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Are CAFO Operators allowed to dump manure in piles on fields?

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Are CAFO Operators allowed to dump manure in piles on fields?

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This is a grey-area question. By dumping manure piles, a CAFO creates an off-site production area of waste. This off-site production area cannot discharge to waters of the state. See page 6 of the Part 21 DEQ Wastewater Discharge Permit Rules for the official definition of “production area”.

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