PERMIT RATIONALE FOR REISSUANCE
Jackson County Utility Authority, JCUA POTW 1C
Jackson County
Ocean Springs, Mississippi
Water NPDES No. MS0045446
September 17, 2019

Facility Information
	
	Facility Name:  Jackson County Utility Authority, JCUA POTW 1C
	Facility Address:  10801 Seaman Road, Ocean Springs, MS  39564    a, 
	Permit No.:  MS0045446
	SIC:  4952
	Permit Writer:  Sandeepa Gill
	EPD Branch:  Municipal and Private Facilities Branch

CLASSIFICATION

Municipal Major

DESCRIPTION OF WASTEWATER

Domestic/ Municipal Wastewater

DESCRIPTION OF WASTEWATER TREATMENT  

Wastewater is collected and treated biologically via aerated lagoons followed by constructed wetlands, chlorine disinfection, dechlorination, and post aeration.  See application for flow diagram.

RECEIVING WATERS

Costophia Bayou.  The receiving stream is located within the Coastal Stream Basin, and is classified as Fish and Wildlife. Costophia Bayou does not appear in the current State of Mississippi’s 303(d) list for impaired waterbodies. The discharge is listed in a pathogen TMDL. The facility disinfects the effluent in order to comply with State criteria for pathogens (fecal coliform), which complies with the TMDL. See application for discharge location map.

APPLICABLE GUIDELINES	

Mississippi Wastewater Regulations (11 MS admin code part 6), State of Mississippi Water Quality Criteria & “Wastewater Regulations for National Pollutant Discharge Elimination System Permits, Underground Injection Control Permits, State Permits, Water Quality Based Effluent Limitations , Water Quality Criteria (MSWQC), Water Quality Certification” applicable. Wasteload Allocation (WLA), Total Maximum Daily Load (TMDL). Jackson County Utility Authority Translator Study (JCUA TS)

SUMMARY OF LIMITATIONS –

Parameters				Value				Basis
Flow				7 MGD				Design
BOD5				10 mg/l				WLA
BOD5 (Percent Removal)		85% Minimum			Technology
TSS				30 mg/l				Technology 
TSS (Percent Removal)		85% Minimum			Technology
NH3-N				5.25 mg/l 			Toxicity
E. Coli				126 Col./100 ml	 		MSWQC
Dissolved Oxygen			6.0 mg/l (Minimum)		WLA
Total Residual Chlorine		0.011 mg/l (Avg.) 0.019 mg/l	MSWQC
pH					6.0 - 9.0 SU			MSWQC
Total Nitrogen			Report				*
Total Phosphorus			Report				*
Total Recoverable Copper		0.009 mg/l (Avg. monthly)	JCUA TS
	       Ceriodaphnia dubia				     100 % Minimum		Admin. code
	       Pimephale promelas		          100 % Minimum		Admin. code

See attached modeling data results attachment no. 1.

BOD5, NH3-N and DO limits are based on the Wasteload Allocation and modeled for oxygen depletion in the receiving stream, and the toxicity limit for NH3-N and Cl2 were determined for the parameters that are potentially acutely and chronically toxic. The more stringent of the modeled limit and the toxicity limit ( for NH3-N) is what is given in the Wasteload Allocation, to meet Water Quality Based Effluent Limitations ( WQBELs).

Facility requested for a name change in the reissuance of the permit. The facility name has been updated from West Jackson County POTW to JCUA POTW 1C. 

E. Coli will now be the bacterial indicator used for all freshwaters in MS designated as Recreation, Fish and Wildlife Support, and /or Public Water supply (replacing the use of fecal coliform). 
	
Permit application data for Hexavalent Chromium was taken and placed into the Chemical Specific Screening  Calculations. Hexavalent Chromium did not exceed the water quality standards. We also reviewed the DMR/Historic Data from the previous two years. Hexavalent Chromium did not exceed water quality standard for that time period and therefore was removed from the current draft permit.

Total Recoverable Copper limit was based on the Copper Translator Study that was submitted with the previous permit reissuance. Permit application data for Total recoverable copper was taken and placed into the Chemical Specific Screening Calculations. It did not exceed the water quality standards. We also reviewed the last two years of DMR/Historic Data from the previous two years. Total Recoverable copper did exceed water quality standard for that time period and therefore, the limit will remain in the current permit. 

Facility is required to submit a Copper Translator Study within one year after permit issuance. The permit may reopen based on the data from the study to determine copper limits.

All previously permitted parameters have remained the same in the reissuance.

WHOLE EFFLEUNT TOXICITY AND CHEMICAL SPECIFIC EVALUATION

WHOLE EFFLEUNT TOXICITY EVALUATION

In accordance to State Regulation WPC-1 VI.B.2b., a whole effluent toxicity evaluation was performed as part of the renewal application.  The applicant was to have tested in accordance with Short – Term Methods for estimating the Chronic toxicity of Effluents and Receiving Water to Freshwater organisms.  Short – term chronic WET test were performed on Ceriodaphnia dubia (invertebrate) and Pimephale promelas (vertebrate).  The facility submitted bioassays that were performed from 2013 to 2014. The submitted bioassay demonstrated a reasonable potential to violate Whole Effluent Toxicity during a period of four and half prior to the submittal of the application. Based upon the results of the WET testing, chronic bioassay requirements will be placed within the permit.

February 2018
Ceriodaphnia dubia					IC25	100%
Pimephales promelas					IC25	100%

July 2018
Ceriodaphnia dubia					IC25	100%
Pimephales promelas					IC25	100%

November 2018
Ceriodaphnia dubia					IC25	100%
Pimephales promelas					IC25	100%

March 2019
Ceriodaphnia dubia					IC25	100%
Pimephales promelas					IC25	100%

February 2019
Ceriodaphnia dubia					IC25	100%
Pimephales promelas					IC25	FAIL

Based on the results of the WET testing, inhibition concentrations were not greater that the predicted IWC of 100%.  Chronic bioassay requirements will be placed within the permit

				

Chemical Specific Analysis

Chemical specific analysis has been performed in accordance with State Regulations WPC-1 V1.B1.  Municipalities shall determine the toxic characteristics of their wastewater by analyzing for the toxic pollutant listed in Table III of appendix D of 40 CFR 122.  The results are tabulated in attachment No. 2.  The reported values are then analyzed and compared to water quality criteria (attachment No. 4) to determine any possible toxic effect to the receiving waters.  A synopsis of these calculations is listed in attachment No. 3.  A column by column description of the calculations in attachment No. 5 is hereby provided:

Column No. 1 – Maximum concentration.  The highest effluent reading of the parameter

Column No. 2 – The maximum concentration mixed with the receiving water IWC.  This     is calculated by the following equation:

{Maximum Concentration (Column 1) * IWC %} / 100

Column No. 3 – Acute allowable – Chemical Specific State Water Quality Criteria                                   
	Column No. 4 – Pass or Fail. If column 2 > column 3 water quality criteria is exceeded                              and failure occurs.

Column No. 5 – Long term average (LTA) of all tests.  The summation of the 12 samples divided by 12.

Column No. 6 – The long term average concentration mixed with the receiving water                                  IWC.  This is calculated by the following equation:

{LTA Concentration (Column 5) * IWC%} / 100

Column No. 7 – Chronic allowable – Chemical Specific State Water Quality Criteria                                   
Column No. 8 – Pass or Fail. If column 6 > column 7 water quality criteria is exceeded                                and failure occurs.

Column No. 9 – Human health determination.  Long term average (Column 5) is mixed                with the mean annual flow IWCMA .  This is calculated by the following                            equation:

{LTA Concentration (Column 5) * IWCMA %} / 100

Column No. 10 – Human health allowable – State Water Quality Criteria   Note: Organisms only column is used if receiving waters are not drinking water supply. 

	Column No. 11 – Pass or Fail.  If column 9 > column 10 water quality criteria is exceeded                        and failure occurs.

Chemical Specific Analysis for Metals and Results

Major municipalities shall determine the toxic characteristics of their wastewater by analyzing for toxic pollutants listed in Table II of Appendix D of 40 CFR 122.  Metal analysis shall be for total recoverable metals.  Municipalities shall submit twelve influent and effluent samples collected.  Chemical specific limits shall be placed in a permittee’s permit if any of the parameters evaluated in the toxic screening procedure indicate the reasonable potential for violation of the appropriate criteria (acute, chronic, and human health).
	
The chemical specific data results submitted did not indicate the reasonable potential for violation of the appropriate criteria in Table III of Appendix D of CFR 122. Total Recoverable Copper will remain in the permit due to DMR data. 

Chemical specific analysis for Volatile Organics Compounds, Acid-Extractable Compounds, and Base-Neutral Compounds and Results

The chemical specific data results submitted had no detects for Acid-Extractable Compounds.

For Volatile Organics, the facility had an average daily concentration of 0.00072 mg/l for Chloroform. According to the 2006 National Recommended: Water Quality Criteria, the Human Health criteria for Chloroform is 0.470 mg/l, Organisms Only. The average concentration, multiplied by the power of 10 (0.00072 mg/l), due to less than 12 samples, does not present a reasonable potential to violate Human Health Criteria.  

For Base-Neutral Compounds, the facility had an average daily concentration of 0.0018 mg/l for Bis (2-Ethylhexyl) Phthalate. The 2006 National Recommended: Water Quality Criteria states, the Human Health criteria for (Bis (2-Ethylhexyl) Phthalate) is 0.0022 mg/l, Organism Only. The average concentration, multiplied by the power of 10 (0.0018 mg/l), due to less than 12 samples, does present a reasonable potential to violate Human Health Criteria.  The following condition has been added to the permit:

“The Permittee shall submit results of 9 effluent samples of Bis-(2-ethylhexyl) Phtalate.
 Sampling of the wastewater treatment facility's influent and effluent shall be performed twice per month for a total of 9 samples. Sampling shall begin 10 days after the issuance date of permit and continuing for 9 consecutive months. Sample results shall be submitted by the 28th day of the month following completion of sampling.”

For Base-Neutral Compounds, the facility had an average daily concentration of 0.00087 mg/l for Fluoranthene. According to the 2006 National Recommended: Water Quality Criteria, the Human Health criteria for Fluoranthene is 0.140 mg/l, Organisms Only. The average concentration, multiplied by the power of 10 (0.00087 mg/l), due to less than 12 samples, does not present a reasonable potential to violate Human Health Criteria.  

For Base-Neutral Compounds, the facility had an average daily concentration of 0.00087 mg/l for Pyrene. According to the 2006 National Recommended: Water Quality Criteria, the Human Health criteria for Pyrene is 4.0 mg/l, Organisms Only. The average concentration, multiplied by the power of 10 (0.00087 mg/l), due to less than 12 samples, does not present a reasonable potential to violate Human Health Criteria.  

Attachments
Attachment 1	Waste Load Application 
Attachment 2	Tabulated Metals Results 
Attachment 3 	Synopsis of Metals Results 
Attachment 4 	MS State Water Quality Criteria 

Attachment 1

Attachment 2

Attachment3

Attachment 4