The regulatory language for alternative treatment systems states that the systems (in this case vegetative treatment systems) must perform equal to or better than the effluent limitation guidelines. The February 2003 rules and regulations for the National Pollution Discharge Elimination System (NPDES) and Concentrated Animal Feeding Operation (CAFO) Point Sources identified species-specific effluent limitation guidelines. For beef cattle, Part 412 Subpart C allows for development and use of alternative technologies (ATs) that meet or exceed performance of traditional systems, including containment of wastewater and runoff from a 25-year, 24-hour rainfall event. For an AT system to comply with the required Voluntary Alternative Performance Standard, the design must include a site-specific comparison to a representative traditional containment system. Technical analysis in the comparison must include
site-specific system inputs and outputs: predicted median annual overflow based on a 25-year period of applicable site rainfall data, site-specific pollutant data, and predicted annual average pollutant discharge
So, to answer your question, a vegetative treatment system is allowed to discharge but only if the discharge is less than or equal to what is predicted for a traditional containment basin designed and managed according to the Effluent Limitation Guidelines. Currently, discharge from traditional containment is evaluated using a computer model developed originally at Kansas State University by Dr. James Koellicker and adapted by Iowa State University.
Author: Lara Moody, Iowa State University
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