PERMIT RATIONALE FOR REISSUANCE
Kingsford Manufacturing Company
Alcorn County
Glen, Mississippi
Water NPDES No. MS0059790
April 2025

I.	FACILITY INFORMATION

Facility Name:  Kingsford Manufacturing Company
Facility Address:  2387 Highway 72 East 
Glen, MS 38846    
Permit No.:  MS0059790
SIC:  2861
Permit Writer:  Samar Patel
EPD Branch:  Chemical Branch

II.	NATURE OF BUSINESS

This industrial point source discharger manufacturers “char” from wood material.  No process water is generated.  The wastewater consists of storm-water runoff, non-process wash water, boiler blowdown, and steam condensate. The effluent is discharged to two settling basins in series.  After the removal of solids, water is routed to two retention ponds. The contents of the second pond are recycled for make-up process water as well as site irrigation. Due to excess volume in the ponds, evaporation losses, and irrigation system requirements, discharge from the ponds only occurs during periods of heavy rain.  The facility has discharged only 18 times in the previous three years.

III.	EFFLUENT AND RECEIVING STREAM FLOW DATA

Outfall 001—storm-water, non-process wash water, boiler blow down, and steam condensate only discharged during periods of heavy rain.  The outfall is discharged to an adjacent wetland, eventually reaching Coke Creek. Coke Creek eventually combines with Little Yellow Creek before flowing into the Tennessee-Tombigbee Waterway.  The facility is located in the Tennessee River Basin.

IV.	303(d) ISSUES

None

V.	TYPE OF WASTEWATER TREATMENT:

Water first runs through the settling basins for removal of settable solids and floatables. The release from the basins is collected in two retention ponds connected in series, before it discharged through the outfall 001. 

VI.	EPA APPLICABLE CATEGORICAL GUIDELINES

The facility is subject to 40 CFR 454 Subpart A (Char and Charcoal Briquets Subcategory).  Part 454.12(a) states that there shall be no discharge of process wastewater pollutants to navigable waters from char and charcoal briquet manufacturers.  

VII.	DATA FROM APPLICATION FORM 2F

Parameter	Maximum Daily Value	
Oil & Grease	<1.5 mg/L	
BOD	<5 mg/L	
COD	63.0 mg/L	
TSS	34 mg/L	
Total Kjeldahl Nitrogen (TKN)	1.54 mg/L	
Ammonia (as N)	<0.10 mg/L	
Total Phosphorus	<0.50 mg/L	
Total Nitrogen (as N)	1.54 mg/L	
pH	8.3 SU	

VIII. 	WATER QUALITY LIMITATIONS BASED ON WASTELOAD ALLOCATION 

	No WLA required due to low oxygen demand of wastewater. 

IX.	CATEGORICAL GUIDELINE LIMITATIONS CALCULATIONS

N/A

X.	TOXICITY SCREENING

N/A

XI.	PROPOSED FINAL LIMITATIONS 

1.	Average Permit Limitations

Outfall	Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis±	
MS0059790-001	BOD5	−	30 mg/L	30 mg/L	30 mg/L	WQBEL	
	Flow	−	−	Report Quarterly Average	Report Annual Average	EJ	
	Oil & Grease	−	−	10 mg/L	10 mg/L	EJ	
	pH	−	6.0—9.0 SU	6.0—9.0 SU	6.0—9.0 SU	WQS	
	TSS	−	−	30 mg/L	30 mg/L	EJ	

2.	Maximum Permit Limitations

Outfall	Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis±	
MS0059790-001	BOD5	−	45 mg/L	45 mg/L
Quarterly Maximum	45 mg/L Annual Maximum	WQBEL	
	Flow	−	−	Report Quarterly Maximum	Report Quarterly Maximum	EJ	
	Oil & Grease	−	−	15 mg/L Quarterly Maximum	15 mg/L Annual Maximum	EJ	
	pH	−	6.0—9.0 S.U.	6.0—9.0 S.U.	6.0—9.0 S.U.	WQS	
	TSS	−	−	60 mg/L Quarterly Maximum	60 mg/L Annual Maximum	EJ	
±Basis of Decision: EJ = Engineering Judgment, WQS = Water Quality Standards, WQBEL = Water Quality-Based Effluent Limit

BOD, oil & grease, pH, and TSS are evaluated by grab sampling at a quarterly frequency.  Flow is measured instantaneously using a continuous flow meter.

XII.	BPJ STATEMENT: 

The permittee discharges storm-water, non-process wash water, boiler blow down, and steam condensate from a series of settling basins and retention ponds to an adjacent wetland.  The water eventually combines with Coke Creek.  As a result of excess volume in the ponds, evaporation losses, and land application requirements, discharge events are infrequent and directly correlated with heavy rainfall.  Because the facility seldom discharges, does not release process wastewater, and has demonstrated compliance with the current parameters, it has been determined that the integrity of the receiving water body will be maintained with less frequent sampling and reporting requirements.

BOD5:  The average BOD5 effluent limit of 30 mg/L and maximum of 45 mg/L are water quality based limits equal to that of secondary treatment standards.  This will be monitored quarterly, utilize grab sampling, and be reported annually.

Flow: The effluent is directly impacted by rainfall.  The facility measures flow instantaneously.  Using engineering judgment, the permittee is required to report the annual average and maximum flow rate. 

Oil & Grease: Oil and grease limits will remain in the permit since they are a good indicator of proper management/housekeeping practices, which should prevent water from coming in contact with oily substances.  Based on the previous permit and engineering judgment, the maximum concentration of oil and grease discharged from the plant cannot exceed 15 mg/L.  The average concentration limit was previously set at 10 mg/L, and the maximum limit was derived by multiplying the average limit by 1.5.  The permittee’s highest reported concentration of oil and grease (since 2009) has been 2.9 mg/L.  This will be monitored quarterly, utilize grab sampling, and be reported on an annual basis.

pH:  The minimum and maximum pH effluent limits of 6.0 and 9.0 S.U. are water quality based limits as defined in 11 Miss. Admin. Code Pt. 6 Rule 2.2.D.  This will be monitored quarterly, utilize grab sampling, and be reported annually.

TSS:  Based on engineering judgment and the previous permit, the average concentration limitation for TSS is 30 mg/L and the maximum limit is 60 mg/L.  These limits are consistent with TSS limits established for secondary treatment systems.  This will be monitored quarterly, utilizing grab sampling, and be reported annually.

SWPPP Requirements:
The permittee will be required to continue implementing the on-site Storm Water Pollution Prevention Plan (SWPPP).  The permit has been written with the specific language regarding the requirements and contents of the SWPPP, which are consistent with the requirements of the Baseline Storm Water General Permit.

On-Site Irrigation Requirements:
In February 2011, Kingsford submitted guidelines for its recently installed irrigation system.  These were developed to assist in maintaining vegetative cover, preventing erosion, and mitigating siltation of the settling ponds. These guidelines have been carried forward from the existing permit and are listed below:

•	There shall be no runoff of effluent from land application of wastewater.  Land application shall not occur during rainfall or when saturated conditions exist.  Furthermore, there shall be no intentional irrigation of impervious surfaces (i.e. rock outcroppings or paved surfaces) other than what is incidental to the irrigation of larger vegetated areas. 
•	The permittee shall not use sanitary wastewater in the irrigation system.
•	Utilization of any cooling water soaps, detergents, or other additives in wastewater used for irrigation is prohibited. 
•	The discharge of oil or other petroleum products in wastewater through the irrigation system is prohibited. 
•	A daily log shall be maintained on-site that indicates the date of land application, the name of the person supervising the application, the time of the application, the duration of the application, the total gallons applied, the atmospheric conditions, and the soil conditions.