RATIONALE FOR PRETREATMENT PERMIT ISSUANCE

July 3, 2018

Hermes Hialeah Warehouse LLC
Lauderdale
Meridian, MS
Permit No. MSP092420, Agency Interest No. 12198
SIC: 1799
 
Permit Writer: Deanna Rush
Water I 
Contact phone number: (601) 961-5019
e-mail: drush@mdeq.ms.gov. 

I.	FACILITY INFORMATION

A.	Nature of Business:  This is an industrial remediation facility located at a former above ground tank farm.  The applicant proposes to remove groundwater contaminants associated with gasoline and diesel and discharge the remediated wastewater to the City of Meridian’s POTW.   

B.	Process Wastewater Description: Groundwater contaminated with diesel and gasoline will be pumped from recovery wells, to a remediation system that will extract diesel and gasoline contaminated ground water, flow through a surge tank, oil/water separator and air stripper, then to the POTW.  

C.	Proposed Flowrate: 72,000 gallons per day (0.072 MGD) continuously throughout the year. There are no batch discharges. 

D.	Applicable Federal Guidelines: None Applicable  

II.	RECEIVING POTW INFORMATION

A.	POTW and Permit Number: City of Meridian (MS0020117), AI 13261

B.	POTW Treatment Type: For Outfall 101: second stage activated sludge followed by chlorination disinfection.  For Outfall 201: sequencing batch reactor followed by UV disinfection and post-aeration. 

C.	POTW Design Flowrate: 20.1 cfs (13 MGD) 

D.	POTW Receiving Stream: Sowashee Creek

E.	POTW Receiving Stream 7Q10 (Q7/10): 0.5 cfs (0.323MGD)

III.	APPLICATION DATA	

The data presented in the application was based on a prior application submitted to MDEQ by Earth Consulting Group for discharge from a remediation treatment system at this location.  A condition has been added to the draft permit for the applicant to submit a complete pretreatment permit application (Form 2P) containing results of data collected from the facility’s wastewater discharge after permit issuance and within 180 days of commencing discharge. Based upon results of the sampling, the permit may be reopened to address additional limits or requirements as deemed necessary. 

Table 1
Parameter	Concentration	
BOD	44 mg/l	
COD	201 mg/l	
TSS	15 mg/l	
Flow	0.072 MGD	
Ammonia (as N)	< 0.2 mg/l 	
Temperature (winter)	15 °C (59 °F)	
Temperature (summer)	27 °C (80.6 °F)	
pH	6.5-8.5	
Oil and Grease	9.1 mg/l	
Toluene	0.021 mg/l  	
Benzene 	0.010 mg/l 	
Ethyl Benzene	0.015 mg/l	
Naphthalene	0.010 mg/l	

IV.	LIMITATIONS AND BASIS

The permit limitations proposed for the draft permit are based on review of MDEQ’s Underground Storage Tank (UST) Groundwater Remediation General Permit since the treatment system is removing gasoline and diesel contaminants from groundwater wells at former refined petroleum bulk storage facility.  Even though the contamination was caused by above ground tanks and not UST, the contaminants for gasoline should be the same. In addition, EPA’s Model NPDES Permit for Discharges Resulting from the Cleanup of Gasoline Released from Underground Storage Tanks was reviewed in establishing limitations.  Since benzene, BTEX (benzene, toluene, ethyl benzene and xylene) and Naphthalene are known constituents of gasoline, limitations for these parameters have been added to the draft permit.  Oil and grease limitations are based on a 1974 EPA memorandum: Oil and Grease Limitations for Petroleum Marketing Terminals. The following limitations are proposed in the draft permit: 

Table 2
Parameter	Monthly 
Average Limitation
 	Daily 
Maximum 
Limitation
	Monitoring 
Frequency	Sample Type	
Benzene	0.5 mg/l 	0.75 mg/l	Twice/Month	Grab Sample	
BTEX	5.0 mg/l	7.5 mg/l	Twice/Month	Grab Sample	
Naphthalene	None	0.75 mg/l	Twice/Month	Grab Sample	
Oil and Grease 	10 mg/l 	15 mg/l 	Twice/Month	Grab Sample	
Flow	Report 	0.072 MGD	Daily	Totalizer	
pH	6.0 SU Min.	9.0 SU Max.	Twice/Month 	Grab Sample	

The POTW permit does not have limitations for Benzene, BTEX, Naphthalene, or oil and grease.