PUBLIC NOTICE PERMIT RATIONALE FOR REISSUANCE
International Paper Company, FTC Facility
Amite County
Crosby, Mississippi
Water NPDES No. MS0062189
June 23, 2025

I.	FACILITY INFORMATION

Facility Name:		International Paper Company, FTC Facility
Facility Address:	6005 Highway 33 South 
	Crosby, MS  39633    
Crosby, 
Permit No.:		MS0062189
SIC:			4959
Permit Writer:		Rusty Parrish
EPD Branch:		Water II Branch

II.	NATURE OF BUSINESS

International Paper Company, FTC Facility previously operated as a wood treatment facility from 1934 until 1971. The facility is currently inactive and consists of a groundwater remediation system which is operated under regulatory oversight by the Mississippi Department of Environmental Quality (MDEQ) Office of Pollution Control (OPC). 

III.	EFFLUENT AND RECEIVING STREAM FLOW DATA

Outfall 001 wastewater consists of treated creosote contaminated groundwater and stormwater runoff from the facility’s spray fields. The facility has a concrete-lined equalization basin where water which is sprayed on the spray fields is recaptured and reused. Discharge from the basin does not occur during normal operation; discharge from the basin is rainfall dependent and occurs manually when excess rainfall and runoff backup into the spray fields thence into unnamed tributary of Foster Creek (7Q10 = 0 MGD). 

IV.	303(d) and TOTAL MAXIMUM DAILY LOAD (TMDL) ISSUES

Since discharges from this facility are rainfall dependent, there are no 303(d) and TMDLs that need to be identified/ addressed.

V.	TYPE OF WASTEWATER TREATMENT

The effluent from outfall 001 is initially passed through a series of separation tanks for creosote removal.  This wastewater is then treated in the Technical Minerals Units and two granular activated carbon units to 	remove dissolved contaminants.  The treated groundwater is then pumped from the granular activated carbon units to a concrete-lined equalization basin where it is land applied on the facility three spray fields.  The fields are vegetated with grass and pine trees. Any runoff from the fields is eventually returned to the basin for reapplication

VI.	APPLICABLE GUIDELINES

State of Mississippi Water Quality Criteria

VII.	DATA FROM APPLICATION FORM 2C
	
Parameter	Maximum Daily Value (mg/L)	Maximum Daily Value (lb/day)	
Biochemical Oxygen Demand (BOD5)	1.19	-----	
Chemical Oxygen Demand (COD)	22.6	-----	
Total Organic Carbon (TOC)	2.66	-----	
Total Suspended Solids (TSS)	15.2	-----	
Ammonia (as N)	0.0215	-----	
Flow	275-350 gpm	
Temperature (winter)	Ambient	
Temperature (summer)	Ambient	
pH	5.04– 6.36 SU	

XI.	PROPOSED FINAL LIMITATIONS 

1.	Average Permit Limitations: Outfall 001

Parameter	Categorical Limitation	Water Quality
Limitation	Present Permit Limitation	Proposed Permit Limitation	1Basis	
pH	--	5.5 SU (min)	5.5 SU (min)	5.5 SU (min)	MSWQS	
Flow	--	--	Report MGD	Report MGD	CPL	

2.	Maximum Permit Limitations: Outfall 001

Parameter	Categorical Limitation	Water Quality
Limitation	Present Permit Limitation	Proposed Permit Limitation	1Basis	
pH	--	9.0 SU	9.0 SU	9.0 SU	MSWQS	
Flow	--	--	Report MGD	Report MGD	CPL	
	Basis: MSWQS = Mississippi Water Quality Standard; CPL = Current Permit Limit

pH shall be monitored once per discharge event via grab sampling. Flow shall be determined for each batch discharge by the pump rate of the effluent pump multiplied by the time length of the discharge. As is found in the existing permit, other special conditions shall be as follows:

1.)	permittee shall maintain a rain gauge on the site.

2.)	A daily log shall be maintained at the facility to indicate daily rainfall events.

3.)	The permittee shall utilize the land application spray fields as the routine and primary means of treating and disposing the wastewater generated from the facility. Conditions that may preclude the use of the spray fields are defined as periods when chronic rainfall events result in the wastewater storage volumes approaching the permitted equalization 	basin safe operating capacity and where the efficacy of the land application system is threatened. 

4.)	If a discharge occurs, a report shall be submitted at the time of DMR submittal 	outlining circumstances requiring the discharge. The report shall be submitted as a 	separate transmittal from the DMR.

5.)	There shall be no runoff from the spray fields except to the equalization basin.  

6.)	All berms surrounding the spray fields shall be properly maintained and shall be inspected monthly. A monthly inspection log shall be maintained at the facility of all berm inspections and of any discrepancies noted and of any corrective actions made