### MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

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### INTEROFFICE COMMUNICATION

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TO: FILE : JBS Plainwell Inc

- MI0050628

FROM Alvin Lam

, Lakes Michigan and Superior Permits Unit

, Water Resources Division

DATE: April 5, 2011

SUBJECT : Treatment Technology Based Effluent Limits (TTBELs) Recommendation

An application was submitted on April 6, 2010 , requesting reissuance of an NPDES permit for JBS

Plainwell Inc

. The facility is a complex beef slaughterhouse with extensive by

- product p rocessing. The

term “complex slaughterhouse” means a slaughterhouse that accomplishes extensive by

- product

processing, usually at least three of such operations as rendering, paunch and viscera handling, blo o d

processing, hide processing, or hair processi ng. The by

- product processing at this facility includes

rendering, paunch handling, and hide processing. The SIC code for this industry is 2011 . Th is

production process is regulated by 40 CFR 432

– Meat Products Point Source Category, Subpart B

– Comple x Slaughterhouse Subcategory. These regulations provide mass loading limitations based on the

daily slaughter rate expressed in LWK (live weight killed) which is defined as the total weight of the total

number of animals slaughtered during the time to whi ch the effluent limitations apply. The facility

processes a live weight of 10 million pounds in five days per week. The finished product is 5 million

pounds per week.

Efflu ent Limitations Recommendations

The following Treatment Technology Based Efflue nt Limitations are based on best practicable control

technology currently available (BPT) specified in §432.22(a) and standards of performance for new

sources (NSPS) specified in §432. 25(a).

Maximum Maximum

Parameters Monthly Daily

BOD 5 420 lbs/day 840 l bs/day

TSS 500 lbs/day 1,000 lbs/day

Oil & Grease 160 lbs/day 320 lbs/day

Fecal Coliform Bacteria 400 cts/100 ml 400 cts/100 ml

Ammonia 480 lbs/day 960 lbs/day

pH within the range 6.0 to 9.0

Calculations

Concentrations for calculating BPT and NSPS effluent limitations.

Maximum Maximum

Parameters Monthly Daily

lb/1,000 lb LWK

BOD 5 0.21 0.42

TSS 0.25 0.5 0

Oil & Grease 0.08 0.16

Ammonia 0.24 0.48

Fecal Coliform Bacteria 400 cts/100 ml 400 cts/100 ml

pH within the range 6.0 to 9.0TTBEL Memo

Designated Name: JBS Plainwell Inc

NPDES Permit No. MI0050628

April 5, 2011

Page 2

For LWK of 10 million pounds/week and production of 5 days/week, the effluent limitations are calculated

as shown below:

BOD 5 (monthly average) = (10,000,000) (0.21)/(5) (1,000) = 420 lbs/day

(daily maximum) = (10,000,000) (0.42)/(5) (1,000) = 840 lbs/day

TSS (monthly average) = (10,000,000) (0.25)/(5) (1,0 00) = 500 lbs/day

(daily maximum) = (10,000,000) (0.50)/(5) (1,000) = 1,000 lbs/day

Oil & Grease (monthly average) = (10,000,000) (0.08)/(5) (1,000) = 160 lbs/day

(daily maximum) = (10,000,000) (0.16)/(5) (1,000) = 320 lbs/day

Ammonia (monthly average) = (10,000,000) (0.24)/(5) (1,000) = 480 lbs/day

(daily maximum) = (10,000,000) (0.48)/(5) (1,000) = 960 lbs/day

Comments & Additional Recommendations

The production rate reported in the application is the same as used for the current permit and the current

permit retains the loading limits for BOD 5 , TSS, Oil & Grease, and Ammonia from the previous permit. It

is recommended that the same loading limits in the current permit be retained in the reissued permit.