April showers bring May flowers; and stormwater compliance issues. If you’re in Missouri, you know we’ve recently experienced torrential storms bringing in rain, high winds, and hail. As you assess hail and wind damage; you should also consider the impact rain water is having on operational compliance.
The Clean Water Act prohibits anybody from discharging “pollutants” through a “point source” into a “water of the United States” unless they have a National Pollutant Discharge Elimination System (NPDES) permit. The permit will contain limits on what you can discharge, monitoring and reporting requirements, and other provisions to ensure that the discharge does not hurt water quality or people’s health. In the case of cannabis operators, pollutants may include extraction solvents, laboratory chemicals, pesticides and insecticides, to list a few. In essence, the NPDES permit translates general requirements of the Clean Water Act into specific provisions tailored toward individual operations and discharging pollutants, and specifies acceptable levels of pollutants, or pollutant parameters in a discharge.
The Missouri Department of Natural Resources (MDNR) has provided guidance to Missouri Cannabis operators to ensure cultivation and manufacturing of cannabis products is done in accordance with applicable regulations and permits. MDNR suggests operators pose the following questions:
Does your facility generate processed wastewater?
This includes any water that, during manufacturing or processing comes into direct contact or results from the production or use of any cannabis product, intermediate cannabis product, finished cannabis product, byproduct, or waste product.
Does your facility discharge wastewater directly to surface water?
Wastewater is defined as water that has been used in the home, business or industrial process; such as plant watering and maintenance.
If your facility is located near a waterway (creek, stream, lake, river, wetlands, etc.) does your facility have the potential to discharge process wastewater into these waterways?
Do you store wastewater in a basin before discharging to waters of the state, or utilize a closed loop, in-house treatment system?
Consider what happens to water captured/contained after watering plants or hydroponics. Is it passed through a drain, recycled, discarded, disposed of, etc.
Does your facility utilize in-house water treatment systems or discharge to municipal wastewater systems?
If you discharge wastewater to a wastewater treatment facility (WWTF) or publicly owned treatment works (POTW), you may not need a permit; but will need prior authorization from the WWTF or POTW.
If you’re still not clear on how to determine if you need a stormwater permit, or have additional questions, Contact the experts at Delta Compliance!
You can view the full MDNR , Wastewater Management for Medical Marijuana Facilities – PUB3007 here.
Talya D. Mayfield
Talya Mayfield is the CEO and Principal consultant for Delta Compliance Consulting. Talya has a B.S. in Biology, an M.S. in Industrial Engineering Management, and a Certificate in Lean Six Sigma.
She spent 8 years in cement manufacturing and hazardous waste working on a range of environmental compliance requirements, from improving safety and employee exposure, to hazardous material management and disposal permitting.
She has now merged this expertise with her love of all things cannabis, and launched Delta Compliance Consulting to help cannabis operators run safe, compliant and successful facilities.
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