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Preparing for and Conducting Compliance Inspections

County Feedlot Officer Compliance/Enforcement Training. Preparing for and Conducting Compliance Inspections. Ed Uhlenkamp, Todd County SWCD/Feedlot Officer. Preparing for Inspections. Overview What to inspect/ Types of inspections File review Tools, biosecurity Conducting the inspection

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Preparing for and Conducting Compliance Inspections

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  1. County Feedlot Officer Compliance/Enforcement Training Preparing for and Conducting Compliance Inspections Ed Uhlenkamp, Todd County SWCD/Feedlot Officer

  2. Preparingfor Inspections • Overview • What to inspect/ Types of inspections • File review • Tools, biosecurity • Conducting the inspection • In the file • Other background information Compliance/Enforcement Training – Preparing for Inspections

  3. Which sites should I inspect? Consult your most recent Work Plan Complaints Facility construction Sensitive/ TMDL Areas Recent Land Application Enforcement related inspections

  4. Preparation: Type of Inspection • Facility Compliance/ Permitting • Complaint (Facility Compliance or Land Application) • Construction • Land Application • Level I (required for facilities over 100 AUs) • Level II • Level III

  5. What type of inspection would you use to document? • Compliance • Complaint • Land Application Level III • Construction

  6. Prior to the inspection • Registration Information (up to date?) • Permitting History • Previous inspection reports, pictures, MinnFARM • Previous enforcement actions or complaints • Other – MMP, phone notes, ect. • Aerial photos, site sketch, plat maps

  7. Aerial Photos 2008 2013

  8. Tools: Facility file Aerial photos, site sketch, plat maps Inspection Forms Customized checklist 7020 Rule Book Camera (film, extra batteries) Measuring devise Other Items (depending on the circumstances): Sampling bottles Chain of Custody Form Cooler, ice Other field monitoring equipment Dissolved Oxygen Meter Jerome Meter What to bring with you

  9. Biosecurity Biosecurity (see MN Board of Animal Health website: www.bah.state.mn.us.html or Enviromental Protection Agency website: http://www.epa.gov/agriculture/tbis.html) Rubber or disposable boots Disinfectant, water, tub, brush Check with producer for appropriate measures Car wash

  10. Safety First Leave Facility if… you feel threatened conditions look unsafe facility representative exhibits strange or violent behavior And always document

  11. Conductingan Inspection • Contact producer • Biosecurity issues • Appropriate responsible party available • Thoroughly walk the site • Look for manure sources • Look for pathways to receiving waters, ditches, tile inlets, slopes - on the maps and at the site • Filling out the Inspection Form • Level 1 records review http://www.pca.state.mn.us/publications/wq-f5-13.pdf

  12. Inspections: Total and Partial Confinement Barns What to look for… Seepage of manure under or around the barn walls such that it can come into contact with precipitation (rain or snowmelt waters) and there are no runoff controls Poultry barn floors that are not maintained according to Minn. R. pt. 7020.2120 (see the factsheet “Technical Guidelines for Poultry Barn Floors”) Manure, litter, spoiled feed that has accumulated outside of the barn

  13. Check for; Ground Seeps, Perimeter Tile outlets, and Dead Stock Piles

  14. Inspections: Open Lots What to look for… Direct conduits to surface waters such as tile inlets within, or adjacent to, the open lot that collect the runoff Manure, litter, spoiled feed that has accumulated outside of the lot as a result of barn cleaning, moving animals in and out, etc.

  15. Does a blind tile intake need to be recorded ? • Yes • No

  16. This is proper composting. • True • False

  17. LOOK FOR POINTS OF DISCHARGE

  18. What to look for… Flow of clean water into open lot area such that it becomes contaminated and contributes to the amount of runoff to be controlled Runoff of manure-contaminated water from open lots without treatment or collection for later land application. Unlined manure storage area Inspections: Open Lots

  19. MinnFARM uses what rainfall event in the modeling? • one inch event • 25 year/24 hour • four inch event • one foot of snow

  20. Pumpkin pie anyone?

  21. Conductinga Full Inspection • Compliance Inspections include site visit and records review (for sites 100 AU ≥) • Requires a Compliance Determination • Compliance- meets applicable requirements • Conditional Compliance- non-conforming requirements can/will be addressed in 4-6 weeks • Non-Compliance- many requirements not met

  22. Inspection Documents for File • Registration Information • Site Inspection Form (Customized checklist) • Aerial photos, site photos, sketch findings • Letter to producer (compliance/non-compliance) • If OLA, then FLEval/MinnFARM results

  23. Questions? Too close of an inspection!

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