PERMIT RATIONALE FOR ISSUANCE
Aluminum Dynamics, LLC
Lowndes County
Columbus, Mississippi
Water NPDES No. MS0062804
March 26, 2024

I.	FACILITY INFORMATION

Facility Name:  Aluminum Dynamics, LLC
Facility Address:  3413 Charleigh D. Ford Jr. Drive 
Columbus, MS  39701    
Fort Wayne , 
Permit No.:  MS0062804
SIC:  3353
Permit Writer:  Rajeev Gupta
EPD Branch:  Water II Branch

II.	NATURE OF BUSINESS

	The facility will operate as a flat rolled aluminum production mill.

III.	EFFLUENT AND RECEIVING STREAM FLOW DATA

	The facility will have two outfalls which they have applied to be permitted for.  Outfall 
	001 will be an internal outfall for all categorically discharged wastewater.  The average 	
	daily flow from this outfall will be 0.340 mgd.   Outfall 002 will consist of discharge 
	from the facility’s retention/sedimentation pond.  Discharge from this outfall will consist
 	of  stormwater (2.225 mgd), process wastewater (0.340 mgd), non-process wastewater 
	(cooling tower blowdown and backwash) (0.667 mgd), and reverse osmosis reject 
	wastewater (0.288 mgd).  The average daily flow from this outfall will be 3.520 mgd.  
	Outfall 002 will discharge to an unnamed tributary of Gilmer Creek.  The 7Q10 of the 
	unnamed tributary is 0 mgd.  

IV.	303(d) and TMDL ISSUES

	Gilmer Creek does not appear on the 2022 State of Mississippi 303(d) List of 
	Impaired waterbodies.  This permit complies with the following applicable TMDL:

•	Total Maximum Daily Load Tombigbee River Basin Designated Streams in HUCs 03160105 (Luxapalllila Creek) and 03160106 (Middle Tombigbee River) for Impairment Due to Sediment (Final Report January 2007; ID: 807012604)

V.	TYPE OF WASTEWATER TREATMENT

The Cooling Tower Blowdown and Filter Backwash will undergo chemical precipitation, flocculation and settling in a clarifier prior to mixing with the process wastewater.  Process wastewater from the passivation process will be treated separately due to its high organic phosphonic acid content. An oxidation, coagulation, and settling process will be utilized for destruction of organic phosphonic acid and the removal of solids.  The raw water source for the facility will be from the city.  The raw water will undergo reverse osmosis prior to its use.  The primary process wastewater treatment system will consist of equalization, followed by oily water removal, dissolved air flotation, neutralization, clarification, moving bed biological treatment (MBBR), followed by dissolved air flotation and sludge treatment.  The primary process wastewater and cooling tower blowdown and filter backwash will be combined prior to routing to the detention/sedimentation pond.  The reverse osmosis reject water will be directly routed the pond. The passivation water will be routed to the primary process wastewater treatment system after undergoing separate treatment.  All wastewater will be routed to the sedimentation pond where further settling will occur.  The pond volume is 11.2 million gallons.

VI.	EPA APPLICABLE CATEGORICAL GUIDELINES

		40 CFR Part 465 Coil Coating Point Source Category; Subpart C-Aluminum Basis 	
		Material Subcategory; 40 CFR 465.33 (NSPS).  40 CFR Part 467 Aluminum Forming 
		Point Source Category; Subpart A – Rolling with Neat Oils Subcategory; 40 CFR 467.14 
(NSPS).  40 CFR Part 467 Aluminum Forming Point Source Category; Subpart B – Rolling with Emulsions Subcategory; 40 CFR 467.24 (NSPS).      

VII.	DATA FROM APPLICATION FORM 2D

		A.  Outfall 001

Parameter	Average Daily Value	
BOD5	0.00133 mg/L	
COD	129 mg/L	
TOC	0.00267 mg/L	
Total Suspended Solids	64 mg/L	
Ammonia (as N)	13 mg/L	
Flow 	0.340 mgd	
Temperature	110.75 deg F	
pH (min)	6.0 s.u.	
pH (max)	9.0 s.u.	
Oil and Grease	26 mg/L	
Total Zinc	0.018 mg/L	
Total Aluminum	0.00003 mg/L	
Total Iron	2.5 mg/L	
Total Chromium	Believed Absent	
Total Cyanide	Believed Absent	

	B. Outfall 002

Parameter	Average Daily Value	
BOD5	7.27 mg/L	
COD	0.83 mg/L	
TOC	8.22 mg/L	
Total Suspended Solids	60.68 mg/L	
Ammonia (as N)	3.7 mg/L	
Flow 	3.52 mgd	
Temperature	84 deg F	
pH (min)	6.0 s.u.	
pH (max)	9.0 s.u.	
Oil and Grease	0.007 mg/L	
Total Zinc	0.01 mg/L	
Total Aluminum	0.006 mg/L	
Total Iron	0.371 mg/L	
Total Chromium	Believed Absent	
Total Cyanide	Believed Absent	

VIII. 	WATER QUALITY LIMITATIONS BASED ON WASTELOAD ALLOCATION 

	See Attachment

IX.	CATEGORICAL GUIDELINE LIMITATIONS CALCULATIONS

	See Attachment 

X.	TOXICITY SCREENING

Not Applicable (Please see below)

XI.	PROPOSED FINAL LIMITATIONS 

	A. Outfall 001 (Internal Outfall)

    Average Permit Limitations

Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
pH	7.5-10.0 s.u.	---	---	7.5-10.0 s.u.	Categorical	
Oil and Grease	414.2 lbs/day	---	---	414.2  lbs/day	Categorical	
Aluminum, TR	110.3 lbs/day	---	---	110.3 lbs/day	Categorical	
Zinc, TR	17.5 lbs/day	---	---	17.5 lbs/day	Categorical	
Cyanide, TR*	3.4 lbs/day	---	---	3.40 lbs/day	Categorical	
Chromium, TR	6.26 lbs/day	---	---	6.26 lbs/day	Categorical	
TSS	497.1 lbs/day	---	---	497.1 lbs/day	Categorical	

Maximum Permit Limitations

Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
pH	7.5-10.0 s.u.	---	---	7.5-10.0 s.u.	Categorical	
Oil and Grease	414.2 lbs/day	---	---	414.2 lbs/day	Categorical	
Aluminum, TR	249.9 lbs/day	---	---	249.9 lbs/day	Categorical	
Zinc, TR	42.3 lbs/day	---	---	42.3 lbs/day	Categorical	
Cyanide, TR*	8.35 lbs/day	---	---	8.35 lbs/day	Categorical	
Chromium, TR	15.4 lbs/day	---	---	15.4 lbs/day	Categorical	
TSS	621.4 lbs/day	---	---	621.4 lbs/day	Categorical	
*Periodic analyses for cyanide are not required when both of the following conditions are met: 
(1) The first wastewater sample taken in each calendar year has been analyzed and found to contain less than 0.07 mg/l cyanide 
(2) The owner or operator of the coil coating facility and aluminum forming facility certifies in writing to the POTW authority or permit issuing authority that cyanide is not used in the coil coating process and aluminum forming process.  (Ref: 40 CFR 465.03 and 467.03)
Flow shall be measured continuously with a continuous recorder.  All other parameters shall be monitored twice per month.  pH, Oil and Grease, and Cyanide shall be monitored with a grab sample while all other parameters shall be monitored with a 24-hour composite sample of the effluent.  

Two special conditions of the permit shall be as follow:

1)  Within fifteen days after the commencement of discharge, the permittee shall notify MDEQ.
2)	 Within one year after the commencement of discharge, the permittee shall submit a complete 
    	 Form 2C Application for this outfall to MDEQ.  

B.  Outfall 002 

Average Permit Limitations

Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
pH	---	6.0-9.0 s.u.	---	6.0-9.0 s.u.	MSWQS	
Dissolved Oxygen (min)	---	6.0 mg/L	---	6.0 mg/L	MSWQS	
Oil and Grease	---	---	---	10 mg/L	TJ	
Aluminum, TR	---	---	---	Report	TJ	
Zinc, TR	---	0.065 mg/L	---	Report	TJ	
Cyanide, TR**	---	0.0052 mg/L	---	Report	TJ	
Chromium, TR	---	0.042 mg/L	---	Report	TJ	
Total Suspended Solids	---	---	---	30 mg/L	TJ	
Ammonia (as N)	---	1.37 mg/L	---	1.37 mg/L	MSWQS	
Total Nitrogen	---	---	---	Report	TJ	
Total Phosphorus	---	---	---	Report	TJ	

Maximum Permit Limitations

Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
pH	---	6.0-9.0 s.u.	---	6.0-9.0 s.u.	MSWQS	
Oil and Grease	---	---	---	15 mg/L	TJ	
Aluminum, TR	---	---	---	Report	TJ	
Zinc, TR	---	0.065 mg/L	---	Report	TJ	
Cyanide, TR**	---	0.022 mg/L	---	Report	TJ	
Chromium, TR	---	0.323 mg/L	---	Report	TJ	
Total Suspended Solids	---	---	---	45 mg/L	TJ	
Ammonia (as N)	---	---	---	2.06 mg/L	TJ	
Total Nitrogen	---	---	---	Report	TJ	
Total Phosphorus	---	---	---	Report	TJ	
MSWQS = State of Mississippi Water Quality Criteria; TJ = Technical Judgement

Flow shall be measured continuously with a continuous recorder.  All other parameters shall be monitored twice per month with a grab sample of the effluent.  One special condition of the permit shall be as follow:

	Within one year after the commencement of discharge from Outfall 001, the permittee shall 
	submit 	a complete Form 2C Application for this outfall to MDEQ.  Twelve analyses shall be 
	provided for each metal required to be tested for as per the Form 2C Application 	instructions. Twenty four analyses shall be provided for Total Recoverable Aluminum.

EPA released updated recommendations for aluminum water quality criteria in December 2018. MDEQ does not currently have water quality criteria for aluminum within MS’s Water Quality Standards (WQS). In the absence of state water quality criteria, it is common practice for MDEQ to use 0.140 mg/L and 0.250 mg/L as the chronic and acute values for aluminum reasonable potential screening. 
 
Research has shown that aluminum toxicity to aquatic life is strongly affected by the water chemistry parameters of pH, dissolved organic carbon (DOC), and hardness. EPA’s previous aluminum criteria recommendations were fixed numeric values. However, the 2018 criteria recommendations provide the information needed to calculate the appropriate value for “total recoverable aluminum” based on the water chemistry present within the waterbody.   As a result, within one year after the commencement of discharge from Outfall 001, the permittee shall sample for Total Recoverable Aluminum, pH, Dissolved Organic Carbon, and Hardness once per discharge event with a grab sample of the effluent until 24 samples are received. All monitoring results shall be submitted to the Mississippi Environmental Quality Permit Board no later than the 28th day of the month following the completed collection of the 24 samples. Sampling may be performed concurrently with the sampling requirements found in Condition S-2 found on page 21 of the permit.

Toxicity Screening was not performed.  The Data provided in the application for all pollutants was based on engineering judgement.  The permit may be reopened to establish limits for toxics once the application and Aluminum data are submitted within one year after the commencement of discharge from Outfall 001.  

Ammonia limits are being proposed as the facility will be adding Ammonia to their wastewater so that the wastewater can be treated biologically in their MBBR treatment system.  The facility estimated in their application that they believe the discharge from Outfall 002 will contain 3.7 mg/L of Ammonia (as N).  Based on further evaluation, the facility now believes that they will be able to comply with the proposed limits.  

CBOD monitoring is not being proposed due to the low level of BOD5 expected in the effluent.

**  Monitoring for Total Recoverable Cyanide shall not be required for Outfall 002 once condition L-1 found on page 20 of the permit has been satisfied.  

An Anti-degradation Review has been completed for this new source. 

ATTACHMENT A

CATEGORICAL GUIDELINE LIMITATIONS CALCULATIONS

   40 CFR Part 465 – Coal Coating Point Source Category; Subpart C – Aluminum Basis 
	Material Subcategory    

The average daily production rate stated in the permit application will be 1,002,005 m2/day 

40 CFR 465.33 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	mg/m2of area processed	
Chromium 	0.072	0.18	
Zinc	0.20	0.49	
Cyanide 	0.038	0.095	
Aluminum	0.59	1.44	
Oil and Grease	4.75	4.75	
Suspended Solids	5.70	7.13	
pH	7.5-10.0 s.u.	7.5-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.072 mg/m2)*(1,002,005 m2/day) * (0.000002204 lbs/mg) = 0.159 lb/day

Daily Maximum Limits: 

Cr:	(0.18 mg/m2)*(1,002,005 m2/day) * (0.000002204 lbs/mg)  = 	0.398 lb/day

40 CFR Part 467 – Aluminum Forming Point Source Category; Subpart A – Rolling with Neat Oils Subcategory    

CORE WITHOUT AN ANNEALING FURNACE SCRUBBER
    
The average daily production rate stated in the permit application will be 1855 tons/day 

40 CFR 467.14 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum rolled with neat oils
	
Chromium 	0.0083	0.021	
Zinc	0.023	0.057	
Cyanide 	0.0044	0.011	
Aluminum	0.15	0.338	
Oil and Grease	0.553	0.553	
Suspended Solids	0.664	0.83	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.0083 lb/1000000 off-lbs*(1855 tons/day) * (2000 lbs/ton)  = 0.03079 lb/day

Daily Maximum Limits:

Cr:	(0.021 lb/1000000 off-lbs*(1855 tons/day) * (2000 lbs/ton)= 	0.07791 lb/day

SOLUTION HEAT TREATMENT CONTACT COOLING WATER

 The average daily production rate stated in the permit application will be 630 tons/day 

40 CFR 467.14 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum quenched	
Chromium 	0.31	0.76	
Zinc	0.86	2.08	
Cyanide 	0.17	0.41	
Aluminum	5.52	12.45	
Oil and Grease	20.37	20.37	
Suspended Solids	24.45	30.56	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.31 lb/1,000,000 off-lbs)*(630 tons/day) * (2000 lbs/ton)  = 0.391 lb/day

Daily Maximum Limits:

Cr:	(0.76 lb/1,000,000 off-lbs)*(630 tons/day) * (2000 lbs/ton)  = 0.9576 lb/day

CLEANING OR ETCHING BATH

The average daily production rate stated in the permit application will be 630 tons/day 

 40 CFR 467.14 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum cleaned or etched	
Chromium 	0.027	0.066	
Zinc	0.075	0.183	
Cyanide 	0.015	0.036	
Aluminum	0.485	1.094	
Oil and Grease	1.79	1.79	
Suspended Solids	2.15	2.69	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.027 lb/1,000,000 off-lbs)*(630 tons/day) * (2000 lbs/ton)  = 0.034 lb/day

Daily Maximum Limits:

Cr:	(0.066 lb/1,000,000 off-lbs)*(630 tons/day) * (2000 lbs/ton)  = 0.083 lb/day

CLEANING OR ETCHING RINSE

The average daily production rate stated in the permit application will be 630 tons/day 

 40 CFR 467.14 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum cleaned or etched	
Chromium 	0.21	0.52	
Zinc	0.59	1.42	
Cyanide 	0.11	0.28	
Aluminum	3.70	8.50	
Oil and Grease	13.91	13.91	
Suspended Solids	16.69	20.87	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.21 lb/1,000,000 off-lbs)*(630 tons/day) * (2000 lbs/ton)  = 0.26 lb/day 

Daily Maximum Limits:

Cr:	(0.52 lb/1,000,000 off-lbs)*(630 tons/day) * (2000 lbs/ton)  = 0.655 lb/day

CLEANING OR ETCHING SCRUBBER LIQUOR

The average daily production rate stated in the permit application will be 630 tons/day 

 40 CFR 467.14 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum cleaned or etched	
Chromium 	0.29	0.715	
Zinc	0.81	1.97	
Cyanide 	0.16	0.387	
Aluminum	5.24	11.81	
Oil and Grease	19.33	19.33	
Suspended Solids	23.2	29.0	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.29 lb/1,000,000 off-lbs)*(630 tons/day) * (2000 lbs/ton)  = 0.365 lb/day 

Daily Maximum Limits:

Cr:	(0.715 lb/1,000,000 off-lbs)*(630 tons/day) * (2000 lbs/ton)  = 0.9009 lb/day 

40 CFR Part 467 – Aluminum Forming Point Source Category; Subpart B – Rolling with Emulsions Subcategory    

CORE

The average daily production rate stated in the permit application will be 2137 tons/day 

 40 CFR 467.24 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum rolled with emulsions	
Chromium 	0.020	0.048	
Zinc	0.055	0.133	
Cyanide 	0.011	0.026	
Aluminum	0.35	0.80	
Oil and Grease	1.30	1.30	
Suspended Solids	1.56	1.95	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.020 lb/1,000,000 off-lbs)*(2137 tons/day) * (2000 lbs/ton)  = 0.0855 lb/day 

Daily Maximum Limits:

Cr:	(0.048 lb/1,000,000 off-lbs)*(2137 tons/day) * (2000 lbs/ton)  = 0.205 lb/day 

DIRECT CHILL CASTING CONTACT COOLING WATER

The average daily production rate stated in the permit application will be 2375 tons/day 

 40 CFR 467.24 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum cast by semi-continuous methods	
Chromium 	0.20	0.49	
Zinc	0.56	1.36	
Cyanide 	0.11	0.27	
Aluminum	3.60	8.12	
Oil and Grease	13.29	13.29	
Suspended Solids	15.95	19.94	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.20 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 0.95 lb/day 

Daily Maximum Limits:

Cr:	(0.49 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 2.3275 lb/day 

SOLUTION HEAT TREATMENT CONTACT COOLING WATER

The average daily production rate stated in the permit application will be 2375 tons/day 

 40 CFR 467.24 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum quenched	
Chromium 	0.31	0.76	
Zinc	0.86	2.08	
Cyanide 	0.17	0.41	
Aluminum	5.52	12.45	
Oil and Grease	20.37	20.37	
Suspended Solids	24.45	30.56	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	(0.31 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 1.4725 lb/day 

Daily Maximum Limits:

Cr:	(0.76 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 3.61 lb/day 

CLEANING OR ETCHING BATH

The average daily production rate stated in the permit application will be 2375 tons/day 

 40 CFR 467.24 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum cleaned or etched	
Chromium 	0.027	0.067	
Zinc	0.075	0.183	
Cyanide 	0.015	0.036	
Aluminum	0.485	1.094	
Oil and Grease	1.79	1.79	
Suspended Solids	2.15	2.69	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	((0.027 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 0.128 lb/day

Daily Maximum Limits:

Cr:	(0.067 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 0.318 lb/day

CLEANING OR ETCHING RINSE

The average daily production rate stated in the permit application will be 2375 tons/day 

 40 CFR 467.24 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum cleaned or etched	
Chromium 	0.21	0.52	
Zinc	0.59	1.42	
Cyanide 	0.11	0.28	
Aluminum	3.70	8.50	
Oil and Grease	13.91	13.91	
Suspended Solids	16.69	20.87	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	((0.21 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 0.998 lb/day

Daily Maximum Limits:

Cr:	((0.52 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 2.47 lb/day

CLEANING OR ETCHING SCRUBBING LIQUOUR

The average daily production rate stated in the permit application will be 2375 tons/day 

 40 CFR 467.24 – New Source Performance Standards  (NSPS)

Pollutant 
   	Maximum for Monthly Average 	Maximum for any 1 day	
	lb/million off-lbs of aluminum cleaned or etched	
Chromium 	0.29	0.72	
Zinc	0.81	1.97	
Cyanide 	0.16	0.39	
Aluminum	5.24	11.81	
Oil and Grease	19.33	19.33	
Suspended Solids	23.2	29	
pH	7.0-10.0 s.u.	7.0-10.0 s.u.	

Monthly Average Limits:

Cr:	((0.29 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 1.3775 lb/day

Daily Maximum Limits:

Cr:	((0.72 lb/1,000,000 off-lbs)*(2375 tons/day) * (2000 lbs/ton)  = 3.42 lb/day

Total Categorical Regulation Limits from all applicable core and ancillary operations	
  Pollutant	Monthly Average	Daily Maximum	
	lb/day	
Chromium	6.26	15.4	
Zinc	17.46	42.3	
Cyanide*	3.4	8.35	
Aluminum	110.3	249.9	
Oil and Grease	414.2	414.2	
Suspended Solids	497.1	621.4	
* Periodic analyses for cyanide are not required when both of the following conditions are met: 
(1) The first wastewater sample taken in each calendar year has been analyzed and found to contain less than 0.07 mg/l cyanide 
(2) The owner or operator of the coil coating facility and aluminum forming facility certifies in writing to the POTW authority or permit issuing authority that cyanide is not used in the coil coating process and aluminum forming process. (Ref: 40 CFR 465.03 and 467.03) 

ATTACHMENT B

WASTELOAD ALLOCATION