Effluent Discharged Into Great Miami River

Discussion in 'General Conversation' started by Ol Whiskers, Dec 26, 2005.

  1. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    24 December 2005


    Mr. Ralph E. Reigelsperger
    Director - City of Hamilton Public Works Department
    345 High Street 4th Floor
    Hamilton, Ohio 45011


    RE: EFFLUENT DISCHARGED INTO GREAT MIAMI RIVER

    While fishing the Great Miami River, in the City of Hamilton, at locations downstream of the lowhead dam, approximately Latitude 39.37135 x Longitude -84.57034, on 24 December 2005, between the hours of 9:10 AM and 10:25 AM, my son and I were fishing immediately below the wastewater discharge adjacent to the wastewater treatment facility operated by the City of Hamilton at 2451 River Road. (re: satellite image of area described) Having fished just below the dam from 5:30AM to 9:00AM the same morning (photo 1), we decided to move downriver about ½-mile to another favorite spot.


    OBSERVATION:
    We arrived at the 2451 River Road site around 9:10 AM, and there was a terrible odor of sewage noticeable from the parking lot, and from the parking lot we could see the river was running bright red from the east bank to approximately 15 yards midstream, as a result of a discharge of unknown composition from a large (approximately 60-inch diameter) concrete pipe and spillway that appears to be connected to the treatment plant. There were none of the signs, usually visible, of natural river life in the area, as the 2 to 5 Great Blue Herons that fish there regularly had departed, and no fish nor any bottom-dwelling invertebrates were visible either. As we approached, the red discharge continued to emanate from the concrete pipe and spillway, at a rate and velocity enough to push it some yards into the mainstem flow (approximate the rate of discharge from the pipe at 50 to 150cfs, and early morning river gage about ½-mile upstream reported river flow at approximately 1720cfs), presenting a distinct boundary of red color visible in contrast with the clear river green (see photo 2). This red coloration appeared to be from some sort of suspended/partially dissolved solid matter, as the slower water on the bank showed the red material settling all over the streambed in areas of little current. (photo 3)

    We attempted to fish in the area anyway, as we had previously been successful without the red flow, and the green, untainted water was within casting reach. We caught no fish, had no bites, and saw no evidence of stream life on the East bank from the spillway to at least 150 yards downstream. At approximately 10:10 AM, we noticed a sudden change in the discharge from the 60-inch pipe. The red effluent had turned to black/gray/brown, flow rate increased, and had a terribly putrid odor. There were visible solid particulates in the discharge, sediment, and waste products appearing to be pulverized paper and other solids. The constituents of the discharge were so thick that you could not see through the liquid, and could not see through the river water into which it mixed at the spillway. (photo 4) This discharge continued uninterrupted, and we determined to leave the area at approximately 10:25AM. (photo 5)


    COMMENT:
    These discharge events appear to the untrained observer to be distinct, flagrant, and detestable violations of laws, rules and regulation regarding Open Dumping as specified in ORC Sections 3734 and OAC Rules 3745-27 by the operators of the wastewater discharge, as well as delinquent disregard of general common sense and natural resource stewardship values. Furthermore, how could the City of Hamilton allow such wanton disregard for all downstream life, including human life, in a river system that it supposedly promulgates as a recreational facility! I guess the fact that they discharge downstream of the Hamilton pool makes it OK?

    I have been fishing the Great Miami River for the last forty years, from Miamitown, to Middletown. This kind of obvious pollution was generally expected in the sixties and seventies, when you could tell what color paper the mills were running by the color in the river. As a kid, I used to catch fish under the Old Colerain Avenue bridge that had big tumors on them, and the river would smell something terrible. I didn’t really know any better, then. Lately, I was thinking the river has cleaned up quite a bit, and I have even taught my children to enjoy fishing there. We’ve had some enjoyable times at the dam, below the dam, all the way to the Ohio River, and have caught some very nice fish. We’ve enjoyed the return of the largemouth and smallmouth basses, walleye and saugeye, white bass, and even catfish, carp, and sheephead provide a great angling challenge. Sadly, I now know why we have days when there are no signs of fish, and can now explain one of the sources of vile colors, foams, and odors on the water. I always said I would never eat a fish from this river, and now my son has first-hand experience to corroborate the feeling. That’s our loss, long-term. Short-term, we were denied the simple pleasure of getting out as a family to enjoy a natural resource that belongs to all of the community. Even if there is a permit for such a discharge (I’d like to personally meet the person that authorizes such a nightmare), for a municipality to dump on its downstream neighbors like this is unconscionable. Think of the untold number of people that use the river for recreation (would you be comfortable wading in a cesspool?), or much worse as a source for agriculture, bathing, or drinking water. Please show some credibility and stop dumping in the river.

    I am not an activist by any means, although witnessing another discharge such as these into a beautiful river system might just drive me to become one. Please feel free to contact me regarding complete resolution of these disgusting events, to the extent that “Hamilton continues to retain the character of the city’s past while sharpening its focus on a bright, happy future.”

    Sincerely,


    Dennis J. Malone



    3808 Schroeder Drive
    Hamilton, OH 45011





    cc:

    Mr. Michael J. Samoviski
    City Manager – Hamilton, Ohio
    345 High Street 7th Floor
    Hamilton, OH 45011


    Mr. Michael Fremont
    Rivers Unlimited
    515 Wyoming Ave
    Cincinnati, OH 45215

    info-request@www.epa.state.oh.us < info-request@www.epa.state.oh.us>

    http://www.ohiogamefishing.com/

    http://www.catfish1.com/




    satellite image: Lowhead dam south of downtown Hamilton, downstream to the wastewater treatment plant (10/20/2000 on Terraserver).

    Photo 1: Pre-dawn saugeye taken immediately below the dam. Water conditions were about 38 to 40 degrees, low, and clear to approximately 2 feet visibilty. USGSS Stream gage 03274000 GREAT MIAMI RIVER AT HAMILTON, OH just upstream reported flow at approximately 1810 cubic feet per second, river level at 63.23 ft, with no precipitation.

    Photo 2: Red discharge into river at 60-inch wastewater pipe spillway 9:15AM 24 Dec 05

    Photo 3: Red sediment settling on riverbed, paper product in the foreground.

    Photo 4: Effluent change to black/gray/brown, visibility zero.

    Photo 5: Black/grey/brown discharge at 10:25AM 24 Dec 2005



    References:
    http://www.epa.state.oh.us/dsiwm/document/guidance/gd_036.pdf

    http://web.epa.state.oh.us/dsw/rules/01-05.pdf

    http://www.hamilton-city.org/
     
  2. dinkbuster1

    dinkbuster1 New Member

    Messages:
    2,272
    State:
    Ohio

  3. H2O Mellon

    H2O Mellon New Member

    Messages:
    3,012
    State:
    Ohio
    Dennis,

    Does the Miami Valley Conservancy own any land in that area? I know they do here my way, you may want to copy them on this too.

    Please keep us updated.
     
  4. nosnag

    nosnag New Member

    Messages:
    284
    State:
    Florida
    Will this insanity ever ease up?We have to report any irregulararities we witness and also post them in the readers voice sections in the local papers.Let all your neighbors know what is happening.
    BILL
     
  5. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    Bryan,

    I contacted an old friend, Don Hopkins, at Little Miami Incorporated, to get the contact info for Mike Fremont at Rivers Unlimited. I hope this makes it out to anyone or any group that has an interest. Y'all feel free to pass it on, and I'll let you know how the reply comes in. The hardcopies are sitting in the mail, as I was going to hand deliver them but the gov't offices are closed today. Same as for Saturday when I called there was noone there. Makes me sick!
     
  6. flathunter

    flathunter New Member

    Messages:
    5,723
    State:
    Ohio
    I hope something is done about it..Last year a city near me got permission to dump huge ammounts of untreated sewage in my favorite river, it really ticks you off.
     
  7. dinkbuster1

    dinkbuster1 New Member

    Messages:
    2,272
    State:
    Ohio
    y'know its sometimes a lot cheaper to illegally dump and pay the fines than to properly dispose of waste's
     
  8. Dano

    Dano New Member

    Messages:
    13,712
    State:
    Texas
    dinkbuster1, you may be right about that on many things. ;)
     
  9. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    Went downtown Hamilton this morning to hand deliver the letter, as it's been sitting in the mailbox since Saturday for pickup. Waiting for that reply.

    Nice lady from ECO called yesterday afternoon to give me the EPA emergency hotline and suggested I call them, even though it had been 2 days. I called, got an answering service that wanted the date, time, location, and said they would have someone contact me. No retrun call yet. Received e-mail replies from the Ohio EPA inspector for that facility asking for the pics.

    Received e-mails from Rivers Unlimited, Miami Conservancy, and ECO, all asking to be updated. Had several e-mails returned undelivered from links on EPA and environmental sites, and one fellow said I must have misdirected as he only runs a database for the EPA.

    It's a darned shame to see this sort of pollution, in this day and age. As a friend of mine says, "IT JUST DON'T MAKE NO SENSE!"

    Will keep you posted.

    Maybe a good standalone forum line? Could tie to some sort of national call list.
     
  10. Gator

    Gator New Member

    Messages:
    1,116
    State:
    Ludowici GA
    Man that sucks what is wrong with these people?! :cursing: :cursing:
     
  11. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    Just to keep you up to date. Thanks for the support, and Happy New Year to
    everyone.

    Dennis



    > Date: Thu, 29 Dec 2005 22:24:19 -0500
    > To: Ned Sarle <Ned.Sarle@epa.state.oh.us>
    > Subject: Re: EFFLUENT DISCHARGED INTO GREAT MIAMI RIVER
    > Cc: Marianne Piekutowski <Marianne.Piekutowski@epa.state.oh.us>,
    Cathryn Allen <Cathryn.Allen@epa.state.oh.us>
    >
    > Mr. Sarle,
    >
    > Thank you for investigating some of the observations I noted in my original
    letter (the same three I identified in my call to the EPA Hotline): ODOR; RED
    DISCHARGE; BLACK/GRAY/BROWN DISCHARGE. Your reply did not address all of my concerns.
    >
    > ODOR: I understand the odor present with composted sludge, and I am satisfied with your response regarding the odor problem. It’s great that Hamilton’s website has an ODOR HOTLINE for its citizens to lean on. The odor doesn’t really hurt anyone, at least not the majority of Hamilton residents that live upwind.
    >
    > RED DISCHARGE: Your glancing response to this item leaves me with some
    unanswered questions. I understand how the Hamilton Wastewater Treatment Plant could be loaded by an upstream industrial facility. I do not, however, understand how a single industrial process could overflow the entire sewage plant on a holiday, especially after there had been no precipitation for many days. This is not stormwater runoff. I do not understand how Mohawk Paper could indiscriminately burden the Hamilton WWTP without prior notice, such that WWTP could manage the discharge in a fashion that might not have such a deleterious effect on the river and surrounding wildlife. Now, the questions:
    >
    > A : Does not Mohawk Paper, or Hamilton WWTP, have the obligation to notify the EPA of its intent to exceed any permitted discharge values? Did you know beforehand that they were going to dump this red discharge on Christmas Eve?
    >
    > B: If Mohawk Paper, or Hamilton WWTP, would plan well enough, this
    discharge volume could be evaporated, filtered, or otherwise treated to the
    point of eliminating any burden at all except for a small amount of hazardous
    waste solid landfill. Do Mohawk Paper, Hamilton WWTP, and EPA have a published abatement plan at hand for reduction or elimination of the liquid waste, including milestones occurring in this lifetime (your current answer seems to indicate a resolute "no")?
    >
    > C: Is it easier for Mohawk Paper and Hamilton WWTP to just pay a fine, and nly when someone such as myself and my son happen to notice they’re dumping into the river? If Hamilton is paying a fine, then my tax dollars are triply wasted! As I stated in the original, I've seen this river run many different colors for 40 years, so it seems that we're closer to the "business as usual" point than we are to any resolution. If Mohawk has a permit to discharge this "nuisance-causing" by-product, they must know by how much they exceeded their permit. What is the frequency and volume of exceedance for this type of dumping by Mohawk Paper and Hamilton Wastewater Treatment Plant, and what fines have been paid?
    >
    > D: If Mohawk Paper did know it was going to discharge and overload the
    Hamilton Wastewater Treatment Plant, did they warn Hamilton?
    >
    > E: Hamilton Wastewater Treatment Plant has to know what is coming out of its pipe. Why did Hamilton not warn anyone in the area?
    >
    > F: We witnessed the red discharge for one hour. What were the total
    duration, total volume, and chemical/biological makeup of the discharge?
    >
    > G: Do Mohawk Paper, Hamilton Wastewater Treatment Plant, and EPA know what this discharged material does to the river, dependent flora and fauna, and anyone or anything moving through the affected areas, short-term and long-term? It certainly curtailed my ability to pursue and catch any fish. Is there any study, data, MSDS? You are discharging or allowing discharge of these materials over the regional permeable water supply aquifer. Would it not be prudent for the discharging facilities to post warnings, or would a posted warning constitute admission of liability for everyone in the chain of custody of the dumped effluent?
    >
    > H: Would you wade in, apply to your skin, or drink this red discharge, the
    water admixed with the discharge in the river, or the water remaining in the
    river post-discharge – with or without pretreatment?
    >
    > BLACK/GRAY/BROWN DISCHARGE: The sudden change from red to black/gray/brown indicates that at least 2 processes were dumping into the river serially. Your reply did not address this black/gray/brown event. Similar, related questions arise when read against your response to the RED DISCHARGE:
    >
    > I: Did the overload caused by Mohawk Paper (RED DISCHARGE) trigger a
    malfunction of the Hamilton Wastewater Treatment Plant?
    >
    > J: Does the Hamilton Wastewater Treatment Plant have a round-the-clock licensed or certified operator on site, and is the operator responsible for
    monitoring the discharge into the river for violating conditions? How many ppm of ammonia, nitrites, nitrates and phosphorous is Hamilton Wastewater Treatment Plant allowed - daily, weekly and monthly, and what is the limit of solids (mg/l) in the discharge? Is there a warning system for the operator that identifies violating conditions at or near the start of such an event, or does the plant operate “after-the-fact”? Is the operator responsible for reporting such dumping to the EPA, and in what timeframe?
    >
    > K: We witnessed the black/gray/brown discharge for fifteen minutes. What were the total duration, total volume, and chemical/biological makeup of the discharge?
    >
    > L: Would you wade in, apply to your skin, or drink this black/gray/brown
    discharge, the water admixed with the discharge in the river, or the water
    remaining in the river post-discharge – with or without pretreatment?
    >
    >
    > I will be in the area for a long time to come. I still enjoy fishing when
    there is no dumping. So that I may plan ahead, and possibly be of more
    immediate service in reporting:
    >
    > M: Should I have called 911, as the number to the plant and public works
    departments gave a holiday out of office message?
    >
    > N: As of yet, I have not had the pleasure of a reply from Mr. Reigelsperger at the Department of Public Works in Hamilton, so I'll continue directing my questions your way. Is your reply the official position, or will I be hearing from Hamilton with supporting documentation?
    >
    > O: Think for a minute – If I was the 600-pound gorilla, and I said Mohawk
    Paper and Hamilton Wastewater Treatment Plant had to suspend dumping these hazardous wastes into the river because I wanted the community to be able to use it in a natural setting ---
    >
    > P: Do I need to file an official notarized complaint?
    >
    > I’ll not apologize if any of these questions or comments seem pointed,
    leading, or heated, and I won't go away. I’ve only now started to get an
    understanding why one of my favorite activities can be curtailed because someone else doesn’t want to come into the 21st century. Please continue to reply on this e-mail.
    >
    > Thank you,
    >
    > Dennis Malone
    >
    >
    > RECEIVED Thursday, 29 December 2005 at 2:20pm:

    > ---- Ned Sarle <Ned.Sarle@epa.state.oh.us> wrote:
    > > Dear Mr. Malone:
    > >
    > > On December 26, 2005, you contact the Ohio EPA about the Hamilton WWTP. You were complaining about the WWTP discharge and the odors at this facility. These conditions were noted while you fished in the Great Miami River on December 24, 2005.
    > >
    > > On December 27, 2005, the Ohio EPA contacted the city of Hamilton (Hamilton) about your complaint. WWTP staff indicated that the noted odors were most likely from the WWTP composting facility. Hamilton was loading composted sludge during the morning of your visit. WWTP odors have been a problem in the past. Hamilton continues to work on minimizing the WWTP odors. The Ohio EPA has noted that Hamilton's past efforts have significantly reduced these odors. However, eliminating all WWTP odors is very difficult due to the nature of the treatment system.
    > >
    > > The red color noted for the WWTP discharge has been an issue that Hamilton has been working on for many years. As indicated, the Hamilton WWTP discharge was a red color on the morning of your visit. A local industry, Mohawk Paper, was producing a color paper that resulted in a red color discharge from the Hamilton WWTP. Altering the color of the Great Miami River to the degree that it produces a nuisance is a violation of their permit to discharge and the State of Ohio's Water Quality Standards. The Ohio EPA is in the process of notifying Hamilton of this violation. The color pass through for the Hamilton WWTP discharge ended later that day. No other permit violations have been noted for their WWTP discharge.
    > >
    > > The color pass through at the Hamilton WWTP has been a problem for many years for two local paper facilities. The WWTP color pass through occurs on an infrequent basis. Hamilton has worked with their local paper facilities to prevent a color pass through at the WWTP. Significant improvements have been noted with the two facilities. The problems of a color pass through have been greatly reduced from previous years. However, additional action is still required to prevent these types of discharges. Unfortunately, a suitable treatment system has not been found by these facilities to completely eliminate the color pass through at the Hamilton WWTP. The Ohio EPA will continue to work with Hamilton and the two local facilities to eliminate these types of discharges.
    > >
    > > Hopefully, this addresses your concerns. If you have any additional
    questions or wish to discuss this further, please contact me by e-mail or by
    phone at (937) 285 - 6096.
    > >
     
  12. Okccatman

    Okccatman New Member

    Messages:
    323
    State:
    Norman,Ok
    Wow. You are giving it to him good. Keep it up and please keep posting the reply's.
     
  13. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    I did a bit of internet searching today and found the headquarters of Mohawk Paper, and a "contact us" for the VP in charge of environmental affairs. I sent him the entire email thread and requested comments and any answers he could provide.
     
  14. nosnag

    nosnag New Member

    Messages:
    284
    State:
    Florida
    Good show Dennis,Keep up the pressure and keep us posted on results.I'm behind you 100%.If we do'nt keep on these corps. they will continue to bend the rules.
     
  15. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    Reply rec'd 4 Jan 06:

    ---- Ned Sarle <Ned.Sarle@epa.state.oh.us> wrote:
    > Dear Mr. Malone:
    >
    > I have received your most recent enquiry. The Ohio EPA is in the process of discussing these issues with the City of Hamilton. We are hopeful that we may be able to address your comments in the next week or so. I just wanted to let you know that we are looking into this further.
    >
    > If you have any questions, please contact me.
    >
     
  16. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    MOHAWK
    MOHAWK FINE PAPERS
    The Beckett Mill
    400 Dayton Street
    Hamilton, OH 45011
    513 896 2500
    www.mohawkpaper.com

    January 4, 2006


    Dear Mr. Malone:

    On December 30th, 2005, you contacted Mr. George Milner via Mohawk Fine Papers' website requesting feedback on questions you submitted to Mr. Ned Sarle of Ohio EPA concerning your observations of the Great Miami River on December 24th. I'm Vice President and General Manager for Mohawk Fine Papers' operations in Ohio, including the Beckett paper mill in Hamilton, Ohio, and I want to respond to your concern.

    On December 29th we became aware of your observations when Hamilton's Department of Public Works issued a Notice of Violation (NOV) of City of Hamilton Sewer Regulations to our facility related to the red color noted in your observations. Although there are many industrial and commercial operations that feed into the City's wastewater treatment plant, city regulators believe that our Beckett Mill was the source of the red tint that you observed. The NOV requires a response to the City regarding circumstances that may have contributed to a color passthrough event, and we immediately began a re-examination of our operating records and interviewing operators, supervisors and engineers associated with our effluent operations on the 23rd and 24th. As mentioned by Mr. Sarle in his response to your letter, we have made dramatic improvements over the last 10 years in our ability to make colored paper without passing tinted water on to the City's wastewater treatment plant, and we take management of this part of our operation very seriously. Any findings from our investigation of this incident will definitely be
    used to continue to improve our systems for controlling effluent color.

    The improvements we have made, and will continue to make, are done in close consultation with the City and State environmental authorities. We have a resolute commitment to comply with all environmental requirements and to go beyond those requirements to continually reduce our environmental footprint in the communities where we operate. One example of our commitment to environmental stewardship is the Beckett Mill's participation in US EPA's Performance Track Program. Performance Track is a voluntary partnership with EPA that, in their words, "recognizes top environmental performance among participating U.S. facilities of all types, sizes, and complexity, public and private". "Program partners are providing leadership in many areas, including preventing pollution at its source." Our Beckett mill is one of only 14 members of this program in Ohio, with only 370 facilities in this program nationwide. Participation in the program requires a solid Environmental Management System, sustained compliance with regulations, and demonstrated results in improving environmental performance beyond what's required by regulation. (http://www.epa.gov/performancetrack/)

    MOHAWK
    MOHAWK FINE PAPERS


    The Beckett Mill became part of Mohawk Fine Papers in May of 2005, and the corporate commitment of Mohawk to be a good environmental citizen is among the highest I've seen. I hope you took the opportunity to study some of the materials regarding environmental stewardship during your visit to our corporate web site, but I'd like to point you to one document
    in particular,
    (http://www.mohawkpaper.com/about/html/environment/EnvStewardshipBrochure.pdf). While this document was produced before we became part of Mohawk, the messages in it apply fully to the Beckett Mill.

    An example of how Mohawk has shared it's environmental citizenship commitment with the Beckett Mill can be seen in our use of electricity generated by wind power. Mohawk is the only paper company in the U.S. to use wind energy to manufacture paper. In 2004, Mohawk first began using the pollution-free alternative energy source for its Cohoes, New York, plant. Then, on June 1, 2005, following acquisition of the Fine Papers business from lnternationa! Paper,
    Mohawk negotiated a contract to purchase an additional 35 million kWh's of wind powered energy for its newly acquired Beckett Mill in Hamilton. This commitment to wind energy allowed
    Mohawk to join the highest level of EPA Green Power Partnership Leadership Club as well as earning a ranking (#16) in the EPA List of Top 25 U.S. Green Power Purchasers.
    Mohawk's annual purchase of 45 million kWh's of wind energy offsets 21 percent of the electricity used at Mohawk Fine Papers' two New York mills and 50 percent of the electricity used at its Beckett Mill. Currently Mohawk manufactures five of its brands entirely with
    windpower.

    I hope you won't assume that these examples are just "corporate speak". The employees of the Beckett Mill, and the owners and leaders of Mohawk Fine Papers are truly committed to excellence in environmental performance. Are we perfect yet? No, but our approach to significant continuous improvement gets us closer every day. We take your concerns very seriously and will work closely with the City of Hamilton and Ohio EPA to address them.

    Best regards,

    [signature]

    Ronald B. Raley
    Vice President & General Manager, Ohio Operations



    cc: Darla Crum, City of Hamilton
    George Milner, Mohawk
     
  17. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    7 January 2006


    MOHAWK FINE PAPERS
    The Beckett Mill
    400 Dayton Street
    Hamilton, OH 45011

    Mr. Ronald B. Raley
    Vice President & General Manager, Ohio Operations


    Dear Mr. Raley:

    Thank you for your 4 January response to my 30 December 05 electronic contact with Mr. Milner. In that contact, I submitted text of mail and e-mail to Mr. Reigelsperger at Hamilton Department of Public Works, and Mr. Sarle of Ohio Environmental Protection Agency, in which were noted observations and questions pertaining to the conditions my son and I observed from the discharge located at 2451 River Road (Hamilton Wastewater Treatment Plant) into the Great Miami River on 24 December 2005. I was not able to include photographs of the effluent and affected areas by using the Mohawk Paper website. If you have not yet seen and wish to have these photos for reference, please advise and I will forward, electronically or as hardcopies. Your reply touches on the red colored effluent observed dumping from the wastewater discharge for at least one hour, but does not answer the questions I posed. While I cannot expect Mohawk Paper to answer for Hamilton’s process, I would appreciate an attempt at specifically addressing each question in the submission pertaining to Mohawk individually. I eagerly await a more detailed reply.

    The red color noted in my observations, termed “pass through” by OEPA’s Mr. Sarle and yourself, and additionally “nuisance,” has a tremendous and immediate negative effect on the river and seemingly all life contacted by the effluent stream. The river area around and downstream of the discharge is normally home to game fish and rough fish, and there are usually as many a five Great Blue Herons fishing in the riffles for the abundant baitfish and crustaceans, as well as several species of duck feeding and swimming. There are no fish, baitfish, crustaceans, birds, or any other visible creatures in the affected area during the discharge. The river water, which above the discharge was clear to a depth of 2 feet that day, ran a brilliant red from the dumping, and seemed to precipitate red sediment onto the downstream riverbed as well. What you have done here is to change the river’s system of life support. Fish cannot see, as you have changed the solar spectral transmission characteristics of the water; these fish also cannot efficiently replenish their supply of oxygen, as you have introduced a chemical irritant. Birds cannot feed where there are no fish. Last and least, we cannot catch fish where there are none present.

    I consider this much more than a nuisance. I, as every citizen of the watershed community, have the right to use the Great Miami River area resource in a non-affected state. That is to say, we should be able to fish a natural streamflow, without chemical or biological attack. We should be able to wade in the water without worrying what it might do to our clothing, equipment, our persons, and our future health. We should be able to expect that this river is available to our sons and daughters, without concern.

    Your response states, “Any findings from our investigation of this incident will definitely be used to continue to improve our systems for controlling effluent color.” With regard to controlling the effluent color, I have read your US EPA Performance Track Membership Application submitted by International Paper in 2005 (https://yosemite.epa.gov/opei/ptrack.nsf/vApplicationViewPrintView/19A27A6329DC8CF885256F5600046D1A). It shows a pre-Mohawk corporate commitment to decrease in hypochlorite bleach used to decolor the effluent, from a 2003 baseline of 83,700 pounds to a projected 2007 volume of 71,145 pounds. While this decrease is absolutely commendable, it appears to be indexed to annual production of A1 paper tonnage, such that an increase in paper production will result in a proportional increase in hypochlorite bleach discharged into the river. Presuming the red discharge was not treated to control the color, would a treated discharge then contain the same materials and include hypochlorite bleach, sans color? Why do you need to discharge 35 tons or more of hypochlorite bleach into the river annually? By the way, were you discharging bleached effluent on 31 December 05, as I was at the same site from 2:00 to 2:30PM and the acrid smell was very evident. The only difference was the river level had risen about four feet, with flow approximately 5 times normal, making visual determination of the discharge constituents virtually impossible.

    The same questions are necessary regarding projected release into the Great Miami River of 1,377,510 pounds (2007) of suspended solids, 26,528 pounds of toxic release inventory (TRI Form R) chemicals (2003 reported), and any heavy metals not included in the above. Why does this toxic material have to be dumped into the waterway at all? Question 3 of Section B: TELL US ABOUT YOUR EMS asks: Have you classified your aspects based on their potential harm to the environment, on community concerns, and/or on other objective factors (i.e., have you determined your significant aspects)?: Your answer was, “YES.” Please share your assessment cited, with respect to environmental harm and of community concerns, particularly the effects of your discharge of these materials into the local recreational waterway and short-term and long-term effects on downstream life. I do address this in my concerns in the letter to Mr. Sarle at OEPA, as well.

    Your response also directs me to a Mohawk Paper brochure outlining the “corporate environmental citizenship commitment” (http://www.mohawkpaper.com/about/html/environment/EnvStewardshipBrochure.pdf) and you state that the messages in it apply fully to the Beckett Mill. You cite examples of use of electricity generated by wind power as a pollution-free alternative energy source for Mohawk’s Cohoes, New York, plant. And the Beckett Mill in Hamilton, which allowed “Mohawk to join the highest level of EPA Green Power Partnership Leadership Club as well as earning a ranking (#16) in the EPA List of Top 25 U.S. Green Power Purchasers.” Mohawk's annual purchase of 45 million kWhr of wind power is very commendable, but is also indicative of the easy way for Mohawk to get on the green side. An Internet search turned up an article adjacent to the Mohawk story wherein a description of wind-generated energy costs is compared to older technologies –

    “In reality, all energy sources are subsidized by the public at varying levels. With current incentives for wind, the cost per kilowatt hour (KWhr) is comparable to the electricity from coal or gas plants. Under New York’s current green marketing options, the premium for wind power is 2.5 cents per KWhr.”
    (http://www.eany.org/capitolwatch/votersguide/vg2005/oil_slick.html)

    The Mohawk brochure fairly substantiates the observation as it goes on, ‘According to George Milner, Mohawk's senior vice president, energy, environmental and governmental affairs…"There is a misconception that choosing the environmentally correct path costs a lot more," notes Milner, "but with the technological advances in windmills, the cost of wind power is within range of traditional energy sources. “’

    So, realistically, the purchase of electric power generated in upstate New York only offsets the generation of coal-fired energy produced for the Hamilton mill, and there is no real benefit to air quality in our locality. Not that I begrudge our friends up there anything, but it all stays in New York. I even thought I heard Governor Pataki on CSPAN this week proposing a statewide tax-free zone for companies around the world that develop green energy sources. What a coup for the corporation.

    In the same brochure, ‘According to Thomas D. O'Connor, Jr., Mohawk's chairman and CEO, "…Our commitment to environmental excellence has sustained -- even propelled us -- to where we are today. Response to our Wind Power Portfolio has opened up new markets with customers committed to preserving the earth's natural resources."’

    "This [wind energy] is a highly visible way to demonstrate our commitment to environmental stewardship," says George Milner, Senior VP, Energy, Environmental and Governmental Affairs. "Customers are responding favorably to Mohawk's commitment. Corporate buyers, in particular, continue to seek ways to make their own sustainability initiatives visible to their customers, shareholders and other interested parties. Printing corporate and marketing messages on paper made with non-polluting windpower is a way to demonstrate commitment to sustainable business practices."

    “Mohawk has a longstanding tradition of striving for environmental excellence in all aspects of its business and is today purchasing windpower for 38 percent of its electric energy requirements.”
    (http://www.mohawkpaper.com/about/html/press/press_releases/2005_0812.htm)

    Don’t stop there – use the springboard you got from wind, profits you get from expanded sales due to wind, recycling and solid waste landfill, and elect to do the right thing here for water in Hamilton, Ohio. Build a process that uses the local natural resources in a manner that affords the same access to all of the community, without concern.

    Take a closer look at the stewardship brochure to which you directed me (I had reviewed it, and the US EPA Performance Track Application, prior to making contact with your company). Ask the young person pictured swimming in a pristine waterway if they would trade location, and swim in the Great Miami where this effluent enters the river. Ask Mr. Milner, in his pensive pose along the Hudson River, if he would mind striking the same profile in front of the Hamilton wastewater discharge flowing red for miles downstream. How would those images affect customers committed to preserving the earth’s natural resources? Where are we on the corporate speak issue?

    I am in contact with Hamilton Wastewater Treatment Plant, and have asked for similar response regarding their portion and responsibility, and potential interrelationship of both the red and black/gray/brown effluent discharges, described in my letter of 24 December 05. I would really like to start receiving some straight answers from the responsible parties. I’m certain there are others like me that would appreciate improved, consistent fishing and other recreational uses of the river, and still others human and otherwise that will greatly benefit from the restoration of this river to its natural water quality.

    I know Mohawk Paper is not the only point source polluter in the watershed. I don’t deny that you have made advances in the general preservation of the environment in Mohawk plants, but I’ve seen the Great Miami River run many colors and with many odors, for forty years, most downstream of this pipe. I have had numerous fishing excursions cut short or altogether denied by such dumping. I have now found one source, though, and eliminating one is the next best step toward eliminating all. It’s not a sewer, decades of dumping notwithstanding. Given time, and careful stewardship, the Great Miami River can heal itself, if left alone. Maybe you’ll help by stepping up, to uphold the opening statement in the Mohawk environmental stewardship brochure, “Environmental leadership requires a willingness to test uncharted waters.”

    I look forward to hearing from you.

    Sincerely,




    Dennis J. Malone


    cc:
    riversunlimited.org

    miamiconservancy.org

    ohiogamefishing.com

    catfish1.com
     
  18. nosnag

    nosnag New Member

    Messages:
    284
    State:
    Florida
    Horray for you Dennis,
    I can see that you have been really been doing your homework on this problem of corruption to the enviroment in your area.My hat is off to you.It is a shame that the local papers hav'nt taken up the cause with you.They can generate a lot of powerful oppositions from area citizens and other corporations that take pride in the area.It is too bad that you did'nt get a glass jar of that discharge to plunk down in the newspapers editors desk.Somehow just hearing about a problem loses impact.The sight and smell of that discharged waste would probably have more impact.A sample of the bed of the rivers mud given to your local DEP can also stir things up.You have a justified concern that needs to be recognized by the citizens before it is too late and too costly to repair.Take care,and my sincerest hopes go out to you that you will prevail in this quest.
    BILL
     
  19. Ol Whiskers

    Ol Whiskers New Member

    Messages:
    290
    State:
    Fairfield Township, Ohio
    Nosnag,

    I haven't gone to local media, yet. I am getting pretty frustrated at the lack of straight answers, and the news and papers are my next stop. They (EPA, MOHAWK PAPER, HAMILTON WASTEWATER TREATMENT PLANT) all seem to want me to just go away, which will not happen. I wish I had gotten samples of the different junk in the flow, but I was just not ready that day. It was about all I could do to get up and own there anyway to fish, as I had 2 kidney stones (passed one just b4 new year's, still have one to go). I thought about making up a little sample kit to keep in the car, 'cause we're on the river a lot in that area. Live and learn. I haven't been out fishing since, just haven't felt well and the river's been up most of the time. What's really disheartening is that they probably have permits for some level of this stuff anyway, and there are 140 miles of WWDs upriver from them. Look at the level thsy are reporting to the USEPA,and then imagine how much stuff is actually in the river. There's a fish consumption advisory on every species in the river, and form this area downstrean it suggest a limit of one meal per month or one meal per 2 months, depending on the fish. PCBs, heavy metals, etc.

    Thanks for your support, everyone.
     
  20. Mutt

    Mutt Administrator Staff Member Supporting Member

    Messages:
    19,206
    State:
    Ca
    Name:
    Mutt
    go get em dennis nail them to the wall its time more people did the same in outer areas too! keep us posted.