Mary S. Nash
104 S. Houston Street
Kaufman , Texas   75142
NashHulme@msn.com
972-962-7706
July 9, 2003

Mr. Frank Espino, Regional Director
Texas Commission on Environmental Quality
2301 Gravel Dr.
Fort Worth , TX 76118-6951  

Re:       Dallas Crown Packing Plant
           
2000 W. Fair,
Kaufman , Texas   75142  

Dear Mr. Espino:  

I am writing to ask your assistance in resolving an issue that I believe to be illegal and certainly constitutes a risk to human health.   Dallas Crown Packing is located within the corporate boundaries of the City of Kaufman and may be illegally discharging pollutants into the city’s sewer system.  I own property adjacent to Dallas Crown and I am very concerned that they habitually exhibit complete disregard to federal, state and local environmental regulations.  

My concerns are further supported by the following items that I am enclosing for your review:  

      ·        San Antonio Current article dated June 19, 2003 , about Dallas Crown’s violations of Kaufman’s Industrial Waste Ordinance
·       
Kaufman city employee Mike Merritt’s May 27, 2003 , and May 13, 2002 , letters to Dallas Crown regarding their violations of the city’s Industrial Waste Ordinance
·       
May 14, 2003 , Analytical Report of TALEM, Inc. showing biochemical oxygen demand (BOD) levels over permit level by 13,000 mg/l
·       
List of monthly test results from January 2000 through May 2003 showing Dallas Crown’s BOD levels to be non-compliant during many of those months
·       
Section 106-130, Authority to Disconnect Service from Kaufman’s Industrial Waste Ordinance  

I was unaware of Dallas Crown’s long history of repeat violations until I read the San Antonio Current article.  I have subsequently thoroughly reviewed the documents and compliance history alluded to in the article.  As a Kaufman property owner, sewer customer, and taxpayer, I am concerned that our municipal sewer system is being strained by Dallas Crown’s illegal discharge.   

I am also aware that the City of Kaufman is in the process of monitoring its effluent to assist the Tarrant Regional Water District (TRWD) document point sources of contamination in the East Fork of the Trinity River watershed.  This monitoring effort will assist the TRWD in developing a Total Maximum Daily Load (TMDL) for the watershed.  I am concerned that the excessive industrial discharge from Dallas Crown will result in state mandated renovations to the City's wastewater treatment system that are expensive, burdensome and perhaps unnecessary. Our sewer rates are already very high due to the construction of a new sewer plant in 1994.   

Mr. Merritt’s letters referenced above make clear some of my additional concerns as an adjacent property owner.  In his May 13, 2002 , letter to Dallas Crown, Mr. Merritt discusses problems associated with blood discharged into the environment as well as bone and other matter scattered about in the plant vicinity.  

Please note that Section 106-130 of Kaufman’s Industrial Waste Ordinance states that the city may terminate service when “A governmental agency informs the city that the effluent from the wastewater treatment plant is no longer of a quality permitted for discharge to a watercourse, and it is found that the customer is delivering wastewater to the city's system that cannot be sufficiently treated or requires treatment that is not provided by the city as normal domestic treatment;”.  I am asking your assistance by conducting a thorough investigation into the compliance history of this industrial plant and a complete technical review of Dallas Crown's pre-treatment process if any.  

I realize that the City should handle this matter under its own authority as a home-rule municipality.  However, the plant's economic impact on the community may overshadow the City's desire to strictly enforce its environmental regulations.  Indeed, Dallas Crown has already been in violation of our Industrial Waste Ordinance several times over the last several months, and I know of no action by the City to terminate municipal services.  

Should you have any questions about this request or need any additional information, please do not hesitate to contact me at the letterhead address or telephone number.  Thank you in advance for your assistance in helping to resolve this persistent issue and in helping to protect the human health and environment of our community.  

Sincerely,  

 

Mary S. Nash

Encl.  

Cc w/encl:        Ms. Paulette Johnsey, Acting Chief
                        Permits Branch (6WQ-P)

                       
U.S. Environmental Protection Agency
                       
1445 Ross Avenue
                       
Dallas , Texas   75202  

Jan Malone, Environmental Investigator
            Region 4 - TCEQ