Oklahoma Bioprocessing Project

The project does ot have a discharge, so no NPDES permit is required.

Argo's current plan is for Rural Water District #4 to supply 100,000 gallons per day; this may include investments funded by Argo working in collaboration with RWD #4. We are not currently pursuing plans for argo to own/operate a new well.

There is no contaminated wastewater being discharged. The water recycling system captures most of the nutrients and Total Suspended Solids (TSS) andputs them into fertilizer form. The fertilizer will be trucked offsite and sold to organic farmers for up to 10 times the incoming value of the poultry litter. The water that can not be recycled is sent to an evaporator to be evaporated. Any materials that cannot be recycled or evaporated will be trucked off-site for disposal at a regulated/licensed facility.

No, this is not part of the plan at this time. Our plan to work with RWD #4 was driven by our understanding that they have the water to provide from existing allocations.

Under steady state operations, the biogas produced will be upgraded into pipeline-spec natural gas, also known as Renewable Natural Gas (RNG). There are biologial H2S removal units part of the Biogas Upgrading System (BUS), which are capable of removing about 3,000 lbs. per day of Sulfur. The upgrading system is designed for at least 98% uptime. If the upgrading system is down but biogas is still being produced, the gas will first be captured in the gas storage membrane, which can store several hours' of production. Then, if storage is exhausted, gas would be flared, which will result in the methane and H2S being combusted to H2O, CO2, and SO2.

The only time when emergency releases with substantial H2S would occur is if the BUS, the storage, and flare are all unavailable. Flares undergo annual inspection and maintenance so that they will reqch target availability of >99% and essentially eliminate upsets. The releases, regulated by pressure release vales (PRVs), would only occur when the at-least-98%-uptime BUS, the gas storage membrane, and the >99% uptime flare are all not functioning.

The biological scrubbers are part of the BUS. Our understanding is that this question is about emergency releases of raw biogas. Those by definition are not being sent to the BUS or the biological scrubbers, but would only occur when the98% uptime BUS, the storage membrane, and the >99% uptime flare are all not available.

Yes. We do not believe the height of the bridge presents any issues for the trucks that will be coming to the site during construction or operations.

All litter is hauled by truck, and the site was chosen because it is close to the current litter routes used by farmers. The plant is configured to process 164,000 tons per year, which is about 540 tons per day or about 16 trucks per day. Many of those trucks are likely already taking the same routes that are close to the plant.

The Average Annual Daily Traffic (AADT) count at this site is 6,200 vehicles per day, based on the database provided by ODOT. So the net increase is estimated to be less than 1%.

Argo applied for required Oklahoma Dept.of Transportation (ODOT) permits in 2024. ODOT determined that the project impacts to roads and bridges did not warrant any upgrades.

There is an existing gas pipeline (underground) running across the site. The project will inject gas directly into the pipeline using a systemthat complies with Southern Star's specifications for gas compression and metering equipment. Southern Star operates 6,000 miles of pipeline systems across the U.S. and will be an integral partner ensuring safe and reliable operations of this system.

The injection to the pipeline is in cooperation with Southern Star and built to their specifications, including American Gas Association (AGA) standards for interconnection and metering. Southern Star operates 6,000 miles of pipeliestems tughout the US. Hauling operations will be in accordance with DOT certifications, and all drivers will have CDL certifications from Oklahoma DPS, Arkansas Office of Driver Services, or any other state the drivers hail from. Argo, in conjunction with its partners that have over 20 years of operations experience operating over 50 plants, will put in place strong safety programs during construction, commissioning, and operations.

The estimate of 14-20 operations jobs is the best information we have at this time. For any calculations that require using a single number vs a range, we recommend using 14.

In most cases, specific farms have not been identified as the litter source. Litter is being bought from an aggregator who buys from many different farms. So here is no way to obtain a precise count. We know a significant portion of the litter will come from Adair County, OK, and Benton County, AR, and is already trucked through Ottawa County on its way to Kansas.

The facility will be built on a 42-acre area within the 110 acres being leased. The actual equipment will cover significantly less.

The lease requires a decommissioning plan and decommissioning bond. If the plant closes or OKBP fails to restore the site pursuant to the lease, the landowner has a bond to restore the site in accordance with the decommissioning plan. The bond can only be used for these purposes so the landowner will have funds and motivation to restore the site.

Expansion is possible in the future, but there are no specific plans at this time. Any expansion would require a new air permit and possibly other approvals.

After the construction permit is issued, Argo will also have to follow up and apply for an operating air permit, which will go to public comment. This will occur around the end of construction, so late 2027 is the current forecast. The air permit allows the facility to operate as long as it complies with the permit requirements, passes any DEQ inspections, an submits annual compliance reports. Sine ODEQ regulates this process, you may wish to follow up with them directly - Alexandra.Mills@deq.ok.gov is the ODEQ point of contact for our project.

In the case of an expansion, a new permit will be required. Since ODEQ regulates this process, you may wish to follow up with them directly - Alexandra. Mills@deq.ok.gov.

Opacity is governed by OAC 252:100-25 (Visible Emissions and Particulates) and is a general requirement in all air permits. Opacity is limited to 20% in general, but there is an allowance for 18 minutes per day at 60% (up to three instances of 6 minutes per hour). Argo does not have any units that typically create opacity. Argo will comply with this permit condition, be subject to DEQ inspections, and certify compliance as required by ODEQ.

Argo submitted all required information for a minor source air permit, as determined by our air permit consultant. The reference to New Mexico is for cooling tower emissions. Our air permit consultant, a certified Professional Engineer, determined the method was more accurate than the EPA emissions factors. ODEQ would have to provide specific information on the length of the permit.

We do not have a specific number yet due to exploring multiple contractors and combinations to complete the work. During peak construction times, the project is expected to employ over 100 workers, paying prevailing wages. In our experience, we find the most cost-effective workers will be from the local region and will likely make up a large portion of the team.

The most common challenges that similar projects in Europe have experienced involve non-compliant feedstock or mixed feedstock and not having adequate back-end processing to create desirable fertilizer products. We have incorporated these lessons-learned into our project's design.

We have secured contracts for the feedstock with reputable farmers and with aggregators that have significant experience with meeting a litter quality specification. Additionally, we will have a robust testing protocol to determine that the incoming feedstock is within our system's specifications. Feedstock that is deemed non-compliant will not be accepted at our facility.

Similarly, we will use a robust digestate processing system tocreate saleable liquid and solid fertilizer. We have take-or-pay contracts (they must by the products from us) with a fertilizer distributor to take the fertilizer products from the facility, ensuring that there is no product buildup at the back end of the process.

Our plan to work with RWD4 was driven by our understanding that they have the water to provide from existing allocations.

RWD4 may decide to drill additional wells if they conclude the water is available from the aquifers. According to the 2024 USGS report on the Roubidoux aquifer, there is approximately 1.0 million acre-feet of water per year flowing in and out of the aquifer. This is about 900 million gallons per day total water available; Argo's project is about 0.01% of this figure.

The data indicate the Roubidoux is quite sustainable even if increased outflows are undertaken. In the increased groundwater demand scenario in the USGS report, the agency looked at a cumulative 58-percent increase in groundwater withdrawl from 2010 - 2050. This 58 percent increase is enough for approximately 5,000 Argo projects. Their groundwater simulation forecast an impact on Roubidoux Groundwater Storage amountng to less than 0.01 percent. Our research shows that "cause for concern" by researchers occurs in the range of 5-15% groundwater depletion, so 0.01% is outside the realm of concern.

Argo is exploring the re-use of stormwater, which could provide meaningful quantities of water if captured. This has not been fully implemented yet.

The plant does not have significant quantities of chemicals that are known to create long-term remediation challenges (heavy metals, PCE, TCE, benzene, etc.). The site is also under a lease that requires the tenant (OKBP) to clean up any environmental contamination. The lease and the bank loans require insurance that is sufficient to restore the plant to operation and address or remediate any environmental contamination or damage.

The Operations & Maintenance responsibility will be managed under a contract. We are currently collaborating with two contractors, one of whom has done 9 anaerobic digestion projects ranging from 36,000 to 100,000 tons. The other has done more than 70 digester projects globally and more than 10 in the United States, and includes some projects at 160,000 tons (Argo's scale). The Argo team members have hands-on experience in engineering, commissioning, and starting up a variety of different project types, including digesters and bioprocessing projects. We have over 55 years of combined experience, with all Argo team members having at least 15 years of experience.

Ideally, construction will start in Q4 of 2025, and the plant will be operational in a steady-state operation in 2027.

Our understanding is that Ottawa County will receive property taxes and a portion of any sales & use taxes. The only other recipients would be the State of Oklahoma and the federal government.

The landowner will receive compensation consistent with local commercial real estate.

See FAQ response. Argo is not receiving any incentives from the City of Miami or Ottawa County.

Rail is not part of the project plan at this time. There was one site plan drawing that showed the space required for a potential rail spur, but it isnot part of the plan for at least 5-10 years. Since we have not been i contact with any rail companies, we are unaware of any initiatives to repair or replace thos areas. Argo would make investments needed to support the rail if that option were pursued.

H2S is a constituent in raw biogas that is actively managed during operations. Under normal operations, H2S levels are 300-500 ppm in the digester and then removed through successive processes to 100 ppm to below 1ppm on to ppb at fencline. The digester H2S concentration will be managed with nutrients and additives into the anaerobic digestion process. In the event that raw biogas cannot be upgraded to RNG, the biogas is fired stroded in the gas membrane, then would be flared, and H2S would be combused to water and SO2 per the air permit.

Safety of the entire system will be ensured by following industry-accepted practices like process hazard assessment (PHA) at key milestones.

The plant is being designed to NFPA 329 and NFPA 400. The operations staff will be trained in all aspects of safe handling of natural gas equipment, including leak deection, ensuring proper ventilation in enclosed areas, PPE, lockout/tagout of equipment, monitoring equipment (maintained and calibrated gas meters), and relevant fire safety.

We understand that a HAZOP study is a critical part of the plant design. The current plan is to perform a HAZOP study or PHA. We will conduct a HAZOP with a third-party facilitator and our engineering team when we enter the next phase of engineering and construction.

Argo has always pursued a partnership model for operations personnel. We will be using a larger firm. One example is an engineering & operations firm with over 1,000 active employees that does this type of contract. Another example/option is one of the European companies that has a U.S. arm; they have built more than 70 digester projects, including poultry litter projects.

The plant is located on a State Highway, and the roads will be maintained by the State of Oklahoma. Communication with ODOT indicates that the traffic associated with the project impacts are below the threshold for a preemptive traffic impact analysis (TIA).

Given the current political environment, we believe the funding for renewable energy and environmental projects may be more difficult.

Argo's project will need to meet the same standards as others in the renewable fuels industry, such as meeting the EPA program for verification of renewable fuel.  As an example, the EPA's Renewable Fuel Standard (RFS) program, which creates RINs, sets specific greenhouse gas (GHG) reduction thresholds that renewable fuels must meet.  Another example of the validation that goes into these projects is Carbon Intensity or "CI score".  Argo's process has been shown to have a negative CI score, i.e., it has a net effect of reducing greenhouse gas emissions.

The renewable fuels markets are well-established and require detailed 3rd party reviews of the project plans and lifecycle emissions before projects can be financed and move forward.  Argo was established with a plan to meet and exceed these thresholds and deliver measurable, verifiable greenhouse gas benefits.

In response to the claims about backing/PR, we think it is fair to point out that Argo is backed by independent investors.  There is no agriculture corporation that can claim Argo's project as a "PR win".  It will also cost over $150 million and multiple years of dedicated engineering, management, and construction effort to construct the facility, which seems not to fit the definition of a "cheap PR win".

The National Clean Air Act plays a crucial role in protecting people from respiratory issues like asthma.  The Act authorizes the Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards (NAAQS) for common air pollutants that are harmful to public health.

The Oklahoma Department of Environmental Quality (DEQ), Air Quality Division (AQD), is charged with protecting public health and our environment. AQD accomplishes this through a State Implementation Plan (SIP) to implement and enforce the various air quality programs.  In addition, the SIP includes State-only requirements which were deemed necessary at the time of the SIP development or to assure continued compliance with the National Ambient Air Quality Standards (NAAQS).

Argo has complied with all permit processes and requirements to ensure the above-mentioned standards for air quality are met.  According to DEQ, review of all the requirements contained in the current SIP plan indicated the facility is in compliance.  Argo also is requiring its contractors to include a best-in-class odor control system.  More information is available in the public copy of the minor source air permit.

This claim appears to be conflating the biosolids from other types of waste disposal facilities, such as municipal sewage treatment, with poultry litter.  This is a different process than Argo is proposing to use versus anaerobic digestion of poultry litter.  Argo has developed a specification for fertilizer in the agreement with our distributor, which requires the fertilizer to contain a certain amount of nutrients.   The fertilizer will not be distributed if it doesn't meet these requirements for high nutrient content (and minimizing pollutants/contaminants).  The fertilizer will also be sold at a premium value up to 10 times more than the incoming poultry litter to farmers who are paying a premium for a desirable product.

According to the EPA, The terms “biosolids” and “sewage sludge” are often used interchangeably by the public; however, the U.S. Environmental Protection Agency typically uses the term “biosolids” to mean sewage sludge that has been treated to meet the requirements in the EPA’s regulation entitled, “Standards for the Use or Disposal of Sewage Sludge,” promulgated at 40 C.F.R. Part 503, and intended to be applied to land as a soil conditioner or fertilizer.

The term biosolids does have a connotation to treatment/processing of human waste as sewage.  This is a different process than Argo is proposing to use versus anaerobic digestion of poultry litter.

PFAS / forever chemicals, while a concern for the community, are not related to Argo's project.  The bioprocessing technology and agricultural production being pursued by Argo do not introduce PFAS into the fertilizer products or the community.   According to the EPA, the most common current and historical activities that generate PFAS include industrial releases (e.g., aqueous film-forming foam, pulp and paper plants), commercial releases (e.g., car washes, industrial launderers), and down-the-drain releases from homes (e.g., use of consumer products like after-market water resistant sprays, ski wax, floor finishes, and laundering of stain or water-resistant textiles with PFAS coatings).

The renewable natural gas (RNG) produced by Argo's project will be in compliance with Southern Star's natural gas specifications, which are set by the Federal Energy Regulatory Commission (FERC).  In other words, at the point of use, it will have no different impact compared to any other natural gas used by home appliances, industrial use, power generation, etc.

Argo had a legal review of local zoning ordinances in Ottawa County, Oklahoma, completed in recent months. This included review of multiple state and county-level regulations and discussions with the Ottawa County Clerk's office. Based on the review, there are no zoning regulations in Ottawa County at this time.