4. Kudos: Increased Communication
Externals
• WDPES permitted food
industries
• WPDES permitted
haulers
• Land application
contract hauler
• Consultants
Internals
• Wastewater specialists
(current and former)
• Wastewater engineers
• IT support
5. Partnerships
Industry Initiatives…
Industry collaboration mtgs.
Professional industry
meeting (WILACT)
DNR staff training
Compliance staff
Enforcement staff
Field demonstrations
Improved communication
Reinforce value to industry
Perspective
Department Services…
Attend industry mtgs.
Face-to-face facility mtgs.
Regional mtgs.
Statewide mtgs.
Suggest compliance options
Listen
Customer service
6. Improved Land Application Mgt. Plans
Decreased complaints
Predictable responses
Department expectations
Land applicator expectations
Improved compliance
Accountability within organization
Less “foolish” compliance issues
7. Standard Operating Procedures
Land application
Site pre-check
Conditions appropriate
Identify restricted areas
Notification
Site post-check
Applicator/Operator guidelines
Restricted area identification
Runoff/ponding
Spill response
9. Objectives of Guidance
Statewide consistency
Predictable responses
Information road map
Communication tool
WW & Runoff Management coordination
Submittal requirements
Transparent review process
Compliance expectations
Reference sources
10. Guidance Impact
Food Industry
Liquid waste generator
Dispose liquid wastes into manure storage units
Contract Haulers
Transport liquid wastes for disposal to manure
storage units
Others
Farmers, Consultants, County Conservation Depts.
11. Storage Discharge Scenarios
Type of facility
Non WPDES-permitted
farms
WPDES permitted farms
(CAFOs)
Threshold % discharge
<10%
10-30% (WPDES
permitted farms only)
>30% (WPDES permitted
farms only)
Farm Type
21. Industrial Sludge
Definition: accumulated solids generated
during the biological, physical, or chemical
treatment, coagulation, or sedimentation of
water or wastewater [s. NR 214.02(34) Wis. Adm. Code]
22. Options for Disposal
Land application
POTW
Landfill
No 10% exemption in s. NR 214.18
Facilities have requested exemption
s. NR 214.06 Wis. Adm. Code
Requirement more stringent than necessary to
comply with ch. NR 140 Wis. Adm. Code
23. Ind. Sludge Exemption Issues
No 10% exemption
Plan/Spec approval (NR 213)
WPDES permit modification
Manure additionally regulated as NR 214 waste
NRCS 590, ATCP 50, NR 214
Additional outfalls
Increased monitoring
Site approvals
Additional reporting
Guidance: Discharge of Liquid Industrial Wastewater into Off-Site Manure Storage Units
Developed by the Landspreading Work Group
Cross program group—members from WW, Runoff Mgt, and Groundwater
I am going to spend a few minutes talking about a guidance document the Department is working on regarding the
“Discharge of Liquid Industrial Wastewater into Off-Site Manure Storage Units”
The overall goal of this guidance document is to improve statewide consistency wit submittal requirements, review, and compliance
Provides predictable responses for
1) Food industry representatives and contract haulers that want consistent, timely, predictable responses
2) Plan and make decisions appropriately
This guidance serves as a informational road map
1) its that communication tool between DNR and stakeholders
2) details coordination between WW and Runoff Mgt. programs (example: waste discharged to permitted farms)
3) All three entities same page regarding A) submittal requirements, B) review, and C) compliance post approval (transparent process)
4) reference source for applicable adm. code requirements (depending on discharge scenario), compliance schedule language, approval letters, etc.
Food Industry will be the primary group affected by the guidance. It would include:
Liquid waste generator
Dispose liquid wastes in manure storage units
Guidance also impact contract haulers that transport/dispose of liquid wastes into manure storage units
Other entities
Farmers/Producers—receive nonfarm wastes into manure storage units
Consultants—hired by farmers, contract haulers, waste generators
--want to know applicable adm. codes, submittal requirements, etc.
County Land Conservation Departments
--review and management manure storage units, review NMPs
--ask them to participate in review process as well
Guidance establishes different discharge scenarios
Scenarios based on 1) whether or not farm is permitted (CAF) or non-permitted, and 2) % volume discharged into manure storage unit
For example:
Non-permitted farm can accept <10% liquid wastewater
>10% unit would need to be permitted (either under waste generator or under separate individual permit)
Permitted farm (CAFO)
Accept varying levels of liquid wastewater
Additional requirements come into play the more wastewater accepted
Another visual representation of the different discharge scenarios
Waste going to a non-permitted or permitted farm
Non-permitted—what volume (<10 or >10)
Permitted farm—what percent volume going into storage unit
Part of this guidance will outline the requirements for a standardized discharge request package
Quickly go through the components of one…
1st document
3400-196 form
“Notice of Intent to Store Industrial Wastes in Existing Off-Site Manure Storage Structures”
Good information (go through)
2nd documentation on construction of the unit.
Want verification that unit meets NRCS 313 design criteria (sign off from county land conservation office)
OR
Verification from a professional engineer that units meets NR 213 design criteria
Aerial photograph identifying relative location of storage unit
to allow reviewers to visually evaluate the current condition of the manure storage
Identification of waste source going into storage unit (what outfall)
Most recent representative analytical results
Identification:
Chlorides
Nutrients
Cleaners/solvents
Pollutants of concern?
Where are we at with this guidance?
Finishing touches and will be proceeding to public notice in the near future
Welcome feedback on this document
Also working on other similar discharge guidance
Industrial sludge
By-product solids
Septage wastes
Biosolids
Into manure storage units