer. I have seen the outfall running 112 F, LGC reports the maximum as 111 F. I found the Two Big Brown units are placing more megawattage per lake surface area discharge into Lake Fairfield than any other cooling lake in Texas. At peak summer ambient conditions Outfall #001 (the hot outfall) reaches 111�F as reported by LGC and 112�F as measured by myself while the cold water intake might only drops 15�F to about 96�F to 98�F. The lake does not contain distilled water but the solubility of oxygen in 112�F distilled water is only 6 ppm see oxygen solubility in distilled water reference item http://www.colby.edu/cpse/equipment2/simple/per.html. This site provides O2 solubility correction for salinity but the above quoted number does not attempt to make salinity adjustments. TPWD advises some species in Fairfield might handle DO levels down to 3 ppm limited time stressful periods and normally require a minimum of 5 ppm. At 6 ppm DO the saturated oxygen solubility has no margin for error left when Outfall #001 hits the summer peak 112 �F and the water has to be saturated with O2.

Since the surface of the lake cools the water and so far I have not heard of a lake extention for any third unit it is likely the 3rd unit could make the main lake even hotter, My rough guess might be another 7-10 F more. Make up water will have to rise 50% as well (ie even more Trinity River water)

since the water coming out of the power station is even hotter than teh 112 F at the outfall. Because hotter water retains less DO it is probable the outfall is NOT saturated with O2 .

http://info.sos.state.tx.us/pls/pub/read...ch=307&rl=Y
The appendices were pdf files at the last link. Fairfield lake was not included. Variances are granted on a case by case basis and I didn't look at their permit. Just giving you ammo