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July 11-12, 2019
MO-AG Summer Meeting;
Lake Ozarks, MO

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Advocacy

Elevator and Feed Mill Permits

On September 7, 2018, the Missouri Department of Natural Resources reissued the multi-industry general stormwater permit MO-R13XXXX. This permit covers feed mills and grain elevators. As required in the previous permit, the permit renewal continues to require a stormwater pollution prevention plan (SWPPP). For new facilities, the new SWPPP must be prepared within 60 days and implemented within 180 days. For existing facilities, the facility must review and revise its SWPPP as necessary within 30 days of reissuance of coverage. The SWPPP must include an Alternative Analysis that is a structured evaluation of BMPs that are reasonable and cost effective. The analysis must demonstrate why "no-discharge" or "no-exposure" are not feasible alternatives.
 
Once again, this permit renewal sets benchmark stormwater sampling requirements for COD, oil and grease, pH and total suspended solids. However, the permit says "there are no regular sampling requirements in this permit." In other words, you are not required to sample stormwater. If you do, you must submit the sample results, and if the sample results exceed a benchmark, you must review the SWPPP and BMPs to determine what improvements or additional controls are necessary to reduce the pollutants in the stormwater discharge.
 
If you have any questions, please contact MO-AG's legal counsel Robert Brundage by email at rbrundage@ncrpc.com or by phone at 573-634-2266.


 


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