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EPA offers 10 tips preparing for CAFO inspections

By Staff | Jun 18, 2010

Producers who own a Concentrated Animal Feeding Operation have probably heard about the federal Environmental Protection Agency 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, an EPA fact sheet said.

Having EPA show up at one’s facility for an inspection can sometimes be a daunting experience. Inspections are very comprehensive and typically cover all aspects of a facility’s operation.

EPA inspectors routinely perform walk-throughs of production and land application areas, review records and collect samples. To assist producers in preparing for inspections, EPA offers the following 10 tips to help ensure operations are in compliance.

  • Is the operation 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.

Those who are discharging, should contact the state regulatory agency to determine waste controls and permit requirements.

  • Is the operator controlling runoff from feed storage areas? CAFOs are required to control runoff from all production areas, including feed storage areas.
  • Is the operator controlling runoff from manure and/or 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.

  • Is the facility medium-sized? If an operation conveys runoff from the production area through a man-made ditch, flushing system or other similar man-made device, then it needs to obtain a permit or stop the discharge.

It is important to read one’s National Pollutant Discharge Elimination System permit and implement its requirements.

  • Is the owner and/or operator 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.
  • If the 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.
  • Maintain complete and accurate animal inventory records. One of the first things an inspector does is determine a CAFO’s status by looking at the number of animals that have been confined at the facility. This determination can take time if the right records are not readily available.

Those who have an NPDES permit, cannot expand operations beyond the capacity listed in the current permit without authorization from the state regulatory agency.

  • Has the operation maintained lagoon berms free of trees, shrubs and erosion features and follow pump-down level requirements for lagoons to maintain adequate storage levels.
  • Has the operation maintained 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 demonstrate that the operator is implementing appropriate land application practices.

Learn more about the NPDES and how it regulates CAFOs at http://cfpub.epa.gov/npdes/home.

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