Weeks after unveiling its “Cleaner GP” campaign, the St. Johns Riverkeeper has unveiled a comprehensive analysis of the Brown and Caldwell study originally used to justify paper giant Georgia-Pacific’s controversial wastewater pipeline.

The Brown & Caldwell report concluded that a pipeline rerouting effluent from Georgia-Pacific’s Palatka mill into the much-larger St. Johns River would be the only hope for the paper company to meet water standards in Rice Creek, where the Palatka mill sits.

Environmentalists have long argued that the pipeline would further wreak havoc on St. Johns, which is already inundated with symptoms of nutrient pollution. Georgia-Pacific waste contains both nitrogen and phosphorus, which often leads to toxic algal blooms and fish kills.

In an effort to dissuade the Florida Department of Environmental Protection from its approval of the pipeline, the Riverkeeper hired Lakeland-based Hayes-Bosworth Inc. to conduct a peer review of the Brown & Caldwell study. In a letter summarizing the study (.pdf), Robert Hayes remarks that the study was deficient and that there are indeed viable alternatives to the pipeline:

The stated objective of that evaluation was a feasibility determination of the capability of various selected technical alternatives in regard to compliance with specific Florida Department of Environmental Protection (FDEP) effluent discharge standards. Brown and Caldwell completely failed to achieve that objective.

Brown and Caldwell’s competency, capability and expertise in waste-water technology was evident throughout the memorandum, as was their unfortunate, clearly evident deficiency in chemical engineering knowledge and experience – a deficiency that predestined the evaluation to its inevitable failure.




I offer no apology for my criticism of Brown and Caldwell’s Technical Memorandum. The quality of the work inspires neither generosity nor delicacy.

Hayes concludes that the Brown and Caldwell study is not only “replete with extraneous, irrelevant contradictory data and information,” but also begs the question of “why such thoroughly professional time and effort was expended estimating and costing alternatives determined non-feasible in the first 55 pages.”

At one point, Hayes suggests that a company with “a broader experience in the world of pulp and paper and in the much wider world of chemical process industries” would have been more appropriate for a study with such far-reaching effects.

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