Pollution Prevention, Water Quality & Mink Farming

A number of federal, state, and local rules, regulations, and ordinances have been created for the purpose of controlling polluted runoff from livestock operations in order to protect groundwater and surface water quality. In general, these rules/regulations incorporate both performance standards and prohibitions for livestock operations.

Performance standards include:

Technical standards for constructing, modifying, or abandoning manure storage facilities;
Diverting clean runoff away from livestock and manure storage areas;
Applying manure and other fertilizers to surface land areas according to an approved Nutrient Management Plan.

Prohibitions include:

Overflow of manure storage facilities;
Unconfined manure piles near waterbodies;
Direct runoff from feedlots/mink pen areas or stored manure into state waters.

CAFOs

States have also developed regulations for issuing permits to Concentrated Animal Feeding Operations (CAFOs) under the National Pollutant Discharge Elimination System (NPDES).

In general, permits are issued to large CAFOs and to smaller CAFOs with identified potential sources of polluted discharge such as the discharge of wastewater from feed-mixing operations and discharge of rainwater that has flowed through a mink pen area or manure storage area. Note: Large CAFOs are operations with 1,000 or more animal units. An animal unit is defined as 1,000 lbs of live weight.

If water generated during feed-mixing and equipment-cleaning operations is discharged to the land surface, the state agency may categorize the facility as one requiring an NPDES permit, and stipulations of the permit must be met.

If the water is applied to the land surface such as an agricultural field, a land application permit is typically required (see below).

Discharge of a wastewater without required permits is a violation and can result in enforcement action by the regulatory agency. Further, the discharge of rainwater that has flowed through a manure storage area or mink pen area containing manure can be considered an unacceptable practice and require a permit.

Simple management practices such as covering mink pen areas and diverting rainwater runoff around mink pen areas around berms can eliminate inappropriate discharges.

The NPDES permit requirements include:

Prohibition from discharging manure or process wastewater pollutants to state waters, unless the discharge complies with water quality standards;
Preparation of an emergency response plan for addressing unauthorized spills or discharges;
Mortality management and disposal – animal carcasses may not be disposed of in a manner that results in a discharge of pollutants or as otherwise prohibited (i.e. in manure storage facilities);
Developing and implementing a Nutrient Management Plan prepared by a qualified planner;
Inspection, maintenance and record-keeping requirements;
Monitoring and inspecting requirements.

Land Application of Wastes

Rules and regulations have also been established for the handling and land application of industrial wastes, including by-product solids and sludges generated by mink farming.

Land application of wastes is typically managed through the issuance of NPDES permits which require the following:

Preparation of a Land Application Management Plan with information about the source of the waste, the waste storage and transportation, and the land application sites;
Tracking and reporting of loading rates;
Sampling and analysis;

Annual reporting to the state.
While this brief summary of water quality regulations which may apply to mink farmers was generally based on Wisconsin regulations, similar rules and regulations are in place across the country. It is suggested that you keep in communication with your local and state agencies to ensure you are complying with all applicable requirements.

How to Respond to an Inspection – Special to FCUSA by Sigma Environmental Services Inc., Milwaukee

If a regulatory agency has a suspicion that a crime has been committed such as an unacceptable discharge, they can enter your property in order to perform an inspection. For instance, the state agency may use the assistance of a game warden or peace officer.

If a request for inspection is made, it is strongly recommended that the land/business owner cooperate with the regulatory agency. If the land/business owner is uncooperative, the regulatory agency will still perform the inspection and the regulators may be inclined to impose forceful actions against the land/business owner.

The land/business owner’s best line of defense to an inspection is to have already employed sound best-management practices for the mink farming operation. In order to employ best-management practices, it is imperative that the land/business owner know and understand the regulations associated with mink farming operations.

Appropriate best-management practices will go a long way in satisfying any concerns of the regulatory agency. Be willing to show and explain the instituted best-management practices and all records of the operation.

If the regulatory agency has suggestions or concerns regarding the mink farming operation, discuss the concerns and ways to eliminate the concerns with the regulator, and employ additional best-management practices to satisfy the concerns.