You have just been hired as the senior environmental manager for a large corporate agricultural complex in the midwestern part of the United States, and you will be responsible for keeping your organization in regulatory compliance with the U.S. Environmental Protection Agency (EPA) and your state’s department of environmental quality (DEQ).

You quickly realize that your company has several active effluent permits (one for combined stormwater/wastewater and one for solid waste hauled off-site) but no pollution prevention plan (P3). After visiting with the company’s executive team, you learn that they have never been alerted of the need for a P3, and they want you to fully explain to them why the organization needs one.

They have asked you to be as comprehensive as possible so that you can ultimately present this to the board of directors for approval. As such, you have decided to conduct a P3 Pre-Assessment Study to study and document the entire situation, knowing that this will help you learn the organization’s complete situation, even while being able to adequately convey it to the board of directors.

Your organization, ABC Agriculture Production, Inc., has the following general operational characteristics:

a. It is situated on 640 acres (one section) of land in southwestern Nebraska.

b. Adjacent to the 640 acres (to the west) is a private rancher’s property sustaining a commercially leased and producing natural gas well.

c. Adjacent to the 640 acres (to the east) is a small, actively running salt-fork of a major river (Platte River).

d. Confined animal feed operations (CAFO) barns and production offices cover approximately 160 acres, with separate, large, full barns for swine, chicken, and beef cattle operations, one feed mill, and six barn-discharge wastewater lagoons.

e. Corn and alfalfa hay fields span 320 acres, with groundwater irrigation wells supplying several large center-pivot irrigation sprinkler systems for both crops.

f. Gypsum (CaSO4-2H2O, or calcium sulfate dihydrate) and caliche (CaCO3, or calcium carbonate) open pit excavation mines are located on the remaining 160 acres, and the products are mined and sold by the truckload.

g. Crops are routinely fertilized with commercial nitrogen fertilizers, weeds are controlled with commercial herbicides, and pests are controlled with commercial pesticides.

h. Animals are routinely vaccinated (injection) and supplemented with vitamins and antibiotics (in both feed and water).

i. Deceased animals’ carcasses are disposed of in a pit and covered with hydrated lime (Ca[OH]2, or calcium hydroxide) daily, with weekly pit coverage for a complete carcass burial.

j. There is an EPA-registered National Pollutant Discharge Elimination System (NPDES) permit active with active outfalls for the CAFO wastewater lagoons and crop fields, operationalized as a combined stormwater/wastewater effluent permit. Total Maximum Daily Load (TMDL) includes limits for the following:

a. Parameter

Limit

DO

> 11.0 mg/L (ppm)

BOD

150 ppm

COD

150 ppm

TSS

100 ppm

TDS

100 ppm

TKN

500 ppm

ammonia (NH3)

300 ppm

fecal coliform

non-detect (ND) (via EPA method 1681)

glyphosate (herbicide)

ND

atrazine (herbicide)

ND

chlorpyrifos (pesticide)

ND

malathion (pesticide)

ND

Phosphorous (P)

2.5 ppm

Potassium (K)

1.5 ppm

Calcium (Ca)

2.0 ppm

Magnesium (Mg)

0.5 ppm

pH

6.5 – 8.5

pharmaceutical scan

0.0001 ppm (via EPA method 1694)

temperature

± 10% ambient water temperatures

oil and grease

15 ppm (via EPA method 1664)

turbidity

< 10 %

flow

< 5,000 gallons per day (gpd)

k. There is a hazardous waste permit for disposing of all discarded pesticide, herbicide, and pharmaceutical wastes.

l. Wind speeds average 12 mph, and rainfall averages 21 inches/year.

m. High/Low temps range from winter (40°F/14°F) to summer (91°F/63°F).

n. Average humidity is 65.8% with an average dew point of 37.9°F.

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