PERMIT RATIONALE FOR REISSUANCE 
RESOLUTE FP US, INC.
GRENADA, GRENADA COUNTY
NPDES PERMIT No. MS0043222
May 3, 2019

I.	INDUSTRIAL CLASSIFICATION - The facility's Standard Industrial Classification (SIC) Code is 2621 – Newsprint Paper.  The facility produces newsprint through the thermomechanical pulping of roundwood and purchased wood chips.  

II.	GENERAL DESCRIPTION OF WASTEWATER AND DISCHARGE FLOW - The facility has one outfall which they have applied to be permitted for.  This outfall is designated as Outfall 002.  The effluent from Outfall 002 consists of process and non-process wastewater from the production of newsprint paper.  The long term average flow from Outfall 002 as reported in the application is 5.06 MGD.  The operations which contribute to discharge from this outfall are as follows: 

	Operation						Average Flow
	Thermomechanical Pulping	1.64 MGD
	Paper Machine				2.55 MGD
	Utilities						0.21 MGD
	Water Treatment				0.40 MGD
	Rain Water						0.20 MGD

III.	DESCRIPTION OF WASTEWATER TREATMENT – The wastewater from the mill’s process sewers is screened prior to entering the primary clarifier.  In the 0.97 MG primary clarifier, settling, as well as chemical precipitation, occurs.  After passing through the clarifier, the wastewater is pumped to the 2 MG sulfite oxidation basin where the wastewater is cooled through aeration.  From there, the wastewater is passed through two aeration stabilization basins.  The first basin has a capacity of 19.2 MG and the second basin has a capacity of 38.4 MG.  After the aeration basins, the wastewater is routed to a 58 MG polishing pond.  After leaving the polishing pond, the wastewater is either directed to a post aeration basin from where it is discharged or to a 230 MG treated water holding pond.  The holding pond is only used when discharge to the Yalobusha River is curtailed due to low river flow. Prior to being discharged to the Yalobusha River, all wastewater is passed through the post aeration basin where the dissolved oxygen of the wastewater is raised.

IV.	RECEIVING WATERS - 	Outfall 002 - the Yalobusha River
					Minimum headwater flow of the Yalobusha River at which           					discharge is allowed is 70 cfs.
					Mean Annual flow of the Yalobusha River = 1714 MGD

There are no 303(d) issues for the site or TMDL’s which apply. 

V.	APPLICABLE GUIDELINES - "State of Mississippi Water Quality Criteria" and 40 CFR Part 430 - The Pulp, Paper, and Paperboard Point Source Category; Subpart G – Mechanical Pulp Subcategory; Section 430.75 (NSPS) 

VI.	PERTINENT DATA FROM FORM 2C -	

A.	OUTFALL 002 (In terms of Mass)

Maximum		Maximum 		Long	     		
Daily			30 Day			Term			No. of 
Parameter		Value			Value			Average Value	Samp.
BOD5			3153 lb/day		2381 lb/day		1815 lb/day		101
COD			14804 lb/day		----			----			1
TOC			777 lb/day		----			----			1
TSS			3468 lb/day		2784 lb/day		1968 lb/day		103
Ammonia		156.7 lb/day		93.6 lb/day		56.4 lb/day		49
Flow			7.38 MGD		6.45 MGD		5.06 MGD		365
Temp. (Winter)	27.4   deg C		22.4 deg C		16.4 deg C		68
Temp. (Summer)	31.6   deg C		30.5 deg C		27.5 deg C		51
pH			7.05-7.78 s.u.		7.16-7.67 s.u.		----			103
Fecal Coliform
Total Aluminum	58.67 lb/day		58.67 lb/day		42.56 lb/day		12
Total Iron		26.2 lb/day		----			----			1
Total Cadmium	0.011 lb/day		----			----			1
Total Chromium	0.087 lb/day		----			----			1
Total Copper		0.28 1b/day		----			----			1
Total Nickel		0.481 lb/day		----			----			1
Total Silver		0.071 lb/day		----			----			1
Total Zinc		0.821 lb/day		----			----			1

B.	OUTFALL 002 (In terms of Concentration)

Maximum		Maximum 		Long	     		
Daily			30 Day			Term			No. of 
Parameter		Value			Value			Average Value	Samp.
BOD5			70.8 mg/L		56.5 mg/L		42.6 mg/L		101
COD			336 mg/L		----			----			1
TOC			19.2 mg/L		----			----			1
TSS			88 mg/L		74 mg/L		47 mg/L		103
Ammonia		3.60 mg/L		2.53 mg/L		1.34 mg/L		49
Total Aluminum	1.60 mg/L		1.60 mg/L		1.05 mg/L 		12
Total Iron		0.648 mg/L		----			----			1
Total Cadmium	0.00028 mg/L		----			----			1
Total Chromium	0.00215 mg/L 		----			----			1
Total Copper		0.00694 mg/L		----			----			1
Total Nickel		0.0119 mg/L		----			----			1
Total Silver		0.00175 mg/L		----			----			1
Total Zinc		0.0203 mg/L		----			----			1
Pentachlorophenol	<5.1 ppb		----			----			1
Trichlorophenol	<5.1 ppb		----			----			1

VI.	SUMMARY OF WATER QUALITY LIMITATIONS, CATEGORICAL LIMITATIONS, EXISTING, AND PROPOSED EFFLUENT PERMIT LIMITATIONS

	OUTFALL 002
	
	Average Limitations

Water		Categorical	Existing	Proposed	
Quality		Effluent	Permit		Permit	
Parameter		Limitations	Limitations	Limitations	Limitations	Basis
BOD5			----		3085 #/day	3575 #/day	3085 #/day	Cat.
TSS			----		5676 #/day	3355 #/day	3355 #/day	TJ
Pentachlorophenol	0.054 mg/L	----		----		----		TJ		
Total Rec. Zinc	0.524 mg/L	----		----		----		TJ
Total Rec. Aluminum	----		----		----		7.4 ppm	TJ
pH			6.0-9.0 s.u.	5.0-9.0 s.u.	6.5-9.0 s.u.	6.0-9.0 s.u.	MSWQS

Maximum Limitations

Water		Categorical	Existing	Proposed	
Quality		Effluent	Permit		Permit	
Parameter		Limitations	Limitations	Limitations	Limitations	Basis
BOD5			***		5676 #/day	6578 #/day	5676 #/day	Cat.
TSS			----		10736 #/day	5592 #/day	5592 #/day	TJ
Pentachlorophenol	2.61 #/day	1.20 #/day/	----		----		Cat./TJ
			0.07 ppm	0.0288 ppm			----		
Trichlorophenol	24#/day/	1.09 #/day/	----		----		Cat./TJ
			0.648 ppm	0.025 ppm			----		
Total Rec. Zinc	19.5 #/day/	210 #/day/	----		----		Cat./TJ
			0.524 ppm	5.09 ppm
Total Rec. Aluminum	----		----		----		10.8 ppm	TJ
Ammonia (as N)	8.0 mg/L	----		8.0 mg/L	8.0 mg/L	MSWQS
pH			6.0-9.0 s.u.	5.0-9.0 s.u.	6.5-9.0 s.u.	6.0-9.0 s.u.	MSWQS

***	The maximum BOD5 limitation is based on the categorical effluent limitation and a wasteload allocation received from the Water Quality Assessment Branch (WQAB) of the MDEQ.  The maximum daily allowable discharge limit is dependent on stream flow and is presented in Attachment D of this rationale.  However, the BOD5 cannot exceed 5676 lbs/day based upon the table. 

Note:	The monthly average categorical limitations for BOD5 and TSS are based on a production rate of 617 tons per day of newsprint. This production rate is based on a straight average of the daily production rate of marketable newsprint produced at the facility from 2014 through 2018. The proposed TSS limitations are based on the long term average flow reported in the previous application, 4.47 MGD, and TSS concentrations of 90 mg/L and 150 mg/L respectively.

Outfall 002

BOD5

The maximum BOD5 limitation for Outfall 002 is based on the categorical effluent limitation and a waste load allocation received from the Water Quality Assessment Branch (WQAB) of the MDEQ. The water quality limitations are based on a model developed by the WQAB and are dependent upon stream flow. On February 12, 1987, MDEQ’s stream computer model was used to develop a discharge table for Bowater Newsprint South, Inc.  The discharge was varied with the headwater flow in the Yalobusha River above Riverdale Creek. A Waste Load Allocation (WLA) of 99-1-6 (mg/l, BOD5 – NH3 – D.O.) was used.  

As is found in the existing permit, the water quality limitations found in Attachment D are based on a WLA of 99-8-5(mg/l, BOD5 – NH3 – D.O.).  The model was based on these limits in order to permit the facility to discharge a higher concentration of ammonia in its effluent.  As can be seen from a review of Attachment D, above 319 cfs, the facility is limited to discharging a maximum of 5,676 #/day.  This maximum amount allowed is based on the categorical limitation which was calculated using the limitations for continuous discharges.  The proposed monthly average BOD5 limit is also based on the categorical limitation.   BOD5 shall be monitored once per week with a 24-Hour Composite sample of the effluent.  
 
TSS

The TSS limits are based on both technical judgement and existing permit limitations.  The maximum monthly limit was derived based on the long term average flow from the facility in the previous application, 4.47 MGD, and a TSS concentration value of 150 mg/L respectively.  The average limit is based on the long term average flow from the facility in the previous application, 4.47 MGD, and a TSS concentration value of 90 mg/L respectively.  TSS shall be monitored once per week with a 24-Hour Composite sample of the effluent.
 
pH 

The pH limits are based on the State of Mississippi Water Quality Criteria.  pH shall be monitored once per week with a grab sample of the effluent.

Total Recoverable Aluminum  

The Total Recoverable Aluminum limits are based on existing permit conditions and the “State of Mississippi Water Quality Criteria”. During a previous permitting process, the facility failed the toxicity screening procedure for Aluminum.  The facility provided data which indicated the source water for the mill, the Yalobusha River, exceed the water quality criteria for this parameter.  The State of Mississippi does not have water quality criteria for Total Recoverable Aluminum.  In these situations, available references such as the “National Recommended Water Quality Criteria” are utilized.  Since the establishment of the existing Aluminum limitations in the permit, the Aluminum limitations found in the “National Recommended Water Quality Criteria” have been revised.  The new instream criteria as calculated per MDEQ’s Water Quality Assessment Branch is an Acute standard of 0.92 mg/L and a Chronic standard of 0.38 mg/L.   As can be seen in attachment E, the source water for the mill exceeds the new criteria.  The Great Lakes Guidance document addresses how to permit these types of situations and was used in the establishment of the existing permit limitations for this parameter. Since the Aluminum concentration in the Yalobusha River is above the new criteria, the existing limits are still being proposed.  Total Recoverable Aluminum shall be monitored monthly with a 24-hour composite sample of the effluent.

Dissolved Oxygen

The dissolved oxygen limit proposed is based on existing permit conditions and the wasteload allocation received from the WQAB.  As mentioned above, the BOD5 limitations were originally developed based on a computer stream model based on the facility having 99-1-6 (mg/l, BOD5 – NH3 – D.O) limits.  It appears that when this model was developed, a dissolved oxygen limit of 5.0 mg/L was also used and that the model indicated the discharge to be protective of water quality in the receiving stream. As a result, since the issuance of the original permit, the facility has had to comply with a minimum dissolved oxygen limit of 5 mg/L.  Dissolved oxygen shall be monitored twice per week with a grab sample of the effluent.

Ammonia (as N)

The maximum Ammonia (as N) limitation for Outfall 002 is based on existing permit limitations and a waste load allocation received from the Water Quality Assessment Branch (WQAB) of the MDEQ. Ammonia (as N) shall be monitored once per week with a grab sample of the effluent.

Pentachlorophenol and Trichlorophenol  

In the categorical regulations, it is stated that, in lieu of monitoring for these parameters, the permittee may certify to the permitting authority that it is not using these compounds as biocides. The permittee has provided correspondence in which they certify that they are not using chlorophenolic containing biocides.  Furthermore, the testing for these parameters revealed them to be non-detect in the effluent as reported in the permit application.  As such, Resolute FP US Inc. – Grenada Operations will not be required to monitor for these parameters as part of the permit.

Zinc  

40 CFR Part 430.75 contains categorical standards for Zinc.  In the categorical regulations, it is stated that Zinc limitations are only applicable at facilities where Zinc Hydrosulfite is used as a bleaching agent and, in lieu of monitoring for this parameter, the permittee may certify to the permitting authority that it is not using this compound.  The permittee has provided correspondence in which they certify that they are not using Zinc Hydrosulfite. As such, Resolute FP US Inc. – Grenada Operations will not be subject to the categorical limitations for this parameter.  

Flow

The flow from Outfall 002 shall be monitored continuously with a recorder.  The facility will be required to monitor flow in the Yalobusha River continuously with a recorder and report each month the minimum daily flow measured.  

One special condition for monitoring flow in the Yalobusha River will be that any river water withdrawal amounts by the permittee must be included in determining the base flow of the Yalobusha River for purposes of permittee effluent control.

Total Nitrogen and Total Phosphorus

Monitoring for these parameters is being added at the request from the WQAB.  Each parameter shall be monitored monthly with a grab sample of the effluent.

Other Conditions

As indicated in Attachment C, the facility failed the toxicity screening for Total Copper, Total Recoverable Cadmium, and Total Recoverable Silver.  The facility failed the toxicity screening procedure for all pollutants due to the multiplication of the 10x factor as the result of the reporting of less than 12 sample results. In lieu of placing limits, additional monitoring will be required as per the State of Mississippi Wastewater Regulations.  The permittee shall monitor for all pollutants twice per month for six months beginning the month following the effective issuance date of the permit or until all 36 samples are received.  All pollutants shall be monitored with a 24 hour composite sample of the effluent.  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 all 12 samples for each pollutant.  The NPDES permit may be modified to include limits for all pollutants after the screening is accomplished with the additional data.

Notes:

In the previous draft permit, categorical limitations for BOD and TSS were developed using the limitations for non-continuous dischargers.  EPA was contacted on 5/2/2019 for clarification on the definition of non-continuous dischargers.  EPA indicated that they believed that term to mean facilities which are required to cease production or those that only operate during certain times of the year (i.e.- non-generating wastewater facilities).  

ATTACHMENT A
CATEGORICAL GUIDELINES SAMPLE CALCULATIONS

ATTACHMENT A
Categorical Guideline Sample Calculations

OUTFALL 002

The following table is extracted from 40 CFR Part 430.75 (thermo-mechanical process) NSPS

			Avg.				Max. 
Parameter		(lbs/ 1000 lbs of gross production) 

BOD5			2.5				4.6
TSS			4.6				8.7
pH				5.0-9.0 s.u.

The production rate is 617 tons/per day.  This production rate is based on production figures provided by the facility from 2014 through 2018.  A straight average of all data was utilized in determining production rate. 

Example Calculation
617 tons/day * 2.5 lbs/1000 lbs * 2000 lbs/1 ton = 3085 lbs/day	

		Avg.				Max.
Parameter			     (lbs/day)

BOD5			3085				5676
TSS			5676				10736

The following table is extracted from 40 CFR Part 430.75 (thermo-mechanical process) NSPS

Parameter					Maximum Limitations

						lbs/1000 lbs		mg/L
Pentachlorophenol				0.00097		(.017)(13.8)/y
Trichlorophenol				0.00088		(.015)(13.8)/y
Zinc						0.17			(3.0)(13.8)/y

y = wastewater discharged in kgal per ton of product
y = ((long term average flow)* (1 kgal/1000 gallons))/(production quantity per day) =  kgal/ton
y = (5.02 MG/day * 1,000,000 gallons/1MG) * (1 kgal/1000 gallons) / 617 tons of product per day
y = 8.136 kgal/ton

 Example Calculation:

617 tons/day * 0.00097 lbs/1000 lbs * 2000 lbs/1 ton = 1.196 lbs/day
(0.017)(13.8)/8.14 = 0.0288 mg/L	
Maximum Limitations
Parameter					lbs/day		mg/L
Pentachlorophenol				1.20		0.0288
Trichlorophenol				1.09		0.025
Zinc						210		5.09

		

ATTACHMENT B
TOXICITY SCREENING PROCEDURE

ATTACHMENT B

Outfall 002

Water Quality Evaluation for discharge to the Yalobusha River

IWC 	=	Instream Wastewater Concentration
Qw	=	maximum 30 day average wastewater flow, if available
Qr 	=	receiving stream flow 
Xr	=	receiving stream concentration 
Xw	=	historical effluent data
Xwa 	=	permit limits from previous permit or from effluent guidelines
Xta      =	the calculated instream concentration based on existing permit limits or the                                   calculated limit based on current effluent guidelines
Xt	=	the calculated instream concentration based on historical effluent data from                 		application
AWQC =	Acute Water Quality Criterion Value
CWQC =	Chronic Water Quality Criterion Value

Xt	= 	((Xr* Qr ) + (Qw * Xw))/ (Qr + Qw) 

Qw = 6.45 MGD (Maximum 30 Day Value for Flow as reported in Form 2C Application)
Qr = 70 cfs = 45.23 MGD (minimum flow in Yalobusha at which discharge is allowed)
Qr = 2652 cfs = 1714 MGD (Mean Annual Flow)   
IWC (minimum flow) =  100 * (Qw / (Qr + Qw) = 100 * (6.45/45.23 +6.45) = 12.48 %
IWC (Mean Annual Flow) =100 * (Qw / (Qr + Qw) = 100 * (6.45/(1714 +6.45) = 0.37 %

Receving Stream data is based on the average of two samples collected near the dam near Grenada at Grenada Lake in 2015.  Grenada Lake is upstream of the discharge.

Total Iron
Xw = 0.648 mg/L *10 = 6.48 mg/L (No. of samples <12) 
Xr =  0 mg/L (No data available) 
Xt (acute and chronic) = ((0 mg/L * 45.23 MGD) +(6.45 MGD* 6.48 mg/L))/(45.23 + 6.45) 
= 0.808 mg/L
Xt (Human Health)= ((0 mg/L*1714 MGD) + (6.45 MGD*6.48 mg/L))/(6.45 MGD +1714) 
		       = 0.024 mg/L  
AWQC = No Data Available
CWQC = 1.0 mg/L
HHWQC = No Data Available

Total Copper
Xw = 0.00694 mg/L *10 = 0.0694 mg/L (No. of samples <12) 
Xr =  0.0015 mg/L (Based on two samples collected in 2015)
Xt (acute and chronic) = ((0.0015 mg/L * 45.23 MGD) +(6.45 MGD* 0.0694 mg/L))/(45.23 + 6.45) = 0.01 mg/L
Xt (Human Health)= ((0.0015 mg/L*1714 MGD) + (6.45 MGD*0.0694 mg/L))/(6.45 MGD +1714) = 0.00175 mg/L  
AWQC = 0.007 mg/L
CWQC = 0.005 mg/L
HHWQC = 1.0 mg/L

Total Zinc
Xw = 0.0203 mg/L *10 = 0.203 mg/L (No. of samples <12) 
Xr =  < MQL (0.01 mg/L) assuming 0 mg/L  (Based on two samples collected in 2015)
Xt (acute and chronic) = ((0 mg/L * 45.23 MGD) +(6.45 MGD* 0.203 mg/L))/(45.23 + 6.45) 
= 0.025 mg/L
Xt (Human Health)= ((0 mg/L*1714 MGD) + (6.45 MGD*0.203 mg/L))/(6.45 MGD +1714) 
		       = 0.00076 mg/L  
AWQC = 0.065 mg/L
CWQC = 0.065 mg/L
HHWQC = 26.0 mg/L
	
Total Nickel
Xw = 0.0119 mg/L *10 = 0.119 mg/L (No. of samples <12) 
Xr =  0.0022 mg/L (Based on two samples collected in 2015) 
Xt (acute and chronic) = ((0.0022 mg/L * 45.23 MGD) +(6.45 MGD* 0.119 mg/L))/(45.23 + 6.45) 
= 0.017 mg/L
Xt (Human Health)= ((0.0022 mg/L*1714 MGD) + (6.45 MGD*0.119 mg/L))/(6.45 MGD +1714) 
		       = 0.0026 mg/L
AWQC = 0.260 mg/L
CWQC = 0.029 mg/L
HHWQC = 4.6 mg/L

Total Cadmium
Xw = 0.00028 mg/L *10 = 0.0028 mg/L (No. of samples <12) 
Xr =  < MQL (0.5 ppb) assuming 0 mg/L  (Based on two samples collected in 2015)
Xt (acute and chronic) = ((0 mg/L * 45.23 MGD) +(6.45 MGD* 0.0028 mg/L))/(45.23 + 6.45) 
= 0.0003 mg/L
Xt (Human Health)= ((0 mg/L*1714 MGD) + (6.45 MGD*0.0028mg/L))/(6.45 MGD +1714) 
		       = 0.00001 mg/L
AWQC = 0.001 mg/L
CWQC = 0.00015 mg/L
HHWQC = 0.168mg/L

Total Chromium
Xw = 0.00215 mg/L *10 = 0.0215 mg/L (No. of samples <12) 
Xr =  0.00031 mg/L (Based on two samples collected in 2015) 
Xt (acute and chronic) = ((0.00031 mg/L * 45.23 MGD) +(6.45 MGD* 0.0215 mg/L))/(45.23 + 6.45) = 0.0029 mg/L
Xt (Human Health)= ((0.00031 mg/L*1714 MGD) + (6.45 MGD*0.0215 mg/L))/(6.45 MGD +1714) = 0.00038 mg/L
AWQC = 0.323 mg/L
CWQC = 0.042 mg/L
HHWQC = 140 mg/L

Total Silver
Xw = 0.00175mg/L *10 = 0.0175 mg/L (No. of samples <12) 
Xr =  0 mg/L (No data available) 
Xt (acute and chronic) = ((0 mg/L * 45.23 MGD) +(6.45 MGD* 0.0175 mg/L))/(45.23 + 6.45) 
= 0.002 mg/L
Xt (Human Health)= ((0 mg/L*1714 MGD) + (6.45 MGD*0.0175 mg/L))/(6.45 MGD +1714) 
		       = 0.000065 mg/L
AWQC = 0.00098 mg/L
CWQC = No Data Available
HHWQC = 0.1 mg/L

Toxicity Screening Summary

	Acute Screening			
Parameter			Xt			AWQC		Pass/Fail
Total Iron			0.808 mg/L		—			N/A
Total Copper			0.01 mg/L		0.007 mg/L		Fail 
Total Zinc			0.025 mg/L		0.065 mg/L		Pass
Total Nickel			0.017 mg/L		0.260 mg/L		Pass
Total Cadmium		0.0003 mg/L		0.001 mg/L		Pass
Total Chromium		0.0029 mg/L		0.323 mg/L		Pass
Total Silver			0.002 mg/L		0.00098 mg/L		Fail

Chronic Screening
Parameter			Xt			CWQC		Pass/Fail
Total Iron			0.808 mg/L		1.0 mg/L		Pass
Total Copper			0.01 mg/L		0.005 mg/L		Fail
Total Zinc			0.025 mg/L		0.065 mg/L		Pass
Total Nickel			0.017 mg/L		0.029 mg/L		Pass
Total Cadmium		0.0003 mg/L		0.00015 mg/L		Fail
Total Chromium		0.0029 mg/L		0.042 mg/L		Pass
Total Silver			0.002 mg/L		---			N/A

Human Health Screening
Parameter			Xt			HHWQC		Pass/Fail
Total Iron			0.024 mg/L		—			N/A
Total Copper			0.00175 mg/L		1.0 mg/L		Pass
Total Zinc			0.00076 mg/L		26.0 mg/L		Pass
Total Nickel			0.0026 mg/L		4.6 mg/L		Pass
Total Cadmium		0.00001 mg/L		0.168 mg/L		Pass
Total Chromium		0.00038 mg/L		140 mg/L		Pass
Total Silver			0.000065 mg/L	0.1 mg/L		Pass

As can be seen above, the facility failed the toxicity screening for Total Recoverable Cadmium, Total Recoverable Copper and Total Recoverable Silver.  The facility failed the toxicity screening procedure for all pollutants due to the multiplication of the 10x factor as the result of the reporting of less than 12 sample results. In lieu of placing limits, additional monitoring will be required as per the State of Mississippi Wastewater Regulations. The permittee shall monitor for all pollutants twice per month for six months beginning the month following the effective issuance date of the permit or until 36 samples are received.  All pollutants shall be monitored with a 24 hour composite sample of the effluent.  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 all 12 samples for each pollutant.  The NPDES permit may be modified to include limits for all pollutants after the screening is accomplished with the additional data.

ATTACHMENT C
WATER QUALITY CALCULATIONS

ATTACHMENT C  

Water Quality Calculations

Maximum 30 day value for flow for Outfall 002 as reported on the Form 2C = 6.45 MGD
Minimum flow in the Yalobusha River at which discharge is allowed = 45.23 MGD
Mean Annual Flow of the Yalobusha River = 1714 MGD

IWC (minimum flow) =  100 * (Qw / (Qr + Qw) = 100 * (6.45/45.23 +6.45) = 12.48 %
IWC (Mean Annual Flow) =100 * (Qw / (Qr + Qw) = 100 * (6.45/(1714 +6.45) = 0.37 %

Parameter		Acute Screening Value	Chronic Screening Value	Human Health Screening Value	
Total Pentachlorophenol	0.0087 mg/L	0.0067 mg/L	0.003 mg/L	
Trichlorophenol	No value	No value	0.0028 mg/L	
Zinc	0.065 mg/L	0.065 mg/L	26.0 mg/L	

Total Pentachlorophenol, Acute		0.0087/0.124 = 0.07 mg/L
Total Pentachlorophenol, Chronic		0.0067/0.124   = 0.054 mg/L

Total Trichlorophenol, Acute			(0.0024/0.0037) = 0.648 mg/L 

Total Zinc, Acute		0.065/0.124 = 0.524 mg/L
Total Zinc, Chronic		0.065/0.124 = 0.524 mg/L

	

	

ATTACHMENT D
WASTELOAD ALLOCATION AND DAILY AVERAGE ALLOWABLE BOD5 DISCHARGE LIMITS

Bowater Newsprint South - NPDES#: MS0043222-Outfall 002
Discharge to Yalobusha River
Discharge, BOD5 and NH3-N loadings for various Headwater Flows
Annual limits - 99-8-5 (mg/L of BOD5-NH3-N and DO) 

Headwater Flow 
(cfs)	Discharge
(MGD)	BOD Loading
(lbs/day)	NH3-N Loading
(lbs/day)	
0-69	0	0.0	0.0	
70-79	0.3	270.0	21.8	
80-89	0.5	450.0	36.4	
90-99	0.8	630.0	50.9	
100-109	1.0	810.0	65.5	
110-119	1.2	990.0	80.0	
120-129	1.5	1279.0	103.4	
130-139	1.9	1589.0	128.4	
140-149	2.3	1899.0	153.5	
150-159	2.7	2209.0	178.5	
160-169	3.1	2519.0	203.6	
170-179	3.4	2829.0	228.6	
180-189	3.8	3139.0	253.7	
190-199	4.2	3449.0	278.7	
200-249	4.4	3633.0	293.6	
250-299	5.4	4458.0	360.2	
> 300	7.2	5676.0	483.7	

ATTACHMENT E
ALUMINUM LIMITATIONS CALCULATIONS