Re: Permit. Dear Andy. On behalf. Thank you. enclosuree

Transcription

1 Proactive Solutions for yourr Environmental and Safety Needss October 12, Mr. Andy Nanneman Arkansas Department of Environmental Quality Water Division Permits Sections/No Discharge Permits 5301 Northshore Drive North Little Rock, Arkansas VIA Re: Permit Modification Application for Proposed Permit 3778 WR 5 Revised Waste Management Plan Pet Solutions, LLC Land Application Facility, Danville, Arkansas Dear Andy On behalf of Pet Solutions, LLC, please accept the attached revised Waste Management Plan (WMP) with regards to the Permit Modification Application for the proposed Permit 3778 WR 5. Previously, the applicant planned to expand the existing facility building within the facility s operational footprint. The applicant now plans to expand the existing facility building within and to the east of the facility s current operational footprint. Also, the numbers of cookers and wett scrubbers have been changed since the previous submission. The enclosed revised WMP presents the revised table of contents, process description, facility site map, process flow diagram, and process area site map corresponding to the proposed facility expansion. The analytical data of Appendix D and the soils report of Appendix E have not changed and are therefore not being resubmitted. Thank you for your review of this application. Should you have any questions or need any additional information, please contact me. Sincerely, HARBOR ENVIRONMENTAL & SAFETY Andrew Rike, P.E. Senior Project Engineer cc: Rusty Bowsher, Pet Solutions, LLC Bobby Bridges, Pet Solutions, LLC Mike Johnson, Pet Solutions, LLC Bryan Posey, Pet Solutions, LLC enclosuree 8114 Cantrell Road, Ste. 350 Little Rock, AR P: F:

2 WASTE MANAGEMENT PLAN REVISED OCTOBER 2011 PROPOSED PERMIT NO WR 5 AFIN: Prepared by: 8114 Cantrell, Suite 350 Little Rock, AR Phone PREPARED FOR: PET SOLUTIONS, LLC GAUGE ROAD DANVILLE, ARKANSAS (479)

3 Table of Contents Table of Contents... i 1. Introduction and Background Process Description Storage Facilities Analysis of Waste Properties Soil Properties Identification of Soils Soils Analysis Site Management Plan Solids Land Application Plan Application Rate Calculations for Solids Wastewater Land Application Plan Application Rate Calculations for Wastewater Professional Engineers Certification APPENDICES Appendix A: Facility Vicinity Map and Facility Site Map Appendix B: Simplified Process Flow Diagrams Appendix C: Process Area Site Maps Appendix D: Analytical Data Pond 3 Wastewater, Pond 1 Sludge, and Soils Data for Application Areas Appendix E: National Cooperative Soil Survey Custom Soil Resource Report for Yell County, Arkansas Harbor Environmental & Safety Page i

4

5 1. Introduction and Background Pet Solutions, LLC owns and operates a protein conversion facility in Centerville, Arkansas. This document constitutes the revised Waste Management Plan (WMP) for the land application of unrecoverable grease solids and process waste water generated at the Pet Solutions facility. Pet Solutions owns approximately 313 acres, of which approximately 170 acres is associated with industrial activity and is located in Sections 11 and 12, Township 5 North, Range 21 West, northeast of Danville, in Yell County, Arkansas. However, due to restrictions such as slopes exceeding 15 percent and maintaining buffer zones around creeks and property boundaries, only about 77 acres in this area is suitable for land application. Appendix A presents the Facility Vicinity Map providing the location of the facility on a Yell County General Highway Map. The plant is surrounded by unmanaged timber and open pasture acreage. The facility is a protein conversion plant (SIC 2077), located on Gauge Road (County Road #50), west of State Highway 7 between Ola and Centerville, Arkansas. Pet Solutions processes chicken material to recover protein nutrients and fats. The recovered products are sold in bulk for use as additives in animal feeds. Prior to the recovery of protein nutrients and fat oils, regional chicken producers commonly land-applied these valuable by-products without attempting to recover and recycle the usable portions of their waste stream. The original Permit (3778-W) was issued to J&B Farms, Inc. on December 30, The facility was purchased in 1994 by Valley Protein and was operated until it was destroyed by fire in In 1997, J&B Farms bought back the facility from Valley Protein and operated it until early The facility was then purchased by Pet Solutions, LLC. The facility operated under Permit No WR-1 until March, 2004 when Pet Solutions submitted a minor permit modification application (PMA) and WMP revision for the consolidation of ponds 1 through 4 and the construction of levees and a compacted clay liner system. The PMA was approved, and Permit No WR-2 was made effective on September 22, A permit application was submitted, and the permit was pending issuance in June of However Permit 3778-WR-3 was not issued. Pet Solutions resubmitted a permit renewal application in December of 2009 which was approved, and Permit No WR-4 was made effective on June 1, The facility currently operates under Permit No WR-4. Harbor Environmental & Safety Page 1

6 2. Process Description Pet Solutions, located in Yell County, Arkansas, provides a service to chicken producers by dehydrating and separating secondary protein nutrients at a protein conversion facility producing grease/oils and protein solids (bone meal) utilized by the Pet Food industry. A simplified process flow diagram for the facility is presented in this section. A more detailed layout of the Process Area is presented in Section 8.0 with the Plot Plan. The planned expansion project will involve expanding and reorganizing the existing plant to incorporate a blood/feather meal and edible chicken parts processing lines in addition to the cooking process (inedible meat processing) currently permitted. Edible materials include chicken materials that are less than three (3) days old, and these materials must be processed within 72 hours to maintain the edible designation. Inedible Processing Lines The primary feedstock of meat, blood, and feathers is trucked to the plant. Upon arriving at the facility, the blood is to be pumped to a holding tank, then to a coagulator, and then to a centrifuge which will separate the blood solids from the serum liquid. The solids from the centrifuge are conveyed to a cyclone where the blood is mixed with hydrolyzed feathers before entering a dryer. Upon arriving at the facility, the feathers are to be dumped into a closed feathers receiving bin. The feathers will then be transferred to the feather hydrolyzer, where they are to be heated, agitated, and reduced to a wet slurry. Hydrolyzed feathers are to be separated from the flash vapors as they depart from the flash chamber and are mixed with blood solids in the cyclone. From the cyclone, mixed blood and hydrolyzed feathers are to be transferred to the dryer. The dryer is an ASME certified steam vessel equipped with steam discs, rather than being direct fired. The dryer is listed as an emission source in the event AP- 42 factors change in the future. The dried feather/blood meal is then to be milled, screened, and conveyed to the storage silos. Other inedible materials are to be received and then dumped into a closed receiving bin. The raw material is then transported to a metal detection/removal process. At this point, the raw material is transferred to one (1) of 12 batch cookers. The facility is adding two (2) new cookers to the edible protein processing line as part of this expansion. The inedible cooking process consists of 12 horizontal, cylindrical, non pressurized vessels (batch cookers) equipped with steam jackets and non-steam agitators. The steam is provided by the natural gas boilers and wood-fired boiler located in the boiler area. A new 73.6 MMBTU natural gas boiler will be installed. Materials placed in the cookers are dehydrated. Vapor is vented from these 12 cookers and passes through an RTO. Upon completion of the cooking process, materials are dumped into a drain pan. The drain pan separates the liquid fat from the protein solids. From the drain pan, the protein solids are conveyed to a press. The press completes the separation of fat from solids, and yields protein solids. These solids are then ground and screened to produce protein (bone Harbor Environmental & Safety Page 2

7 or poultry) meal. The Hammermill room air is vented to the scrubber system which consists of five (5) total scrubbers. The meal is stored in holding bins that are located adjacent to the ship-out area. The fat from both the press and the drain pan is screened and pumped to the grease storage tanks for shipping. Wastewater from the centrifuge is directed to the wastewater ponds. Both grease and bone meal are stored and shipped from the load-out area located on the southeast portion of the facility. To reclaim protein from the solutions, a dissolved air flotation unit may be utilized to process the liquids from the blood and fat centrifuge units, and the separated water would be directed to Pond 1. Other sources of wastewater include blow down from the wet scrubbers, drop out from the cyclones and condensers, and facility wash down water. All wastewater is directed to the wastewater ponds. Edible Processing Lines Edible materials are to be received and directed to the cookers. The open top trucks and totes are to be received at the receiving dock, and then dumped into the closed raw receiving bin. The raw material is then to be transported to a metal detection and removal process. From this point, the material is to be transferred to the cookers in the protein recovery area via a closed pipe pumping system. The protein recovery area includes two (2) new large capacity continuous cookers, two (2) oil separators, two (2) surge bins, two (2) screw presses, two (2) centrifuges, and two (2) coolers with bag house. The continuous cookers consist of two (2) horizontal, cylindrical, non-pressurized vessels (HM2266 batch cookers) equipped with an outer steam jacket and 66 steam discs. The steam is to be provided by two (2) natural gas boilers and the wood fired boiler located in the boiler area. Materials placed in the cookers will be dehydrated thereby facilitating the separation of the fats and proteins. Cooking time will be dependent upon various factors that include the consistency of the raw materials and ambient temperatures inside the plant. Vapor will be vented from each cooker and routed to the RTO to remove odor prior to discharge. Materials from the cookers are to be dumped into one of two (2) pre-heated closed surge bins with mixing capability, thence transferred into one of two (2) screw presses. The press completes the separation of fat from solids. These solids are then ground and screened to produce protein meal. The meal is stored in holding bins that are located adjacent to the ship-out area after passing through the milling/screen room. The fat from both the presses and the drain pans is processed in centrifuges and pumped to the grease storage tanks for shipping. Wastewater from the centrifuges is directed to the wastewater ponds. Both grease and bone/poultry meal are stored and shipped from the load-out area. All plant air is exhausted to the scrubber system which consists of five (5) total scrubbers. Blow-down water from the scrubbers will be directed to Pond 1. Harbor Environmental & Safety Page 3

8 To reclaim protein from the solutions, a dissolved air flotation unit may be utilized to process the liquids from the fat centrifuge units, and the separated water would be directed to Pond 1. Other sources of wastewater include drop out from the cyclones and condensers, and facility wash down water. All wastewater is directed to the wastewater ponds. Harbor Environmental & Safety Page 4

9 3. Storage Facilities Process wastewater effluent from various sources associated with the operations of the protein recovery facility will flow into a series of ponds for treatment. Dehydration of the feedstock condenses and becomes a process wastewater stream. Other wastewater streams are generated from the two boilers (blow-down and by-pass condensate), the wash down of equipment and maintenance cleanup, spent scrubber liquids, and preprocess feedstock drainage. Bound fat in these wastewater streams separates and floats to the water s surface as they enter Pond 1 of the treatment system. Since complete separation of the bound fat is not a pure separation that could be accomplished by screening, a series of settling ponds are utilized to accomplish this process. However, the separation of fat from water is a simple process and does occur naturally. Based on land application volumes from previous years, it is estimated that approximately 18,000 gallons of wastewater per production day will be generated. Upon completion of treatment, the waste will be stored and then land applied as needed. An overall layout of the site and treatment system is presented in Appendix A. The average annual rainfall for this area, Dardanelle Weather Station Gauge, is inches Average annual lake evaporation (U.S. Weather Bureau Technical Paper #37, 1959) is 44inches. The inches of annual rainfall less 44 inches of annual evaporation is 2.89 inches of annual accumulated rainfall in the ponds. Pond 1 is the primary anaerobic lagoon used as a receiving, settling and separation pond. The dimensions of Pond 1 are approximately 125 feet, by 335 feet (rainfall watershed area), by 11 feet deep, with 1 foot of freeboard. The sides of the pond were constructed with 2:1 (H:V) slopes. Fat separates from the wastewater stream and floats to the surface, and settled water from mid depth of the pond drains through a pipe structure to Pond 2. Chemical adjustment may be done as needed. The maximum holding capacity for Pond 1 is approximately 2,430,745 gallons. This is approximately 134 days of throughput for process and rainfall loading accounting for evaporation. A 25-year, 24-hour rain event at 7.3 inches is approximately 189,408 gallons of loading that must pass through Pond 1 to maintain the required freeboard. TABLE 1 provides a design summary of the ponds. Pond 2 is the aerated pond. This top of the pond s berm is approximately five feet lower than the top of the berm of Pond 1. Aerobic biological treatment and chemical adjustment are accomplished in Pond 2. The dimensions of Pond 2 are approximately 130 feet, by 150 feet (rainfall watershed area), by 21 feet deep with 1 foot freeboard. The sides of the pond were constructed with 2:1 (H:V) slopes. Settled water from this pond flows through a pipe structure to the next and final holding lagoon (Pond 3). The maximum holding capacity of Pond 2 is approximately 1,443,641 gallons. This is approximately 80 days of throughput for process and rainfall loading accounting for evaporation. At this point some evaporation could be considered, but for simplicity have been avoided in this calculation. Harbor Environmental & Safety Page 5

10 A 25-year, 24-hour rain event at 7.3 inches is approximately 88,732 gallons of loading that must pass through Pond 2 to maintain required freeboard. Pond 3 is the final holding pond of the treatment system. Two surface aerators are utilized to maintain aerobic conditions in Pond 3. This pond is the lowest pond in the treatment system. The top of the berm of Pond 3 is approximately four feet lower than the top of the berm of the Pond 2. Pond 3 is the holding lagoon on which the No Discharge permit is determined. All process wastewater is treated and held in this pond. Water sampling analysis for this pond is provided in Appendix D. The dimensions of Pond 3 are approximately 140 feet, by 560 feet (rainfall watershed area), by 13 feet deep with two feet of freeboard. The sides of the pond were constructed with 2:1 (H:V) slopes. Retained water in this pond will be reused as equipment wash water in the plant and also land applied by an irrigation sprinkler system. The maximum holding capacity for Pond 3 is approximately 4,810,534 gallons. This is approximately 262 days of throughput for process and rainfall loading accounting for evaporation. A 25-year, 24-hour rain event at 7.3 inches is approximately 356,746 gallons of required freeboard volume for Pond 3. With the additional pass through loading received from Ponds No. 1 through No. 3, the total storm event that must be contained by Pond 3 is approximately 634,885 gallons or a minimum maintained freeboard requirement of 13.0 inches, worst case scenario. A minimum freeboard of 2 is to be maintained at all times in Pond 3. The process wastewater annual throughput and average annual rainfall, based on double the highest discharge volumes of the past three years for the existing facility is 6,821,345 gallons. The system s throughput design is calculated to be 476 days with a total working volume of approximately 8,684,920 gallons. Harbor Environmental & Safety Page 6

11 TABLE 1. TREATMENT SYSTEM SUMMARY RAIN EVENT IDENTIFICATION POND CAPACITY 1 LOADING THROUGHPUT (ft 2 ) DIMENSIONS (Gallons) (Gallons) (Days) Pond 1 (41,625) 185' x 225' x 11', 1 FB 2,430, , Pond 2 (19,500) 130' x 150' x 21', 1 FB 1,443,641 88, Pond 3 (78,400) 140' x 560' x 13', 2 FB 4,810, , Notes: TOTAL 8,684, , Capacities were calculated with 2:1 (H:V) side slopes. The AREA indicated in the table is the surface area (rainfall watershed area). 2. Throughput is calculated by the Capacity of the Pond divided by the sum of the Annual Production Rate and Annual Accumulated Rainfall in the pond. Annual Production Rate = 18,000 gallons/day x 365 days = 6,570,000 gallons/year Annual Accumulated Rainfall = in 44 in = 2.89 Annual Rainfall Pond 1 = (2.89 in/yr / 12 in/ft) x (41,625 sf) x (7.48 gal/sf) = 74,985 gallons/yr Annual Rainfall Pond 2 = (2.89 in/yr / 12 in/ft) x (19,500 sf) x (7.48 gal/sf) = 35,128 gallons/yr Annual Rainfall Pond 3 = (2.89 in/yr / 12 in/ft) x (78,400 sf) x (7.48 gal/sf) = 141,232 gallons/yr Harbor Environmental & Safety Page 7

12 4. Analysis of Waste Properties Analyses of the physical and nutrient properties of the waste were performed by analytical laboratories and the results were supplied to Pet Solutions, LLC. The results have been used in the calculations to determine application rates (See Section 6.0). A summary of the wastewater and sludge analyses are included in TABLE 2 and TABLE 3 respectively. The values presented in TABLE 2 are the average values of 10 water samples collected from Pond 3 between April 27, 2010 and March 8, 2011, except for the Chromium value which is from a single analysis of the March 8, 2011 sample. The values presented in TABLE 3 are the values of 3 sludge samples collected from Pond 1 on March 8, The laboratory test results are located in Appendix D. TABLE 2: SUMMARY OF WASTEWATER ANALYSIS PARAMETERS RESULTS PARAMETERS RESULTS % Volatile Solids % Total Kjeldahl Nitrogen mg/l % Total Solids! 0.66% Oil & Grease 9.3 mg/l BOD mg/l Total Phosphorus 64.8 mg/l Nitrate - Nitrogen 83.0 mg/l Total Potassium 145 mg/l Nitrite - Nitrogen 32.4 mg/l Ammonia - Nitrogen 157 mg/l Arsenic mg/l Cadmium mg/l Copper mg/l Molybdenum mg/l Lead mg/l mg/l Mercury mg/l Nickel mg/l Selenium mg/l Zinc mg/l ph (standard units) 6.7 SU Chromium mg/l 1. Average Total Solids (TS) are presented as 0.66% and Volatile Solids (VS) as 0.28%, however analytical results from September 2010 until February 2010 had a reporting limit of 1% by weight for TS. As presented in the attached data, all samples were <1% by weight for TS. After February 2010, the reporting limit for TS has been changed to 0.05% by weight for TS. An average TS of the four (4) samples presented with lower reporting limits (4/27/10, 6/15/10, 8/17/10, 3/8/11) is calculated to be 0.14% by weight, and VS is calculated to be 0.06%. Harbor Environmental & Safety Page 8

13 TABLE 3: SUMMARY OF SLUDGE ANALYSIS PARAMETERS RESULTS PARAMETERS RESULTS % Volatile Solids 59.6% Total Kjeldahl Nitrogen 5,337 mg/kg % Total Solids 62.3% Oil & Grease 1,6333,333 mg/kg BOD-5 71,200 mg/kg Total Phosphorus 1,447 mg/kg Nitrate - Nitrogen <5.00 mg/kg Total Potassium 228 mg/kg Nitrite - Nitrogen <5.00 mg/kg Ammonia - Nitrogen 1,222 mg/kg Arsenic 3.60 mg/kg Cadmium mg/kg Copper 4.50 mg/kg Molybdenum 2.88 mg/kg Lead 7.20 mg/kg Mercury mg/kg Nickel 1.64 mg/kg Selenium 7.20 mg/kg Zinc 38.0 mg/kg ph (standard units) 5.2 SU Chromium 3.11 mg/kg Harbor Environmental & Safety Page 9

14 5. Soil Properties 5.1 Identification of Soils The National Cooperative Soil Survey custom soil resource report of the site classifies the soil located at Pet Solutions property associated with land application as Leadvale silt loam and Nella gravelly fine sandy loam. The custom soil resource report is presented in Appendix E. 5.2 Soils Analysis As required by ADEQ s Technical Requirements for a No Discharge Permit, the facility collected and tested six soil samples. A summary of the analyses performed is shown in TABLE 4. A copy of the laboratory test results is included in Appendix D. TABLE 4. SUMMARY OF SOILS ANALYSIS PARAMETERS RESULTS PARAMETERS RESULTS Nitrate-Nitrogen 5.49 mg/kg Specific Conductance 53.2 μs/cm Phosphorus 1,043 mg/kg Potassium 1,270 mg/kg Arsenic 7.7 mg/kg Magnesium 930 mg/kg Copper 10.1 mg/kg Cadmium mg/kg Lead 17.6 mg/kg Molybdenum 2.34 mg/kg Nickel 14.1 mg/kg Mercury mg/kg Zinc 39.2 mg/kg Selenium 5.84 mg/kg Cation Exchange Capacity (meq/100g) 3.47 meq/100g ph (SU) 5.0 SU Harbor Environmental & Safety Page 10

15 6. Site Management Plan A total of 76.2 acres is available for land application of solids and wastewater. Two (2) center pivots and a travelling reel sprinkler irrigation system are to be used to land apply wastewater. Solids are rarely land applied, but when they are applied, a manure spreader and disc are utilized. The center pivots are to cover an area of approximately 39.8 acres and are to be used for wastewater application. This will leave a remaining 36.4 acres to be utilized for wastewater and solids application by means of travelling reel sprinkler or manure spreader respectively. Use of the center pivots will be the land application method of choice, and may be used exclusively depending on wastewater volumes, wastewater characteristics, and field conditions. 6.1 Solids Land Application Plan Excess, unrecoverable waste solids are collected in the storage ponds, adjacent to the plant. The unrecoverable waste solids are from naturally occurring separation of the fat from saturated carriers that were part of the process wastewater discharge stream (organic material). The proposed application areas are illustrated on the Facility Site Map presented in Appendix A. Land application of these solids has been approved in the past under permit 3778-WR-4. The current proposed land application is the same in nature The limiting agent that determines the safe rate per acre for applying the unrecoverable waste (sludge) is plant available nitrogen (PAN). Of the total nitrogen in the waste, 15% will be lost to leaching and 20% will be lost to denitrification during the application process. Therefore, only 65% of the total nitrogen in the waste would be considered plant available nitrogen. The safe application rate for Bermuda grass is 150 lbs of nitrogen per acre per year. This is even higher for Bahia and other more growth aggressive grasses. Consideration is given only for the ability of plants to use certain nutrients (nitrogen). Other properties of the waste material (biological and chemical) are not addressed in this plan. The test results do not indicate excess heavy metals, toxicity levels, or volatile solids (VS) outside the range of soil background level concentrations for concern at this time. The VS (95%) will create a temporary odor problem, as this is mainly the decomposition of organic substrates. The unrecoverable waste solids will be applied to existing vegetated areas with a manure spreader as needed and incorporated immediately by disking. 6.2 Application Rate Calculations for Solids The following presents a summary of the nitrogen analytical data of the Pond 1 sludge followed by the nitrogen loading calculations. Harbor Environmental & Safety Page 11

16 DESCRIPTION YEAR SAMPLE TAKEN RESULTS Total Kjeldahl Nitrogen ,337 mg/kg Nitrate Nitrogen 2011 <5.0 mg/kg Nitrite Nitrogen 2011 <5.0 mg/kg Ammonia Nitrogen ,222 mg/kg PAN = 0.25(Organic Nitrogen) + 0.5(Ammonia Nitrogen) + Nitrate Nitrogen Organic Nitrogen = Total Kjeldahl Nitrogen Ammonia Nitrogen PAN = 0.25(5,337 mg/kg 1,222 mg/kg) + 0.5(1,222 mg/kg) mg/kg = 1,645 mg/kg Convert: mg/kg to (lb PAN/lb matl.) = 1,645 mg/kg /10,000 = lb PAN/lb matl. Application Rate = (150 lb/acre - yr) / (( lb/lb)(0.65)) = 140,4321 lb/acre-year = 70.2 tons/acre-year 6.3 Wastewater Land Application Plan The area to receive wastewater irrigation will be rotated over the entire pasture area surrounding the plant. The pump house for the sprinkler irrigation system is located on the south side of Pond 3, midway of the pond. The pasture area consists of Bermuda grass and Bahia grass. The pastures will be mowed as needed to maintain good agricultural practices. The Facility Site Map of Appendix A illustrates the proposed application areas. Sprinkler irrigation application from Pond 3 has been used in the past under conditions of Permit 3778-WR-4. The current proposed irrigation application will utilize two (2) center pivots and a travelling reel sprinkler system in areas not covered by the center pivots. The use of center pivots or a travelling reel sprinkler during periods of intense sunshine and dryness causes an increase in the evaporation rate. For the purpose of calculating an application rate, this system will allow for up to a 30% increase in the application rate due to evaporation. 6.4 Application Rate Calculations for Wastewater The following presents a summary of the nitrogen analytical data of Pond 3 wastewater followed by the nitrogen loading calculations. Harbor Environmental & Safety Page 12

17 DESCRIPTION YEAR SAMPLES TAKEN AVERAGE RESULTS Total Kjeldahl Nitrogen mg/l Nitrate Nitrogen mg/l Nitrite Nitrogen mg/l Ammonia Nitrogen mg/l PAN = 0.25(Organic Nitrogen) + 0.5(Ammonia Nitrogen) + Nitrate Nitrogen Organic Nitrogen = Total Kjeldahl Nitrogen Ammonia Nitrogen Assume Organic Nitrogen to be 0 mg/l because TKN is less than Ammonia Nitrogen. The lab was consulted regarding this contradictory result, and the lab attributed it to the difficulty of testing this particular wastewater. PAN = 0.25(0 mg/l) + 0.5(157 mg/l) mg/l = 165 mg/l Convert: mg/kg to (lb PAN/lb matl.) = 165 mg/kg /10,000 = lb PAN/lb matl. Application Rate = (150 lb/acre - yr) / (( lb/lb)(0.65)) = 1,400,044 lb/acre-year = tons/acre-year Weight of Wastewater = 8.34 lb/gal Volume of Wastewater for Safe Application = (1,400,044 lb/ac-yr)/(8.34 lb/gal) = 167,871 gal/ac-yr Volume of Wastewater Produced + Rain Accumulated = 6,821,345 gallons per year Acres Required = (Vol of WW Produced + Rain) / (Vol of WW for Safe Application) = (6,821,345 gal/yr)/(167,871 gal/ac-yr) = 40.6 acres required for Nitrogen Application Center pivots and the travelling reel sprinkler system will be used for the land application of wastewater. The maximum application depth will not exceed 1 per day. Use of the center pivots will be the application method of choice based on effectiveness and ease of operation. The center pivots will cover a 40 acre area, so the use of the irrigation reel may not be required depending on wastewater volumes and field conditions. Peak gallons per acre may be increased by 1.3 the application rate per day conditionally based on hot arid days to reduce the number of applications required. Also the application area may be increased to reduce the applications required. Harbor Environmental & Safety Page 13

18

19 APPENDIX A Facility Vicinity Map and Facility Site Maps Harbor Environmental & Safety

20

21

22 APPENDIX B Simplified Process Flow Diagrams Harbor Environmental & Safety

23

24 APPENDIX C Process Area Site Maps Harbor Environmental & Safety

25

26 APPENDIX D Analytical Data Pond 3 Wastewater and Pond 1 Sludge Harbor Environmental & Safety

27 APPENDIX E National Cooperative Soil Survey Custom Soil Resource Report for Yell County, Arkansas Harbor Environmental & Safety

28 Hanson, Kim From: Sent: To: Subject: Attachments: Andrew Rike Thursday, October 13, :59 AM Nanneman, Andrew RE: Pet Solutions - Land Application Permit Application - Revised WMP Pet WMP Cert Page pdf Andy, Attached is stamped and signed certification for the Pet Solutions October 2011 Revised WMP. Please let me know if you require a hardcopy. Thank you for your assistance. Sincerely, Andrew Rike, P.E. Harbor Environmental and Safety 8114 Cantrell Road, Suite 350 Little Rock, AR (tel) (cell) (fax) From: Nanneman, Andrew [mailto:nanneman@adeq.state.ar.us] Sent: Thursday, October 13, :17 AM To: Andrew Rike Subject: RE: Pet Solutions - Land Application Permit Application - Revised WMP Andrew, Thanks for the revised WMP. However, we required a PE stamp on WMPs for them to be Department approved and to be incorporated into a land application permit. Please send me a PE certification, with a stamp and signature, for the October 2011 Revised WMP. Thanks for your cooperation in this matter and if you have any questions do not hesitate to get in contact with me. Andy Nanneman, E.I. No-Discharge Permits Branch, Water Division, ADEQ 5301 Northshore Drive North Little Rock, AR P: (501) F: (501) From: Andrew Rike [mailto:arike@harborenv.com] Sent: Wednesday, October 12, :36 PM To: Nanneman, Andrew Cc: Rusty Bowsher (rbowsher@3dcorpsol.com); bbridges@3dcorpsol.com; Mike Johnson (mjohnson@3dcorpsol.com); Bryan Posey (bposey@3dcorpsol.com) Subject: Pet Solutions - Land Application Permit Application - Revised WMP 1

29 Andy, Pet Solutions (AFIN ) has modified the plans for the expansion of the facility associated with the modification of the Land Application Permit 3778 WR 4. The attached cover letter and revised WMP details the new plans for the expansion. Please note that none of the values of the land application areas, wastewater volumes, or analytical data have changed from the previous revision submittal. Please let me know if you have any questions regarding the revised WMP and facility expansion. Thank you for your work on this permit! Sincerely, Andrew Rike, P.E. Harbor Environmental and Safety 8114 Cantrell Road, Suite 350 Little Rock, AR (tel) (cell) (fax) 2