About the FRG
The AltEn Facility Response Group (FRG) includes six former AltEn customers – AgReliant, Bayer, Beck’s, Corteva Agriscience, Syngenta and WinField United – that formerly supplied corn seed to AltEn. It was formed after the NDEE sought assistance with their efforts to address environmental issues at the AltEn site caused by how AltEn mishandled materials at its facility, its failure to follow requirements outlined in its customer agreements and its lack of compliance with federal and state environmental regulations.
The companies comprising the FRG joined together to address the unsafe conditions created by AltEn’s mismanagement of solids and water generated by the ethanol production process on-site and are participating in the NDEE’s Voluntary Clean-up Program based on a Memorandum of Agreement. The FRG has stabilized the AltEn site, developed a Remedial Action Plan (RAP) for water stored at the site and is developing a RAP for the onsite solids. This work is helping the FRG to ensure the safety of the surrounding community and environment. To date, there has been no evidence of impacts to local drinking water.
The FRG members do not own the site, have never operated the ethanol facility, and played no role in AltEn’s management of its facility. The site owner, AltEn, is the permitted entity at the site and is not a member of the FRG and is not contributing to the voluntary measures being implemented by the FRG.
History of AltEn’s Operations at the Site
NDEE orders AltEn to cease discharging process water into the site’s three lagoons and emergency pond. AltEn soon after vacates the site.
A digester at the site fails due to heating being shut off to the digester by AltEn employees. It releases approximately four million gallons of thin stillage and manure. The manure is a byproduct from the adjacent Mead Cattle Company property.
NDEE issues another emergency order prohibiting AltEn from resuming operations until the digester discharge is sufficiently remediated.
The AltEn Facility Response Group (FRG), a group of six companies that were former customers of AltEn, begins to collaborate after NDEE sought assistance with their efforts to address environmental issues at the AltEn site. Groundwater and environmental monitoring begin. NDEE testing has consistently shown no evidence of impacts to local drinking water.
This system creates 29 million gallons of above-ground temporary storage to begin moving, treating, and storing water from the emergency pond and lagoons to begin to bring back the lagoons to within safe operating levels. This multi-stage treatment process reduces pesticide residues to very low levels, which will result in a fraction of EPA-approved agricultural rates during land application.
After AltEn fails to comply with NDEE order, the State of Nebraska files suit against AltEn in the District Court of Saunders County. The lawsuit against AltEn remains pending while the FRG has managed the substantial work necessary to mitigate and stabilize the site.
FRG submits an interim Remedial Action Plan (RAP) detailing the substantial activities undertaken by the FRG to manage the immediate concerns relating to lagoon water and wet cake stored on the AltEn site, as well as stormwater runoff.
The FRG refurbishes the emergency pond, ensuring the digester tanks can be safely drained, treats 13.4 million gallons of lagoon water, consolidates wet cake in one location, winterizes AltEn’s ethanol process plant and piping, and manages the chemical inventory left behind by AltEn.
The temporary Posi-Shell covering is installed to contain waste, control odor, and prevent contact between the wet cake and any precipitation, preventing the generation of additional contaminated stormwater.
FRG companies file civil lawsuits against AltEn for breach of contract to hold the AltEn entities accountable for remediation of the environmental conditions they created at the AltEn site.
NDEE enters an administrative consent order with AltEn that supersedes the emergency orders issued in February 2021. However, despite the order, AltEn and its affiliated companies (and their management) continue to evade their obligations to finance or otherwise substantively address the environmental conditions at the site.
NDEE conducts a groundwater investigation consisting of 7 direct-push borings and installing 2 monitoring wells (MW-EE1 and MW-EE2). Constituents are materially present in one of the direct-push groundwater samples taken adjacent to the Northwest Lagoon (SP-2), but the constituents are not consistent with those in the Northwest Lagoon water or any other monitoring well. NDEE testing has consistently shown no evidence of impacts to local drinking water.
The FRG continues to treat wastewater, treating over 18 million gallons by May 25. The water is tested and confirmed to comply with approved NDEE thresholds for land application. Over 9 million gallons of treated water is successfully applied to local fields as a nutrient-rich benefit for crop health.
An additional monitoring well was installed by the FRG at the same location as NDEE’s direct-push boring SP-2 which indicated constituents were materially present. The analytical results from this well indicated that two pesticides were present at concentrations above groundwater screening levels identified by the NDEE as being appropriate for human health exposure. All other site groundwater samples collected since then have been well below screening levels. NDEE testing has consistently shown no evidence of impacts to local drinking water.
Repairs are made to Posi-Shell covering of wet cake due to cracks that formed from settling. There is no indication that these cracks resulted in any release of contact stormwater. The FRG will continue routine inspections, monitoring, and repairs as needed of the Posi-Shell.
The FRG installs 3 additional monitoring wells on the AltEn site for expanded monitoring purposes and NDEE installs two additional monitoring wells. The FRG and NDEE sample all 10 wells on the AltEn site. The NDEE also samples 48 off-site wells. MW-5, the well immediately adjacent to the AltEn Northwest lagoon, continues to be the only groundwater monitoring well where constituents present in the lagoon water appear to have been materially present in the groundwater sample. NDEE testing has consistently shown no evidence of impacts to local drinking water.
FRG submits its final Water RAP for NDEE approval on October 14, 2022.
The NDEE and the FRG continue conducting additional groundwater testing following the detection of active ingredients in one groundwater well adjacent to the Northwest AltEn lagoon. A final deep monitoring well was installed and groundwater is sampled; results will be shared when available. NDEE testing has consistently shown no evidence of impacts to local drinking water.
FRG treated 49 million gallons of water throughout the year, 29.4 million gallons of which has been applied to nearby farms as a nutrient-rich benefit for crop health, after working with the NDEE to meet several regulatory steps and secure permits required for this process. The FRG also has worked closely with the Saunders County Highway Department so that treated water can be safely piped under roads and onto nearby fields.
The FRG implemented a Solid Waste Pilot Program to better understand variables at play with off-site disposal of non-hazardous wet cake at the abandoned AltEn site. The program addressed solidification and the rate at which the FRG could send truckloads to the landfill, potential impact on communities and infrastructure along the transportation routes, and landfill contractor coordination.
In preparation to remove non-hazardous wet cake from the AltEn site, trucks began removing trash, wooden pallets, empty containers and biochar that was taken to WM’s Pheasant Point landfill in October 2023.
A total of 157 truckloads removed 1,587.73 tons of trash and debris from the AltEn site.
A new water treatment plant began operating to remove solids and pesticides more efficiently from water on the AltEn site. The treated water will eventually be applied to land.
The FRG announced engagement or contract? with WM to begin disposal of the solidified wet cake at WM’s Pheasant Point Landfill, which is authorized by the Nebraska Department of Environment and Energy (NDEE) to accept non-hazardous waste such as wet cake. The AltEn site is preparing for solidification and transportation of the wet cake to begin the last week of September, including the installation of equipment (e.g., pugmill mixers to enable solidification, wheel washers for loaded trucks prior to exiting the site) and other steps to prepare the site.
Each truck carries approximately 20 tons of wet cake at a rate of six trucks per hour. Up to 1,000 truckloads are expected to transport solidified wet cake to WM’s Pheasant Point landfill. This phase of the Solid Waste Pilot Project will conclude in November 2023.
The FRG worked with a contractor to transport and dispose of seed at a waste-to-energy facility. More than 2,600 tons of seed were removed from the AltEn site’s North and South Hoop Buildings from August to October 2023. An additional 4,400 tons of seed will be removed from an on-site silo.
The FRG has treated 8.8 million gallons of water in 2023, bringing the total to 58.2 million gallons treated to date. The process is on track to apply 20 million gallons of treated water to land by mid-November 2023.