CCA Texas has submitted comments on TPDES Permit No. WQ0000447000 and has called for a public meeting. Additionally, CCA Texas submitted letters to Senator Lois W. Kolkhorst (District 18) and Representative J.M. Lozano (District 43), requesting that they also call upon the TCEQ to host a public meeting for this permit.
In early January 2026, Dow and its subsidiary, Union Carbide Corporation, requested to amend its wastewater permit in a 320-page NORI application (Notice of Receipt of Application and Intent to obtain permit). One of the most consequential elements of their permit application is a requested clarification or change to the permit’s prohibition on floating solids (pre-production plastics or nurdles). Specifically, Dow asks to “change to the language requiring no discharge of floating solids other than trace amounts. This language does not provide fair notice to DHRL (Dow) and UCC (Union Carbide) of its obligation to control pollutants and is vague. In addition, this language has the potential to be more stringent than necessary to attain the relevant receiving waters standard. Proposed language will be forthcoming.”
CCA Texas urges TCEQ to host a public meeting for this permit because the proposed changes could have broader, industry-wide implications and affect how floating solids are addressed in discharge monitoring and compliance. Additionally, the public meeting will provide an opportunity for the applicants and TCEQ to fully explain:
- How the proposed monitoring consolidations and reporting changes will protect water quality,
- The specific intent and practical effect of the requested permit language changes (particularly the floating solids clarification), and
- Any technologies, operational controls, or additional safeguards the facility uses or could implement to prevent accidental releases of floating solids into nearby waterways.
CCA Texas encourages members to submit comments to TCEQ, requesting a public meeting. Click here to view the CCA Texas Comments.
