Ten Tips from USEPA for CAFOs

Is this an indication of future enforcement initiatives?

The United States Environmental Protection Agency (EPA) Region 7 recently issued a “Fact Sheet” entitled, Ten Tips to Prepare for EPA Concentrated Animal Feeding Operations Inspections. They state in their introduction, “…you have probably heard about EPA’s inspection and enforcement activities in Region 7. These activities are part of an increased national emphasis aimed at ending harmful discharges of pollutants from CAFOs into rivers and streams.”

With this as a background, the EPA offers the following ten tips to help “ensure operations are in compliance.”

  1. Are you discharging? Answering this question is one of the primary purposes of an EPA CAFO inspection. Owners and operators of CAFOs should evaluate their facilities to determine if any runoff is getting into nearby rivers and streams. If you are discharging, contact the state regulatory agency to determine waste controls and permit requirements.
  2. Are you controlling runoff from feed storage areas? CAFOs are required to control runoff from all production areas, including feed storage areas.
  3. Are you controlling runoff from manure/bedding stockpiles? These stockpiles are considered part of a facility’s production area even if they are located outside the facility’s footprint. Care should be taken to prevent runoff from discharging into nearby rivers and streams.
  4. Is your facility medium sized? If your operation conveys runoff from the production area through a man-made ditch, flushing system or other similar man-made device, then you need to obtain a permit or stop the discharge.
  5. It is important to read your National Pollutant Discharge Elimination System (NPDES) permit and implement its requirements.
  6. Are you counting animals correctly? Both EPA and state regulatory agencies require that species in open lots be counted together with similar species in confinement for the purposes of determining your size status as a CAFO. Also, if your operation confines enough animals of one species to be considered a large CAFO, then all animals at the operation must be counted and runoff from these areas must be contained.
  7. Maintain complete and accurate animal inventory records. One of the first things an inspector does is determine your CAFO status by looking at the number of animals that have been confined at your facility. This determination can take time if the right records are not readily available.
  8. If you have an NPDES permit, you cannot expand operations beyond the capacity listed in your current permit without authorization from the state regulatory agency.
  9. Maintain lagoon berms free of trees, shrubs and erosion features and follow pump-down level requirements for lagoons to maintain adequate storage levels.
  10. Maintain records for land application of manure solids and liquids and follow a nutrient management plan/manure management plan in the application of any manure. These records are vital to demonstrating that you are implementing appropriate land application practices.

(Source: http://www.epa.gov/region07/factsheets/2010/ten_tips_cafo_inspection.htm)

While it is nice that the EPA is offering helpful hints to CAFO owners, I am reminded of something an “old salesman” was fond of saying, “You’re telling me that for a reason.”

If you have any questions or need assistance with an environmental issues contact Matthew Schroeder, P.E. (mschroeder@dragun.com) or Christopher Paré (cpare@dragun.com) at 248.932.0228.

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