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Groundwater Discharge Permits
6 Plays49 minutes ago
This podcast episode features Allissa Conley, a Produce Safety Technician with the Newaygo Conservation District, and Tess Van Gorder, the Conservation & Regulatory Relations Specialist with Michigan Farm Bureau. Tess goes over what Michigan growers need to know when it comes to wastewater discharge and the groundwater discharge permit process.
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Transcript
Introduction to Agri-Food Safety Podcast
00:00:00
Speaker
Hello, and welcome to the Agri-Food Safety Produce Bites podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule.
00:00:13
Speaker
Hello, my name is Alyssa Conley, and I am a produce safety technician located in the west central area of the state out of the Nuevo Conservation District.
Introduction of Guests: Alyssa Conley and Tess Van Gorder
00:00:22
Speaker
I'm here with Tess from Farm Bureau, and we're going to be diving into the topic of wastewater.
00:00:29
Speaker
Hi, everyone. my name is Tess Van Gorder. I am a conservation and regulatory relations specialist with Michigan Farm Bureau. Basically work with our farmer members on voluntary conservation topics, but then also if they have regulatory questions like they often do with wastewater. Thanks for having me today, Alyssa.
00:00:50
Speaker
Yeah, we're really excited you could join us, your wealth of knowledge and information when it comes to this topic.
Overview of Produce Safety Rule and Wastewater
00:00:56
Speaker
Water has been a hot topic for us with the water rule changes with pre-harvest water.
00:01:01
Speaker
And also, where does water go once we use it? The produce safety rule touches on it, but they're our produce safety is not in a vacuum, right? There's other rules at hand. So we're going to dive into that more.
00:01:15
Speaker
And I'll start by explaining more of that federal produce safety rule requirement related to wastewater. And it really only says that any wastewater, hand-washing water, what you're washing produce, it really just needs to not be in contact with food contact surfaces, areas that you are working with covered crops, preventing workers from walking through it and getting into your production area. or getting into other bodies of water, but there's that's kind of it. It doesn't tell you how to do that, and it doesn't explain any other rules associated with wastewater discharge.
Michigan's Groundwater Discharge Permit Requirements
00:01:52
Speaker
So could you start by explaining to the listeners what is the Michigan requirements for wastewater discharge and groundwater discharge permitting and all of that kind of stuff as a quick background?
00:02:06
Speaker
Yeah, quick background. In this case, Michigan has their own set of rules for what is called a groundwater discharge permit. And this is really for wastewater that is put on the ground, essentially, or in a subsurface system, and then travels towards or to groundwater.
00:02:23
Speaker
Eagle looks for things like fruit and veg wash water, contact and non-contact cooling water. So we think of our cherry cooling pads, for example. Another related industry would be wineries, breweries, distilleries, cideries. So those also would fall under this in addition to a number of other ag processing And so what EGLE looks for in these permits and why there is a permit in the first place, the main two things they look for are if there's any nutrients in the wash water. And so this is something that, for example, if you're land applying wash water, wastewater, that actually gives you a credit with the understanding that you're applying to something that's growing.
00:03:07
Speaker
Therefore, that will uptake nutrients and that's a beneficial use of the nutrients. Then also looking at what's called biological oxygen demand or biochemical oxygen demand. And basically this has to do with the amount of oxygen needed to break down what's in the wastewater. And so sometimes this can impact water quality of the receiving body's water.
00:03:31
Speaker
Sometimes this can cause the metals in the soil to mobilize and travel to the groundwater, which is, I think, something we can agree that no one wants to be a part of
Assessing Wastewater Management and Permit Specifics
00:03:44
Speaker
in that case. And so those are the two main things, but really the permit itself is looking at how the wash water is being handled, sort of start to finish in terms of when it leaves Production areas, is the management that's being employed protecting groundwater?
00:04:02
Speaker
Is it also protecting the surface water sort of it as that secondary piece? And really just making sure the tools are in place to have a system that continues to function as intended to ensure there's treatment.
00:04:16
Speaker
Yeah, that's really good to know. I feel like these discharge permits, while they have been around, they haven't necessarily been promoted heavily. So it's good to learn why they're concerned about wastewater and where it's going.
00:04:31
Speaker
So if a farm listens to this podcast today today and they're like, I was doing the right thing and i still want to do the right thing, they realize that maybe they do need that permit. How is it determined who does or doesn't need that permit? Does it depend on how much water they're using or where it's going?
00:04:48
Speaker
Are there any exemptions to that permit? Could you dive into that a little bit more for us? Yeah, so these permits are very operation specific. It's good if you look at, for example, my imaginary operation. i don't want necessarily want to have the restrictions as Bog's imaginary operation because we're in due two different situations. We handle our wastewater differently. we may be closer further to surface water than the other and things like that so this means it makes things really tricky to talk about in black and white you know and it's hard to say you're in you're out or this is what happens so it's really dependent on you know how much wastewater you're using what type what you're using it for so is it a cooling pad or is it a A large packing house, how often are you discharging? So is there a small window? are there any additives? One of the things where we've seen sort of federal and state rules butt heads against each other is for use of a water treatment additive. So if we think, for example, like pericetic acid, sometimes it's fine and they say, yes, you can use it. Other times they may have concerns based on concentration, location characteristics, and things like that.
00:06:04
Speaker
So how much water, what's in your water, how often are you discharging, how close are you to surface water, what type of system do you have? So if we think about whether you have, for example, like a subsurface system with a septic field, or if you are land applying, or we have a lagoon and then there's land application. So there's really a number of layers into this. And EGLE does look at those different layers to say, okay, you know, What will help us as EGLE be protective of groundwater quality? And then what is the operation doing that will help them meet those steps?
00:06:40
Speaker
It's not a one size fits all. There are some very limited exemptions available, so keep in mind that you still have to apply for an exemption, even if you think you qualify for an exemption. So there's a limited wholesale processing exemption for less than 100 gallons per day, which is small, in addition to a fruit and vegetable washing exemption for less than 50 gallons per day, which is $1.
00:07:07
Speaker
ah even smaller. One of the things that, especially as you get a more complex operation, you know, a lot of folks do end up having to hire consultants to be able to work what is required and, you know, where they should go. Because keep in mind, I'm from Michigan Farm Bureau. I am not that person. You can't take this podcast eagle and say, Tess said this on this podcast, so this is the thing we were doing. um It really is that many, many, many shades of gray in terms of what this means for a producer.
00:07:41
Speaker
Yeah, no, that's great
Process of Obtaining a Discharge Permit
00:07:42
Speaker
information. I feel like this is the one place where the federal produce safety rule and these other state rules are the same and where it depends. Every situation is so different. That's why this information is important to get out there to the growers and give them the right steps and things so that they can be in compliance and keep growing food and keep making money. And we know that with these permits usually comes a paperwork process, right? So what is that process? How long does that take to get that A-OK that you can proceed
00:08:16
Speaker
and you're ready to go with your permit permitting. Paperwork-wise, unfortunately, there is a decent chunk of paperwork. so And some of these are more simple than others. For example, basis of design. it sounds scary, but really it's a simple sort of design of how your wastewater or wash water handling works. Then you go on to the sampling and analysis plan.
00:08:40
Speaker
You may have sampling requirements depending on Your permit, that will either be maybe yearly, quarterly, monthly, weekly. Again, it depends. But this is making sure that everything is being sampled and analyzed correctly. And so this is something that's important for anyone who has this permit because you want to make sure that you're getting an accurate report. read on of whatever is in your wastewater and wash water, and you don't want to sample incorrectly. That may flag you as being out of compliance with your permit.
00:09:12
Speaker
Another thing is just an operations and maintenance manual, just making sure that facilities taking all the steps needed to ensure that however you handle your wash water or wastewater, that system is being maintained and that there wouldn't be a failure in that capacity in terms of just everyday operations and maintenance. The other Technically, it's paperwork, but technically you do it online. So it's the digital paperwork we're all becoming it used to is a discharge monitoring report.
00:09:41
Speaker
That report could be as simple as reporting your flow and your discharge on a certain cadence, or it could be This is, you're reporting your discharge, your BOD, your nitrogen, your phosphorus, your what have you. And so again, it really, there is a huge spectrum in what these permits can look like. But that is something that, you know, that Eagle says, hey, this has to be reported by this time, like by this time of day every month. So something to keep on top of, especially if you're operating for longer periods of time. Yeah, that's really good to know. I think the whole getting your ducks in a row is definitely something we talk a lot about in produce safety. So just adding this extra step.
00:10:24
Speaker
It is a lot of work, but it is something that's going to be worthwhile. Has any grower reached out to your farm bureau about any hurdles besides just getting the paperwork done, having their consultant, whoever is helping them, have they noticed any other hurdles to getting the permit?
00:10:42
Speaker
And then d does Farm Bureau offer any support for growers who might need help figuring out some of this regulation on their farm?
Support and Resources for Permitting
00:10:52
Speaker
So one of the things that seems to be a big pain point right now is just the time it takes to get through the process. And so again, things are very individualized, which means that sometimes depending on the operation, it can take longer.
00:11:07
Speaker
The statute says that they have 30 days to tell you if your permit application is administratively complete. Then they have 180 days to issue a permit once your application is administratively complete. So one of the tips we offer, especially for folks going through bit process, is that Eagle follows up and says, hey, we don't have x Y, or Z to make sure that that is a prompt response because then that clock has stopped in terms of your timeline for a permit.
00:11:40
Speaker
And this is sort of, I think goes in back to the hurdles and support is that these rules and this permit weren't necessarily designed with agriculture in mind. And so the application, it can be difficult for folks to work their way through I've been given a few presentations throughout the countryside to help give folks sort that regulatory translation. i am not an engineer on purpose, much to my dad's chagrin, but really just trying to make the regulatory texts and situations seem a little less intimidating and more accessible for folks. So I encourage folks to reach out if they need assistance.
00:12:19
Speaker
Some folks, a consultant may be the answer for kind to sort things out on your operation, on what things look like. So that would also be a consideration in terms of what you might need to support you through the process.
00:12:34
Speaker
Yeah, I think between you and Farm Bureau and consultants It is a lot of work, but those are all great resources for someone to start looking into if they are feeling a little scared about this and need some extra help.
00:12:47
Speaker
Like always to our Michigan on-farm produce safety team, us technicians are that free voluntary confidential service. So maybe we can connect you with someone like Tess or someone else who does know more than one of us, or we can chat with our team as a whole.
00:13:03
Speaker
to help the growers out in this big, scary world of water and wastewater discharge and all of these things.
Conclusion and Further Resources
00:13:11
Speaker
We really appreciate your time today, Tess. It is great to hear from other industry professionals as to what they do and how they're helping growers and connect with you. so like I said, we really appreciate it.
00:13:24
Speaker
Yeah, thanks for having me and let me know if there's other ways I can help support and help folks sort through the adventure of groundwater discharge permitting. Links to anything referenced in this episode can be found in the podcast description.
00:13:38
Speaker
For more produce safety resources, tools, and upcoming trainings, visit the MSU Agri-Food Safety website at gaps.msu.edu. That's that's g a p s dot m su dot edu We hope today's episode helped you take another step towards safer produce.