ADDENDUM

Applicant: John Morrell and Company

Permit Number: SD-0000078

Contact Person: Mr. Cary Pieterick, Direct or, Environmental Affairs

1400 N Weber Avenue Sioux Falls, SD 57103 (605) 338-8200 Permit Type: Minor Industrial Facility -- Modification

PURPOSE OF MODIFICATION

This permit is being modified in accordance with the Administrative Rules of South Dakota (ARSD) §74:52:04:03. Typographical errors were discovered re lated to effluent monitoring. These errors are summarized as follows:

• Monitoring for fecal coliform was intended to be required year-round. However, the permit only requires monitoring from May through September;

• Daily maximum rather than 7-day average BOD 5 and total suspended solids results must be reported; and

• BOD 5 and total suspended solids loading resu lts (in lbs/day) mu st be reported.

Appropriate modifications have been incorporated into the permit. These changes all qualify as minor modifications, and are not subject to public notice requirements.

ENDANGERED SPECIES

This is a modification to the existing permit. No listed endangered species are expected to be impacted by activities related to this modification.

PERMIT EXPIRATION

The current permit expiration date of March 31, 2005, shall remain in effect.

CONTACT

Any questions pertaining to this modificati on can be directed to Lonnie Steinke, Natural Resources Engineer, at (605) 773-3351.

July 5, 2000STATEMENT OF BASIS

Applicant: John Morrell and Company

Permit Number: SD-0000078

Contact Person: Mr. Cary Pieterick, Director, Environmental Affairs

1400 N Weber Avenue Sioux Falls, SD 57103 (605) 338-8200 Permit Type: Minor Industrial Facility -- Renewal

DESCRIPTION

John Morrell and Company operates a meat packing facility located in Sioux Falls in Section 9, Township 101 North, Range 49 West (Latitude 43 o 33' 55", Longitude 96 o 43' 12" - navigation-quality GPS).

Morrell is a complex slaughterhouse with a full line of meat processing, where approximately 20,000 hogs are slaughtered per day. The hogs are killed, and the carcasses are trimmed, washed, and hung in cooling rooms where they are later processed into bacon, hams, and franks. The production of sausages, canning of meat, and other edible and inedible products are also included in the production processes.

Skins are removed from the pigs, cured, and shipped to tanners. All other by-products are rendered including the blood. In addition, some outside products are brought in for rendering or processing.

Morrell produces a maximum flow of 3.5 million gallons per day (MGD) during its daily operations. A breakdown of the wastewater production follows:

FLOW (MGD) Meat Processing Operations Meat Processing 2.25 Cooling Water/Boiler Blowdown 0.125 Defrosting wastewater 0.05 Sanitary wastewater 0.075 Total Meat Processing Flow - 2.5

Rendering/Stockyard Operations Rendering 0.62 Spray Water/Stockyard Cleanup 0.35 Sanitary wastewater 0.03 Total Rendering/Stockyard Flow - 1.0

Engine/Boiler Blowdown 0.01

Total Plant Flow 3.51 Total Flow

1The wastewater treatment facility, completed in 1983, provides tertiary treatment and consists of the following processes:

Influent wastewater from two segregat ed wastestreams is pumped through four rotostrainers. One wastestream is pretreated in two dissolved air flotation tanks thatcurrently operate as primary clarifiers. The two segregated wastestreams flow to a fourcell covered anaerobic lagoon system. This lagoon system removes BOD and suspended solids, and also acts as an equalizing basin. The five-day packing plant flow is equalized over a seven-day period. Lagoon effluent flows in parallel through two sets of concrete

aeration basins. Aeration basin effluent flows to two final clarifiers, and then to four gravity filters for polishing. The filters can be bypassed if clarifier supernatant is of acceptable quality. Following filtration, the flow is directed to the chlorination/dechlorination system, and then aerat ed in the post aeration basin. Effluent is then pumped to the discharge structure at the Big Sioux River.

Biosolids thickening occurs in a 50-foot diameter lagoon clarifier/thickener. Thickened biosolids is pumped to a belt filter press, dewatered, and disposed of in landfill facilities for land treatment by a contract hauler.

In 1998, the facility installed a chemical treatment system to enhance the removal of grease and solids from the existing dissolved air flotation units. A new sludge press and building was installed to dewater recovered material from the dissolved air flotation units.

A portion of the wastewater can be pretreated and discharged to Sioux Falls' sanitary sewer system. This discharge occurs following primary clarification. Between 0 to 1.2 MGD is typically is discharged to the Sioux Falls WWTF.

Average design flow is 3.5 MGD, with a peak design flow of 4.2 MGD. Actual average daily flows are approximately 2.5 MGD.

RECEIVING WATERS

Any discharge from the facility will enter the Big Sioux River, which is classified by the South Dakota Surface Water Quality Standards (SDSWQS), Administrative Rules of South Dakota (ARSD), Chapters 74:51:01 and 74:51: 03, for the following beneficial uses:

(1) Domestic water supply waters; (5) Warmwater semipermanent fish life propagation waters; (7) Immersion recreation waters; (8) Limited contact recreation waters; (9) Fish and wildlife propagation, recreation, and stock watering waters; and (10) Irrigation waters.

Approximately 1/8 mile below the discharge, the Big Sioux River is classified by the SDSWQS, ARSD, Chapters 74:51:01 and 74:51: 03, for the following beneficial uses:

(5) Warmwater semipermanent fish life propagation waters;

2(7) Immersion recreation waters; (8) Limited contact recreation waters; (9) Fish and wildlife propagation, recreation, and stock watering waters; and (10) Irrigation waters.

ANTIDEGRADATION

The South Dakota Department of Environment and Natural Resources (SDDENR) has fulfilled the antidegradation review requirements for this permit. In accordance with South Dakota’s Antidegradation Implementation Procedure and the SDSWQS, no further review is required for this discharge. The results of this review are included in Attachment B.

SELF MONITORING DATA

Attachment A summarizes Morrell’s effluent mon itoring data. This data shows consistent compliance with current effluent limits.

INSPECTIONS

The most recent “compliance evaluation” inspection was performed on June 29, 1999 by SDDENR. The results of this inspection were not available at the time this statement of

basis was drafted.

EFFLUENT LIMITS

The permittee shall comply with the effluent limits specified below. These limits are based on the SDSWQS, the Best Practical C ontrol Technology (BPT) currently available in 40 CFR 432.22, Total Maximum Daily Load s (TMDLs) developed for the Big Sioux River, and Best Professional Judgement (BPJ):

Outfall 001 -- Any discharge from the wastew ater treatment facility to the Big Sioux River, approximately 1/8 mile a bove the Big Sioux Diversion Ditch (Latitude 43 o 34' 00", Longitude 96 o 43' 11" - navigation-quality GPS).

1. The five-day biochemical oxygen demand shall not exceed the limits specified in the table below. The 30-day average limits are based on a TMDL developed for the Big Sioux River near Sioux Falls, and BPJ. The dissolved oxygen TMDL indicates that 30-day average BOD 5 loadings listed in the table below (assuming a

CBOD 5 /BOD 5 ratio of 0.75) maintained the minimum dissolved oxygen SDSWQS of 5.0 mg/L for each season, when combined with the proposed dissolved oxygen and ammonia limits. The daily maximum limits are based on BPT in 40 CFR 432.22, Subpart B. A total live weight kill (LWK) of 4,401,564 lbs per day was reported on the permit application. This value, multiplied by the values listed in 40 CFR 432.22(a) yields the daily maximum limits listed in the table below.

Five-Day Biochemical Oxygen Demand Limit

3Season 30-Day Average (lbs/day) Daily Maximum (lbs/day)

Spring (April - May) 1000 1849 Summer (June - August) 667 1849 Fall (September - October) 1000 1849 Winter (November - March) 1000 1849

30-day average limits were also comput ed using BPT values listed in 40 CFR 432.22(a). However, the 30-day average TMDL-derived limits for BOD 5 were more stringent, so those values were used instead.

2. The Total Suspended Solids concentrati on shall not exceed 1100 lbs/day (30-day average) and 2200 lbs/day (daily maximum). These limits are based on BPT in 40 CFR 432.22, Subpart B. A total live weight kill (LWK) of 4,401,564 lbs per day was reported on the permit application (1998-99 re cords). This value, multiplied by the values listed in 40 CFR 432.22(a) yields the proposed limits.

3. The pH shall not be less than 6.5 units nor greater than 9.0 units in any single analysis and/or measurement. These limits are based on the warmwater semipermanent fish life propagation waters classification of the Big Sioux River, and the SDSWQS (ARSD §74:51:01:48). The BPT limits in 40 CFR 432.22, Subpart B (6.0 to 9.0) were also considered in developing the limits for pH, but were less stringent than the proposed water quality-based limits.

pH shall be taken within 15 minutes of sa mple collection with a pH meter. The pH meter must be capable of simultaneous calibration to two points on the pH scale that bracket the expected pH and are appr oximately three standard units apart. The pH meter must read to 0.01 standard units and be equipped with temperature compensation adjustment.

4. Fecal coliform organisms from May 1 to September 30 may not exceed a concentration of 200 per 100 milliliters as a geometric mean based on a minimum of five samples obtained during separa te 24-hour periods for any 30-day period, and they may not exceed this value in more than 20 percent of the samples examined in this 30-day period. Fecal coliform organisms may not exceed 400 per 100 milliliters in any one sample. This limit shall apply year-round. These limits

are based on the immersion recreation waters classification of the Big Sioux River, the SDSWQS (ARSD §74:51:01:50), and BPT limits in 40 CFR 432.22, Subpart B.

5. The oil and grease concentration shall not exceed 10 mg/L (daily maximum) or impart a visible film or sheen to the surface of the water or to the adjoining shorelines. The oil and grease loading shall not exceed 352 lbs/day as a 30-day average limit. The daily maximum limits are based on the fish and wildlife

6. propagation, recreation, and stock watering waters classification of the Big Sioux River and the SDSWQS (ARSD §§74:51: 01:52 and 74:51:01:10). The 30-day

4average limit is based on BPT in 40 CFR 432.22, Subpart B. A total live weight kill (LWK) of 4,401,564 lbs per day was reported on the permit application. This value, multiplied by the value listed in 40 CFR 432.22(a) yields the 30-day average limit. 40 CFR 432.22, Subpart B also contains a daily maximum mass loading limit. However, the proposed 10 mg/L daily maximum water quality-based limit is far more stringent than the BPT daily maximum limit. Therefore, only the daily maximum water qualitybased limit and 30-day average BPT-based limits are being applied.

7. The minimum dissolved oxygen shall not fa ll below the values specified in the following table. These limits are base d on the SDSWQS and a TMDL developed in accordance with section 303(d) of the fe deral Clean Water Act, and BPJ. The

TMDL relies on EPA’s STREAMDO IV mode l, the surface water quality standard for dissolved oxygen of 5.0 mg/L, and BPJ. See the TMDL for Ammonia and Dissolved Oxygen in the Big Sioux River near Sioux Falls, 1999 for more detail.

The summer and fall seasonal limits are ba sed on the wasteload allocation (WLA) as determined in the TMDL. The TMDL indicates that a WLA of 0.0 mg/L would be protective of the SDSWQS for the sp ring season. However, a limit of 5.0 mg/L is being proposed for all seasons, based on BPJ and the SDSWQS for dissolved oxygen of 5.0 mg/L for waters classified for warmwater semipermanent fish life propagation (ARSD §74:51:01:48).

Dissolved Oxygen Limits

Season Instantaneous Minimum (mg/L)

Spring (April - May) 5.0 Summer (June – August) 5.0 Fall (September – October) 5.0 Winter (November – March) 5.0

For the winter season, the proposed limit fo r dissolved oxygen is less stringent than the current permit limit. However, back sliding is allowed in this case, per §402(o)(1) and §303(d)(4) of the federal Cl ean Water Act, as the Big Sioux River is currently meeting SDSWQS for dissolved oxygen, and the proposed limit ensures that SDSWQS for dissolved oxygen will continue to be maintained. In addition, the change is not prohibited by South Dakota’s Antidegradation Implementation Procedure, 1999.

8. The ammonia-nitrogen concentration shall not exceed the limits specified in the table below. These limits are based on a TMDL developed in accordance with section 303(d) of the federal Clean Wate r Act, and the SDSWQS. The TMDL is based on the background water quality of th e Big Sioux River near Sioux Falls, the surface water quality standard for un-ionized ammonia of 0.04 mg/L, and BPJ. See

the TMDL for Ammonia and Dissolved Oxygen in the Big Sioux River near Sioux Falls, 1999 for more detail. The 0.04 mg/L instream standard for un-ionized

ammonia is based on the warmwater semi permanent fish life propagation waters classification of the Big Sioux Rive r and the SDSWQS (ARSD §74:51:01:48).

5The TMDL contains seasonal computations of an ammonia wasteload allocation, to be allocated among point sources. Morre ll’s 30-day average ammonia limits are based on their allocation of the allowable wasteload. The daily maximum limits were determined by multiplying the 30-day average limits by 1.75, in accordance with the SDSWQS and ARSD §74:51:01:48.

Total Ammonia Limits (as N)

Season 30-Day Average (lbs/day) Daily Maximum (lbs/day)

Spring (April - May) 70 123 Summer (June - August) 58 102 Fall (September - October) 75 131 Winter (November - March) 163 285

For the winter season, the proposed limit for ammonia is less stringent than the current permit limit. However, backslidi ng is allowed in this case, per §402(o)(1) and §303(d)(4) of the federal Clean Water Ac t, as the Big Sioux River is currently meeting SDSWQS for ammonia, and the proposed limit ensures that SDSWQS for ammonia will continue to be maintained. In addition, the change is not prohibited by South Dakota’s Antidegradation Implementation Procedure, 1999.

SDDENR considers the analytical detection limit for ammonia to be 0.01 mg/L. If

the effluent ammonia concentration is less than the analytical detection limit, "0" shall be used for reporting and averaging purposes.

9. The total residual chlorine concentration shall not exceed 0.019 mg/L. This limit is based on the warmwater semipermanent fish life propagation waters classification of the Big Sioux River and the SDSWQS (ARSD §74:51:01:48).

SDDENR considers the analytical detection limit for total residual chlorine to be 0.05 mg/L. If the effluent total residual chlorine concentration is less than the analytical detection limit, "0" shall be used for reporting purposes. Total residual chlorine measurements below 0.05 mg/L shall not be c onsidered violations of the total residual

chlorine limit.

10. There shall be no Chronic Toxicity, as m easured by the Whole Effluent Toxicity

test. This limit is based on the USEP A-Region VIII WET policy for South Dakota

and BPJ.

Temperature, nitrates, CBOD 5 , and flow shall be monitored, but will not have limits. These parameters shall be monitored to aid in the development of future Total Maximum Daily Loads.

The Big Sioux River is classified as a dri nking water supply at the point where Morrell’s discharge enters the river. Therefore, SDSWQS for total coliform apply to this portion of

6the Big Sioux River. However, this classifi cation is “removed” 1/8 mile downstream, and the SDSWQS for total coliform no longer applies. Since this 1/8 mile portion of the river is not actually being used as a drinking water source, no effluent limits or monitoring for total coliform are being required in the permit.

SELF MONITORING REQUIREMENTS

As a minimum, upon the effective date of this permit, the following parameters shall be monitored at the frequency and with the t ype of measurement indicated; samples or measurements shall be representative of the volume and nature of the discharge.

Effluent Characteristic Frequency Reporting Values 1 Sample Type

Rate of Discharge, MGD Continuous daily maximum;

30-day average Instantaneous

Oil and Grease, mg/L Daily presence or absence of sheen; daily

maximum Visual/Grab 2

Oil and Grease, mg/L Weekly daily maximum Grab 2

Oil and Grease, lbs/day 8 Monthly 30-day average Calculated

pH, standard units 7 Daily daily minimum;

daily maximum Instantaneous 3

Total Residual Chlorine, mg/L

(Required only if the effluent is chlorinated) Daily daily maximum 4 Grab

Dissolved Oxygen, mg/L Five times per week daily minimum Grab

Five-Day Biochemical Oxygen Demand, mg/L Five times per week 7-day average;

30-day average Composite

Total Suspended Solids, mg/L Five times per week 7-day average;

30-day average Composite

1 See definitions, Part I.A. of permit.

2 The presence or absence of an oil sh een shall be visually monitored. In the event that an oil sheen or

floating oil is observed during discharge, grab samples shall be taken immediately, analyzed and reported. At a minimum, a sample shall be taken and analyzed weekly for oil and grease.

3 pH is to be taken within 15 minutes of sample collection with a pH meter. The pH meter must be capable of

simultaneous calibration to two points on the pH scale that bracket the expected pH and are approximately three standard units apart. The pH meter must read to 0.01 standard units and be equipped with temperature compensation adjustment.

4 SDDENR considers the analytical detection limit for total residual chlorine to be 0.05 mg/L and for

ammonia to be 0.01 mg/L. If the effluent value is less than the analytical detection limit, "0" shall be used for reporting and averaging purposes.

7Reporting Values 1 Effluent Characteristic Frequency Sample Type

Fecal Coliform, no./l00 mL Five times per week 5 daily maximum;

30-day geometric

mean Grab

Water Temperature, o C 7 Five Times per week daily maximum;

30-day average Instantaneous 6

Ammonia-Nitrogen, mg/L (as N) 7 Three times per week daily maximum; 4

30-day average Composite

Ammonia-Nitrogen, lbs/day (as N) 8 As sample results are

received daily maximum;

30-day average Calculated

Nitrates, mg/L (as N) Monthly daily maximum;

30-day average Grab or Composite

Five-Day Carbonaceous Biochemical Oxygen Demand (CBOD 5 ), mg/L Monthly daily maximum;

30-day average Grab or Composite

Chronic Whole Effluent Toxicity Quarterly 9 see Part I.C.3 Grab

5 For fecal coliform, all samples co llected in a 30-day period shall be used in determining the geometric

mean. The sampling protocol for fecal coliform only app lies if the discharge occurs between May 1 and September 30.

6 The water temperature of the effluent shall be taken as a field measurement at the time of sampling.

Measurement shall be made with a mercury-filled, or dial type thermometer, or a thermistor. Readings shall be reported to the nearest whole degree Celsius.

7 The pH and temperature of the effluent shall be determined during when ammonia samples are collected.

8 Daily loading (lbs/day) shall be calculated by multiplying the discharge flow rate (million gallons per day)

by the measured pollutant concentration (mg/L) times 8.34 (a conversion factor). 30-day average loading (lbs/day) shall be calculated by averaging the computed daily loadings (lbs/day).

9 The permittee shall obtain and analyze a valid chronic whole effluent toxicity sample at least once during

each calendar quarter.

All samples collected and analyzed using approved analytical methods, during the 7-day or 30-day period, are to be used in determining th e averages. If only one sample is collected during the period, it must be considered the same as the average for that period. The permittee always has the option of collecting a dditional samples if appropriate. Discharge Monitoring Report Forms (DMRs) must be si gned by the principal executive officer and

submitted to SDDENR and EPA monthly

.

Monitoring shall consist of inspections of the wastewater treatment facility daily to determine if proper operation and maintena nce procedures are being undertaken.

Documentation of each of these visits shall be maintained to be reviewed by SDDENR or EPA personnel when an inspection occurs.

8WHOLE EFFLUENT TOXICITY TESTING

Effective immediately, the permittee shall samp le and test for Chronic Whole Effluent Toxicity (WET) on a quarterly basis, using Ceriodaphnia and fathead minnows as test species. The permittee may request to alternate test species each quarter.

There shall be no chronic toxicity as measured by the 25% inhibition concentration (IC

25 ) calculated on the basis of test organism surviv al and growth or survival and reproduction. A multi-dilution test consisting of five concentra tions and a control is required for the chronic test. Chronic toxicity occurs when the IC

25 is less than or equal to the values in the table below. These dilutions are based on the seasonal receiving water low flow dilution ratio, USEPA-Region VIII WET policy for South Dakota, and BPJ.

Chronic Whole Effluent Toxicity Testing Summary

Season Chronic WET Test IC 25

Spring (Apr - May) 36% Summer (Jun – Aug) 36% Fall (Sep – Oct) 48% Winter (Nov - Mar) 47%

The IC 25 is computed using the following equation:



### Q5 adjusted 7 f low effluen t design equalizeds M orrell' ion Concentrat IC
25 

### =

The values for the adjusted 7Q5 were obt ained from the Total Maximum Daily Load developed for the Big Sioux River near Si oux Falls. This value takes into account SDDENR’s Mixing Zone and Dilution Procedures , and includes the flow from the permittee’s discharge.

The current permit contains monitoring requirements for only single-dilution chronic whole effluent toxicity tests. Due to changes in the USEPA-Region VIII WET policy for South Dakota, chronic toxicity testing is being changed to require multi-dilution tests.

Morrells has requested that lab water, rather than receiving water, be allowed for dilution water. This request was granted, and may be continued in the proposed permit.

ENDANGERED SPECIES

This is a renewal of an existing permit. No listed endangered species are expected to be impacted by activities related to this permit.

9PERMIT EXPIRATION

A five-year permit is recommended.

PERMIT CONTACT

Any questions pertaining to this Statement of Basis can be directed to Lonnie Steinke, Natural Resources Engineer at (605) 773-3351.

February 8, 2000

10

### Attachment A

DMR Data for John Morrell and Company

A-1

### Copies of Discharge Monito ring Report Summary Data are Available Upon Request

A-2

### Attachment B

40 CFR 432

Effluent Guidelines and Standards for the Meat Products Point Source Category

B-1

### Attachment C

Antidegradation Review

C-1Permit Type: Major Industrial Applicant: John Morrell and Company

Date Received: 09/25/ 98 Permit #: SD-0000078 County: Minnehaha Legal Description: S9 T101N R49W Receiving Stream: Big Sioux River Classification: 1 5 7 8 9 10 If the discharge affects a downstream waterbody with a higher use classification, list its

name and uses: N/A

APPLICABILITY

1. Is the permit or the stream segment exempt from the antidegradation review process under ARSD

74:51:01? Yes No If no, go to question #2. If yes, check those reasons why the review is not required:

Existing facility covered under a surface water discharge permit is ope rating at or below design flows and pollutant loadings; *Existing effluent quality from a surface water discharge permitted fac ility is in compliance with all discharge permit limits; *Existing surface water discharge permittee was discharging to the cu rrent stream segment prior to March 27, 1973, and the quality and quantity of the discharge has not degraded the water quality of that segment as it existed on March 27, 1973; *The existing surface water discharge permittee, with DENR approval, has upgraded or built new

wastewater treatment facilities between March 27, 1973, and July 1, 1988; The existing surface water discharge permittee discharges to a receiving water assigned only the beneficial uses of (9) and (10); the discharge is not expected to contain toxic pollutants in concentrations that may cause an impact to the receiving stream; and DENR has documented that the stream cannot attain a higher use classification. This exemption does not apply to discharges that may cause impacts to downstream segments that are of higher quality; Receiving water meets Tier 1 wa ters criteria. Any permitted di scharge must meet water quality standards; or The permitted discharge will be authorized by a Section 404 Corps of Engineers Permit, will undergo a similar review process in the i ssuance of that permit, and will be issued a 401 certification by the department, indicating compliance with the state’s antidegradation provisions.

*An antidegradation review is not required where the proposal is to maintain or improve the existing effluent levels and conditions. Proposals for increased effluent levels, in these categories of activities are subject to review.

No further review required.

C-2ANTIDEGRADATION REVIEW SUMMARY

2. The outcome of the review is:
A formal antidegradation review was not require d for reasons stated in this worksheet. Any permitted discharge must ensure water quality standards will not be violated. The review has determined that degradation of water quality should not be allowed. Any permitted discharge would have to meet effluent limits or cond itions that would not result in any degradation estimated through appropriate modeling techniques based on ambient water quality in the receiving stream, or pursue an a lternative to discharging to the waterbody. The review has determined that the discharge will cause an insignificant change in water quality in the receiving stream. The appropria te agency may proceed with permit issuance with the appropriate conditions to ensure water quality standards are met. The review has determined, with public input , that the permitted discharge is allowed to discharge effluent at concentrations determined through a total maximum daily load (TMDL). The TMDL will determine the appropriate effluent limits based on the upstream ambient water quality and the water quality standa rd(s) of the receiving stream. The review has determined that the discharge is allowed. However, the full assimilative capacity of the receiving stream cannot be used in developing the permit effluent limits or conditions. In this case, a TMDL must be completed based on the upstream ambient water quality and the assimilative capacity allowed by the antidegradation review.

Other:

3. Describe any other requirements to implem ent antidegradation or any special conditions that are required as a result of this antidegradation review:

Lonnie Steinke, Natural Resources Engineer 7/01/99

Reviewer Date

Kelli Buscher, P.E., Natural Resources Engineer 7/01/99 Program Supervisor or Team Leader Date

C-3