PERMIT RATIONALE FOR REISSUANCE
NSLC Southern, Inc.
Claiborne County
Hermanville, Mississippi
Water NPDES No. MS0028266
August 23, 2017

I.	FACILITY INFORMATION

Facility Name:  NSLC Southern, Inc.
Facility Address:  11167 Pattison Hermanville Road, Hermanville, Mississippi 39086
Permit No.:  MS0028266
SIC:  2421
Permit Writer:  Sherryl Couch
EPD Branch:  Water II

II.	NATURE OF BUSINESS

NSLC Southern, Inc.’s Standard Industrial Classification (SIC) Code is 2421 - Sawmills and Planing Mills.  The facility manufactures lumber from southern yellow pine timber.  The facility is an existing source and expansion was not applied for or indicated in the permit application.  Therefore, the permit is proposed to be reissued in accordance with MDEQ’s permitting procedures for NPDES discharges.

III.	EFFLUENT AND RECEIVING STREAM FLOW DATA

The facility has three outfalls.  The effluent from Outfall 001 consists of boiler blowdown, water softener backwash, storm water runoff from 30 acres of plant site, and is inclusive of storm water overflow from the facility’s log spray re-circulation pond (Internal Outfall 002).  The average flow for the boiler blowdown and water softener back is 10.5 gallons per minute and 660 gallons per regeneration, respectively.  Regeneration occurs on average once every seven days.  The storm water runoff from the plant site and from the log spray pond are intermittant and occur only as a result of a rainfall event.  The average flow from Outfall 001 as reported in Item V of the Form 2C Application is 0.0025 MGD.

As mentioned above, the effluent from Internal Outfall 002 consists of storm water overflow from one of the facility’s two log spray ponds.  Discharge from this outfall occurs only as a result of a rainfall event.  There is no normal discharge.

The effluent from Outfall 003 consists of storm water overflow from the second of the facility’s two log spray ponds. This pond is located at the former International Paper log yard site.  Discharge from this outfall occurs only as a result of a rainfall event.  There is no normal discharge.

Receiving Stream: Unnamed Tributary of Bayou Pierre (7Q10 of unnamed tributary = 0 MGD); located in the South Independent Streams Basin.

IV.	TOTAL MAXIMUM DAILY LOAD (TMDL) AND 303(d) ISSUES:

A.  TMDL:	Under the South Independent Streams Basin reports, Bayou Pierre is listed for Pathogens (December 23, 2010).

B.   303(d):	Bayou Pierre is not listed in the 2016 Section 303(d) List of Impaired Water Bodies.

V.	TYPE OF WASTEWATER TREATMENT:

For Outfall 002 and Outfall 003, the facility has log spray re-circulation ponds where water which is sprayed on the logs is recaptured and reused.  Sedimentation and settling occur in the log spray re-circulation ponds.  Discharge from the ponds occurs only as a result of a rainfall event.  No treatment of the wastewater from Outfall 001 was indicated in the application.

VI.	EPA APPLICABLE CATEGORICAL GUIDELINES

"State of Mississippi Water Quality Criteria" and 40 CFR Part 429 - Timber Products Processing Point Source Category; Subpart K - Sawmills and Planing Mills Subcategory; Section 429.123 and Subpart I - Wet Storage Subcategory; Section 429.103.

VII.	DATA FROM APPLICATION FORM 2C

A.  Outfall 001
Maximum 		Maximum      		Long Term      	# of 
Parameter		Daily Value		30 Day Value		Avg. Value		Sam.
BOD			10.7 ppm (mg/L)	—			—			1
COD			62.0 ppm		—			—			1
TOC			20.1 ppm		—			—			1
TSS			10.8 ppm		—			—			1
Ammonia (as N)	3.95 ppm		—			—			1
Flow			0.0144 MGD		0.0076 MGD		0.0025 MGD		11
Temp. (winter)	78 deg F (26 deg C)	—			64 deg F (17.8 deg C)	4
Temp. (summer)	80 deg F (27 deg C)	—			75 deg F (24.2 deg C)	5
pH			7.3-8.6 S.U.		—			—			11
Sulfite	(as SO3)	< 3.0 ppm		—			—			1

B.  Outfall 002 
			Maximum      		Maximum		Long Term      	# of 
Parameter		Daily Value		30 Day Value		Avg. Value		Sam.
BOD			4.0 ppm		—			—			1
COD			78.5 ppm		—			—			1
TOC			23.9 ppm		—			—			1
TSS			15.0 ppm		—			—			1
Ammonia (as N)	< 0.10 ppm		—			—			1
Flow			0.0014 MGD		0.0011	MGD		0.0008 MGD		3
Temp. (winter)	Ambient		—			—			—
Temp. (summer)	Ambient		—			—			—
pH			6.5-8.5 S.U.		—			—			3

C.  Outfall 003
Maximum      		Maximum		Long Term      	# of 
Parameter		Daily Value		30 Day Value		Avg. Value		Sam.
BOD			< 3.33 ppm		—			—			1
COD			21.2 ppm		—			—			1
TOC			7.23 ppm		—			—			1
TSS			16.5 ppm		—			—			1
Ammonia (as N)	< 0.10 ppm		—			—			1
Flow			0.0022 MGD		0.0016	MGD		0.0016 MGD		3
Temp. (winter)	Ambient		—			—			—
Temp. (summer)	Ambient		—			—			—
pH			6.6-8.0 S.U.		—			—			3

VIII. 	SUMMARY OF WATER QUALITY LIMITATIONS, CATEGORICAL 	                 	LIMITATIONS, AND PROPOSED EFFLUENT PERMIT LIMITATIONS
		
A.  Outfall 001 	

Minimum Limitations

Water				Existing	Proposed
Quality		Categorical	Permit 		Permit	
Parameter	Limitations	Limitations	Limitations	Limitations	Basis
pH		6.0 - 9.0 S.U.	6.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	MSWQS

Maximum Limitations

Water				Existing	Proposed
Quality		Categorical	Permit		Permit	
Parameter	Limitations	Limitations	Limitations	Limitations	Basis	
Temperature	32.2 C (90 F)	—		32.2 C (90 F)	32.2 C (90 F)	MSWQS
pH		6.0 - 9.0 S.U.	9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	MSWQS
B.  Internal Outfall 002

Minimum Limitations

Water				Existing	Proposed
Quality		Categorical	Permit 		Permit	
Parameter	Limitations	Limitations	Limitations	Limitations	Basis
pH		6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	MSWQS
Maximum Limitations

Water				Existing	Proposed
Quality		Categorical	Permit		Permit	
Parameter	Limitations	Limitations	Limitations	Limitations	Basis	
pH		6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	MSWQS 

C.  Outfall 003

Minimum Limitations

Water				Existing	Proposed
Quality		Categorical	Permit 		Permit	
Parameter	Limitations	Limitations	Limitations	Limitations	Basis
pH		6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	MSWQS

Maximum Limitations

Water				Existing	Proposed
Quality		Categorical	Permit		Permit	
Parameter	Limitations	Limitations	Limitations	Limitations	Basis	
pH		6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	6.0 - 9.0 S.U.	MSWQS

	Outfall 001				

The temperature and pH limits are based on the “State of Mississippi Water Quality Criteria”.  Temperature and flow shall be monitored instantaneously once per month.  pH shall be monitored once per month with a grab sample of the effluent.  As per 40 CFR Part 429, Subpart K, Section 429.123, one special condition of the permit for this outfall shall be that there shall be no discharge of process wastewater.

	Internal Outfall 002

The pH limits are based on the “State of Mississippi Water Quality Criteria”.  pH shall be monitored twice per year with a grab sample of the effluent.  Flow shall be monitored twice per year instantaneously.  As per 40 CFR Part 429, Subpart I, Section 429.103, one special condition of the permit for this outfall shall be that there shall be no discharge of debris from the log spray pond.  Another special condition of the permit for this outfall shall be that there shall be no discharge of process wastewater.

	Outfall 003	

The pH limits are based on the “State of Mississippi Water Quality Criteria”.  pH shall be monitored twice per year with a grab sample of the effluent.  Flow shall be monitored twice per year instantaneously.  As per 40 CFR Part 429, Subpart I, Section 429.103, one special condition of the permit for this outfall shall be that there shall be no discharge of debris from the log spray pond.  Another special condition of the permit for this outfall shall be that there shall be no discharge of process wastewater.

	Other Conditions

The federal regulations require that storm water from certain types of facilities, such as lumber mills, be regulated either under an individual NPDES Permit or under a Baseline General Permit. The facility’s storm water is currently permitted under their NPDES permit, which the facility wishes to continue.  In order to ensure that this permit is consistent and as stringent as the current State of Mississippi Storm Water Baseline General Permit in regards to storm water, the facility will be required to document the results of all monthly site inspections on the Annual Comprehensive Site Inspection and SWPPP Evaluation Report Form and shall be kept with the SWPPP.  Other conditions of the permit relating to storm water shall be the following:

1.	If notified at any time by the Executive Director of the MDEQ that the SWPPP does not meet the minimum requirements, the permittee shall amend the SWPPP and certify in
writing to the Executive Director that the requested changes have been made.  Unless otherwise provided, the permittee shall have 30 days to make the requested changes.  

2.	The permittee shall amend the SWPPP whenever there is a change in design, construction, operation, or maintenance, which may increase the discharge of pollutants to State waters or the SWPPP proves to be ineffective in controlling storm water pollutants.  The permittee shall submit it to the MDEQ within 30 days of amendment.  

3.	The permittee shall implement the SWPPP and retain a copy of the SWPPP at the permitted site.  Failure to implement the SWPPP is a violation of permit requirements.  A copy of the SWPPP must be made available to the MDEQ inspectors for review at the time of an on-site inspection.

4.	The permittee shall perform routine visual site inspections as often as needed, but no less than once monthly.  All areas contributing to storm water discharges associated with industrial activity (including, but not limited to, ground storage piles, tanks, hoppers, silos, dust containment/collection systems, cleaning and maintenance areas) shall be visually inspected as often as needed, but no less than once monthly.  The inspection shall evaluate whether the SWPPP adequately minimizes pollutant loadings and is properly implemented in accordance with the terms of this permit or whether additional control measures are needed.  This includes observing storm water discharges for obvious industrial storm water pollution such as color, lack of clarity, floating solids, settled solids, suspended solids, foam, odor and oil sheens.  If feasible, the inspections shall be conducted during or after storm events. As part of the inspection, storm water shall be collected in a clean, clear jar and examined in a well lit area.  Should any of the objectionable characteristics described above be observed, the permittee shall investigate upstream from the sample location to identify the potential sources of pollution and implement corrective action. The results of all inspections and associated corrective actions shall be documented on the Annual Comprehensive Site Inspection and SWPPP Evaluation Report Form (Appendix A of the permit) and kept with the SWPPP.