PERMIT RATIONALE FOR REISSUANCE
Riverbend Environmental Services LLC, Riverbend Environmental Services Landfill
Jefferson County
Fayette, Mississippi
Water NPDES No. MSS061514
June 29, 2018

I.	FACILITY INFORMATION

Facility Name:  	Riverbend Environmental Services LLC., Riverbend Environmental 	Services 
			Landfill

Facility Address:  	4451 Highway 61 North 
	Fayette, MS  39069    
Starkville, 
Permit No.:  		MSS049735

SIC Code:  		4953

Permit Writer:  	Rajeev Gupta

EPD Branch:  		Water II

II.	NATURE OF BUSINESS

This facility is a Municipal Solid Waste (MSW) landfill.  

III.	EFFLUENT AND RECEIVING STREAM FLOW DATA

Outfall No.	Discharge Type	Total Area Drained	Receiving Stream	Current Status	
001	Storm water	113 acres	Unnamed Tributary of Stampley Creek	Constructed	
002	Storm water	215 acres	Unnamed Tributary of Stampley Creek	Constructed	
003	Storm water	23.51 acres	Unnamed Tributary of Stampley Creek	Not Constructed	

The discharge from Outfalls 001 and 002 consist of storm water runoff associated with the developed portion of the municipal landfill.  Storm water which comes into contact with solid waste materials is contained and treated as leachate. The discharge from Outfalls 001 and 002 is passed through sedimentation basins prior to discharge.

Outfall 003 is a proposed outfall and will consist of storm water runoff associated with the developed portion of the municipal landfill. The discharge from Outfall 003 will be passed through a sedimentation basin prior to discharge.

The facility and receiving stream are located in the South Independent Streams River Basin.  The receiving stream, Stampley Creek, is classified as Fish and Wildlife and has a 7Q10 flowrate at the point of discharge of zero.  

IV.	TMDL AND 303(d) ISSUES

	There are no 303(d) issues for the site.
	
V.	TYPE OF WASTEWATER TREATMENT

A sedimentation pond is associated with each outfall.  Each constructed pond is capable of handling rain from a 25-year, 24-hour rain event.  Additional BMPs are used in accordance with the SWPPP.  

VI.	EPA APPLICABLE CATEGORICAL GUIDELINES

Not applicable.  

VII.	DATA FROM APPLICATION FORM 2F  

Outfall 001

Parameter	Maximum Value	
Chemical Oxygen Demand (COD)	768 mg/L	
Total Suspended Solids (TSS)	79 mg/L	
pH (minimum)	7.1 SU	
pH (maximum)	7.9 SU	
Arsenic	0.017 mg/L	
Mercury	ND (0.002 mg/L)	

	Outfall 002
	
Parameter	Maximum Value	
Chemical Oxygen Demand (COD)	783 mg/L	
Total Suspended Solids (TSS)	66 mg/L	
pH (minimum)	7.0 SU	
pH (maximum)	8.10 SU	
Arsenic	0.017 mg/L	
Mercury	ND (0.002 mg/L)	

NOTE: Outfall 003 has not yet been constructed.  

VIII. 	WATER QUALITY LIMITATIONS BASED ON WASTELOAD ALLOCATION 

	Not applicable.  

IX.	CATEGORICAL GUIDELINE LIMITATIONS CALCULATIONS

Not applicable.  

X.	TOXICITY SCREENING

Not applicable.  

XI.	PROPOSED FINAL LIMITATIONS 

1.	Average Permit Limitations

Outfall Nos.	Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis1	
001, 002,  and 003	COD	N/A	N/A	Report	Report	CPL	
	TSS	N/A	N/A	Report	Report	CPL	
	Turbidity 	N/A	---	---	Report	TJ	
	Total Rec. Arsenic	N/A	N/A	Report	---	TJ	
	Total Rec. Mercury	N/A	N/A	Report	---	TJ	
	pH (minimum)	N/A	6.0 SU	6.0. SU	6.0 SU	MSWQS	

2.	Maximum Permit Limitations

Outfall Nos.	Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis1	
001, 002, and 003	COD	N/A	N/A	Report	Report	CPL	
	TSS	N/A	N/A	90 mg/L	90 mg/L	CPL	
	Turbidity	N/A	***	---	Report  	TJ	
	Total Rec. Arsenic	N/A	**	0.024 mg/L	---	TJ	
	Total Rec. Mercury	N/A	**	0.000153 mg/L	---	TJ	
	pH (maximum)	N/A	9.0 SU  	9.0 SU	9.0 SU	MSWQS	

1 Basis: CPL = Current Permit Limitation; MSWQS = Mississippi Water Quality Standard; TJ = Technical Judgement.  

** Not Calculated.

***Turbidity outside the limits of a 750-foot mixing zone shall not exceed the background 
      turbidity at the time of discharge by more than 50 NTU. 
 
All parameters will be monitored once semiannually with a grab sample.  Results will be reported annually.  

Turbidity monitoring is being added to the permit as this is found in other permits for facilities with similar type discharges.
Total Recoverable Arsenic and Total Recoverable Mercury limits are being removed from the permit. A review of the background for the limits indicates the limits were erroneously given without any justification.  A proper Toxicity Screening Procedure was not performed.  Had the procedure been performed, even with a 10x safety factor, the facility would have likely passed the screening for Arsenic and Mercury using the Human Health Criteria for these parameters and the Mean Annual flow for Stampley Creek of 43.8 cfs. While the facility has been in compliance with the Arsenic and Mercury limits, no treatment system was built for the removal of Arsenic and Mercury.  As a result, these limits are being removed from the permit.

Since the permit being reissued is for the discharge of storm water from the facility, language is being added to the permit regarding the development and implementation of a Storm Water Pollution Prevention Plan.  This language is consistent with that found in the State of Mississippi Baseline General Storm Water Permit.

Flow is being removed from the second draft permit because there is no value in obtaining the discharge flow since there are no loading limits in the permit. 

“Representative Sampling” and “Sample Type” language have been updated to reflect state and federal stormwater discharges from stormwater ponds. These revisions can be found in the following Conditions:

Representative Sampling Condition T-16 on page 9 
Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored wastewater. [11 Miss. Admin. Code Pt. 6, R. 1.1.4.A(28)(e).] 

Sample Type Condition T-68 on page 28
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. [40 CFR 122.21g(7)(ii)] 

DMR Submittal Condition S-1 on pages 29-31
The Permittee shall submit analytical results on an annual Discharge Monitoring Report (DMR): Due annually by the 28th of January. If a measurable storm as described in Condition T-68 does not occur so that the required sample cannot be collected, "NODI=9" shall be reported on the DMR. [11 Miss. Admin. Code Pt. 6, R. 1.1.4.A(15)(c).]