OPERATING PLAN

1.0     Purpose:

Big Fish Environmental, LLC (“Big Fish”) is a privately held enterprise formed for the purpose of providing treatment of household domestic septage and municipal wastewater treatment plant biosolids in an arrangement of vessels designed specifically to treat the material to a level acceptable for discharge to a municipal Wastewater Treatment Facility.  This treatment facility was designed to employ the aerobic micro organism wastewater treatment technology (U.S. Patent No. 6,780,318), used with permission, with the express purpose of non-conventional treatment of septage and biosolids.

This receiving facility, located in Charlevoix Township, Michigan, discharges its treated effluent to the Charlevoix wastewater treatment plant via existing sanitary sewers under contract with the City of Charlevoix sewer collection system.

This program was proposed in accordance with the feasibility study conducted by the Health Department of Northwest Michigan to determine potential methods for proper management and disposal of septage material.  In particular, the Big Fish program follows Option 3B of the Interim Report to the Septage Waste Disposal Committee of the Septage Feasibility Study.  Specifically, this option presents the potential for a private entity to construct a pretreatment system featuring screening equipment, a receiving building, equalization tank(s), and pretreatment technology to result in an effluent quality from the facility capable of being received by a municipal wastewater treatment facility for final treatment and discharge into the environment.

2.0     Acceptable Material:       

2.1     Material Type:

Material not listed in paragraph (a) below will require prior approval from the facility operator in order to discharge into the Big Fish receiving facility.

  (a)  Acceptable Materials:

       i.   Domestic septage, including septic tank and holding tank material consisting solely of
            sanitary sewage.

      ii.   Portable toilet wastes.

      iii.  Domestic wastewater treatment plant biosolids. (July 2007)

  (b)  Conditionally Acceptable Materials:

      i.  Food establishment septage consisting of grease trap material. This material will require
            prior specific approval by the facility operator on a limited basis. (Offer October 2007,
            testing only)

      ii.  Food processing facility waters or wastewaters. This material will require testing and
           review by the facility operator prior to acceptance. Initial testing is paid for by the
           discharger.

      iii.  Other biologically treatable materials not listed in paragraph (a) above.

  (c)   Unacceptable Materials:

      i.    Petroleum laden waters or wastewaters.

      ii.   Waters containing chlorinated solvents.

      iii.  Waters containing certain high metal concentrations such as from, but not limited to,
            metal plating operations.

     iv.   Any material not normally treatable by biological processes or otherwise found
            unacceptable to the facility operator.

 2.2     Conditions of Acceptance

  (a)  At no time shall the Big Fish facility receive more than 1 part by volume food establishment
        septage (FES) to 3 parts domestic septage [Based on MCL 324.11710(j) relating to direct
        land application of FES].  The ratio of FES to domestic septage accepted by the facility will
        be recorded by the facility operator. (Offer October 2007, testing only)

  (b)  A load manifest clearly indicating point of origin and type of material (e.g. septage or holding
        tank material) will accompany all delivered material.  The hauler is solely responsible for
        materials meeting the facility operator’s acceptance. 

  (c)  Any costs incurred by the Big Fish receiving facility for clean-up, equipment damage, permit  
        violations, discharge violations or other damages due to materials delivered to Big Fish
        without the facility operator’s approval or for materials delivered that were not as stated
        on manifests will be borne upon the hauler.  All haulers will be required to agree to
        contract terms prior to discharging to the Big Fish facility.  A sample contract is included
        in Appendix A.

3.0     Hours of Operation:

Normal operating hours for accepting materials are 7:30 a.m. to 5:00 p.m. Monday through Friday, except holidays. 

If a hauler has a need to deliver materials outside of these hours, the hauler may call (231) 547-4429 to make an appointment.  Calls made to this number after normal office hours (7:30 a.m. to 5:00 p.m. Monday through Friday) will be directed to a 24 hour Emergency Service Center that will immediately notify on-call staff and a return call will be made to the hauler to make the appointment.  The facility will be manned when receiving material.  Contracted haulers have facility access 24 hours a day 7 days a week including holidays.

4.0     Service Area:

The Big Fish facility will service haulers on a contractual basis, not necessarily defined by a geographical area. 

After facility performance is reviewed by the Michigan Department of Natural Resources (MDEQ), a geographical service area of up to 15 radial miles from the receiving facility may be established.  This area includes portions of Emmett, Charlevoix and Antrim Counties roughly bounded by the cities of Eastport, East Jordan, Boyne City, Walloon Lake, and Petoskey, Michigan. 

After October 12, 2010, the service area may expand to 25 radial miles based on the capacity of the facility, extending the range to the cities of Bellaire, Elmira, Alanson and Cross Village, Michigan.  A map showing the service area radiuses is shown in Appendix B.

5.0     Fee Structure:

A fee charged to the hauler has been initially established at a flat rate of $0.10 per gallon received.

6.0     Facility Capacity:

6.1     Hydraulic Capacity:

The Big Fish facility is permitted by the city of Charlevoix for a hydraulic capacity of 10,000 gallons per day (gpd); however it was designed at an improved capacity of 20,000 gpd. 

6.2     Organic Capacity:

The organic capacity of the facility is estimated at approximately 1,000 pounds per day of 5-day biochemical oxygen demand (BOD₅).  This is equivalent to approximately 12,000 mg/l BOD₅ at 10,000 gpd or 6,000 mg/l BOD₅ at 20,000 gpd. This estimate is based on aerobic micro organism technology based facilities at lower hydraulic capacities. Because the application of the aerobic micro organism technology is largely undocumented at this capacity, the stated organic capacity may be revised after a period of operating the facility. 

Organic and hydraulic capacities are influenced by the type of materials accepted and treated at the facility.  For example, the facility’s hydraulic capacity of materials containing high concentrations of fats, oils and grease (FOG) will be much lower than the facility’s capacity of treating materials containing high concentrations of sugars, as typically found in fruit processor waters. 

7.0     Facility Features:

The Big Fish Septage Receiving and Treatment Facility has six primary features or facility components:

7.1     Receiving:  Deliveries are received at a heated, enclosed structure with a partitioned, indoor drive-through lane for septage delivery vehicles.  Haulers access the indoor receiving point by use of an access card.  A hauler simply inserts the card into the card reader located on the exterior of the building, allowing entrance into the facility.  Once entered, the hauler connects the delivery truck to a JWC Environmental, Inc. Septage Receiving Station via cam-lock couplings.  The Receiving Station provides grinding, ¼-inch screening and dewatering of removed inorganic solids for landfill disposal.  As the truck discharges, the Receiving Station automatically tallies the flow.  Questions regarding the delivery process can be answered by the on-site facility operator.

Manual sampling of delivered loads will provide monitoring of material.  Material delivered outside of specification can be diverted from the process into a holding tank for proper disposal as necessary.  The capacity of the holding tank is 15,000 gallons.

Material entering the facility is continuously monitored for pH at the Receiving Station.  The facility is programmed to close an electrically actuated valve if the pH of any material is outside of established limits. 

The facility also automatically monitors available capacity within the receiving tank.  If the receiving tank does not have sufficient space, a float switch actuates a valve, preventing further discharges to the plant until space is made available.

The receiving building uses an odor control system consisting of exhaust fans and a biofilter to scrub the exhaust air.  Offensive odors are vented directly from the tank and from the building atmosphere to the biofilter.  Material receiving takes place within the drive-through lane when both the entrance and exit doors are closed.

7.2     Equalization Tank:  After flow measurement, grinding and screening, material is sent directly to a partitioned 15,000-gallon equalization tank. The first section of the tank (4,000 gallons) will receive the initial flow from the delivery vehicle and provide a basin for settlement of inorganic material (grit) that has passed through the screening process.  As more material is delivered to the facility, the first chamber material cascades into the second chamber.

The second chamber (11,000 gallons) provides an aerated mixing area for blending raw material as needed to balance waste strength and initial treatment inoculation.  The initial bacterial inoculation occurs using a series of aerobic micro organism generating units.  The blended/inoculated material in the second chamber will be pumped into the subsequent treatment vessels at a controlled rate of up to seven  gallons per minute (gpm). (June 2007 increased to 14 gpm)

7.3     Secondary Receiving Tank:  A second receiving tank will be utilized for receiving biosolids from the quiescent tanks. (Approximately 12% of the total solids entering the system)

7.4     Treatment Vessels:  The treatment train of the process is conducted through one, 15,000-gallon and eight, 2,000-gallon treatment vessels.  Each vessel is equipped with aerobic micro organism technology. As flow is pumped from the equalization tank, the partially treated material cascades from one treatment vessel to the next.  Cascading through the vessels provides the appropriate contact time with the bacteria blend and air to treat the material to a level that can be sent to the municipal wastewater treatment facility for final treatment and discharge to the environment.

7.5     Post Equalization Tank:  The Big Fish facility incorporates a post-equalization tank prior to discharging treated material to the municipal collection system. The post-equalization tank provides a semi-quiescent zone for settling of solids not consumed in the treatment vessels. Settled solids are pumped back to the front of the plant for further treatment or to the biosolids holding tank for storage prior to disposal. Treated effluent may also be returned to the equalization tank if additional blending material is needed.

7.6     Effluent Discharge:  The facility will produce a treated effluent with waste strength characteristics equal to or less than that seen in a typical domestic household waste stream. The treated effluent is discharged to the City of Charlevoix wastewater collection system for final treatment at the Charlevoix Wastewater Treatment Facility, as per Order of Determination.

7.7     Biosolids will be stored in the holding tank (15,000 gallons) and/or City of Charlevoix drying beds. The biosolids will be land applied at an approved MDEQ site.

8.0     Facility Staffing:

The Septage Receiving Facility will be staffed during normal business hours and at other times when receiving septage.  An attendant will be on site during unloading operations.  The attendant will be responsible for monitoring the unloading operation and checking the delivered material for contamination that cannot be treated within the plant as currently configured.


9.0     Truck Traffic:

With established contractual relations with haulers the facility expects to receive up to seven truckloads per weekday.  The facility is located in a commercial/industrial zoned location within the Township of Charlevoix, and anticipated truck traffic is within accepted uses.

_______________________

Appendix B