READ MAIL Date: Thu, 21 Jan 1999 21:49:33 -0500 From: "CieloSand" Add to Address Book Subject: Re: Letter re Stormwater Analysis NC Study To: , , , , , ALL- Here is some recent research by Devin Schrubel, Heartwood, in response to recent Willamette-Mill Springs MO, individual NPDES permit draft. Maybe some of this could go after the PA, Lanigan Brook example. Devin has a chem background. I have sent this to EPA folks for comment. But, in meantime, it wouldn't hurt to include as a concern: Devin: "Our preliminary research indicates that the presence of phenol and related compounds in storm water runoff is potentially significant and should be regulated. The formation of toxic leachate from wood chips has been found to be rapid, and this leachate has been found to remain toxic for many months. Containment in a basin, as provided for in the existing draft permit, is unlikely to remediate this toxicity. Phenolic compounds have been found to make up the majority of identifiable toxic compunds. Of the isolated compounds phenol itself appears to be the major component. Phenol's listing as a priority I toxic compound by EPA makes this significant. The toxicity of the other phenolic compounds appears to be in the same range as that of phenol, with an LC50 for aquatic species in the range of 5 to 10 mg/L. The expected concentration of phenols may depend on the tree species being chipped. One study of phenol concentrations in pulp mill effluent deduced that the phenols present were largely derived from the decarboxylation of p-hydroxybenzoic acid. High concentrations of p-hydroxybenzoic acid are found in poplar and willow species, lesser amounts in catalpa, sycamore and cherry species, and "insignificant" amounts in oak and maple. Of course this study was conducted on pulp mill effluent, not on leachate from wood chips and also did not exhaustively explore other chemical routes to the production of free phenols. It is consistent, however, with the high phenol concentrations found in wood chip leachate from aspen, a species in the poplar family. It is important to stress that while phenolic compounds make up the identified toxins in wood chip leachate, the total toxicity of leachate can not be attributed to phenols alone. Other unidentified compounds are significantly toxic in the leachate. Some of the concerns relevant to this site have been addressed by municipalities in their design of composting sites for organic maters. Here a variety of techniques have been used to insure that runoff does not contaminate surface waters. These include choosing an appropriate site away from streams and rivers, diversion of water run-on from upslope, roofing the site to exclude rain, vegetative filter strips, recirculation of runoff, and the construction of a runoff collection pond. We suggest that some or all of these techniques be applied to this site. Based on this preliminary research on phenols, we recommend that phenol be added to the list of chemicals tested for in the storm water permit, at a maximum level of 250 µg/L(micrograms/Litre). We derive this figure by assuming that phenol itself will make up approximately half of the concentration of phenolic compounds present with similar toxicity and factoring in an order of magnitude safety factor to account for damaging effects to the Black River watershed other than acute toxicity to aquatic life. Furthermore, we repeat with added emphasis our contention that tests of the runoff should be conducted on live fish and invertebrate in addition to the required chemical sampling. Incomplete identification of the compounds responsible for the toxicity found in studies of leachate support this concept." To: harvard@boone.net; mlfaltra@rfci.net; sabp@main.nc.us; mdkerley@worldnet.att.net; chipwatch@justicemail.com; cielosand@mindspring.com Subject: Re: Letter re Stormwater Analysis NC Study ate: Thursday, January 21, 1999 4:35 PM Dr. James Gregory College of Forest Resources NCSU Campus Box 8008 Raleigh NC DATE Re: North Carolina Woodchip Study element: "Survey of Stormwater and Process Water management at Round Wood Chip Mills In North Carolina." Dear Dr. Gregory It has been very interesting to watch the unfolding of your research vis-a-vis the North Carolina Wood Chip Industry Impacts Study, from the vantage point of the Study's advisory committee. In your Work Plan for the study, you noted the purpose of your research as determining "the potential for adverse impacts on receiving water quality of stormwater and process water runoff from round wood chip mills." This is a very important area of the Study, and we look forward with great anticipation for the final results of your efforts. In the interim, however, we have a number of observations and questions that we herein offer for your consideration. In your work plan for the study, you noted that "funding and time constraints" limit the scope of your research. We believe, however, that it is possible, even imperative, that you expand the scope to some degree beyond the research regime you have outlined. Of particular concern to us is the lack of water sampling of runoff from chip mill sites and the dependence on a canvass of chip mill operators about whether their storm water runoff is following acceptable guidelines. While you will visit some chip mills, (those that give permission), you will confine the field work at those locations to a visual observation of the water runoff on site, recording primarily whether it was clear or cloudy. Because we know of at least one receiving water body in another state where runoff from a chip mill has caused a considerable buildup of an unknown, but very visible material, we believe that every effort should be made too expand this part of your research. One of the consequences of this build-up, which is directly a result of runoff from an operating chip mill, is the disappearance of trout from this particular stream. Due to cost constraints, you said, there will be no chemical analysis of the runoff from the chipmills for such compounds as woodchip or bark pile leacheates, or petroleum products. In the absence of these parameters, we feel an adequate analysis of "the potential for adverse impacts on receiving water quality of stormwater and process water runoff from round wood chip mills" is unlikely. Of equal concern to us is the refusal on the part of several chip mills to cooperate in the data collection related to stormwater runoff. The State of North Carolina has authority and jurisdiction over this issue through the general stormwater permitting process. Doesn't the State of North Carolina have a right to gather data at sites where permits have been issued to ensure that the permit conditions are being met and that water quality is not adversely impacted from storm water and wastewater runoff? Because this is a study funded by the State of North Carolina, the cooperation of chip mill owners (while certainly preferable) should not be a prerequisite to gathering essential data necessary to adequately assess stormwater runoff impacts. Is it possible that DENR Division of Water Quality could analyze stormwater runoff from all chip mills in NC through the gathering of water samples? In response to a query at the December meeting, you said that there is very little research available on stormwater quality in North Carolina; however, you will not review research that takes place outside of North Carolina. Could you explain this? In your remarks at the December 1998 meeting you noted an assumption that BMPs are being followed by chipmill builders and operators. Could you explain what this is based upon? Again, we realize that your research is limited by available funding and appreciate your commitment to ensuring that the most critical questions regarding storm water impacts are adequately addressed. We are ready to assist you in any way that you may find useful in making this element of the study as comprehensive as possible. Sincerely Danna Smith READ MAIL Date: Thu, 21 Jan 1999 20:57:13 -0500 From: "CieloSand" Add to Address Book Subject: Fw: Letter to Sara Warren re; NC chip study To: , good! Is this the place where: 1. truck traffic impacts to communities would fit? Will that be considered. I know it is the big socio-economic issue in all the EA's done on Tenn River. One community still suffers greatly with two of its schools on the logtruck route..which passes through this tiny low-economic, impoverished black community of Bridgeport, AL. It is where one of the chip mills had been proposed. Instead, they got logs! 2. .. the "environemental justice" issue; these high-tech mills most frequently placed in low- economic/education areas. Can this component of the Study document that? What is the common denominators for site locations. --cielo ---------- From: Danna Smith To: harvard@boone.net; mlfaltra@rfci.net; sabp@main.nc.us; mdkerley@worldnet.att.net Cc: chipwatch@justicemail.com; cielosand@mindspring.com Subject: Letter to Sara Warren re; NC chip study Date: Thursday, January 21, 1999 2:15 PM Please send me any comments you may have... Danna Sarah Warren Division of Multidisciplinary Studies NCSU Campus Box 7107 Raleigh NC 27695-7107 RE: "Wood Chip Production in North Carolina: the Social Impact Assessment Component." Dear Dr. Warren: We enjoyed the review of your study plan at the November woodchip study advisory committee meeting, and look forward to observing your research as it unfolds. As you note in your study work plan "Changes in the manufacturing and natural resources environment of a community can often produce tension among the inhabitants". We agree, having seen first hand some of the divisions and discord that chip mill proposals have engendered. As we understand your plan, you will use census data, one-on-one personal interviews and focus groups, to analyze these tensions and divisions. The interviews and group meetings will be repeated several times over the course of the study, to see if sociological impacts of chip mill construction and operation are causing changes over time. We highly recommend emphasizing research in Stokes and Rutherford County where tension over chip mill impacts at the local level is high and where real people are being impacted. One question that has arisen concerns the decision to limit your research to a comparison of counties with chip mills versus counties without chip mills. The average chip mill relies on the clearcutting of forests from a 75-mile radius of the mill, thereby creating the potential for social impacts in counties adjacent to where the chip mill is actually located. One concern we have is the social impact of increased intensive resource extraction. A comparison of counties where logging and chipping is at a very high level, versus those where it is not would, we believe, add depth to the analysis of social impacts. Again, we look forward to observing your research on this important topic as it unfolds over the course of the study. Sincerely Danna Smith (c)1998 FindLaw, Inc. (c)1995-1998 WhoWhere? Inc. All Rights Reserved. (c)1998 Lycos, Inc. All Rights Reserved. Lycos is a registered trademark of Carnegie Mellon University READ MAIL Date: Thu, 21 Jan 1999 20:43:41 -0500 From: "CieloSand" Add to Address Book Subject: Re: Letter re Wildlife Analysis NC Chip Study To: , Excellent letter! I forwarded to Barclay. --C ---------- From: Danna Smith To: harvard@boone.net; mlfaltra@rfci.net; sabp@main.nc.us; mdkerley@worldnet.att.net; chipwatch@justicemail.com; cielosand@mindspring.com Subject: Re: Letter re Wildlife Analysis NC Chip Study Date: Thursday, January 21, 1999 3:50 PM Please give input if you have any. I'm planning to fax all these letters out tomorrow. All letters will be ccd to Richter, Cubbage, Flournoy, Henry's replacement and the Gov. Danna Dr. George Hess Ph.D Department of Forestry North Carolina State University Re: North Carolina Woodchip Study element - "Modeling small scale and cumulative impacts on North Carolina Wildlife" Dear Dr. Hess We are writing in regard to your element of the North Carolina woodchip industry impacts study. As you may know, researching the impacts of this industry on North Carolina wildlife is something that we consider extremely important. Having had an opportunity to review your proposal and related documents, we would like to take this opportunity to share our observations with you. In your work plan you state that "The goal of this research is to produce a preliminary evaluation of the effect of wood chip mills on wildlife in North Carolina." From our perspective, it appears that you propose to limit your efforts to reviewing and combining existing information about North Carolina forests with existing information about wildlife habitat requirements in North Carolina. From this you will "predict the wildlife species one would expect to find in the forests." This predicted wildlife abundance and distribution will then be combined with the SERTS economic model to predict stand-level ecological impacts, and to model impacts at a number of different scales. We are troubled by your total reliance on computer modeling in place of actual comparisons of wildlife abundance and distribution at sites that have been logged for chip mill production, with sites where chip-directed logging has not taken place. Such sites could be both undisturbed sites and those sites that are being selectively managed. In addition to field research, some of this information may be available both anecdotally from hunters' associations and naturalist groups such as Audubon, and from researchers in botany and zoology departments at NCSU and other universities. We are also concerned with the reliance on the SERTS model for analyzing wildlife impacts since the SETS model's "forest types" do not coincide with ecological forest types. Since many species are dependent on a specific ecological forest type, reliance on the SERTS model seems unreliable. During your presentation, you placed an emphasis on the findings in the Minnesota GEIS. Not only is the Minnesota GEIS specific to the forest types found in the Great Lakes region (which are significantly different from the forest types found in North Carolina,) but it also looked generally at forest industry impacts and not wood chipping impacts in particular. As we pointed out in the chip study advisory committee meeting, federal agencies conducted an EIS in 1993 on chip mill impacts in the Tennessee Valley. (Final Environmental Impact Statement Chip Mill Terminals on the Tennessee River, Tennessee Valley Authority - TVA, US Army Corps of Engineers, US Fish & Wildlife Service, February 1993.) Because this study dealt with cumulative logging impacts of chip mills in a 42 county area in 3 states, we feel this document should be given more weight in your analysis than the Minnesota GEIS. The TVA EIS contains detailed information about the projected impacts of chip mills on wildlife in forest types similar to those found in Western North Carolina. May we suggest that you contact Lee Barclay of the USFWS in Tennessee directly (931) 528 6481? He conducted the wildlife impacts analysis in the TVA EIS and may have some additional suggestions for assessing chip mill impacts on wildlife in North Carolina. We are also concerned that the wildlife study will limit itself to a small number of species representative of the four broad categories of threatened and endangered species, birds, game species and nuisance species. Because the prupose of the study is to assess impacts of increased chip mill-directed forestry over time, we feel it is essential to look at species in decline or species that are of concern. I am enclosing for your review a list of species that should be included. In addition, I am enclosing a study conducted at UNC relating to the impacts of clearcutting on salamander populations in the Southern Appalachians. Finally, could you provide clarification of what constitutes a "nuisance species"? Dogwood Alliance is involved with nuisance species reviews in other venues, in which "nuisance species" are typically non-indigenous organisms that have invaded an existing or native ecosystem. Such species would include kudzu, zebra mussels, chestnut blight, and the Asian longhorned beetle. We understand that there is a utilitarian school of thought that categorizes raccoons and other native species as "nuisance" animials. We presume for the purpose of this study that you are using the former definition rather than the latter. Is this so? We understand that there is a limited amount of funding to work with and appreciate the dilemma this creates. We also deeply appreciate your commitment to ensuring the study answers the most critical questions relating to the impacts of chip mills on wildlife in North Carolina. Thank you for participating in the woodchip study. We look forward to your responses to our questions and look forward as well to the unfolding of your research over the course of the study. With Highest Regards, Danna Smith (c)1998 FindLaw, Inc. READ MAIL Date: Thu, 21 Jan 1999 16:35:46 -0500 From: Danna Smith Add to Address Book Subject: Re: Letter re Stormwater Analysis NC Study Organization: Dogwood Alliance To: harvard@boone.net, mlfaltra@rfci.net, sabp@main.nc.us, mdkerley@worldnet.att.net, chipwatch@justicemail.com, cielosand@mindspring.com Reply To: lorax@CITCOM.NET Dr. James Gregory College of Forest Resources NCSU Campus Box 8008 Raleigh NC DATE Re: North Carolina Woodchip Study element: "Survey of Stormwater and Process Water management at Round Wood Chip Mills In North Carolina." Dear Dr. Gregory It has been very interesting to watch the unfolding of your research vis-a-vis the North Carolina Wood Chip Industry Impacts Study, from the vantage point of the Study's advisory committee. In your Work Plan for the study, you noted the purpose of your research as determining "the potential for adverse impacts on receiving water quality of stormwater and process water runoff from round wood chip mills." This is a very important area of the Study, and we look forward with great anticipation for the final results of your efforts. In the interim, however, we have a number of observations and questions that we herein offer for your consideration. In your work plan for the study, you noted that "funding and time constraints" limit the scope of your research. We believe, however, that it is possible, even imperative, that you expand the scope to some degree beyond the research regime you have outlined. Of particular concern to us is the lack of water sampling of runoff from chip mill sites and the dependence on a canvass of chip mill operators about whether their storm water runoff is following acceptable guidelines. While you will visit some chip mills, (those that give permission), you will confine the field work at those locations to a visual observation of the water runoff on site, recording primarily whether it was clear or cloudy. Because we know of at least one receiving water body in another state where runoff from a chip mill has caused a considerable buildup of an unknown, but very visible material, we believe that every effort should be made too expand this part of your research. One of the consequences of this build-up, which is directly a result of runoff from an operating chip mill, is the disappearance of trout from this particular stream. Due to cost constraints, you said, there will be no chemical analysis of the runoff from the chipmills for such compounds as woodchip or bark pile leacheates, or petroleum products. In the absence of these parameters, we feel an adequate analysis of "the potential for adverse impacts on receiving water quality of stormwater and process water runoff from round wood chip mills" is unlikely. Of equal concern to us is the refusal on the part of several chip mills to cooperate in the data collection related to stormwater runoff. The State of North Carolina has authority and jurisdiction over this issue through the general stormwater permitting process. Doesn't the State of North Carolina have a right to gather data at sites where permits have been issued to ensure that the permit conditions are being met and that water quality is not adversely impacted from storm water and wastewater runoff? Because this is a study funded by the State of North Carolina, the cooperation of chip mill owners (while certainly preferable) should not be a prerequisite to gathering essential data necessary to adequately assess stormwater runoff impacts. Is it possible that DENR Division of Water Quality could analyze stormwater runoff from all chip mills in NC through the gathering of water samples? In response to a query at the December meeting, you said that there is very little research available on stormwater quality in North Carolina; however, you will not review research that takes place outside of North Carolina. Could you explain this? In your remarks at the December 1998 meeting you noted an assumption that BMPs are being followed by chipmill builders and operators. Could you explain what this is based upon? Again, we realize that your research is limited by available funding and appreciate your commitment to ensuring that the most critical questions regarding storm water impacts are adequately addressed. We are ready to assist you in any way that you may find useful in making this element of the study as comprehensive as possible. Sincerely Danna Smith