PERMIT RATIONALE FOR REISSUANCE

March 20, 2019

I.	FACILITY INFORMATION

Facility Name:  Sanderson Farms Inc, Hazlehurst Processing Division
Facility Address:  28163 Highway 28 East 
 Hazlehurst, MS  39083
 Copiah County   
Laurel, 
Permit No.:  Water NPDES Permit No. MS0044725
Standard Industrial Classification (SIC) Code:  2015 (Poultry Slaughtering and Processing)
Permit Writer: Deanna Rush
		(601) 961-5019
		drush@mdeq.ms.gov. 

II.	NATURE OF BUSINESS

Live birds are brought from farms to the plant where they are slaughtered, cut-up/deboned, cleaned, chilled, packaged and shipped to customers. 125,000 birds per day are processed with an average weight of 8.5 lbs/bird for total production of 1,062,500 lbs/day live weight. 

Wastewater is generated when chickens are cleaned in the following operations: evisceration, chilling, cutting up and deboning, and packaging.  In addition to cleaning the birds, conveyor belts and equipment are cleaned and sanitized. There is a sanitation shift where processing equipment is cleaned and disinfected using various cleaning agents and disinfectants. In addition to these operations, sanitary waste and boiler blowdown is treated and discharged. 

EFFLUENT AND RECEIVING STREAM FLOW DATA

Wastewater is discharged from Sanderson Farms treatment works into Copiah Creek at latitude 31.890096 and longitude of -90.366463 which is approximately 1.2 miles from the plant. The maximum average 30-day flow into Copiah Creek used to calculate the draft permit limits is 1.5 million gallons per day (MGD) or 2.32 cfs.  The maximum average 30-day flow for the period reported in the application (starting September 2018 and ending August 2018) was 0.78 MGD and the maximum daily flow value reported in the application was 1.22 MGD.  

Copiah Creek has a 7Q10 flow (lowest 7-day average flow that occurs (on average) once every 10 years) of approximately 995,332 gallons per day (1.54 cfs) and a mean annual flow of 10.77 MGD (10.77 cfs). The instream waste concentration (IWC) is 60.12 % based on the permitted flow and 7Q10 flow of the creek. The discharge point into Copiah Creek is located in the Pearl River Basin.

III.	303(d) and TMDL ISSUES 

Copiah Creek is not listed on the 2018 Section 303 (d) List of Impaired Water Bodies.  

A TMDL for Total Nitrogen and Total Phosphorus for the Pearl River located in the Pearl River Basin was approved June 29, 2009.  Although this facility is not listed in the TMDL, the limitations recommended in MDEQ’s Waste Load Allocation (WLA) for phosphorus and nitrogen were based on limits recommended for other facilities of this type that were listed in this TMDL. The WLA recommended a total nitrogen limit of 1289 lb/day and a total phosphorus limit of 73 lb/day (annual average). 

A Phase One TMDL for Mercury for the Pearl River (HUC 03180003) located in the Pearl River Basin was approved June 28, 2004.  This TMDL required discharges that have flows greater than 0.05 MGD monitor mercury using clean techniques and accurate testing methods. Sanderson Farms sampled the wastewater using a 24-hour composite and clean techniques on January 10, 2019 using method 1631E with results of 0.5 ng/l total mercury. Since mercury analysis results were below the chronic water quality criteria of 12 ng/l and below the trigger level of 6 ng/l, MDEQ is not requiring a mercury monitoring program for this facility. 

A TMDL for Fecal Coliform for the Pearl River (Marion County) located in the Pearl River Basin was approved December 15, 2000.  The WLA recommends an e-coli limit of 126 col/100 ml which is adequate to meet the requirements of the Fecal Coliform TMDL report.  

IV.	TYPE OF WASTEWATER TREATMENT:

Physical Separation: Wastewater goes through screening to remove meat parts and feathers, and through dissolved air flotations to remove some of the solids and oils/grease. 

Biological Treatment: Two anaerobic lagoons, a facultative lagoon, and an aeration basin (activated sludge) are used to remove biological oxygen demand and to convert ammonia to nitrogen gas.  From the second anaerobic lagoon, wastewater either flows into the facultative lagoon, or bypasses the facultative lagoon and goes directly to the aeration basin.  Wastewater is sent directly from the anaerobic lagoon to the aeration basin when higher BOD is needed to control treatment in the activated sludge process. All wastewater goes to the aeration basin.  Biological oxygen demand loading is reduced in the aeration basin by the action of microorganisms. 

Nitrification and Denitrification: Dissolved oxygen, added to the aeration basin through aeration, is used by nitrifying bacteria to convert ammonia to nitrite and then to nitrate. The next step in removing nitrogen compounds is denitrification in which air to the aeration basin is turned off allowing the aeration basin to become anoxic to favor denitrifying bacteria. Chemicals are added, if needed, to maintain the proper operating pH.  

Clarification: Treated wastewater from the top of the aeration basin is routed to a clarifier in which solids are settled and supernatant is routed to the chlorination step.  Settled sludge from the bottom of the clarifier goes to the aeration basin to maintain microbial concentrations in the activated sludge process.  Some sludge is wasted from the bottom of the clarifier.

Chlorination and De-chlorination: Wastewater from the top of the clarifier is routed to the chlorine contact chamber where chlorine is added.  Sulfur dioxide gas is added and a water flows down post aeration steps to remove the residual chlorine before discharging effluent into Copiah Creek.  The discharge point into Copiah Creek is approximately 1.2 miles from the monitoring and sampling point. Effluent is sampled after sulfur dioxide gas is added, but before the water flows down the aeration steps.

Sludge Disposal: Wasted sludge goes to a sludge pond or to one of the anaerobic lagoons where it settles.  The decanted water from the top of the sludge pond goes back to the facultative lagoon for further treatment.  Sludge in the pond is removed every two to three years, and potentially has a beneficial use such as for land application. 

V.	EPA APPLICABLE CATEGORICAL GUIDELINES

This facility’s operations fall under the Meat and Poultry Products Effluent Guidelines (40 CFR Part 432) which covers slaughterhouses, further processors, independent renderers and poultry processors.  40 CFR 432 – Subpart K applies to this poultry operation. Poultry first processing means slaughtering of poultry and producing whole, halved, quarter or small meat cuts. The facility is an existing facility that slaughters more than 100 million pounds per year of live weight kill

Limitations in both 40 CFR 432.113 (BAT) and 40 CFR 432.117 apply to the discharge. 40 CFR 432.117 (BCT) limitations for BOD5, TSS, O&G (as HEM), and fecal coliform are the same as the corresponding limitation specified in 40 CFR 432.112.  The technology based limitations are shown below:  

40 CFR 432.117 (BCT) 
Parameter	Average (*lbs/day)	Maximum (*lbs/day)	
BOD5					16 mg/L (200)			26 mg/L (325)			
Fecal Coliform				N/A			400 MPN
O&G (as HEM)			8 mg/L (100)			14 mg/L (175)	
TSS					20 mg/L (250)			30 mg/L (375)		

40 CFR 432.113 (BAT)

Parameter	Average (*lbs/day)	Maximum (*lbs/day)
NH3-N					4 mg/L (50)			8 mg/L	(100)		
Total Nitrogen				103 mg/L (1,288.53)	147 mg/L (1,838.97)

*Pound per day (lb/day) limits are not specified in the categorical guidelines, but have been calculated and set as limits in the permit utilizing the following equation: loading = flow (MGD) x concentration (mg/l) x 8.34 conversion factor.  A maximum 30-day average flow of 1.5 MGD was used to calculate loading. 

VI.	DATA FROM APPLICATION FORM (Form 2C) 

Parameter	Maximum Daily Value	
BOD	5.4 mg/l	
COD	26 mg/l	
TSS	18 mg/l	
Ammonia (as N)	1.2 mg/l	
Flow	1.22 MGD (0.78 max. avg. 30 day)	
Temperature Winter	24 °C (75.2 °F)	
Temperature Summer	29 °C (84.2 °F) 	
pH	6.2 min., 7.9 max.	
Chlorine	0.01 mg/l 	
Fecal Coliform	20 col/100	
Nitrate-Nitrite	113 mg/l	
Nitrogen (Total Organic 	114 mg/l	
Oil and grease	7 mg/l	
Phosphorus 	14 mg/l	
Mercury	0.5 ng/l	

VIII. 	WATER QUALITY LIMITATIONS BASED ON WASTELOAD ALLOCATION 
	
	WLA recommendations 
Parameter	Average lb/day (mg/l)	
Flow (MGD)	1.5 MGD	
CBOD 5 (mg/l)	16 mg/l	
Total Ammonia Nitrogen 	4.0 mg/l	
Minimum Dissolved Oxygen 	6.0 mg/l 	
Total Suspended Solids 	20 mg/l 	
e. coli 	126 col/100 ml	
Chlorine, Total Residual (mg/l)	0.018 mg/l	
Total Nitrogen (lb/day)	1289 lbs/day 	
Total Phosphorus (lb/day)	73 lb/day 	
pH	6 - 9 s.u.	

VII.	TOXICITY SCREENING

Toxicity screening is not required. 

XI.	PROPOSED FINAL LIMITATIONS 

1.	Average Permit Limitations:  lb/day (mg/l)
Outfall 001
Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
CBOD5	N/A	200 (16)	No limit	No limit	Limited by BOD5	
BOD5	200 (16)	N/A	250 (20)	250 (20)	Categorical	
TSS	250 (20) 	250 (20)	250 (20)	250 (20) 	Categorical	
D.O. (minimum)	N/A	6.0	6.0	6.0 	MSWQS	
NH3-N (winter)	4.0, 8.0 	4.0 mg/l	44 (3.5)	44 (3.5)	PPL (Anti-backsliding)	
NH3-N(summer)	4.0, 8.0 	4.0 mg/l	31 (2.5)	31 (2.5)	PPL (Anti-backsliding)	
Fecal Coliform (col/100 ml)	N/A	N.A. 	200  	No limit	E.Coli limit is protective	
e.coli (col/100ml)	N/A	126	No Limit 	126 	MSWQS	
Chlorine, total residual 	N.A. 	0.255 (0.018)	0.23 (0.018)	0.23 (0.018)	WLA	
Oil and Grease	100 (8)	N/A	100 (8)	100 (8)	Categorical 	
pH (minimum)	N/A	6.0 S.U.  	6.0 S.U. 	6.0 S.U.	MSWQS	
Total Phosphorus	N/A	73 l/day	73 lb/day	73 lb/day	TMDL	
Total Nitrogen	1,289 (103)	1,289 (103)	1,289 (103) 	1,289 (103) 	TMDL & Categorical 	
Nitrate + Nitrite Nitrogen 	N/A	N/A	Report (mg/l)	Report (mg/l)	1/	
Total Kjeldahl Nitrogen	N/A	N/A	Report (mg/l)	Report (mg/l)	1/	

2.	Maximum Permit Limitations

Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
CBOD5	N/A	300 (24)	N/A	N/A	Limited by BOD5	
BOD 5	325 (26)	N/A	325 (26)	325 (26)	Categorical	
TSS	375 (30)	375 (30)	375 (300	375(30)	Categorical 	
NH3 - N (winter)	100 (8)	75 (6)	66 (5.3)	66 (5.3)	PPL (Anti-backsliding)	
NH3 - N (summer)	100 (8)	75(6)	48(3.8)	48 (3.8)	PPL (Anti-backsliding)	
Fecal Coliform	400 	N.A. 	400	400	Categorical	
e.coli (col/100 ml)	N.A.	410	N.A.	410	MSWQS	
Total Residual Chlorine	N.A.	0.338 (0.027)	0.34 (0.027)	0.34 (0.027)	WLA	
Oil & Grease	175(14)	N.A.	175 (14)	175(14)	Categorical	
pH	N/A	9.0 S.U.	9.0 S.U.	9.0 S.U.	MSWQS	
Total Phosphorus	N/A	WLA * 1.5	109	109	TMDL	
Total Nitrogen	1,838.97 (147)	No Max. 	1,839.0	1839.0	Categorical 	
Nitrate + Nitrite Nitrogen	N/A	N/A	Report mg/l	Report mg/l	1/	
Total Kjeldahl Nitrogen	N/A	N/A	Report mg/l	Report mg/l	1/	

       1/ There is no test method to monitor total nitrogen.  Total Nitrogen is the sum of nitrate/nitrite and total kjeldahl nitrogen.  Nitrate/nitrite nitrogen and total kjeldahl nitrogen must be monitored and the results added together to obtain a value for total nitrogen. 

       PPL = previous permit limits.

Since Escherichia coli (E.Coli) bacteria replaced Fecal Coliform bacteria as the bacterial indicator for all freshwater in Mississippi, E. Coli limits have been added to the permit.  Since Fecal Coliform limits are categorical, they will remain in the permit.

Biochemical Oxygen Demand (5-Day), Total Suspended Solids, Total Phosphorus, Total Ammonia (as N), Total Kjeldahl Nitrogen, and Nitrate/Nitrite Nitrogen shall be monitored once per week using a 24-hour composite sample. Oil and Grease, Fecal Coliform, E - Coli, pH, Total Residual Chlorine, and Dissolved Oxygen shall be monitored once per week with a grab sample of the effluent.  Flow shall be measured once per week instantaneously. 

XII.	PUBLIC PARTICIPATION  

The proposed permit is being made available to the public for a 30-day public comment period starting March 27, 2019 and ending April 26, 2019. The Environmental Permits Division will make recommendations to the permit board after any public notice comments are addressed.