PERMIT RATIONALE FOR REISSUANCE
Cleveland POTW
Bolivar County
Cleveland, Mississippi
Water NPDES No. MS0020567
January 2025

I.	CLASSIFICATION – NPDES Major Municipal 

II.	DESCRIPTION OF WASTEWATER – Domestic / Municipal Wastewater

III.	DESCRIPTION OF WASTEWATER TREATMENT – Wastewater is collected and treated biologically by means of multiple cell lagoons followed by overland flow treatment. See Attachment 1 for a flow diagram. The current design capacity of the facility is 3.0 MGD. Only one discharge to surface waters is described in the application with no increase in treated effluent flow proposed.

IV.	RECEIVING WATERS – Big Sunflower River. At the point of discharge the receiving stream does not appear on the 2018 State of Mississippi 303(d) List of Impaired Waterbodies. The facility is mentioned in a Total Nitrogen and Total Phosphorus TMDL for Large Rivers in the Delta, as well as an Organic Enrichment, Nutrients and Sediment TMDL for the Big Sunflower River. Nutrient limitations (Total Nitrogen and Total Phosphorus) have been included in the draft permit in order to comply with Nutrient TMDL. BOD5, NH3-N, and DO limitations included in this draft permit are STREAM modeled, which accounts for oxygen depletion in the receiving stream, in order to comply with the Organic Enrichment, Nutrients, and Sediment TMDL. The receiving stream is classified as Fish & Wildlife and is located in the Yazoo River drainage basin.

The 7-day, 10-year minimum flow (7Q10) of the receiving stream is 67.8 cfs. The Instream Wastewater Concentration (IWC) at the point of the discharge is determined by the following calculation:

IWC = {(Qw)/(Qw + QR)} * 100 
	Where:
	Qw = Design flow of the wastewater treatment facility 3.0 MGD or 4.65 cfs.  
	QR = Receiving stream 7Q10, 67.8 cfs.

IWC = {(4.65 cfs)/(4.65 cfs + 67.8 cfs)} * 100 = 6.41 %

V.	APPLICABLE GUIDELINES – 11 Mississippi Admin Code pt. 6, Mississippi Water Quality Standards (MSWQS), Wasteload Allocation (WLA, Attachment 3), Municipal Facility Guidelines (Technology), TMDL, EPA Nationally Recommended Human Health Water Quality Criteria (HHWQC)

VI.	SUMMARY OF LIMITATIONS – 
Parameter				Value				Basis
Flow					3.0 MGD			Design
	BOD5					30 mg/l 			WLA
	TSS					90 mg/l 			Technology
	Ammonia Nitrogen			6.0 mg/l 			WLA
	Dissolved Oxygen			> 6.0 mg/l 			WLA
	Chlorine, Total Residual		0.172 mg/l 			Previous permit
E. coli					126 Col. /100 ml		WLA
	pH					6.0 – 9.0 SU			WLA
	Nitrogen (Total)			287.7 lbs/day			WLA
	Phosphorus (Total)			130.1 lbs/day			WLA
Ceriodaphnia dubia				     IC25 ≥ 6.41% 			MSWQS
Pimephales promelas				     IC25 ≥ 6.41% 			MSWQS

VII.	CHANGES FROM PREVIOUS PERMIT – 

No changes to limitations based from 2024 Waste Load Allocation. Chemical Specific limitation (

No WET Tests were submitted; therefore, Conditions M1-M6 is added to the proposed draft permit. Facility will be required to submit four WET Tests to assess effluent toxicity after reissuance. Condition L-2 has also been added to the proposed draft permit.

Bis(2-ethylhexyl) Phthalate was removed from the proposed draft permit.

Outfall 001 discharging water into the an Unnamed Creek then into Lead Bayou was removed from the proposed draft permit. The previously permitted Outfall 002 into the Big Sunflower has been reclassified as Outfall 001 for this and future issuances.

BIOASSAY AND CHEMICAL SPECIFIC EVALUATION

BIOASSAY

In accordance with State Regulation 11 Mississippi Admin Code pt. 6, VI.B.2b., Cleveland POTW is required to perform a Whole Effluent Toxicity (WET) evaluation as part of the renewal application. The applicant was to have tested in accordance with Short – Term Methods for estimating the Chronic Toxicity of Effluents and Receiving Water to Freshwater Organisms.  Short – term chronic WET tests were performed on Ceriodaphnia dubia (invertebrate) and Pimephale promelas (vertebrate). The facility submitted no WET Test with application. Due to less than four (4) bioassays having been completed, chronic bioassay requirements have been placed in the draft permit in order to satisfy the reapplication testing requirements and determine the toxicity of the discharge.

CHEMICAL SPECIFIC ANALYSIS

	Chemical specific analysis has been performed in accordance with State Regulations 11 Mississippi Admin Code pt. 6, V1.B1.  Municipalities shall determine the toxic characteristics of their wastewater by analyzing for the toxic pollutant listed in Table III of appendix D of 40 CFR 122.  The results are tabulated in Attachment 4.  The reported values are then analyzed and compared to water quality criteria (see Attachment 5) to determine any possible toxic effect to the receiving waters.  A synopsis of these calculations is listed in Attachment 6.  A column by column description of the calculations in Attachment 6 is hereby provided:
Column No. 1 – Maximum concentration.  The highest effluent reading of the parameter

Column No. 2 – The maximum concentration mixed with the receiving water IWC.  This is 			calculated by the following equation:

		{Maximum Concentration (Column 1) * IWC %} / 100

Column No. 3 – Acute allowable – Chemical Specific State Water Quality Criteria                                   
	Column No. 4 – Pass or Fail. If column 2 > column 3 water quality criteria is exceeded                                		and failure occurs.

Column No. 5 – Long term average (LTA) of all tests.  The summation of the 12 samples divided                                         by 12.

Column No. 6 – The long term average concentration mixed with the receiving water                                		 	IWC.  This is calculated by the following equation:

		{LTA Concentration (Column 5) * IWC%} / 100

Column No. 7 – Chronic allowable – Chemical Specific State Water Quality Criteria                                   
Column No. 8 – Pass or Fail. If column 6 > column 7 water quality criteria is exceeded                               			and failure occurs.

Column No. 9 – Human health determination.  Long term average (Column 5) is mixed                  		with the mean annual flow IWCMA .  This is calculated by the following equation:
{LTA Concentration (Column 5) * IWCMA %} / 100

Column No. 10 – Human health allowable – State Water Quality Criteria   Note: Organisms only                              column is used if receiving waters are not drinking water supply. 

	Column No. 11 – Pass or Fail.  If column 9 > column 10 water quality criteria is exceeded                       	         	 and failure occurs.
Chemical Specific Analysis for Metals and Results

Major municipalities shall determine the toxic characteristics of their wastewater by analyzing for toxic pollutants listed in Table III of Appendix D of 40 CFR 122.  Metal analysis shall be for total recoverable metals.  Municipalities shall submit twelve influent and effluent samples collected.  Chemical specific limits shall be placed in a permittee’s permit if any of the parameters evaluated in the toxic screening procedure indicate the reasonable potential for violation of the appropriate criteria (acute, chronic, and human health).

Cleveland POTW submitted the data as described above, submitting at this time the twelve (12) samples required. The arithmetic  average and maximum daily concentrations from Attachment 5 by 10 (due to a data set of less than 12 samples) determines the reasonable potential of the compound’s concentration to violate the Water Quality and Human Health Criteria. For Cleveland POTW, the chemical specific data results submitted with the reapplication indicated a reasonable potential for violation of the criteria in Table III of Appendix D of CFR 122 for the following pollutants:

See Attachment 6 for Chemical Specific Screening sheet and results.

Chemical Specific Analysis for Volatile Organic Compounds, Acid – Extractable Compounds, and Base – Neutral Compounds and Results

Bromodichloromethane

Average Daily Concentration = 3.6 ug/L

National Recommended Water Quality Criteria for Human Health = 27 ug/L

3.6 ug/L*10*0.0641 = 2.31 ug/L<27 ug/L

Chloroform

Average Daily Concentration = 24 ug/L

National Recommended Water Quality Criteria for Human Health = 2,000 ug/L

24 ug/L*10*0.0641 = 15.38 ug/L<2,000 ug/L

There were no detects for Acid-Extractable Compounds and Base-Neutral Compounds

ATTACHMENTS:

Attachment 1 – Flow Diagram
Attachment 2 – Location Map
Attachment 3 – Wasteload Allocation 
Attachment 4 – Chemical Specific Tabulated Test Results
Attachment 5 – MS Water Quality Criteria
Attachment 6 – Chemical Specific Screening
Attachment 1 – Flow Diagram

Attachment 2 – Location Map

Outfall 001

Plant Location

Attachment 3 – Wasteload Allocation

Attachment 4 – Chemical Specific Tabulated Results

Attachment 5 – MS Water Quality Criteria

Attachment 6 – Chemical Specific Screening