# Tupelo Bayou Treated-Effluent Cooling The plan to cool the [[Project Stratus]] data center with **treated effluent (reclaimed wastewater) from [[Conway Corporation]]'s Tupelo Bayou Wastewater Treatment Plant**, rather than potable water or groundwater — the cooling-water mechanism the Conway MOU disclosed and the Conway Corporation production now documents at the engineering level. ## The scheme - **Source.** Conway Corporation's **Tupelo Bayou Wastewater Treatment Plant (TBWWTP)**, 1405 Lollie Road, Conway — adjacent to the rezoned data-center site. The plant treats municipal wastewater and discharges to the **Arkansas River (Segment 3F) via Outfall 001** under **NPDES permit AR0051951** (effective 2023-07-01, expires 2028-06-30; issued by DEE/DEQ). The MOU and the April 2026 FAQ describe a ~**5 million gallon-per-day** treated-effluent cooling supply piped by Conway Corporation to the site. See [[Tupelo Bayou NPDES Permit and Conway Pretreatment Program]]. - **Evaluation.** [[Garver]] (2024) and then [[Black & Veatch]] (2025–2026) evaluated whether the effluent's quality supports cooling-tower use, sampling 30-plus constituents (TDS, TSS, BOD, ammonia, silica, metals, chloride, etc.) against required detection limits, and whether **pretreatment** of the effluent is needed before it can feed cooling towers. The developer funds this work under a **Reimbursement Agreement for the TBWWTP Evaluation**. See [[Black & Veatch Effluent-Cooling Engineering for Project Stratus]]. - **Blowdown / discharge.** Concentrated cooling-tower **blowdown** (carrying constituents and the corrosion inhibitor SD2535) must be disposed of. The open engineering question, posed by Garver in 2024, is whether the data center returns blowdown through Conway's wastewater system — subject to the City's **industrial pretreatment program (Ordinance O-12-08)** — or obtains "**its own treatment and NPDES discharge permit to the Arkansas River**." - **PFAS.** Black & Veatch's Work Order No. 1 is a PFAS review and workshop — per- and polyfluoroalkyl substances in the effluent/discharge stream are an explicit part of the engineering and regulatory scope. ## How it appears in the corpus - The [[2026-05 Conway Corporation Produces Project Stratus Records|Conway Corporation production]] is the Tier-1 anchor: the NPDES permit, the pretreatment ordinance, the water-quality data request, the Reimbursement Agreement, the PFAS work order, and the Final Engineering Report transmittals. - The April 1, 2025 MOU and the [[April 2026 FAQ Project Stratus|April 2026 FAQ]] (City production) first disclosed the treated-effluent cooling plan and the ~5 MGD / Arkansas-River-blowdown design at the policy level. ## Notes The treated-effluent approach distinguishes Project Stratus from the two **groundwater-cooled** unnamed data centers in the Department of Agriculture record — Conway draws reclaimed wastewater, not a dedicated well field (see [[Identifying the Unnamed Cooling-Water Data Centers]]). It also relocates the cooling-water "who pays" question onto Conway Corporation's ratepayers: the utility designs, permits, and builds the conveyance and (possibly) pretreatment, and how that capital cost is recovered is unaddressed in any produced record (FOIA Item 4(e), "no records"; the Black & Veatch Rate Analysis memorandum is referenced but unproduced).