PERMIT RATIONALE FOR REISSUANCE
KA3M Management LLC
Oktibbeha County
Starkville, Mississippi
Water NPDES No. MS0043524
February 2023

I.	CLASSIFICATION – NPDES Commercial

II.	DESCRIPTION OF WASTEWATER – Domestic 

III.	DESCRIPTION OF WASTEWATER TREATMENT – Domestic wastewater is collected and treated by means of a conventional lagoon.  No increase in treatment capacity is indicated at this time.  

IV.	RECEIVING WATERS – Unnamed Tributary of Tobacco Juice Creek.  The receiving waters are located within the Tombigbee River Basin and are classified as Fish and Wildlife.  At the point of discharge the receiving stream does not appear on the current State of Mississippi 303(d) list for evaluated or impaired waterbodies. The facility does appear on Total Maximum Daily Load (TMDL) on the Noxubee River for Nutrients and Organic Enrichment/Low DO.  Only one discharge to surface waters is described within the application with no increase proposed.  

V.	APPLICABLE GUIDELINES – – 11 Mississippi Admin Code pt. 6, Commercial Facility Guidelines (Technology), State of Mississippi Water Quality Criteria (MSWQS)

VI.	SUMMARY OF LIMITATIONS – 
Parameter					Value				Basis
Flow						0.00125			Design
Phase I BOD5					30 mg/l			Technology
Phase II BOD5					8 mg/l				WLA
Phase I Ammonia Nitrogen			2 mg/l				WLA
Phase II Ammonia Nitrogen 			1.37 mg/l			WLA
Phase I Dissolved Oxygen			Report, mg/l			Last Permit
Phase II Dissolved Oxygen			≥6.0 mg/l			WLA
TSS						90 mg/l 			Technology
E. Coli						126 Col./ 100 ml		WLA
Chlorine, Total Residual			0.1-1.0 mg/l			Last Permit
pH						6.0 – 9.0 SU			WLA
Phase I Total Nitrogen			Report, lbs. /day		Last Permit
Phase II Total Nitrogen			0.0013 lbs./ day		Last Permit
Phase I Total Phosphorus			Report, lbs./ day		Last Permit
Phase II Total Phosphorus			0.006 lbs./ day			Last Permit

VII.	CHANGES FROM PREVIOUS PERMIT – 

E. coli has replaced fecal coliform as the bacterial indicator for all freshwaters in Mississippi designated as Recreation, Fish and Wildlife Support, and/or Public Water supply. 

2023 Waste Load Allocation established new BOD and Ammonia limits, These permit limitations have been added to the proposed draft permit.

The permittee shall achieve compliance with the effluent limitations specified for discharge in accordance with the following schedule:
Upon issuance of this permit, the permittee shall achieve compliance with the effluent limitations specified for the parameters without a phase designation and for the parameters noted as Phase I; Phase II limitations shall not apply at this time.

Beginning upon completion and start-up of improvements needed to comply with Phase II limitations or three (3) years after the issuance of the permit, whichever comes first, the permittee shall achieve compliance with the effluent limitations specified for the parameters without a phase designation and for the parameters noted as Phase II; Phase I limitations shall no longer apply at this time. 

The permittee shall notify our office orally at least 24 hours prior to start-up and in writing no later than 48 hours after start-up.

The Permittee shall Submit engineering report: Due once within a year (365 days) after effective date. Said report shall outline the improvement activities needed to upgrade the wastewater treatment facility to comply with the site's Phase II limitations and shall include a proposed schedule for those improvement activities.

The Permittee shall Submit progress report: Due annually - every 1 year after effective date. Said report shall update the Permittee's progress in addressing needed upgrades to the wastewater treatment facility in order to meet the site's Phase II limitations. Said report should also include an updated schedule for completing these activities.