Document KRwQz72R5J4q9DmOgGz8X3BnN

U.S. Environmental Protection Agency Region 5 Purpose: Industrial User Pretreatment Compliance Inspection Facility: Green Plains Mount Vernon LLC 8999 W Franklin Road Mount Vernon, IN 47620 Inspection Date: February 23-24, 2021 EPA Representatives: Rajen Patel, Environmental Engineer, 312-886-5741 Cheryl Burdett, Environmental Scientist, 312-886-1463 Facility Representatives: Daniel Labhart, Plant Manager, 812-270-1411 Ryan Rezac, Water & Waste Compliance Manager, 402-952-4839 Chelsea Holscher, Lab Manager, 812-890-8844 Sarah Oskins, Senior Lab Technician & Wastewater Operator, 812-454-5648 Report Prepared by: Rajen Patel Water Enforcement and Compliance Assurance Branch, Section 2 patel.rajen@epa.gov RAJEN PATEL Digitally signed by RAJEN PATEL Date: 2021.04.27 18:43:41 -05'00' Inspector Signature: __________________________________ Approver Name and Title: Ryan Bahr, Chief, Section 2 Water Enforcement and Compliance Assurance Branch Digitally signed by RYAN BAHR RYAN BAHR Date: 2021.04.27 Approver Signature And Date: ____________________1_9_:0_2_:4_9__-0_5_'0_0_'_______ BACKGROUND The purpose of the inspection was to describe, evaluate, and document compliance with the Clean Water Act (CWA) and associated pretreatment regulations with respect to the Green Plains facility located at 8999 West Franklin Road, Mount Vernon, Indiana 47620 (the facility). There are two entities (Approval and Control Authority) that have the responsibility to develop and implement the federal pretreatment program. An Approval Authority is either the state Director of a National Pollutant Discharge Elimination System (NPDES) in an authorized state with an EPA-approved pretreatment program or the EPA Regional Administrator in a state without an approved pretreatment program. A Control Authority is either a Publicly Owned Treatment Works (POTW) with an approved pretreatment program or the Approval Authority for any POTW that does not have an approved program. The State of Indiana and City of Mount Vernon POTW do not have an EPA-approved pretreatment program. EPA is the "Control Authority" in Indiana and has the enforcement authority pertaining to the pretreatment requirements at Green Plains. This ethanol manufacturing facility is authorized to discharge in accordance with effluent limitations, monitoring requirements and other conditions set forth in the NPDES Permit (Permit Number IN0063096) issued by the Indiana Department of Environmental Management (IDEM). The facility discharges into the unnamed ditches to the Ohio River. The current permit is valid through July 31, 2024. The facility's stormwater is regulated under its NPDES discharge permit - IN0063096 requiring the facility to monitor and comply with non-numerical limits. The facility has an IDEM approved Stormwater Pollution Prevention Plan (SWPPP). The permit requires the facility to sample (from both outfalls) and report its stormwater analysis biannually. EPA has developed nationally applicable pretreatment standards under CWA section 307(b) in its General Pretreatment Regulations for Existing and New Sources of Pollution at 40 CFR Part 403. Such pretreatment standards are directly applicable to indirect dischargers based on the processes conducted at the facilities and the applicability of those standards. Green Plains discharges to the City of Mount Vernon's Publicly Owned Treatment Works (POTW). The applicable technology-based standards for the production of ethanol are contained in 40 CFR 414 - Organic Chemicals, Plastics, and Synthetic Fibers; Subpart F - Commodity Organic Chemicals Point Source Category. SITE INSPECTION Opening Conference EPA representatives entered the facility at 2 pm on February 23, 2021. We signed in at the reception desk and were greeted by Daniel Labhart, Plant Manager at the facility. 2 Mr. Labhart then escorted us to a common sitting area for an opening conference with him, Ryan Rezac, Water & Waste Compliance Manager and Sarah Oskins, Senior Lab Technician & Wastewater Operator. The EPA inspection team presented credentials to the facility representatives and began the opening conference at 2:40 pm. I explained to the representatives that EPA was performing the CWA compliance evaluation inspection of the facility operations and we would evaluate its wastewater discharges and take photos during the inspection. I also mentioned that confidential business information (CBI) may be declared for materials reviewed during the inspection. I informed the Green Plains representatives that they would receive copies of the photographs collected during the inspection as an attachment to the inspection report. The opening conference began with general questions about the facility's background, manufacturing processes, any applicable wastewater treatment process, and compliance reporting history. Facility Background I asked Mr. Labhart about the nature of products and the company's history of operations. He stated that Green Plains Inc., is an Iowa corporation, founded in 2004 as a producer of low carbon fuels and that Green Plains acquired this facility from Abengoa Bioenergy in 2016. Green Plains Inc., owns and operates 12 biorefineries in Indiana, Illinois, Iowa, Minnesota, Nebraska, and Tennessee with total US Capacity to produce 1.0 billion gallons of biofuels annually. Green Plains Mount Vernon, LLC (Green Plains) is classified under Standard Industrial Classification (SIC) Code 2869 - Industrial Organic Chemicals, Not Elsewhere Classified. The facility manufactures fuel-grade ethanol, distillers grains, and corn oil. Green Plains has the capacity to produce a maximum of 90 million gallons of denatured fuel-grade ethanol per year. Using corn as a feed stock, the starch is converted to sugars, and then the sugars to ethanol. The ethanol is then blended with a denaturant (natural gasoline) to render the final product unfit for consumption. A map showing the location of the facility is attached as Attachment 2/Figure 1. Mr. Labhart stated that Green Plains operates three shifts per day, seven days a week, with two scheduled shutdowns (spring and fall) for maintenance and process modifications. Mr. Labhart added that 52 employees work at the facility and their production remains steady for the most part throughout the year. Process Description Ethanol, also known as ethyl alcohol or grain alcohol, is a colorless liquid produced by fermenting carbohydrates found in a number of different types of grains, such as corn. Ethanol is a significant component of the biofuels industry, which includes all transportation fuels derived from renewable biological materials. This facility is equipped with an ICM ethanol processing technology - also used across other Green Plains Inc.'s biorefineries in the US. Incoming utility water is supplied from on-site groundwater wells. The well water is prepared for use by chlorination, oxidation, and filtration. After the water is prepared, it is held in storage tanks and directed to either the cooling tower or the Reverse Osmosis (RO) system for further treatment. From the RO system, water is sent to a softener system, which provides the make-up water for the ethanol manufacturing process. 3 Corn is received at the plant by truck or rail then weighed and unloaded into a receiving building. Grain storage facilities are used to inventory grain that is passed through a scalper to remove rocks and debris prior to processing. The corn is then transported to a hammer mill where it is ground into flour and conveyed into a slurry tank for enzymatic processing. Water, heat, and enzymes are added to convert the complex starch molecules into simpler carbohydrates. The slurry is heated to reduce the potential of microbial contamination and pumped into a liquefaction tank where additional enzymes are added. Next, the grain slurry is pumped into fermenters, where yeast, enzymes, and nutrients are added, and the fermentation process is started. A beer column, within the distillation system, separates the alcohol from the spent grain mash. The alcohol is dehydrated to 200-proof alcohol and either pumped into a holding tank and blended with approximately 2% denaturant as it is pumped into finished product storage tanks or marketed as undenatured ethanol. Distillers Grains: The spent grain mash is pumped from the beer column into a decanter-type centrifuge for dewatering. The water, or thin stillage, is pumped from the centrifuge into an evaporator, where it is concentrated into a thick syrup. The solids, or wet cake, that exit the centrifuge are conveyed to the dryer system and dried at varying temperatures to produce distillers grains. Syrup is reapplied to the wet cake prior to drying to provide additional nutrients. Distillers grains, the principal co-product of the ethanol production process, are used as high-protein, high-energy animal feed and marketed to the dairy, beef, swine, and poultry industries. Three forms of distillers grains, depending on the number of times the solids are passed through the dryer system: a) wet distillers grains, which contain approximately 65% to 70% moisture, have a shelf life of approximately three days and is therefore sold to dairies or feedlots within the immediate vicinity; b) modified wet distillers grains, which is dried further to approximately 50% to 55% moisture, have a shelf life of approximately three weeks and are marketed to regional dairies and feedlots; and c) dried distillers grains, which have been dried more extensively to approximately 10% to 12% moisture, have an almost indefinite shelf life and may be stored, sold and shipped to any market. Corn oil: Corn oil systems extract non-edible corn oil from the thin stillage evaporation process immediately before the production of distillers grains. Corn oil is produced by processing the syrup through a decanter-style, or disk-stack, centrifuge. The centrifuges separate the relatively light corn oil from the heavier components of the syrup. Green Plains extract approximately 0.7 pound of corn oil per bushel of corn used to produce ethanol. Industrial uses for corn oil include feedstock for renewable diesel, biodiesel, livestock feed additives, rubber substitutes, rust preventatives, inks, textiles, soaps, and insecticides. The syrup is blended into wet, modified wet or dried distillers grains. Most of the water used in an ethanol plant is recycled in the production process. The facility was not in operation during the EPA inspection. On January 11, 2021, the facility sent a letter to IDEM about an extended period shutdown to accommodate the annual maintenance and significant construction improvements associated with the "continuous-tobatch-fermentation" conversion process. I requested Mr. Labhart to provide details of all the 4 planned and current "process changes." In his February 26, 2021 letter to me, Mr. Labhart provided information pertaining to ongoing process modifications to the facility operations: mainly the 1) Batch Fermentation Conversion, and 2) P24 Distillation. Batch Fermentation Conversion: Prior to January 2021, the facility operated as a continuous fermentation plant with a continuous fermentation configuration where fermentation never stops. Milled corn, yeast, and water are added at regular intervals and these materials move continuously through each of the six fermentation tanks. The facility planned to convert to a batch fermentation configuration after the inspection (early March 2021). Under batch fermentation, each of the six fermentation tanks (1-million-gallon capacity) gets filled with the milled corn, yeast, and water and these materials are allowed to ferment in these individual tanks until fermentation is completed. Then the solids and alcohol are extracted from each fermenter and routed for additional processing. The fermenter is then cleaned and sterilized for the next batch. Mr. Labhart explained that the batch process is currently a predominant fermentation method in the fuel-grade ethanol industry, which provides a higher alcohol content and better infection controls. Batch process set up is less susceptible to contamination compared to the continuous set up. Project 24 Distillation: P24 distillation is an approximate half/half combination of steam (pressure) and vacuum applied distillation as opposed to all pressure induced distillation for the continuous process. Vacuum induced distillation can run at low temperatures and it would consume 30% less electricity and would also reduce the cooling water blow down temperatures. Stormwater: The facility's stormwater sampling and monitoring requirements are identified at Outfalls 001S and 002S. The total drainage area contributing to the outfalls is approximately 200 acres. The SWPPP is intended to document the selection, design, installation, and implementation (including inspection, maintenance, monitoring, and corrective action) of control measures. The SWPPP must be kept up-to-date, and modified when necessary, to reflect any changes in control measures that were found to be necessary to meet the non-numeric effluent limits set forth in Part 1.D of the IDEM permit. There are no known stormwater changes associated with the current plant modifications described above. A schematic flow diagram of the entire production process (with the updated fermentation and distillation system) was not available at the time of the inspection. I asked Mr. Labhart to provide the updated schematics of the revised production process and updated water mass balance diagram when available. Facility Walk-Through Chelsea Holscher, Lab Manager, joined us during the site walk-through on February 24, 2021. We began the walk-through at 9:15 am. Ms. Holscher escorted us to the on-site laboratory located north of the office building and showed us the sampling containers, instruments used for on-site analysis, the refrigerator for the sample storage (photos 1through 5), and the chain-ofcustody log folders. We proceeded to the control room office adjacent to the laboratory (photos 6 thru' 7), where multiple large screen monitors track the entire production process at the facility. 5 Mr. Labhart escorted us to Ethanol Storage, Denaturing Tank, and Shifter Tank area located south of the truck loading area on the southwest side of the facility (photo 9). These 7 tanks are housed in a large rectangular diked area to contain any spill. I asked Mr. Labhart if the facility has had any such product spillage in this diked area since its 2016 acquisition and he confirmed that the facility has not had any spill in the diked area. While at this location, we inspected the Ethanol and Corn Oil Truck Loading Area (photo 10). Mr. Labhart stated that the spill during loading of the ethanol or corn oil would flow to the drain at the Truck Loading Area (photo 12) and flow through underground piping to the Spill Containment Area (photo 11). We then proceeded to the first step of grain receiving area (photo 13), where grains are received via rail cars (photo 14). We noticed Corn oil storage near the rail lines without secondary containment (photo 17). Ethanol is filled in the rail cars from the top. Mr. Labhart stated that they have not had ethanol spill at the rail lines and there have only been rare occurrences of corn oil spills, which are first captured in the catch basin on the rail lines (photo 19). The facility has a dedicated containment area (located between the rail track and fence) to capture any corn oil and ethanol spills (photo 20), which would pump off any spill collected from the containment area for off-site disposal. The inspection continued towards the east of the facility. We passed through two large corn storage bins and the flour mill area (photo 14). We then proceeded to inspect the above ground chemical Storage area (center of the facility - south of the cook building). It houses Phosphoric Acid, Sulfuric Acid, and Anhydrous Ammonia (photos 21 & 22) stored within concrete containment. Since these tanks are stored outside, they are exposed to stormwater. Mr. Labhart stated that the visible contaminated stormwater is rainwater and dust and is free from chemicals, He stated that it is disposed of in accordance with the facility's Spill Prevention, Control, and Countermeasure (SPCC) plan and all chemical deliveries occur via hose connections between the transfer location and the tank under the supervision of an employee. The chemical delivery area is paved and sloped. In the event of a spill, it would be noticed immediately, mitigated, and disposed of in accordance with the SPCC plan. The concrete catch basin was epoxy coated to contain potential hose drips/leaks during chemical transfer. Drains within the cook building (photo 24) collect water from the floor washing to an underground holding tank, which would pump the water (photo 25) to the digestor tank T-7002. Antibiotics used for fermentation are stored in the Cook Building (photo 26). The inspection continued to the mixing pond area located on the southeast side of the facility. Aeration sprinklers have been installed in small and larger mixing ponds for further cooling of non-contact boiler and cooling tower blowdown water (photos 27 thru' 29). Grab samples are collected from one of the two locations prior to discharge from Outfall 001S (phots 30 & 31). Stormwater from the eastern portion of the industrial section is diverted above ground via drainage conveyances to a retention basin (underground) southeast of the six large fermentation tanks (photo 32), to allow infiltration and settling of solids prior to discharging from stormwater Outfall 001S. A normally closed gate valve (photo 29) mitigates the probability of unintentional 6 discharges from stormwater Outfall 001S. The discharge from Outfall 001S enters a dry creek which flows west, southwest, and ultimately south until it discharges into an unnamed tributary to the Ohio River (south of the facility). We walked past the six large (1 million-gallon each) Fermentation Tanks (photo 32). Prior to 2021, these tanks were operated as continuous fermentation. Mr. Labhart stated that these tanks will operate as batch fermentation tanks after March 2021. They will remain at their existing locations. Each tank is currently being upgraded and retrofitted to the batch operation. Mr. Labhart escorted us to the Distillation Area, Beer Well, Evaporation Tanks, Eductor Tank area (photo 34) and cooling towers (3 chillers - photo 36). On our way to these process areas, we noticed an oil sheen in the stormwater culvert located east of the cooling tower. I asked Mr. Rezac for the potential source of the oil and he stated that the source could have been from the parked maintenance vehicles near the culvert. Mr. Rezac mentioned that the oil sheen couldn't have resulted from the non-contact sump pump malfunctioning (as they have in the past), since the plant was not in the operation at that time. The inspection continued towards the wastewater treatment system (aerobic digestor) located on the northeast side of the facility (photos 37 thru' 41). Mr. Labhart stated that the discharge from Outfall 001 consists of filter backwash and filter-press wastewater, RO reject water (photo 53), softener regenerant, boiler blowdown, non-contact cooling water, and condensate from heat exchangers, as well as storm water. The outfall has an average discharge of approximately 0.95 million gallon per day (MGD) into the unnamed ditch to the Ohio River. Mr. Labhart stated that the discharge from Outfall 002 (discharges into the unnamed ditch to the Ohio River) consists of treated process wastewater from the ethanol production as well as storm water. Wastewater from the ethanol process is sent to a 750,000-gallon Equalization Tank (T7001) followed by the wastewater holding tank T-7002 (photo 43). From there, the wastewater is fed to the wastewater treatment system(digestor) consisting of aeration, flocculation, and clarification. The wastewater treatment system had an average discharge of approximately 0.36 MGD. Due to recent plant modifications, wastewater discharges from the new batch fermentation and P24 distillation would be significantly reduced. The batch process is a net "water negative" system. The continuous process ran as a "water positive" system. The batch process consumes more water in the process and discharges less. The wastewater digester will remain shut down and will be eliminated from the process when the facility starts to use the batch process. Mr. Labhart stated that the facility is in the process of procuring a vendor to empty and clean the digestor. We inspected the wastewater discharge sampling collection point at the bottom of the Digester (photo 42), which is out of commission at present. The inspection continued to the northwest side of the facility where we inspected outfall, discharge, and sampling locations for Outfall 002 and Outfall 002S (photos 44, 48, 49). Before we ended the facility walk-through, we inspected the Wet Distillers Grains storage area (photo 45) and the newly installed evaporator and beer well (photo 51). Finally, we entered the energy center building to inspect the flow meter that measures the flow from RO reject water, softener regenerant, boiler blowdown, non-contact cooling water and condensate from heat exchangers 7 leading to Outfall 001. Mr. Labhart provided the attached water mass balance diagram prepared by Weas engineering, which reflects the mass balance for the continuous process. After completing the facility walk-through portion of the inspection, Mr. Labhart escorted us to office meeting room for the closing conference. Closing Conference We began the closing conference at 1:30 pm with Mr. Labhart and Mr. Rezac. We discussed the three primary areas of concern as follows: [1] Non-Contact Water Temperature Discharge Plan: During January 2018, the facility had 10 temperature exceedances, 1 in March 2019, five in January 2020, and two in January 2021 at Outfall 001. Mr. Labhart stated that the non-contact water discharge temperature has been a challenge during January and February each year. In an effort to curb annual temperature exceedances from the boiler and cooling tower blow downs, the facility constructed a quarter acre containment pond in December 2018, installed a heat exchanger in 2019, and added aeration fountains in 2020 to enhance ambient cooling prior to discharge at Outfall 001. Mr. Labhart stated that the facility plans to add larger fountains in March this year. With the reduction of 1 boiler and change in distillation process, Mr. Labhart expects that the facility would come into compliance for temperature at Outfall 001 by next winter. [2] Continued Effluent Exceedances: Review of the DMR records showed an average of one or two zinc, lead, TSS, and BOD exceedances annually. Mr. Labhart stated that the wastewater digestor has been eliminated from the process. He stated that the net "water negative" batch fermentation process and elimination of the aerobic digestor would result in significant volume reduction of discharge water to the permitted Outfall 002. Mr. Labhart stated that the facility expects significant reduction in TSS, metals, and BOD discharges. [3] High Sulfate Results: During May 2020, extremely high levels of total sulfates were reported on the DMR for the first time (752% higher than the daily maximum). Mr. Labhart stated that the normal sulfate level in the supply water wells is around 94 ppm. During last May, the sulfates in the supply water well tested at 250 ppm. The facility's contractor, Ortman Drilling, pressure blasted each well to loosen biological growth, cleaned the side walls of solids, chemically cleaned each well, and installed a liner in well C to prevent contamination. The Sulfate results dropped down to an average range of 94 ppm and the DMR data for the last 2 quarters of 2020 did not show any sulfate violations. During the closing conference, we had not discussed the concern related to the oil sheen observed in the stormwater culvert located east of the cooling tower. Mr. Rezac stated that the 8 source could have been from the parked maintenance vehicles near the culvert and that he would look into preventing similar occurances in the future. We ended the closing conference and departed the facility at 2 pm. List of Attachments I. Inspection photographs II. Aerial View of the entire Facility and photolog locations III. Map of the facility IV. Facility Stormwater Drainage Diagram V. Current Water Mass Balance Diagram 9 Green Plains Mount Vernon, LLC 8999 West Franklin Road Mount Vernon, Indiana 47620 NPDES Permit IN0063096 Photos Taken by Cheryl Burdett Olympus Tough F2.o Photo Number: P2240001 Description: Green Plains Mount Vernon laboratory Location: Onsite laboratory Facing: Northwest Date/Time: 02/24/2021 10:52 AM Page 1 Green Plains February 24, 2021 Photo Number: P2240002 Description: Another photo of the laboratory Location: Onsite laboratory Facing: West Date/Time: 02/24/2021 10:52 AM Page 2 Green Plains February 24, 2021 Photo Number: P2240003 Description: Another photo of the laboratory Location: Onsite laboratory Facing: Northwest Date/Time: 02/24/2021 10:56 AM Page 3 Green Plains February 24, 2021 Photo Number: P2240004 Description: Thermometer inside the refrigerator in the laboratory Location: Onsite laboratory Facing: East Date/Time: 02/24/2021 11:00 AM Page 4 Green Plains February 24, 2021 Photo Number: P2240005 Description: Samples collected onsite and stored in the refrigerator in the laboratory Location: Onsite laboratory Facing: East Date/Time: 02/24/2021 11:00 AM Page 5 Green Plains February 24, 2021 Photo Number: P2240006 Description: Control Center Location: Adjacent to the onsite laboratory Facing: Southwest Date/Time: 02/24/2021 11:14 AM Page 6 Green Plains February 24, 2021 Photo Number: P2240007 Description: Control Center Location: Adjacent to the onsite laboratory Facing: Southwest Date/Time: 02/24/2021 11:14 AM Page 7 Green Plains February 24, 2021 Photo Number: P2240008 Description: KPI Screen within the Control Center Location: Adjacent to the onsite laboratory Facing: Northwest Date/Time: 02/24/2021 11:15 AM Page 8 Green Plains February 24, 2021 Photo Number: P2240009 Description: Ethanol Storage, Denaturing Tank, and Shifter Tank Location: Southwest side of the facility - south of the truck loading area 37.908083, -87.7268 Facing: Southwest Date/Time: 02/24/2021 11:22 AM Page 9 Green Plains February 24, 2021 Photo Number: P2240010 Description: Ethanol and Corn Oil Truck Loading Area Location: Southwest side of the facility - South of Corn Bins and Flour Mill 37.908107, -87.726702 Facing: Northeast Date/Time: 02/24/2021 11:23 AM Page 10 Green Plains February 24, 2021 Photo Number: P2240011 Description: Spill Containment for the Truck Loading Area for the Corn Oil and Ethanol Location: Southwest side of the facility - Southwest of the Truck Loading Area 37.90811, -87.726715 Facing: West Date/Time: 02/24/2021 11:25 AM Page 11 Green Plains February 24, 2021 Photo Number: P2240012 Description: Drain at the Truck Loading Area for the Corn Oil and Ethanol Location: Southwest side of the facility - South of the Corn Bins and Flour Mill Facing: Northeast Date/Time: 02/24/2021 11:25 Page 12 Green Plains February 24, 2021 Photo Number: P2240013 Description: Grain Receiving Area Location: West of the Corn Bins and Flour Mill on the west side of the Facility 37.908333, -87.726667 Facing: Northwest Date/Time: 02/24/2021 11:30 AM Page 13 Green Plains February 24, 2021 Photo Number: P2240014 Description: Corn Bins and Flour Mill Location: West side of the Facility 37.90879, -87.727068 Facing: Northeast Date/Time: 02/24/2021 11:31 AM Page 14 Green Plains February 24, 2021 Photo Number: P2240015 Description: Rail line loading area for Ethanol and Corn Oil Location: West of Grain Receiving - west side of the facility 37.908611, -87.72722 Facing: Northwest Date/Time: 02/24/2021 11:34 AM Page 15 Green Plains February 24, 2021 Photo Number: P2240016 Description: Corn Oil with 2nd containment. Location: At the rail line loading area - west of Grain Receiving 37.908795, -87.727462 Facing: West Date/Time: 02/24/2021 11:36 AM Page 16 Green Plains February 24, 2021 Photo Number: P2240017 Description: Corn oil storage near the rail lines without secondary containment Location: At the rail lines loading area for ethanol and corn oil 37.908897, -87.72745 Facing: East Date/Time: 02/24/2021 11:36 AM Page 17 Green Plains February 24, 2021 Photo Number: P2240018 Description: Ethanol is filled in the rail cars from the top Location: West of Grain Mill on the west side of the Facility 37.908611, -87.7275 Facing: Northwest Date/Time: 02/24/2021 11:41 AM Page 18 Green Plains February 24, 2021 Photo Number: P2240019 Description: The catch basin on the rail lines to capture any corn oil spillage Location: West of Grain Mill on the west side of the Facility 37.908897, -87.72745 Facing: South Date/Time: 02/24/2021 11:41 AM Page 19 Green Plains February 24, 2021 Photo Number: P2240020 Description: Containment area between the rail track and fence - for corn oil and/or ethanol spill Location: West of Grain Mill on the west side of the Facility 37.908842, -87.727845 Facing: Northeast Date/Time: 02/24/2021 11:42 AM Page 20 Green Plains February 24, 2021 Photo Number: P2240021 Description: Above Ground Chemical Storage Area with concrete secondary containment Location: In the center of the Facility, south of Cooking Building 37.908905, -87.725743 Facing: Southeast Date/Time: 02/24/2021 11:52 AM Page 21 Green Plains February 24, 2021 Photo Number: P2240022 Description: Above Ground Chemical Storage Area with concrete secondary containment Location: In the center of the Facility, south of Cooking Building 37.908905, -87.725743 Facing: Southeast Date/Time: 02/24/2021 11:52 AM Page 22 Green Plains February 24, 2021 Photo Number: P2240023 Description: Blurry picture so another photo is taken P2240024. Location: Within the Cook Building in the center of the Facility. 37.908905, -87.725743 Facing: Northwest Date/Time: 02/24/2021 11:55 AM Page 23 Green Plains February 24, 2021 Photo Number: P2240024 Description: Drains within the Cook Building Location: Within in the Cook Building in the center of Facility 37.908905, -87.725743 Facing: Northwest Date/Time: 02/24/2021 11:55 AM Page 24 Green Plains February 24, 2021 Photo Number: P2240025 Description: Pump area within the Cook Building for the wastewater collected in the drains within the Cook Building Location: Within the Cook Building in the center of the Facility 37.908611, -87.725556 Facing: West Date/Time: 02/24/2021 11:59 AM Page 25 Green Plains February 24, 2021 Photo Number: P2240026 Description: Antibiotics used for fermentation stored in the Cook Building Location: Within the Cook Building in the center of the Facility 37.908611, -87.725556 Facing: Southwest Date/Time: 02/24/2021 12:03 PM Page 26 Green Plains February 24, 2021 Photo Number: P2240027 Description: Sprinklers in the smaller cooling area of the mixing pond Location: Ponds located on the southeast side of the Facility 37.909115, -87.724365 Facing: Southeast Date/Time: 02/24/2021 12:07 PM Page 27 Green Plains February 24, 2021 Photo Number: P2240028 Description: Sprinklers in the larger cooling area of the mixing pond Location: Ponds located on the southeast side of the Facility 37.908927, -87.724308 Facing: Southeast Date/Time: 02/24/2021 12:08 PM Page 28 Green Plains February 24, 2021 Photo Number: P2240029 Description: Stormwater Outfall 001S Gate Valve Location: Southeast side of the Facility 37.908437, -87.724350 Facing: Northeast Date/Time: 2/24/2021 12:09 PM Page 29 Green Plains February 24, 2021 Photo Number: P2240030 Description: Outfall 001s into the unnamed waterway Location: Southeast side of the Facility 37.908056, -87.723611 Facing: Southeast Date/Time: 02/24/2021 12:!2 PM Page 30 Green Plains February 24, 2021 Photo Number: P2240031 Description: Another sampling location for outfall 001S Location: Southeast side of the Facility 37.908263, -87.723805 Facing: Southwest Date/Time: 02/24/2021 12:13 PM Page 31 Green Plains February 24, 2021 Photo Number: P2240032 Description: Collection pole for collection of grab samples and T for shutting of the slough gate before Outfall 001 Location: Southeast side of the Facility 37.908313, -87.724010 Facing: Northeast Date/Time: 02/24/2021 12:17 PM Page 32 Green Plains February 24, 2021 Photo Number: P2240033 Description: 1 million-gallon Fermentation Tanks (six) Location: East side of the Facility 37.908413, -87.724192 Facing: North Date/Time: 02/24/2021 12:18 PM Page 33 Green Plains February 24, 2021 Photo Number: P2240034 Description: Distillation Area, Beer Well, Evaporation tanks, and the eductor tank Location: North side of the Facility 37.909665, -87.724383 Facing: Northwest Date/Time: 02/24/21 12 12:26 PM Page 34 Green Plains February 24, 2021 Photo Number: P2240035 Description: Stormwater culvert - noticeable oil sheen Location: East of the Cooling Tower Area 37.909870, -87.724542 Facing: West Date/Time: 02/24/2021 12:28 PM Page 35 Green Plains February 24, 2021 Photo Number: P2240036 Description: Cooling Towers Location: Eastside of the facility - north of the Fermentation Tanks 37.909923, -87.724702 Facing: Southwest Date/Time: 02/24/2021 12:30 PM Page 36 Green Plains February 24, 2021 Photo Number: P2240037 Description: On top of the Digester, which was turned off at the time of the inspection Location: Northeast side of the facility 37.910556, 87.724722 Facing: Southwest Date/Time: 02/24/2021 12:33 PM Page 37 Green Plains February 24, 2021 Photo Number: P2240038 Description: Sampling Areas for the Digester Tank Location: Northeast side of the facility 37.910728, -87.724767 Facing: Southwest Date/Time: 02/24/2021 12:34 PM Page 38 Green Plains February 24, 2021 Photo Number: P2240039 Description: Another site for collection of samples in the Digester Tank Location: Northeast side of the facility 37.910723, -87.724783 Facing: Southwest Date/Time: 02/24/2021 12:34 PM Page 39 Green Plains February 24, 2021 Photo Number: P2240040 Description: Sampling location of the Digester Tank. Location: Northeast side of the facility 37.910770, -87.724748 Facing: Southwest Date/Time: 02/24/2021 12:35 PM Page 40 Green Plains February 24, 2021 Photo Number: P2240041 Description: Grab pole to collect samples from the Digester Tank. Location: Northeast side of the facility 37.910848, -87.724733 Facing: Northwest Date/Time: 02/24/2021 12:36 PM Page 41 Green Plains February 24, 2021 Photo Number: P2240042 Description: Sampling collection point at the bottom of the Digester Location: Northeast side of the Facility 37.910550, -87.724677 Facing: Northeast Date/Time: 02/24/2021 12:42 PM Page 42 Green Plains February 24, 2021 Photo Number: P2240043 Description: Equalization Tank 7001 and treated wastewater holding tank 7002 Location: Northeast side of the Facility - immediately west of the digester 37.910853, -87.725272 Facing: Southeast Date/Time: 02/24/2021 12:45 PM Page 43 Green Plains February 24, 2021 Photo Number: P2240044 Description: Sluice Gate at Stormwater Outfall 002S Location: Northwest side of the Facility 37.910742, -87.726813 Facing: North Date/Time: 02/24/2021 12:47 PM Page 44 Green Plains February 24, 2021 Photo Number: P2240045 Description: Wet Distillers Grain Storage Area Location: Northwest side of the facility 37.910742, -87.726813 Facing: Southeast Date/Time: 02/24/2021 12:49 PM Page 45 Green Plains February 24, 2021 Photo Number: P2240046 Description: Accidental Photo Location: Northwest corner of the Facility. 37.91177, -87.726813 Facing: Northeast Date/Time: 02/24/2021 12:53 PM Page 46 Green Plains February 24, 2021 Photo Number: P2240047 Description: Evaporator Tanks - southeast of the wet distillers grain storage area Location: Northcentral area of the Facility 37.911177, -87.726668 Facing: Southeast Date/Time: 02/24/2021 12:53 PM Page 47 Green Plains February 24, 2021 Photo Number: P2240048 Description: Sample Collection for Outfall 002S Location: Northwest corner of the Facility. 37.911272, -87.726682 Facing: Northeast Date/Time: 02/24/2021 12:55 PM Page 48 Green Plains February 24, 2021 Photo Number: P2240049 Description: Outfall discharge location for outfall 002S Location: Northwest corner of the Facility. 37.911315, -87.726667 Facing: East Date/Time: 02/24/2021 12:57 PM Page 49 Green Plains February 24, 2021 Photo Number: P2240050 Description: New Evaporators Location: Northcentral part of the facility 37.910278, -87.725833 Facing: East Date/Time: 02/24/2021 1:03 PM Page 50 Green Plains February 24, 2021 Photo Number: P2240051 Description: New Evaporator and Beer Well Location: Northcentral part of the facility 37.909903, -87.725740 Facing: Northeast Date/Time: 02/24/2021 1:04 PM Page 51 Green Plains February 24, 2021 Photo Number: P2240052 Description: Blurry photo retook to look at the water level. Location: 37.909722, -87.725556 Facing: Southeast Date/Time: 02/24/2021 1:09 PM Page 52 Green Plains February 24, 2021 Photo Number: P2240053 Description: RO cooling, Blowdown Cooling Location: Energy Center - central part of the facility (south of the cook building) 37.909722, -87.725556 Facing: Southeast Date/Time: 02/24/2021 1:09 PM Page 53 Green Plains February 24, 2021 Photo Number: P2240054 Description: Level meter that is triggered when the water level reaches a certain height in the tank Location: Energy Center - central part of the facility (south of the cook building) 37.909722, -87.725556 Facing: Northeast Date/Time: 02/24/2021 1:10 PM Page 54 Green Plains February 24, 2021 Photo Number: P2240055 Description: Flow meter to measure flow leading to outfall 001S Location: Energy Center - central part of the facility (south of the cook building) 37.909722, -87.725556 Facing: North Date/Time: 02/24/2021 1:14 PM Page 55 Green Plains February 24, 2021 Figure 1: Facility Location 8999 West Franklin Rd Mt. Vernon, Posey County, Indiana 4 Green Plains Mount Vernon Indiana Legend c100OLYMP_GeoTaggedPhotosToP1 NHDLine NHDFlowline flowlines waterbodies World Boundaries and Places World Imagery Low Resolution 15m Imagery High Resolution 60cm Imagery High Resolution 30cm Imagery Citations Miles 0 0.0275 0.055 0.11 0.165 0.22 Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community, Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community