PERMIT RATIONALE FOR REISSUANCE
Illinois Central Railroad
Pike County
McComb, Mississippi
Water NPDES No. MS0000141
September 20, 2016

I.	FACILITY INFORMATION

Facility Name:  Illinois Central Railroad
Facility Address:  South Railroad Boulevard 
McComb, MS  39648    
Permit No.:  MS0000141
SIC:  4011
Permit Writer:  Thomas Kelly
EPD Branch:  Energy and Transportation Branch

II.	NATURE OF BUSINESS

Railroad and Line Haul Operations

III.	EFFLUENT AND RECEIVING STREAM FLOW DATA

Effluent from Outfall 001 consists of treated storm water runoff from the facility storm water collection system, wash water from the locomotive refueling and maintenance apron, and storm water runoff from the railcar inspection and repair area. The facility was previously permitted to discharge treated ground water, however the ground water remediation was removed and this discharge was eliminated. The outfall has a maximum daily flow of 0.364 MGD and will discharge directly into Town Creek (7Q10 flow = 0.2585 MGD) then into the Little Tangipahoa River located in the South Independent Streams Basin.

IV.	303(d) and TMDL ISSUES

	None.

V.	TYPE OF WASTEWATER TREATMENT

•	Oil/Water Separator.
•	WW Lagoon#1 – Oil Separation and removal, solids settlement.
•	WW Lagoon #2 – Flow Equalization and biological stabilization.

VI.	EPA APPLICABLE CATEGORICAL GUIDELINES

None.

VII.	STATE APPLICABLE GUIDELINES

The Mississippi environmental regulations have been renumbered and reformatted pursuant to the amended Administrative Procedures Act passed by the state legislature. While the numbering and citation of the regulations have changed, the content of the regulations have not.

1.	Mississippi Commission on Environmental Quality National Pollutant Discharge Elimination System (NPDES) Permits, Underground Injection Control (UIC) Permits,
State Permits, Water Quality Based Effluent Limitations, and Water Quality Certification [11 Miss. Admin Code Pt. 6, Ch.1.]

2.	Mississippi Commission on Environmental Quality Regulations for Intrastate, Interstate, and Coastal Waters [11 Miss. Admin Code Pt. 6. Ch. 2]

VIII.	DATA FROM APPLICATION FORM (2C)

Parameter	Maximum Daily Value	
BOD	7.62 mg/L	
COD	16.1 mg/L	
TOC	7.40 mg/L	
TSS	< 4.0 mg/L	
Ammonia (as N)	0.120 mg/L	
Flow	0.364 MGD	
Temperature (winter)	--	
Temperature (summer)	27 ˚C	
pH	8.31 SU	

VIII. 	WATER QUALITY LIMITATIONS BASED ON WASTELOAD ALLOCATION 

	None.

IX.	CATEGORICAL GUIDELINE LIMITATIONS CALCULATIONS

Not Applicable

X.	TOXICITY SCREENING

Not Applicable

XI.	PROPOSED FINAL LIMITATIONS 

1.	Average Permit Limitations

Outfall	Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
001	Flow	--	--	Report	Report	Technical Judgment	
001	Oil & Grease	--	--	10 mg/L	10 mg/L	Technical Judgment	
001	pH	--	6.0 SU	6.0 SU	6.0 SU	11 Miss. Admin
Code Pt. 6. Ch. 2	

2.	Maximum Permit Limitations

Outfall	Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
001	Flow	--	--	Report	Report	Technical Judgment	
001	Oil & Grease	--	--	15 mg/L	15 mg/L	Technical Judgment	
001	pH	--	9.0 SU	9.0 SU	9.0 SU	11 Miss. Admin
Code Pt. 6. Ch. 2	

MONITORING TYPE AND FREQUENCY

·     ”Flow” shall be monitored monthly utilizing a instantaneous sampling and reported on a quarterly basis.

•	“pH” shall be monitored monthly utilizing grab sampling and reported on a quarterly basis.      

•	“Oil & Grease” shall be monitored monthly utilizing grab sampling and reported on a quarterly basis.

XI.	BASIS FOR LIMITATIONS: 

Flow

The average and maximum limits of “Report” are based on technical judgment. 

Oil & Grease  

The average and maximum effluent limit of 10 mg/l and 15 mg/l are technology based limits, which reflect the ability of simple oil/water separation equipment to easily remove oil & grease from the discharge.  

pH

The minimum and maximum pH effluent limits of 6.0 SU and 9.0 SU are water quality based effluent limits (WQBELs) that reflect the 11 Miss. Admin Code Pt. 6, Ch.2 requirement for the normal pH of water to be in the range of 6.0 to 9.0 SU.

Benzene, BTEX Combination, Benzo(a)anthracene, Benzo(a) pyrene, and Total Recoverable Lead 

Limitations for Benzene, BTEX Combination, Benzo(a)anthracene, Benzo(a) pyrene, and Total Recoverable Lead were originally placed in the permit during a permit modification to install a ground water remediation system that was issued on April 8, 2004. Monitoring for these parameters was required only when wastewater from the groundwater remediation system was discharged. This system discharged treated groundwater until operation of this system was discontinued in August 2005. The system treated groundwater to remove Light Non-Aqueous Phase Liquids (LNAPL).  The facility has since removed the system and has eliminated the discharge. The facility now utilizes Enhanced Fluid Recovery (EFR) technology that involves the use of high-efficiency vacuum trucks to remove residual LNAPL from the groundwater wells.  Fluids recovered from these wells are transported to Walker Hill Environmental Located in Foxworth, MS for treatment and disposal. Because the discharge has been eliminated, monitoring for these parameters have been removed from the permit.