Today Mobile Baykeeper submitted comments on ADEM's re-issuance of a general permit for discharges associated with lumber, wood, and paper products industry. These comments address several deficiencies we saw in the proposed permit.
- A number of the permits require facilities to monitor important parameters such as pH, total suspended solids but have no limitations. It is not productive to have a facility monitor for a pollutant without implementing a limitation. We believe it is important that these pollutants are within ranges that protect water quality. Imposing reasonable limitations will ensure that is the case.
- Other outfalls do not impose any monitoring requirements whatsoever for pollutants. For instance, some outfalls pose no monitoring requirements for biochemical oxygen demand (BOD). BOD is the amount of oxygen consumed by organisms breaking down organic matter. If large amounts of organic matter (sewage, grass clippings, leaves, wood pulp etc) are added to a waterbody BOD can skyrocket causing the amount of oxygen in the water to decrease dramatically. These lowered oxygen levels can be responsible for fish kills and other. This lack of monitoring requirements is even more egregious due to the fact the EPA has found BOD is commonly be associated with these activities. Analysis of 203 samples from 101 facilities in the lumber industry found an average biochemical oxygen demand (BOD) of 58 mg/l and a maximum of 1925 mg/l. The level where BOD starts to be a concern is 30 mg/l. Therefore, Mobile Baykeeper has asked ADEM to institute monitoring requirements for BOD.
- Some outfalls don't require monitoring for oil and grease. At facilities that working to prevent pollution, oil and grease should never be found in their discharge. Mobile Baykeeper has asked ADEM to ensure these facilities are not releasing oil and grease by adding monitoring requirements for oil and grease into permits.
You can read our full comments and find a copy of the draft permit below.