Contract analysis

Section 1: Introduction and Purpose of Application 1.1 Overview. Greenfield Agricultural Partners LLC ("GAP"), an Iowa limited liability company organized under the laws of the State of Iowa (Iowa Secretary of State Filing No. 548213; Employer Identification Number 46-3827194), hereby submits this application narrative in support of its National Pollutant Discharge Elimination System ("NPDES") Individual Permit appli

Section 2: Facility Description 2.1 Project Overview The Muscatine Expansion Facility is a new greenfield soybean processing and specialty fertilizer blending facility to be constructed by GAP on a 147-acre site in Muscatine County, Iowa. The MEF represents a significant expansion of GAP's existing operations and will be the company's first fully integrated soybean crush and specialty fertilizer blending facility. Th

Section 3: Wastewater Sources and Characterization 3.1 Process Wastewater Sources The MEF will generate process wastewater from several distinct sources within the facility. All process wastewater streams will be combined and routed to the on-site wastewater treatment system for treatment prior to discharge through Outfall 001. The principal process wastewater sources are described below. Soybean Wash Water. The soyb

Section 4: Receiving Water Characterization 4.1 Receiving Water Identification The proposed receiving water for both Outfall 001 (treated process wastewater) and Outfall 002 (industrial stormwater) is Sweetland Creek, a perennial stream located in Muscatine County, Iowa. Sweetland Creek originates approximately seven miles northwest of the MEF site, flows generally southeastward through agricultural and rural residen

Section 5: Discharge Points — Outfall Descriptions 5.1 Outfall 001 — Treated Process Wastewater Outfall 001 will serve as the discharge point for all treated process wastewater from the MEF. The characteristics of Outfall 001 are summarized below: Discharge Type: Continuous during facility operations. The facility is expected to operate approximately 345 days per year, with approximately 20 days of scheduled downtime

Section 6: Wastewater Treatment System Design 6.1 Treatment System Overview The MEF wastewater treatment system has been designed to treat the combined process wastewater flow of 0.38 MGD from all process wastewater sources identified in Section 3.1 of this narrative. The treatment system will produce a treated effluent suitable for discharge through Outfall 001 that meets or exceeds the proposed effluent limitations

1. Equalization Basin — Flow and load equalization to dampen peak flows and concentration variations associated with batch processing operations.

2. Dissolved Air Flotation (DAF) Unit — Physical-chemical separation of oils, greases, and suspended solids from the equalized wastewater.

3. Aerated Lagoon System (Three-Cell) — Biological treatment for BOD₅ removal, nitrification of ammonia-nitrogen, and additional settling and polishing.

4. UV Disinfection System — Ultraviolet disinfection for reduction of fecal coliform bacteria to meet Class A1 bacteriological criteria.

5. Outfall 001 — Discharge of treated effluent to Sweetland Creek. The treatment system was designed by Ridgeline Engineering Group LLC under the direction of Thomas Novak, P.E., with wastewater characterization inputs provided by Pinnacle Environmental Consultants Inc. The treatment system design drawings and specifications are included as Appendix E, and the process flow diagrams and mass-balance data are included

Section 7: Proposed Effluent Limits 7.1 Basis for Proposed Limits The proposed effluent limitations for Outfall 001 have been developed based on the following considerations: • Iowa Water Quality Standards: Iowa Administrative Code 567—Chapter 61 establishes water quality criteria for the protection of designated uses of surface waters, including the Class A1 (Primary Contact Recreation) and Class B(WW) (Warm Water A

Section 8: Antidegradation Review 8.1 Regulatory Framework Iowa's antidegradation policy, codified at Iowa Administrative Code 567—61.2(2), establishes a framework for the protection of water quality in the state's surface waters. Iowa's antidegradation policy implements the federal antidegradation requirements set forth at 40 C.F.R. § 131.12 and is consistent with the three-tier antidegradation framework established