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SPECIAL:
DEADDRIFT REPORTS

The Middle of Nowhere
Joe Hawbaker
Three Days With the Pig Boys
Kathy Martin, PE 

The following is a post by Kathy Martin, my favorite CAFO warrior.
Look in our deaddrift odds and ends for more no holds barred comments from a respected engineer and CAFO expert. She can be found in a lively debate on the Carolina Health and Environmental Community Center at. CHECC
(Select FORUMS > HOG WASTE LAGOONS) For some reason a direct link to the forums page won't work.

I was a permit writer for the State of Oklahoma for several years and was responsible for permitting non-hazardous industrial lagoons. My "backlog" including over 300 different facilities so I feel I have a pretty good feel for the types of industry wastewater out there in a typically rural state. The vast majority of the industrial lagoons have cooling tower blowdown, washwater from momandpop slaughterhouses, rural truck washes, rural car washes, and stormwater runoff from outdoor product storage areas. Very rarely did I find problems -- mostly associated with asphalt manufacturing, drilling company truck washes, and computer chip manufacturers (ie., plating waste washwater).

When I started evaluating CAFO Permit applications three years ago -- I was astounded at the pathetic attempt by most state agencies to address the environmental and health issues associated with CAFO lagoons. These lagoons, as they are built in Oklahoma, represent the largest lagoons AND contain the most toxic wastewater (ie., not hazardous according to federal definition but toxic according to impact to human health and the environment, including aquatic).

The wastewater characteristics of CAFO lagoons are anywhere from 10 to 100 times more concentrated than national design figures for typical raw human sewage. The parameters of concern include biochemical oxygen demand (surface water issue because it deprives surface water of dissolved oxygen) occurs at 14,000 ppm whereas raw human sewage ranges from 250 to 400 ppm --- that is a range of 35 to 56 times more concentrated.

Take another parameter - nitrogen compounds - in the CAFO lagoon values of 500 to 1500 ppm as compared to raw human sewage of 20-85 ppm or 17 to 25 times more concentrated.

Another parameter -- total dissolved solids or "salts" -- in the CAFO lagoon values range from 3300 for hogs to 5000 for dairy as compared to raw human sewage values of 250-800. In the case of dairy - the salt concentration is anywhere from 6 to 20 times more concentrated.

That is why I say to you that CAFO lagoon wastewater is most likely the largest single wastewater problem in your state. It far exceeds any rural sanitary lagoon by 10 to 50 times. If you were to look at the regulations for sanitary wastewater (ie., raw human sewage) and take those standards and compare them to the pitiful regulations for CAFOs and you will see firsthand that Nebraska, and all states, have a long ways to go to actually get a handle on this particular waste problem and regulate it at the level that it warrants.

For example, I have a one inch thick book that is entitled Process Design Manual for the Land Application of Sewage Sludge and Domestic Septage.
ONE INCH THICK - and that is only on the land application part -- doesn't include lagoon structure and operation/maintenance law/regs. Your regulations for CAFOs last year was only 16 "half-pages" long and now is about 50 pages.

AAACCKKKK - how can that be? Lobbying my friend and lots of it. Meanwhile CAFO expansion is rabid across the midwest and bread basket states and everyone is arguing over a few pitiful sentences. Municipalities have much more regulation and they seem to be able to cope.

So back to the subject of DEQ responsibility. The ultimate authority in your state is the water quality standards. Know them and use them in your arguments. The DEQ not only creates them and edits them but is obligated to use them in their permitting programs. Ask them for a copy of their Implementation Plan for Groundwater Quality Standards......

The permit writer that reviewed the CAFO permit application for the TeVelde Dairy did not do an adequate job in insuring that the resulting permitting action would not violate water quality standards. The best way to do that would be to calculate the quantity of seepage from the lagoon and to do a water quality model of interaction between the lagoon and groundwater and the contaminated groundwater and surface water via the spring. The results of that model should have been in the permit writer's Statement of Fact and Basis of Rationale. You might want to call up the DEQ and get a copy of that document.

More later - kathy martin