CBD Oil Extraction & Hemp

CBD oil extraction can produce varies air pollutants, also known as air emissions. The use of solvents in the extraction process can generate emissions of Volatile Organic Compounds (VOC) and/or Hazardous Air Pollutants (HAPs). Emitting VOCs or HAPs may require a permit from the Tennessee Department of Environment and Conservation's (TDEC) Division of Air Pollution Control (APC). The Small Business Environmental Assistance Program (SBEAP) Guidance explains a couple ways to calculate the potential air emissions from these VOCs and HAPs.

Boilers, emergency engines, or other processes may also emit pollutants. Depending on the potential emissions, APC Permits may be needed.

Wastewater

Disposal of wastewater generated from the manufacturing process needs to be considered. If a facility discharges all wastewater to the municipal wastewater treatment plant, then no TDEC Division of Water Resources wastewater permits are needed. If access to the municipal wastewater treatment plant is not available, then wastewater should be directed to a subsurface sewage disposal system, commonly referred to as a septic system. A construction permit is required to install a septic system.

Stormwater

Tennessee Multi-Sector Permit (TMSP)

CBD manufacturers are required to obtain coverage under the TDEC Division of Water Resources' Tennessee Multi Sector Stormwater Permit (TMSP), because it falls in the industry classification Medicinal Herbs and Botanical Products, Standard Industrial Classification (SIC) 2833.

The TMSP requires implementation of Best Management Practices to minimize contact of rainwater with pollutants commonly used in manufacturing, such as sawdust piles and chemicals. A complete permit application includes a Notice of Intent and a Stormwater Pollution Prevention Plan.

A facility can avoid this permit if measures are taken to eliminate exposure of rainwater to pollutants. A No Exposure Certification must be submitted to TDEC Division of Water Resources in lieu of a TMSP application. A complete notification includes a No Exposure Certification for Exclusion from NPDES Stormwater Permitting form. To find this form, use the link in the first paragraph of this section to go to the TMSP web page, scroll to the bottom of the page, and click the "Forms" dropdown. 

Construction General Permit (CGP)

Construction activities, including but not limited to clearing, grading, or excavation, that result in one acre or more soil disturbance requires coverage under a Construction General Permit.

If ethanol or other solvents are not removed from the plant material, the plant material could be considered a hazardous waste. Disposal of hazardous waste requires notifying TDEC’s Division of Solid Waste Management that hazardous waste is being generated. The generator must comply with storage, record keeping, and handling requirements. Waste that is not hazardous may be a special waste, which may allow for reuse options.

For additional information about potentially hazardous waste related to CBD oil extraction, go to page 20 in the Small Business Environmental Assistance Program (SBEAP) Guidance.