Webster County Groundwater Impact Committee
Questions & Answers about the Proposed Ethanol Plant
On August 23, 2006, residents of the Rogersville, Missouri area learned that an ethanol manufacturing plant was being proposed for construction on a site east of Rogersville in Webster County.
The same day, the Webster County Commission appointed a study group, named the Webster County Groundwater Impact Committee (or Committee for short), to help research the issues associated with such a manufacturing plant and provide unbiased answers to citizens’ concerns and interests about it.
Committee members are:
On August 30, the Committee was allowed to meet with officials representing Gulfstream Bioflex Energy, LLC, based in Mt. Vernon, MO, to question them about their plans for an ethanol plant. Those representing the company at the meeting were Greg Wilmoth, CEO; Jeff Negre, vice-president; Charles Luna, vice‑president; Richard Quint, senior vice-president of Walton Construction based in Springfield MO and general contractor for the project; and Brett Carlgren, one of the engineers assisting with the project.
Based on answers to questions asked at that meeting, plus additional research by the Committee, the following information has resulted.
1. Where is the site
located?
The site
is a 252-acre property northeast of the junction of U.S. Highway 60 and
Porter Crossing Road. The approximate location is the NEĽ of Section 15,
Township 28N, Range 19W in Webster County.
Click here for an aerial photo of the site.
2. Who are the owners
of the company wanting to build the ethanol plant?
A group
of investors, doing business as Gulfstream Bioflex
Energy, LLC, (or GBE for short) is a new corporation whose mailing
address is P.O. Box 487, Mt. Vernon, MO 65712. The company CEO is Greg
Wilmoth, a native of Lawrence County. His family has been in the oil
business since 1952, and he said he currently runs 165 gasoline trucks
across the U.S.
3. What determined
the selection of the site near Rogersville, MO?
According to Greg Wilmoth, GBE is reviewing seven sites, and plans to
build ethanol plants on three of those sites in the first phase of their
expansion plans. They found the Rogersville site by just going down the
highway and noticing the lay of the land, the proximity to a natural gas
pipeline, and easy accessibility to rail and four-lane highway for
ethanol export. The large livestock industry in southern Missouri was
not one of the reasons from the site selection, and “planning and zoning
never came to mind” in their decision.
Plans are to locate the plant somewhere in the middle of the property, to minimize impact on neighboring property owners. Wilmoth stated “I don’t want to do anything that’s not going to preserve the environment.”
Location of the actual facilities may be influenced by the location of the fire protection districts and school district boundaries, which split the property. Locating the plant on the Fordland side of the school district boundary may result in lower property tax costs to the company, while locating on the Rogersville side may result in lower fire insurance rates.
4. How much ethanol
would the plant produce per year?
GBE
stated the plant would have a rated capacity of 88 million gallons per
year (MGY), with no company intentions of expanding beyond that size.
The weekly output would be 1,833,000 gallons of ethanol.
5. Why ship in the
corn rather than locating in corn country, and where would the corn be
shipped in from?
Wilmoth
stated he can ship corn cheaper than he can ship ethanol, and is working
with one of the largest corn brokers in the country to ship in the
grain. Approximately 90 percent of the grain (which could be corn or
milo) would be shipped in by rail and the rest by trucks. The grain
would come from the Midwest and possibly the South, and he also intends
to buy locally from farmers if possible.
6. Would this be a
dry-mill or a wet-mill process plant?
GBE
stated the plant would be primarily dry-mill, but can do both. That
means most of the byproduct will be dried-distillers grains (DDGs).
Wet-distiller grains (WDGs), will be produced on order from agricultural
producers. If an order of WDGs is produced, they expect the buyer to be
prompt on pick-up to avoid spoilage issues.
Committee research shows the approximately 194 rail cars of grain processed per week (each containing about 3,500 bushels of grain), the plant would process about 97,000 bushels of grain per day. A bushel of corn weighs 56 pounds and reduces to 17 pounds of DDGs in the ethanol-making process. So about 825 tons of DDGs would be produced by the plant each day.
The DDGs are a medium-protein feed that typically has a 12 percent moisture content, and can be fed to a variety of livestock and poultry. Beef cows typically would use 1-2 pounds per day in their diet, and dairy cows would use 3-4 pounds per day in their diet. The WDGs typically have a 50 percent moisture content and are harder to handle and store.
Questions about the numbers of livestock produced in southwest Missouri that could benefit from the use of DDGs in their ration are still being researched by the Committee.
7. Where would the
ethanol and distillers grains be shipped out? How far?
GBE
stated the majority of the ethanol would be shipped by rail (about
24,000 gallons per railcar) to the East Coast and Atlanta, GA. The plant
would have a “load rack” for trucks and the fuel would go by truck to
Kansas City and St. Louis, and possibly to the fuel terminal at
Brookline, MO. Regarding safety issues, Wilmoth said they will not
accept overweight trucks.
GBE is not yet sure about who will get the DDGs to be shipped by rail, but mentioned Arkansas, Mississippi and Alabama, and perhaps the poultry companies of Tyson’s and George’s in Arkansas and southwest Missouri. Local agricultural producers would also be able to stop at the plant to pick up loads of DDGs or WDGs.
8. How will the plant
be fueled?
GBE
stated the plant will be fueled by natural gas. No coal will be used.
9. Has the land been
purchased yet?
No. GBE
has an option-to-buy based on the results of the test well they are
drilling for water availability and a gridwork of soil borings on the
property to determine soil suitability for construction and absence of
sinkholes, caves, or other geologically-hazardous formations. They are
not going to commit to the property unless these tests come back
favorably.
10. Assuming the
tests are favorable, when would the company hope the plant is up and
operating?
GBE
said they hope to be operating 16-18 months from the time leveling dirt
on the site begins.
11. The company plans
have the capability to pump up to 2,000 gallons per minute from wells.
What will be the effect on water tables from this amount of water
withdrawal?
GBE’s
plan is to drill four wells on the premises, capable of extracting 2,000
gallons per minute (GPM) of groundwater. According to GBE, the actual
gallons used by the plant would be about 880 GPM or 1.26 million gallons
per day. Use of the wells would be rotated, with only three in operation
at any given time. The wells would be kept 2,000 feet apart from each
other to reduce their influence on each other. Based on the shape of the
property. the wells would need to be drilled near the property lines to
achieve this separation distance.
According to Jim Vandike, Groundwater Section Chief with the Missouri Department of Natural Resources (or MoDNR for short) at Rolla, MO, a demand of 2,000 GPM will have “some impact” on the water table. The wells will likely have a 2-mile radius of impact. To get the required gallonage, the wells would need to be drilled into the Potosi geologic formation of the Ozark Aquifer some 1,300-1,500 feet deep. An aquifer is a water-bearing rock formation. The wells would likely have 300-400 feet of 10-inch diameter steel casing pressure-grouted into a 14-inch diameter bore hole. A 200-300 foot water level drop is possible in the drawdown cone around each well. These wells could be pumped for several years before the water table re-stabilizes at a lower level.
The Committee cautions these are very general estimations. The actual influence and level of impact could be significantly different. The effect of these wells will depend upon variables such as the amount of groundwater under the site and rate of recharge. Actual rates of recharge are not, and will not be, known until the wells are in operation for an extended period of time and well testing is conducted in the area.
The Northview geologic formation has a restrictive shale layer that is anticipated to be about 100 deep at the site, typically blocking surface water from going to deeper levels. Below the Northview shale, there are no other restrictive layers, so trying to case out shallower wells would not be effective. The drawdown would affect groundwater supplies from below the Northview shale through the 1500-foot level.
Most residential wells in the area are drilled 500-700 feet, so it is possible some wells in the influence area may be lost, and new deeper wells would need to be drilled to replace them. Other wells may need to have their pumps lowered, and possibly changed to larger-horsepower pumps. Deepening existing wells can be risky, due to casing problems or loss of the drilling equipment. If a new well is drilled, the existing well must be properly plugged if it is no longer going to be used, so it does not cross‑contaminate the new well or other groundwater. Plugging an abandoned well is the responsibility of the landowner, following the procedures outlined in the Missouri Code of State Regulations 10 CSR 23-3.110.
The MoDNR has a groundwater observation well near Marshfield, MO which is drilled into the Potosi geologic formation of the Ozark Aquifer, the same formation that the company proposes to use for their wells. The Marshfield observation well is at 1,485 feet land surface elevation and drilled to a 1,315 foot depth, with a depth to water level that ranges from 210-290 feet below the land surface. The land surface elevation of the proposed plant site is about 1,520 feet, but the geographical distance of Marshfield to Rogersville is great enough that there could be considerable difference in the water table depth at the proposed ethanol plant site.
The MoDNR is currently seeking a location to drill a 6-inch diameter monitoring well near the proposed plant site. They hope to have it in and working before operation of the plant might begin.
Anyone with a water source and equipment capable of producing 100,000 gallons of water per day (or 70 gallons per minute) falls under Missouri Statute 256.400 Major Water Users Act. It requires major water users to register with MoDNR and report their yearly water use.
12. Is the company
willing to financially assist those who must drill new wells or lower
pumps due to the plant’s water usage?
Greg
Wilmoth stated he does not believe GBE has any responsibility to provide
financial assistance.
Committee research shows Missouri follows the riparian water doctrine. This means there are no state laws, regulations or policies that specify the quantity of water that any diverter may use. All landowners have a right to a “reasonable use” of the water resources. Reasonable use requires that other users and landowners not be overly adversely impacted. Water disputes are typically settled in circuit court by lawsuit.
Any landowner concerned about their well water level dropping due to influences by nearby wells should contact their pump installer and have a water depth gauge installed in their well. This is a simple device that uses a pressure gauge and plastic tubing secured to the drop pipe in the well. Cost to do this ranges from $300-$400. That way the landowner will have proof of lost capacity on the well.
Should the project go forward, the Committee suggests GBE financially assist landowners with restoring their well water supplies, if the landowners can document their well water levels were affected. This would potentially be less expensive than court litigation.
13. Considering the
area’s dependence upon the finite resource of groundwater and the
proposed plant use of over 440 million gallons of water per year that
would supply the needs of 21,000+ people, is this the best allocation or
utilization of groundwater?
The
Committee advises that this is a question that goes beyond the
construction of an ethanol plant or any other type of high-water-use
facility. All the groundwater in the Ozarks comes from rainfall and
takes several years to percolate to the deeper rock formations, unless
the water finds a fault line,
sinkhole or
solution channel to move rapidly down without filtering. The Ozarks
with its
karst (soluble limestone) topography is geologically among the most
fragile and susceptible to pollution in the U.S.
Due to the county’s high elevation, it has the headwaters of seven major streams with no streams entering the area. Therefore, the county will likely be dependent upon groundwater for growth due to the absence of any substantial streams. This question of water utilization is a general planning issue. Does the county want to start a trend of high-water-demand industrial growth or maintain a primarily residential population and light manufacturing businesses? Industrial use of groundwater is unlikely to inhibit growth any time in the near future, but will have some impact on the degree of accessibility of that water. This is evident by the lowering of water tables being experienced now from the extraction of water for current demands.
14. What is the
expected population growth in Webster County, and how will the lack of a
comprehensive sewage ordinance affect water availability and ability to
retain quality drinking water?
Webster
County is rapidly growing in population
(see graph), according to data provided by the
Office of Social and Economic Data Analysis. The county currently
has no organized method in place to manage this growth. Properties are
routinely being subdivided into 3-acre and larger building sites to
avoid sewage ordinances that regulate proper management of rural
residential waste. Each of these properties typically is served by its
own private water well. As this pattern of growth continues, there will
be greater demand on groundwater supplies and an expected higher
percentage of contaminated drinking water wells. Evidence of this
pattern is documented in the
1999 Water Testing Survey done by the Webster County Health Unit,
which showed 44 percent of randomly-sampled private water wells testing
positive for coliform bacteria, and 28 percent of sewage systems with
open discharge and surfacing effluent.
15. Would the cooling
water and the wastewater be mixed together or kept separate? Would the
cooling water be recycled? Are there algaecides or other chemicals added
to the water before it is released?
GBE
states the cooling water would be kept separate from the wastewater. The
cooling water would be recycled back through the plant until the mineral
content becomes high enough that it needs to be discharged to avoid
fouling the plumbing lines of the plant.
GBE has not provided the Committee with the exact amount of discharge water to make an accurate determination about how much would be recycled, how much would be evaporated to the atmosphere, and how much would go to retention pond(s) dug into the soils at the site.
It is unclear at this time whether GBE will use ICM technology, or something similar, in their plant design. Such technology could significantly reduce the amount of discharge water.
GBE stated that they are not aware of any plans for the use of algaecides in the water, and they would provide the Committee with a list of the chemicals coming out of the plant when the engineering firm completes its design of the plant. The company doing the engineering on this is C. J. Schneider in Omaha, Nebraska.
16. What is the
nature of the wastewater and how will it be treated?
GBE provided the Committee the following information: The discarded
“non-contact” cooling water would be separated from the wastewater. The
water would have an abnormally high concentration of minerals due to the
plant’s cooling process. They are not aware of any algaecides or other
chemicals in the cooling water. All of the “mash water” from the
process of producing ethanol will be recycled. The effluent of the
wastewater plant will be “as good or better than the Rogersville Waste
Treatment Plant.” Discarded water will either be evaporated from
evaporation retention ponds or irrigated onto their land or other
property. There will be no open discharge water into waterways or
streams. There will be domestic sewage from the fifty employees.
The Committee is also aware there will be laboratory chemical waste, and there may be other plant wastewater due to cleaning practices. The domestic sewage will be permitted by the local Department of Health since the design flow would be less than 3,000 gallons per day (50 employees x 25 GPD/person = 1,250 GPD). Under MoDNR’s wastewater permitting process, domestic sewage would not be allowed to be combined with the industrial waste. Consequently, there will be at least three categories of discarded water: coolant water, domestic wastewater, and laboratory/cleaning wastewater. For reasons given below under the retention pond section, it is likely that open discharge into the waterways and stream channels will be needed for the coolant water.
17. What is the
potential impact of the plant’s cooling water and wastewater on surface
and groundwater resources?
Based
upon the information provided by GBE to date, wastewater does not appear
to present a serious problem at this time. This conclusion hinges on
the following data:
The Committee needs to emphasize that this assessment is only as good as our data from GBE, and we are waiting for confirmation of this data from the firm doing the engineering for this project, which is C. J. Schneider in Omaha, Nebraska.
The discharge of any “treated” wastewater is a significant concern because of soil and geological characteristics of this part of the Ozarks which, as stated above, is among the most fragile and susceptible land to pollution in the U.S. The drainage channels and streams they flow into are considered “losing streams,” and the lower soil residuum and bedrock is permeable. Due to the restrictive shale layer of the Northview geologic formation, present below the more permeable formations above it, there is some protection for the aquifers. However, due to improperly-cased wells, abandoned wells, and bedrock fractures and faults, groundwater contamination is always a significant concern with “treated” wastewater.
Any discharged water will either end up in the groundwater or resurface in a stream, most likely James River, without any further treatment. Therefore the quality of discharge water is a significant concern, even if it meets MoDNR’s discharge limits for the contaminants still present within the water, and even if it is comparable to other wastewater plants discharging partially-treated water.
18. Are the soils
suited to building a retention pond for the cooling water or for a
wastewater lagoon? How big will the retention pond be and how will it be
built to keep it from leaking or collapsing?
Committee research shows the
soils on the site are
09B Captina-Needleye
Silt Loams and
10 Bado Silt Loams, and have a moderate limitation for pond
construction due to seepage below the fragipan (hardpan). Below the
restrictive fragipan at approximately 24 inches deep, the soils will be
red and yellow clays that, in their natural state have areas of moderate
to high permeability. The soil would need to be worked while moist,
compacted in several 6‑inch thick lifts, and kept moist to keep the pond
from leaking.
MoDNR would decide if the site requires an artificial liner to prevent leakage. This would especially be a critical decision for any proposed wastewater lagoon. Risk of collapse is unknown until results of soil test borings at the site are completed. If sinkholes are identified in the area, this could preclude the use of lagoons or retention ponds altogether. The size of the coolant water retention pond(s) is unclear at this time because design of the plant has not been finalized.
19. How will the
water from the retention pond(s) be disposed? Are the soils on the site
suited for irrigation?
GBE
indicated they plan to irrigate the water to fields on the 252-acre
site, and perhaps to fields of consenting neighboring landowners. They
are also counting on evaporation from the retention pond(s).
Committee research shows the predominant 09B Captina-Needleye soils have limitations for irrigation due to wetness, slow percolation and a finite water holding capacity due to a restrictive layer approximately two feet below the surface. The 10 Bado soil has greater limitations for irrigation due to the greater significance of the same features listed above for the 09B Captina-Needleye soils. The area soils have a moderate limitation for harvest equipment operability due to seasonal wetness and low soil strength.
Climatological data for Missouri show historical rainfall at 40 inches per year near at that site, and evaporation rates on an annual basis are similar, so minimal evaporation annually would occur from the pond if it is properly sealed.
Based on the 880 GPM water use rate of the plant, the Committee estimates a worst‑case scenario of about 47 acre-inches of water would be produced per day. It is estimated the soils present over 200 acres could receive 20 days of water at this rate under ideal circumstances before becoming saturated. Therefore, the data indicate the site would not be able to handle this volume of water due to soil characteristics and the limited area. As a result, unless there is a major network set up for dispersing this large volume of water to other properties, the cooling water from the retention pond(s) would need to be surface-discharged to waterways and streams. Therefore, it is imperative the cooling water not be contaminated with any other wastewater or chemicals.
20. How would the
roads be built to minimize “haul road” emissions?
GBE
stated the roads would be paved to minimize
fugitive dust.
Committee research indicates they must meet MoDNR air quality standards for PM10 particulate standards. The same rules would apply for the dust produced from unloading the rail cars of grain.
21. What about noise
and light pollution?
GBE
officials state the facility would be fenced, and noise would be
contained inside the buildings. The site would have lighting equivalent
to a well-lit shopping mall parking lot.
Site visits by Committee members to existing ethanol plants at Malta Bend and Laddonia, MO suggest the noise level will be a low roar, easily detectible at a distance of one-half mile. The noise would mostly come from the hammer mills and distillers-grain dryers inside the buildings.
22. How would odors
be managed?
The
ethanol manufacturing plant will be in enclosed buildings, and according
to GBE Vice-President Jeff Negre, people would not be able to smell
odors more than 200 yards away. The plant would have an exhaust stack 75
feet in height and the dried distillers grains (DDGs) would be stored
under roof.
Site visits by Committee members to existing ethanol plants at Malta Bend and Laddonia, MO suggest the odor level is like a yeast smell of a bread factory, detectible at the main gate of the plants.
Wind rose data recorded at the Springfield, MO, Regional Airport was obtained by the Committee and indicates the predominant wind direction for the warmer months of April through September will be from the south-southeast toward the north-northwest. This data collection site is the nearest location to the proposed ethanol plant site.
23. How many tons per
year of particulate matter, volatile organic compounds(VOCs), carbon
dioxide (CO2), nitrogen oxides, and Hazardous Air Pollutants
(specifically acetaldehyde) do you expect the plant to emit? Will you
install scrubbers to minimize these emissions?
Greg
Wilmoth dismissed the question of particulate matter, VOCs,
nitrogen oxides, and HAPs, but stated GBE plans to recover all the CO2
and sell it.
According to Kendall Hale, New Source Review Unit Chief of MODNR’s Air Pollution Control Program, in Jefferson City, MO, air quality permits would need to be obtained from them. Ethanol plants that produce less than 100 million gallons per year (MGY) can apply for a “minor permit” rather than a “major permit.” With a minor permit, no formal public notice period is required. A company also has the option to request a pre‑construction waiver, which allows them to be building the plant before a MoDNR construction permit is issued. In other words, they can clear the ground, but cannot do other construction until the pre-construction waiver is approved by MoDNR.
Since all plants are different in their emissions, air quality data prior to construction must be determined. This “ambient air quality analysis” is typically done by the engineering firm designing the plant, using computer modeling software.
Once the waiver is approved, a company can be building the plant and simultaneously be completing an application for a “construction permit.” (Supplemental information to assist a company in preparation of a construction permit application is available in a 51-page MoDNR document.) They cannot start up the plant until they have submitted the construction permit application and received approval of it from MoDNR, which takes a maximum of 90 days from when a complete application is received. Once the plant is operational, the company would then submit an application for an “operating permit.” The permit would state what level of emissions the plant has, and is a matter of public record.
State standards for air emissions are currently not allowed to be more strict than federal standards. An example of an approved air quality construction permit is the Missouri Ethanol, LLC ethanol plant, at Laddonia, MO.
Issues about air emission quantities and quality for ethanol plants are still being researched by the Committee.
24. Will the site
have any storage tanks with hazardous materials or fuels? If so, what
kind of containment structures will they have in case of failure?
GBE
stated there would be fuel stored on-site away from the plant. This
would include an E95 (95% ethanol/5% gasoline) blend to mix with the
ethanol made by the plant before the ethanol is shipped out. Company
officials downplay safety issues from explosion, citing the
U.S. Energy Partners, LLC ethanol plant within the town of Russell,
KS, but acknowledge that pressure release is the only risk.
The Committee has learned that the Russell, KS ethanol plant is currently seeking to double its production capacity from its current 48 million gallons per year, but is having difficulty locating enough water to do it.
Spill containment of fuel storage structures are required to meet MoDNR standards.
25. What will be the
electrical demand on created when the plant is running?
GBE stated
the plant will have a 10,000 Kilowatt-Hour demand. They are looking at
the possibility of using natural gas turbines to supply some of the
power.
26. The railroad
crossing at Porter Crossing Road is a concern for school bus safety. How
will the company maintain safety at that intersection?
Greg
Wilmoth stated that is a responsibility of the Burlington Northern
Railroad, which intends to increase their rail traffic from 48 trains
per day to 70 trains per day. The Gulfstream Bioflex Energy (GBE) plant
would be two trains per week of that total.
Committee conversations with Webster County Presiding Commissioner Paul Ipock indicate Burlington Northern Railroad may require GBE to pay for rail crossing lights and crossing arms.
Similarly, to alleviate congestion at the U.S. Highway 60 and Porter Crossing Road junction, the Missouri Department of Transportation may require GBE to help pay for turn lane improvements.
27. What kinds of
jobs would the ethanol plant create?
Greg
Wilmoth stated GBE would employ 35-45 people with a $2.1 million per
year payroll. Salaries would be $35,000 or more per person per year in
jobs like rail car loading/unloading, scale operators for weighing
trucks, laboratory personnel and clerical workers. They would be willing
to hire from within Webster County if people have the skills. An
additional 200-300 outside workers would be coming in during the
construction phase of the ethanol plant.
The Committee advises that for permanent plant employees to benefit the county the most, the employees would need to own homes in the county and spend their take-home salaries on products provided by Webster County businesses. Economic benefit to the county from the construction workers would mostly be to eating places.
28. What economic
benefit will the county receive in general revenue funds?
Committee
research shows that due to the roll-back of the county portion of the
general revenue property tax when the county sales tax was passed in
November 2005, the county would receive no general revenue from this
plant. Property taxes associated with the road and bridge department,
schools, libraries, health department, etc. would still apply.
29. Would the
environmental impact concerns be the same for other locations, thereby
making concerns about the ethanol plant just a matter of ‘not in my
backyard’ mentality?
The
Committee advises that the environmental concerns definitely are not the
same in all other areas.
Missouri is one of the most diverse states in terms of soils and geology. Other ethanol plants in Missouri are in areas that do not have a significant groundwater threat and are not in residential areas competing for groundwater. Another contrasting area would be the southeast Missouri Bootheel, where there is virtually unlimited supply of water from a different type of groundwater source and minimal wastewater impact from an ethanol plant.
This proposed location of this plant is unique not just because of distance from corn, but because it is the first one proposed in the part of the state that is most susceptible to groundwater contamination and in an area with a high demand for residential water from individual wells.
Created: 2006-09-07 Last revised: 2006-11-13
