IL EPA Rules Apply to All Pig Farms

In an on-going effort to educate farmers about the Illinois EPA Livestock Rules, information is being provided by the collaborative work of the Illinois Agricultural Coalition which includes: Illinois Beef Association, Illinois Farm Bureau, Illinois Milk Producers’ Association, and Illinois Pork Producers Association. Farmers may contact any of these organizations to request a free copy of a Resource Guide on the EPA Rules.

One of the biggest misperceptions that pig farmers may have about the IL EPA Livestock Rules is that they don’t apply to your farm.

The reality is that the IL EPA Livestock Rules, which became effective in August 2014, contain provisions that apply to all pig farms in Illinois. Regardless of the size of a farm or whether it meets the CAFO definition or not, parts of the IL EPA Livestock Rules apply to AFOs of all sizes. The requirements increase if the farms are defined as a Large CAFO or are a permitted CAFO. (See “Is Your Farm a CAFO?” article for information on this topic.)

There are three requirements that all pig farms, regardless of their size, must comply with:

1.  Determine if the farm is a CAFO and if a National Pollutant Discharge Elimination System (NPDES) permit is needed.

2.  Transport manure safely

3.  Do not allow runoff to cause water pollution

Let’s look at each of these more closely.

Any farm that confines pigs either inside a building or outside in a concrete or dirt lot where vegetation is absent has the obligation to evaluate their specific farm and determine if their farm is a CAFO. Farmers must have an understanding of what defines a CAFO and then take a realistic look at their farm to make that determination.

If you determine that your farm is a CAFO, then you must decide if you are subject to the NPDES permit requirements. NPDES permits are required if CAFOs are discharging pollutants into Waters of the U.S. (WOTUS). Refer to the Resource Guide for more information on this subject.

All pig farmers must transport manure in a safe manner by following all required rules and making certain that NO pollution occurs. Properly maintaining manure equipment, ensuring operators are well trained and having an Emergency Response Plan will help achieve this objective.

The other main requirement is to ensure that the site where pigs are housed and manure is stored does not cause water pollution. This includes preventing any discharges to WOTUS of manure, as well as runoff of feedstuffs or dead animal disposal areas, such as a composter. All pig farms are required to keep manure at levels that provide adequate storage capacity so that an overflow does not occur. Routine monitoring of manure levels and planning ahead for unforeseen circumstances is essential. Any barns or manure storage for liquid manure built after January 1, 1978 must have a minimum of 120 days of storage in the manure pit, holding tank or lagoon.

The Rules provide an exception to manure storage levels for outside storage structures with open tops, such as lagoons or slurry store tanks. The 25 year, 24 hour storm exemption allows for rainfall from such a deemed event, which in Illinois amounts to approximately 4.5 to 6.25 inches of rain in a 24 hour period. New large swine CAFOs do not qualify for this exemption.

Proper field application of manure is crucial to preventing any discharges and several requirements must be followed. A farmer must ensure that the quantity of manure applied to soils does not exceed what is practical based on the following:

• Soil type (especially the permeability of the soil)
• Condition of the soil (frozen or unfrozen)
• Percent slope of the land
• Amount of residue on soil
• Distance to surface waters
• Likelihood of manure reaching groundwater

It is important to balance the nutrients in the manure with the nutrient needs of the crops. Current soil tests and analyzing the nutrients in the manure are important parts of properly applying manure. Manure application must not exceed the agronomic nitrogen rate, which is the annual amount of nitrogen required to produce a reasonable crop yield.

The method of manure application also plays a big role in protecting the environment. Whenever possible inject or incorporate liquid manure to prevent runoff and reduce odors. Surface application of manure may be used on soils with 5% or less slope OR when yearly average soil loss is 5 ton/acre or less. Injection or immediate incorporation of manure should be used on slopes greater than 5% or soil loss of more than 5 tons/acre.

There are several setbacks and restrictions for manure application that apply to all farms.

• Do not apply within 200 feet of surface water (unless water is upgrade or there is adequate diking to prevent any runoff from entering water)
• Do not apply within 150 feet of any water well
• Do not apply in 10 year flood plain (unless injected or incorporated)
• Do not apply in waterways
• Do not apply when raining or to saturated soils

All pig farmers must practice odor control methods during manure removal and field application so that it does not affect neighbors or populated areas by causing air pollution. Odor control methods during field application can include:

• Injecting or incorporating the manure
• Considering the climate conditions including wind direction and possible temperature inversions

By following these requirements, you can ensure that your farm will be in compliance with the IL EPA Livestock Rules and continue to improve your environmental performance. More detailed information is included in the Resource Guide. Contact the IPPA office for your free copy.