PRETREATMENT RATIONALE FOR ISSUANCE

J Strickland and Company, Manufacturing Plant
Desoto
Olive Branch, MS
Chemical

MSP092463
SIC: 2844
June 3, 2024
Permit Engineer: Samar Patel

I.	FACILITY INFORMATION

A.	Nature of Business: J Strickland and Company is a manufacturer of multicultural hair care and skin care products.

B.	Process Wastewater Description: 

The existing process wastewater treatment system at this facility consists of oil-water separation.  Process wastewater from manufacturing operations flows into a 1,000-gallon inceptor tank with oil-water separation capabilities. The wastewater is discharged to the site’s sanitary sewer system, then flows to the industrial park’s collection system for transport to the Metro WWTF, operated by the Desoto County Regional Utility Authority. 
The proposed wastewater treatment system upgrades expand the pre-treatment activities prior to discharge to the industrial park’s collection system.  Specifically, process wastewater flows to the modified interceptor tank, where it is pumped to an elevated tank for pH neutralization.  Provision is made for addition of both acid and base in necessary quantities to yield a target process wastewater pH between 6 and 8 SU.  pH is monitored at tank entry to insure proper adjustment.  From the neutralization tank, process wastewater flows by gravity through an oil-water separator for removal of the oil and grease present in the water, along with temperature adjustment achieved by residence in the oil-water separator.  Upon exiting the oil-water separator, treated process wastewater enters the outlet side of the existing interceptor tank for discharge to the site sanitary sewer system, then to the park’s collection system for treatment at the Metro WWTF. 

C.	Proposed Flowrate: 8,000 Gallons per day (0.008 MGD) 

D.	Applicable Federal Guidelines: Not applicable

II.	RECEIVING POTW INFORMATION

A.	POTW and Permit Number:  Desoto County Regional Utility Authority, Metro Desoto WWTP, MS0028479 (AI-3129)

B.	POTW Treatment Type: Activated Sludge
C.		
D.	POTW Design Flowrate: 	Phase I: 	0.537 MGD
Phase II:	1.0 MGD
Phase III:	1.5 MGD  
   
E.	POTW Receiving Stream: Unnamed tributary thence of Nonconnah Creek

F.	POTW Receiving Stream, 7Q10 (Q7/10) at the point of discharge: 0.0 cfs 

III.	APPLICATION SUMMARY

The table below presents a summary of the information submitted on the Form 2P application.

Parameter	Maximum (mg/L)	Average (mg/L)	# of samples	
BOD	125	---	1	
COD	346	---	1	
TSS	137	---	1	
Oil and Grease	2160	219.60	26	
Ammonia	12.1	---	1	
Nitrate-nitrite (as N)	0.362	---	1	
Copper	0.016	---	1	
Lead	ND	---	1	
Mercury	Believed absent	---	---	
Cadmium	Believed absent	---	---	

•	
IV.	PROPOSED PERMIT LIMITATIONS

Parameter	Reported Max. Conc. (mg/L)	Allowable Concentration 	Proposed Permit Limits	Sampling Frequency 	Sample Type	Basis of Decision1	
		Acute (mg/L)	Chronic (mg/L)	Max. (mg/L)	Avg. (mg/L)				
Flow	0.040 MGD			Report
MGD	Report
MGD	Daily	Estimate	EJ	
pH	5.1-11.0 SU			9.0 S.U.
(max)	6.0 S.U. (min)	Weekly	Grab	POTW	
Temperature	52oC (125.6oF)			120oF	---	Weekly	Instantaneous	POTW	
Oil & Grease (O&G)	2160			150 mg/L
(62.0 lb/day)	R mg/L
(R lb/day)	Weekly	Grab	POTW	
Copper, Total Recoverable	0.016			0.05 mg/L	---	Monthly	24-Hr Composite	POTW	
Cadmium, Total Recoverable	Believed Absent			R mg/L	---	Monthly	24-Hr Composite	POTW	
Cyanide, Total Recoverable	Believed Absent			R mg/L	---	Monthly	Grab	POTW	
Mercury, Total Recoverable	Believed Absent			R mg/L	---	Monthly	24-Hr Composite	POTW	
Lead, Total Recoverable	Believed Absent			R mg/L	---	Monthly	24-Hr Composite	POTW	

1 Basis of Decision: WQC = Water Quality Criteria; EJ = Engineering Judgment; POTW = Publicly Owned Treatment Works

•	The permittee must comply with the general pretreatment regulations established in 40 CFR 403.

•	The monitoring for copper, O&G, pH, temperature, and metals are proposed in the permit based on the Metro Desoto Utilities Sewer Ordinance. Due to a very small discharge from J Strickland, MDEQ does not believe they need to be evaluated for metals contribution. 

•	The facility can request a permit modification on the monitoring frequency of pH, temperature, and oil & grease to once per month after demonstrating compliance for at least a year. DCRUA will have to agree to that as well and so, the facility needs to get that permission from DCRUA as part of the submission of the request for modification. 

•	For those parameters marked as believed absent in the application, we are proposing “report only” with once per month sampling frequency. The facility can request a modification to reduce frequency to once per quarter if they demonstrate non-detect for at least a year and DCRUA will have to agree to that as well as part of the modification request.