Pilgrim’s Pride files for ADEM permit

December 23, 2020 chris
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By Katie Bohannon, News Editor

Recent documentation revealing that Pilgrim’s Pride applied for a State Indirect Discharge (SID) Permit with the Alabama Department of Environmental Management is generating considerable discussion throughout the community.

Those in opposition to the rendering plant are investigating the permit’s details to discover its implications.

The ADEM website states that an industrial facility is required to apply for a SID permit if it meets one or more of the following definitions for a Significant Industrial Discharger or Significant Industrial User:

“All “industrial users” subject to Categorical Pretreatment Standards under 40 CFR 403.6 (1994) and 40 CFR Chapter I, Subchapter N (1994);

All “industrial users” that “discharge” an average of 25,000 gallons per day or more of process wastewater (excluding sanitary wastewater, non-contact cooling water, and boiler blowdown) to a “publicly owned treatment works”;

All “industrial users” that “discharge” an average quantity of process wastewater (excluding sanitary wastewater, non-contact cooling water, and boiler blowdown) that makes up five percent or more of the average dry weather organic or hydraulic capacity of the “publicly owned treatment works”;

All “industrial users” that “discharge” an average organic loading that makes up five percent or more of the design capacity of the “publicly owned treatment works”;

All “industrial users” that “discharge” to a “privately owned treatment works”; or

Any “industrial user” that is determined by the “Director” to have a reasonable potential to adversely affect the operation of the “publicly owned treatment works” or for violating any pretreatment standard or requirement (in accordance with 40 CFR 403.8(f)(6)(1994).”

A letter dated October 23, 2020 from Pilgrim’s Pride Head of Byproduct/MSC Mark Glover addressed to ADEM’s Rachel Lounsberry proceeded the SID application (also dated Oct. 23) and noted that Pilgrim’s was working with local City of Gadsden and state economic officials in the siting of the new plant.

Glover referenced an October 22, 2020 letter from the Gadsden Water Works & Sewer Board’s Superintendent of Environmental Services Mike Lankford which certified that Pilgrim’s Pride was granted “permission to dispose of pretreated process wastewater by discharging into the Gadsden Water collection system for further treatment at the Gadsden West River Wastewater Treatment plant.”

The permit anticipated that the Pilgrim’s Pride plant would generate approximately 60,000 gallons per day of floor drainage and truck drainage wastewater and approximately 600,000 gallons per day of condensate, scrubber, miscellaneous and industrial stormwater wastewater.  The permit states, “The WWPTS (Wastewater Pretreatment System) will be designed for treatment of a total maximum daily influent wastewater flow volume of approximately 660,000 gpd on production days, 5.5 to 6.5 days/week and discharge a maximum wastewater flow volume of 621,000 gpd, 7 days/week into the City of Gadsden municipal sewer system.”

Pilgrim’s Pride’s potential rendering facility includes a 4,800 square foot wastewater treatment plant, with storage tanks, a stormwater lagoon and parking for byproduct carrying trucks. The wastewater pretreatment system’s design draws from an ultimate poultry byproduct material production capacity of around 20,000,000 raw materials per week with a 5.5 to 6.5 day work operation week.

The SID application also discussed future expansions planned for the next three years that might alter wastewater volumes or characteristics. The permit noted that a chicken meal line is an anticipated addition to the facility in the future, with the process estimating to increase wastewater volume by approximately 20 percent. According to the permit, wastewater characteristics should prove similar to other processes and the wastewater pretreatment system has been designed to accommodate this addition.

Coosa Riverkeeper Executive Director Justinn Overton described the wastewater disposal process in a public video on Facebook. Overton focused on three topics: stormwater, wastewater treatment on site and water discharge.

Stormwater originates from the elements, including rain, snow or melted ice. According to the permit, the stormwater generated from the proposed Gadsden plant will be collected, stored and equalized in a stormwater lagoon prior before it is pumped to the wastewater pretreatment system for treatment with process wastewater.

The technical memorandum accompanying the permit application notes that the annual rainfall for the proposed location is 55 inches per year, with the stormwater lagoon’s maximum rainfall collection capping at 1.6 inches per event over the course of three consecutive days of rainfall.

Overton equated 55 inches of rainfall per year to an average of eight days of rain per month. She said that in 2020, the county received 12 days of rainfall that exceeded 1.6 inches. Overton contemplated if the stormwater could be retained on the site.

The permit application contains a list of waste liquids or sludges generated and not disposed of in the sanitary sewer system. Dissolved air flotation skimmings, a water treatment process, will be returned to the plant for protein and fat recovery. Waste biosolids and secondary processing nutrients will be disposed via off-site land application or landfill, while used oil will be recycled off-site.

“This is not just an air, odor or water issue,” said Overton. “We’ve also got to think about what this means for our land and the properties surrounding the land application.”

An attachment within the permit detailed the estimated treated effluent (liquid waste) composition, which included biochemical oxygen demand (BOD), carbonaceous biochemical oxygen demand (CBOD), total suspended solids (TSS), total kjeldahl nitrogen (TKN), Ammonia-N, total nitrogen, Organic N, nitrous oxide emissions, fat, oils and grease, total phosphorus, chemical oxygen demand (COD) and total organic carbon (TOC).

According to the permit, the dissolved air flotation system in place at the plant would remove 50 percent of BOD, 30 percent of TKN, 80 percent of oil and grease, zero Ammonia-N, 80 percent of TSS and 50 percent TP. The permit also states that the facility’s equalization cooling basin would remove 20 percent of BOD, 10 percent of TKN, 50 percent of oil and grease, 10 percent of Ammonia-N and 20 percent of TP.

Following the treatment of these pollutants, the facility will pump the wastewater through the municipal sewer system running from Steele Station Road almost six miles to Wills Creek Drive, the location of the West River Wastewater Treatment Plant. The West River Wastewater Treatment Plant discharges directly into Big Wills Creek. Overton expressed that while Big Wills Creek is on ADEM’s 303(d) list for nutrient impairment.

“Big Wills Creek makes its way into Lake Gadsden,” said Overton. “Lake Gadsden feeds into Neely Henry Lake, which is also receiving the potential stormwater at Canoe Creek. Everything between Lake Gadsden and Canoe Creek could potentially be getting effluent further contamination.”