PERMIT RATIONALE FOR ISSUANCE
Water NPDES No. MSS062731
March 29, 2023

I.	FACILITY INFORMATION

First Chemical LLC dba Oleo-X		MSS062731
1001 Industrial Road					SIC:  2075, 2076, 2077, 2079
Pascagoula, Mississippi 				Permit Writer:  Tracy Tomkins
Jackson County						Water I Branch

II.	NATURE OF BUSINESS

Soybean, animal fats and other vegetable oil processing. Oleo-X developed a process to remove contaminants from renewable feedstocks. The product is decanted, water washed (with strong acids and bases to react with certain compounds), chelated, centrifuged, vacuum dried, and filtered with the assistance of a bleaching earth. The finished product will be a deep degummed and super-bleached renewable diesel plant feedstock.

III.	EFFLUENT AND RECEIVING STREAM FLOW DATA

Outfall 001: Stormwater runoff from the southeast tank farm in drainage area one. The drainage area is approximately 3.2 acres of impervious surface.

Outfall 002: Stormwater runoff from the west tank farm and non-contact stormwater from inactive process areas in drainage area two. The drainage area is approximately 15.5 acres of impervious surface.

Outfall 003: Stormwater runoff from the truck loading shed, train loading racks and non-contact stormwater from inactive process areas in drainage area three. The Drainage area is approximately 28.3 acres of impervious surface.

IV.	TOTAL MAXIMUM DAILY LOAD (TMDL) ISSUES

Bayou Casotte: A TMDL for Phenol was finalized and approved on May 24, 2002, for Bayou Casotte. According to the TMDL, the state standard for the phenol in salt water is an acute criterion of 300 mg/l and a chronic criterion of 58 mg/l. The type of discharge occurring at each outfall consists primarily of storm water runoff and is not commingled or treated with process wastewater prior to discharge into Bayou Casotte. There is no indication of the presence of phenol in the type of discharge activity taking place at these outfalls; thus, a water quality based effluent limitation for total phenols is not necessary. 
The Bayou Casotte TMDL for un-ionized ammonia and total toxics was approved and signed by EPA on March 29, 2007. Based on the TMDL, Mississippi Phosphate Corporation (MPC) is the only facility that causes and contributes un-ionized ammonia and toxicity to the Bayou.

V.	TYPE OF WASTEWATER TREATMENT

Best Management Practices

VI.	EPA APPLICABLE CATEGORICAL GUIDELINES

Not applicable.

VII.	DATA FROM APPLICATION FORM 2F

Parameter	Maximum Daily Value	
Outfall 001		
Oil and Grease	Non-detect	
BOD5	Non-detect	
COD	Non-detect	
TSS	10.3 mg/L	
Total Phosphorus	0.110 mg/L	
TKN	1.13 mg/L	
Total Nitrogen (as N)	1.13 mg/L	
pH	7.70 S.U.	
Outfall 002		
Oil and Grease	Non-detect	
BOD5	Non-detect	
COD	14 mg/L	
TSS	24 mg/L	
Total Phosphorus	1.2 mg/L	
TKN	1.27 mg/L	
Total Nitrogen (as N)	2.19 mg/L	
pH	7.32 S.U.	
Outfall 003		
Oil and Grease	Non-detect	
BOD5	Non-detect	
COD	18 mg/L	
TSS	36.5 mg/L	
Total Phosphorus	6.19 mg/L	
TKN	2.7 mg/L	
Total Nitrogen (as N)	4.25 mg/L	
pH	7.04 S.U.	

VIII. 	TOXICITY SCREENING

Not applicable.

IX.	PROPOSED FINAL LIMITATIONS 

1.	Average Permit Limitations

Outfall	Parameter	Proposed Permit Limit	Sampling Frequency	Sample Type	Basis1	
001	Flow 	Report (MGD)	Once/Month	Calculations	ENG	
	pH 	6.0 S.U. (min)	Once/Month	Grab	WQS	
	TSS	Report (mg/L)	Once/Month	Grab	ENG	
						
002	Flow	Report (MGD)	Once/Month	Calculations	ENG	
	pH 	6.0 S.U. (min)	Once/Month	Grab	WQS	
	TSS	Report (mg/L)	Once/Month	Grab	ENG	
						
003	Flow 	Report (MGD)	Once/Month	Calculations	ENG	
	pH 	6.0 S.U. (min)	Once/Month	Grab	WQS	
	TSS	Report (mg/L)	Once/Month	Grab	ENG	

2.	Maximum Permit Limitations

Outfall	Parameter	Proposed Permit Limit	Sampling Frequency	Sample Type	Basis1	
001	Flow 	Report (MGD)	Once/Month	Calculations	ENG	
	pH 	9.0 S.U. (max)	Once/Month	Grab	WQS	
	TSS	Report (mg/L)	Once/Month	Grab	ENG	
	PFAS Analytes2 	Report (ng/L)	Quarterly	Composite	ENG	
						
002	Flow 	Report (MGD)	Once/Month	Calculations	ENG	
	pH 	9.0 S.U. (max)	Once/Month	Grab	WQS	
	TSS	Report (mg/L)	Once/Month	Grab	ENG	
	PFAS Analytes2 	Report (ng/L)	Quarterly	Composite	ENG	
						
003	Flow 	Report (MGD)	Once/Month	Calculations	ENG	
	pH 	9.0 S.U. (max)	Once/Month	Grab	WQS	
	TSS	Report (mg/L)	Once/Month	Grab	ENG	
	PFAS Analytes2	Report (ng/L)	Quarterly	Composite	ENG	
1ENG= Engineering Judgement; WQS=Water Quality Standard

	2Report in nanograms per liter (ng/L), using EPA Draft Method 1633

XII.	SAMPLING

For pH and TSS, a grab sample during the first 30 minutes (or as soon thereafter as practicable). When a grab sample during the first 30 minutes is impracticable an explanation shall be included with the Discharge Monitoring Report.  

For PFAS analytes, a composite sample will be collected. The composite sample shall either be flow-weighted or time-weighted. Composite samples may be taken with a continuous sampler or as a combination of a minimum of 3 sample aliquots taken in each hour for the first 3 hours or entire discharge, with each aliquot being separated by a minimum period of 15 minutes. The composite sample that shall be analyzed using EPA Draft Method 1633 until there is an analytical method approved in 40 CFR Part 136 for PFAS in wastewater. Report in NetDMR the results in nanograms per liter (ng/L) for all PFAS analytes required to be tested as part of the method as shown in Attachment A. Any parameters that are removed from the method based on multi-lab validation of the method will not be required for reporting and Oleo-X may report "NODI=9" for any such parameters. Oleo-X shall submit the results of the Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) monitoring, including the lab reports, no later than 45 days following the end of each quarterly period.

The sampled discharge must result from a storm greater than 0.1 inches in magnitude and occurring at least 72 hours from the previously measurable (greater than 0.1-inch rainfall) storm. Sampling test procedures shall be in accordance with the methods set forth in 40 CFR Part 136.

Storm Water Pollution Prevention Plan (SWPPP) requirements for facilities subject to SARA Title III, Section 313 have been included due to the bulk storage of significant materials listed in the application. 

ATTACHMENT A

PFAS ANALYTE LIST