HydroAg Environmental, LLC collects and recycles pretreatment wastewater industrial food residuals that are of food or organic origin from various industrial food processing plants. The residuals may come from sources such as livestock processing including beef, pork and poultry facilities; further food processing facilities; and industrial facilities that produce a beneficial food by-product. These treated residuals are land applied as organic fertilizers and soil amendments to farmland across the United States.
On June 30, 2023, the department issued a statement to HydroAg and other facilities previously authorized to land apply certain sludges, biosolids and other process wastes without a permit according to 10 CSR 20-6.015(3)(B)8. Due to a decision by the Missouri Fertilizer Control Board, these companies and businesses are no longer exempt from department permitting requirements. The letter stated the department’s intent to exercise enforcement discretion for entities performing the continued land application of material formerly licensed as fertilizer, as long as the entity adhered to the minimum operational parameters and conditions set by the department in that letter, including the condition that the entity apply for an operating permit.
The department drafted the June 2023 letter to expire at the end of 2023, anticipating that permits would have been able to be issued before the end of the year. On Dec. 29, 2023, the department issued another letter, stating the department will continue exercising its enforcement discretion to withhold pursuing formal enforcement action and penalties until their permit can be issued.
Permitting
On Aug. 28, 2023, HydroAg submitted a wastewater operating permit application for a land application permit and associated Waste Management Plan.
- HydroAg Environmental LLC Form A-Application for Nondomestic Permit Under Missouri Clean Water Law, Aug. 28, 2023
- HydroAg Environmental LLC Waste Management Plan, Aug. 28, 2023
On the basis of preliminary staff review and applying applicable standards and regulations, the department issued a draft operating permit and invited the public to review and offer written comments on the proposed permit conditions until April 21, 2024. A final permit determination has not yet been issued.