URGENT REQUEST FOR OZARK SOCIETY COMMENTS: C & H HOG FARM PERMIT MODIFICATION

C & H Hog Farm has requested ADEQ to modify their CAFO General Permit ARG590000.

Only the requested modification to install pond liners in Waste Storage Ponds 1 and 2 as well as to install a methane flare system and cover on Waste Storage Pond 1 are open for comments. Any other comments will be rejected.  The following concerns may be used for your comments.  Please write in your own words on one or more talking points.

Comment period ends Friday, August 7, 2015 at 4:30 PM. Send e-mail comments to:   Water-Draft-Permit-Comment@adeq.state.ar.us.

The following concerns merit a public hearing.  ADEQ should provide one prior to a decision on the request to modify CAFO General Permit, ARG590000.  (Include this request for a public hearing)

Concerns:

1. How will it be verified that all the hog waste sludge has been removed prior to installing pond liners?

2. If all the sludge is not removed prior to installing the liners, methane gas can build up beneath the liners and cause the liner to “float” up or possibly rupture.

3. How will the hog waste be removed?  Vacuumed up, washed down and vacuumed more or how?  If so, there is the risk that the original clay liner could be damaged or disturbed causing the current leakage of waste to accelerate.

4. Is there any precedent in Arkansas for installing pond liners after clay liners have been receiving waste for about two years?

5. The methane flare operation is a concern in that it appears to be unknown what toxic fumes are left in the air as methane burns.  My understanding is that if just methane is flared, only CO2, water and possibly some sulfates would be expelled.  What about sulfates, how much?  With President Obama’s new clean air directives, it is currently unknown how that will impact methane flaring of hog waste.

6. Given the unknowns, what is the success rate at other hog farms of this size in Arkansas and other states?