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Subject:

Public Comment on Permit Modification

Northport WWTP—City of Northport

P.O. Drawer 569

Northport , AL , 35476

NPDES PERMIT NUMBER AL0064394

From: Trevor Jones

Fax: (205) 458-0094

Tel: (205) 458-0095

E-mail: cahabariver@aol.com OR nbrooke@blackwarriorriver.org

July 15, 2005

Russell A. Kelly

Chief, Permits & Services Division

Alabama Department of Environmental Management

Fax: (334) 271-7950

E-mail: rak@adem.state.al.us

Subject: Public Comment on Permit Modification for Northport WWTP—City of Northport (NPDES Permit AL0064394)

Dear Mr. Kelly:

I am concerned about the proposed permit modification for Northport Wastewater Treatmant Plant (W.W.T.P.) – City of Northport NPDES permit (AL0064394). The proposed modifications will negatively impact Mill Creek. I do not believe that the department should allow the City of Northport to modify its permit, applied for on June 10, 2005, based on my comments provided below.

Mill Creek and its tributaries are classified for Fish and Wildlife. A.D.E.M.’s own water quality criteria from 335-6-10-.09 state that for Fish and Wildlife: “sewage, industrial wastes or other wastes shall not cause the pH to deviate more than one unit from the normal or natural pH, nor be less than 6.0, nor greater than 8.5.” The daily maximum for pH for Northport WWTP is listed in the permit application as 9.0 s.u. This must be changed to a daily maximum of 8.5 s.u. or below for all eligible outfalls.

Northport WWTP’s previous violations must be considered in NDPES permit AL0064394. In July 2002, the monthly and weekly averages for Biological Oxygen Demand (BOD) for discharge number 001-1 exceeded the permit’s legal limit. Furthermore in July 2002, the same month, the monthly and weekly averages for Nitrogen and Ammonia for discharge number 001-1 exceeded the permit’s legal limit. These violations indicate a disregard for A.D.E.M.’s water quality criteria and suggest that Northport WWTP’s noncompliance will persist in the future.

Experts with the United States Department of the Interior recommend that wastewater treatment plants closely adhere to protective measures, including those found in ADEM regulations sections 335-6-10-.06 (a) and (c), to maintain minimum water quality conditions applicable to all State waters. Additional protective measures may be needed if listed aquatic species occur adjacent to, or downstream of the proposed wastewater treatment plants. (Elaine Snyder-Acting Field Supervisor, Fish & Wildlife Service Jan. 4, 2005).

335-6-10-.06 (a) State waters shall be free from substances attributable to sewage, industrial wastes or other wastes that will settle to form bottom deposits which are unsightly, putrescent, or interfere directly or indirectly with any classified water use.

335-6-10-.06 (c) State waters shall be free from substances attributable to sewage, industrial wastes or other wastes in concentrations or combinations which are toxic or harmful to human, animal or aquatic life to the extent commensurate with the designated usage of such waters.

Thank you for the opportunity to comment on this facility. I look forward to a response from A.D.E.M. addressing the issues I have raised above.

To cleaner water,

Trevor Jones, For Black Warrior Riverkeeper

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712 37^th Street South

Birmingham , AL 35222

www.BlackWarriorRiver.org

Riverkeeper is a registered trademark of Waterkeeper Alliance, Inc.

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NPDES PERMIT NUMBER AL0064394

712 37th Street South

Birmingham , AL 35222

712 37^th Street South