Department of Natural Resources fields questions, comments on CAFO permits

Area resident raises concerns over ag truck washing units

As Missouri's Department of Natural Resources (DNR) takes public input on its wastewater permit requirements for agricultural operations, some local voices are raising environmental concerns about the trucks that are hauling the animals.

Concentrated Animal Feeding Operations (CAFOs), which are operations that confine 1,000 or more animal units for at least 45 days during the course of a year, are issued permits by DNR. This takes place under Missouri's Clean Water Law, which ensures that water quality meets federal standards.

Permit templates are revised every five years, with a 30-day comment period after a draft has been published leading up to its issuance to applicants. The conditions of a permit cannot be altered until the next revision cycle, per DNR, and facilities receiving a permit must adhere to its stipulations until the next revisions or until the applicant obtains a permit specific to its site.

There are two permit templates up for revision this year:

• MOGS1, a state CAFO general permit that does not allow for wastewater discharge, and

• MOGO1, a federal permit that allows discharges only if due to a catastrophic storm or chronic weather event.

These general permits are issued to multiple sites that are similar enough to be covered by the same permit.

The department held a public meeting Thursday at the Lewis and Clark State Office Building to go over changes to the draft revision and take questions and comments from interested parties. This was its third informal session.

"We want to make sure that as we are prioritizing our time and our inspectors' times, that we are focusing on the things that have a potential impact on the environment," said DNR environmental supervisor Heather Peters, who gave a presentation on the revisions. "We want to make sure that we are getting the attention that they deserve."

Much of the discussion Thursday revolved around a revision to the standards that would allow DNR to issue these permits for agricultural truck washing facilities, something the department does not currently have the authority to do. The new proposal incorporates DNR's understanding of these facilities, which do produce some discharge, and their association with CAFOs in the state.

The proposal would cover fields that are exclusively used for truck wash wastewater; it would not be applicable if the wastewater from the truck washing was mixed with CAFO wastewater, according to the latest draft.

There are four agricultural truck washes currently in operation in Missouri, according to Peters, which are required to do routine sampling tests.

Several attendees, both virtual and in-person, questioned the potential impact of more truck washes and called for further regulation of the chemical composition of their runoff.

"Even though they do not know what percentage the waste is, they do not have to have a management plan. It is very dangerous; we have no idea where the waste is going," said Jeanne Heuser, an activist from Moniteau County. "It is a terrible breakdown of our permit system, and we have to do something about it in this cycle."

Despite several questions and comments regarding similar environmental concerns, including recent federal health advisories on PFOS -- an acid used in many common everyday products -- Water Protection Program Director Chris Wieberg said it was not a major concern with this proposal.

"These are the chemicals that keep your eggs from sticking to the frying pan or keep your suit from getting a stain when you drop something on it. ... That's where PFOS comes from, and it's in everybody," he said. "It's complex, and so maybe someday we want to address it. Today, I don't think it's a primary issue with regard to truck wash water."

The DNR team fielded questions from other attendees on sampling standards and a provision that would allow nighttime application of wastewater. Some, including Ashlen Busick with the Socially Responsible Agriculture Project, questioned how nighttime emergencies such as spills or leaks could be handled, though Wieberg said there were already water facilities that ran 24/7 which manage to mitigate emergencies and contaminants.

Other proposed changes would put all annual reporting deadlines on Jan. 28 and create an electronic filing system that would make CAFO records and permits publicly available.

The department plans to have its next draft, which will have further proposed changes based on comments from this week's meeting, in August. It intends to issue these renewal permits once the current versions expire in early 2023.