PERMIT RATIONALE FOR REISSUANCE
Exide Technologies, Florence Oxide Plant
Water NPDES No. MSS047945
May 1, 2023, 2023
Samar Patel, Water I Branch

I.	FACILITY INFORMATION

Facility Address:  407 Briarhill Road, Florence, MS  39073
Facility County:   Rankin    Florence, 
SIC:                      2819

II.	NATURE OF BUSINESS

There are no industrial operations presently occurring at the site. The facility filed for bankruptcy in May 2020 and was dissolved on October 26, 2020. The current owner of the site is the Exide Environmental Response Trust (ERT), One World Trade Center, 8th Floor, Long Beach, CA 90831. Under the Trust, the site name is the Exide ERT – Florence Smelter. The Trust conducts limited operations in terms of remediation and maintenance at the site as needed to maintain environmental compliance and security. Montrose is a contractor retained by the Trust to perform day-to-day operations and management of the site. 

Note: In the past, this facility was operating as Exide Technologies and was producing expander material used in the manufacture of automotive batteries.

III.	EFFLUENT AND RECEIVING STREAM FLOW DATA

A.	MSS047945-101grab/102comp (Outfall 101grab/102comp) – Storm water runoff from approximately 1.7 acres (~88% impervious) consisting of employee parking lot and the main office building roof drains to Indian Creek.

B.      MSS047945- 201grab/202comp (Outfall 201grab/202comp) – Storm water runoff from                    approximately 14.1 acres (~12.8% impervious) consisting of the loading rack, lead            oxide storage silos, and 10,000-gallon mineral oil tank area located outside the                   expander manufacturing building drains to Indian Creek.

C.      MSS047945-301grab/302comp (Outfall 301grab/302comp) – Storm water runoff from                     approximately 2.5 acres (~32% impervious) consisting of the sales building                       parking lot and open field property (remediated and closed pond) area drains to                  Indian Creek.

IV.	303(d) ISSUES

I.	Indian Creek: The receiving stream is in the Pearl River Basin and is classified as fish and wildlife. The section of the receiving stream segment where the permittee discharges into the Indian Creek does not appear on the updated State of Mississippi 303(d) List of Impaired Water bodies. However, this site is listed in a State of Mississippi Pearl river Basin TMDL for Cadmium for Indian Creek, which was completed in August of 2013. The draft permit proposes effluent monitoring for Cadmium consistent with the TMDL. We have included a reopener clause in the proposed permit which allows the permit to be modified in case more stringent limitations and additional monitoring are determined to be necessary based on the completed TMDL or water quality study of the receiving stream. 

V.	TYPE OF WASTEWATER TREATMENT:

None.

VI.	EPA APPLICABLE CATEGORICAL GUIDELINES

None.

VII.	DATA FROM APPLICATION FORM (Enter the type of application, i.e. 2F)

MSS047945-101grab/102comp (Outfall 101grab/102comp)
	
Parameter	Daily max. Values
(Grab/Comp)	# of Analyses	
Oil & Grease	1.5 mg/l	1	
Total Phosphorus	0.5 mg/l / 0.5 mg/l	1	
Total Nitrogen	0.100 mg/l / 0.100 mg/l	1	
pH (min/max)*	6.67 S.U. / 
7.28 S.U.	6	
Lead(Grab/Comp)*	0.504 mg/l / 0.504 mg/l	6	

MSS047945-201grab/202comp (Outfall 201grab/202comp)	
Parameter	Daily Max. Values
(Grab/Comp)	# of Analyses	
Oil & Grease (Grab)	1.5 mg/l 	1	
Total Phosphorus	0.5 mg/l / 0.5 mg/l	1	
Total Nitrogen	0.645 mg/l / 0.652 mg/l	1	
pH (min/max)*	6.7 S.U. / 
7.22 S.U.	6	
Lead*	0.141 mg/l / 0.141 mg/l	6	

MSS047945-301grab/302comp (Outfall 301grab/302comp)
	
Parameter	Daily Max. Values
(Grab/Composite)	# of Analyses	
Oil & Grease	1.5 mg/l / 5.4 mg/l 	1	
Total Phosphorus	0.500 mg/l / 0.500 mg/l	1	
Total Nitrogen	0.638 mg/l / 0.551 mg/l	1	
			
pH (min/max)*	6.67 S.U. / 
7.55 S.U.	6	
Lead*	0.097 mg/l / 0.443 mg/l	6	

* Reported values for these parameters are based on the DMR reports from year 2019-2021.

VIII. 	WATER QUALITY LIMITATIONS BASED ON WASTELOAD ALLOCATION 

	Not Applicable.

IX.	CATEGORICAL GUIDELINE LIMITATIONS CALCULATIONS

Not Applicable

X.	STORMWATER SCREENING CALCULATIONS

See Attachment I

XI.	PROPOSED FINAL LIMITATIONS 

1.	Average Permit Limitations

Outfall	Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
MSS047945-101/102	Lead
pH(min)
Cadmium	-
-
-	2.30 mg/l
6.0 SU
-	2.30 mg/l
6.0 SU
-	2.30 mg/l
6.0 mg/l
R mg/l	Antibacksliding
MSWQS
TMDL	
MSS047945-201/202	Lead
pH(min)
Cadmium	-
-
-	2.30 mg/l
6.0 SU
-	2.30 mg/l
6.0 SU
-	2.30 mg/l
6.0 mg/l
R mg/l	Antibacksliding
MSWQS
TMDL	
MSS047945-301/302	Lead
pH(min)
Cadmium	-
-
-	2.30 mg/l
6.0 SU
-	2.30 mg/l
6.0 SU
-	2.30 mg/l
6.0 mg/l
R mg/l	Antibacksliding
MSWQS
TMDL	

2.	Maximum Permit Limitations

Outfall	Parameter	Categorical Limitation	Water Quality Limitation	Present Permit Limitation	Proposed Permit Limitation	Basis	
MSS047945-101/102	Lead
pH(max)
Cadmium	-
-
-	3.46 mg/l
9.0 SU
-	3.46 mg/l
9.0 SU
-	3.46 mg/l
9.0 mg/l
R mg/l	Antibacksliding
MSWQS
TMDL	
MSS047945-201/202	Lead
pH(max)
Cadmium	-
-
-	3.46 mg/l
9.0 SU
-	3.46 mg/l
9.0 SU
-	3.46 mg/l
9.0 mg/l
R mg/l	Antibacksliding
MSWQS
TMDL	
MSS047945-301/302	Lead
pH(max)
Cadmium	-
-
-	3.46 mg/l
9.0 SU
-	3.46 mg/l
9.0 SU
-	3.46 mg/l
9.0 mg/l
R mg/l	Antibacksliding
MSWQS
TMDL	
1 MSWQC = State of Mississippi Water Quality Criteria for Intrastate, Interstate and Coastal Waters; TMDL = State of Mississippi - Cadmium TMDL for Indian Creek (August 2013)

The proposed limit for Lead is based on our engineering judgment, the anti-backsliding provisions of Wastewater Regulations for NPDES permits, and the existing permit. The facility shall sample lead and Cadmium in accordance with EPA storm water sampling protocol that requires a first thirty-minute grab sample and a three-hour composite sample during a storm after 72 hours of dry weather.