Record Keeping for CNMP and NPDES Compliance

1. Section 6: Record Keeping Adapted CNMP Core Curriculum CNMP & NPDES Requirements Presented by: Roberto Maisonnave, Ag Engineer & M. Sc. International Environmental Consultant robermaison@hotmail.com www.ambientagro.com

2. Objectives • Become familiar with the need for good record keeping and the logic for keeping high-quality records. • Become familiar with the record keeping requirements set by NRCS for CNMPs and the additional requirements for when the plan is used in an (NPDES) permit. • Learn which records should be kept daily, weekly, monthly and annually. • Have a clear understanding of the record keeping requirements for comprehensive nutrient management plans.

3. Why Recordkeeping? • IT IS REQUIRED! • Save Time, Money and Energy • Good documentation for regulatory questions • Accurately credit nutrient application ($$$) • Everything in one place to meet CNMP • Regulatory requirements • Provide record keeping that meets a producers state or federal requirements

4. Who is Responsible? • Producers must maintain records • Document implementation and management to meet CNMP goals • TSP responsibility to inform producers • What records should be kept • Records should be kept for 5 years (min.)

5. Annual vs. Frequent Records Annual • Soil tests • Manure analyses • Process water analyses • Nutrient budgeting Frequent • Containment structure records • Operation and Maintenance • Manure application • Manure transfer • Mortality disposal

6. Annual RecordsCNMP Requirements • Soil Testing • Record testing date and results • Perform in accordance with Nutrient Mgmt. Code 590 • Collect every 1-5 years • At minimum analyze for pH, N, P & K • Use Land Grant University methods • Use certified or LGU accepted lab • NPDES also requires reporting lab procedure and sampling protocol

7. Annual RecordsCNMP Requirements • Manure and Wastewater Testing • Sample waste from each manure storage unit • Analyze for N, P and K • Record results and sample date • Can benefit from sampling at every pump/clean-out • NPDES also requires reporting lab procedure and sampling protocol

8. Annual RecordsCNMP Requirements • Nutrient Budgets • Determine nutrient inputs and removal using manure analyses, crop yields and application rates • These are the records that show CNMP implementation • NPDES requires documentation of how nutrient budget was calculated

9. Frequent RecordsCNMP Requirements • Waste Containment Structure Records • Dates of Emptying • Level Before Emptying • Discharge or Overflow Events • Including Levels Before and After Rain Event

10. Frequent RecordsCNMP Requirements Manure Containment Structure Records • NPDES also requires: • Records of weekly inspections of waste impoundments • Depth marker indicating minimum capacity requirements for the design storm • On-site rainfall and temperature data

11. Frequent RecordsCNMP Requirements • Maintenance in accordance with Operation and Maintenance plans • Record maintenance as performed according to plan • Each conservation practice contains associated O&M requirements

12. Frequent RecordsCNMP Requirements Operation and Maintenance • NPDES also requires: • Daily inspections of water lines • Weekly inspections of storm water diversions channeling water to or away from the waste structure • Records of actions taken to correct deficiencies

13. Frequent RecordsCNMP Requirements • Manure Application Records • Containment source • List source for each application event • Fields receiving nutrients • List each Field ID per event • Record info is field specific • Application rate • CNMP provides planned rates, records provide actual rates

14. Frequent RecordsCNMP Requirements • Manure Application Records • Weather conditions • Wind, precipitation • General soil moisture condition • Wet, dry, saturated • Application method • Broadcast, injection, spray field, etc. • Equipment calibration records • Material flow rates, Application depth,Implement speed

15. Frequent RecordsCNMP Requirements • Manure Application Records

18. Frequent RecordsCNMP Requirements • Cropping Records • Plant & Harvest dates by field • Crop yields • Commercial fertilizer applications • Biosolids?

19. Frequent RecordsCNMP Requirements • Manure transfer records • Off-site or third party movement • Record nutrient content, volume and date • Record recipient

20. Record Keeping Company Protocol • Farm are required to report … • Staff gauge reading (weekly) • Rainfall reading (weekly & monthly) • Water meter readings (weekly) • Lagoon/meter maintenance needs (weekly) • Visual Inspection of Impoundments • Daily Water Line Inspections • Regulatory requirements include… • Daily rainfall • Daily Water Line Inspections • Visual Inspection of Impoundments • Weekly lagoon level • Annual water usage

21. Staff Gauge & Rain Gauge

22. Rainfall Calendar Example

23. Pump Sheet

24. Additional NPDES Requirements • Keep Records On-Site For At Least 5 Years • Copy of CNMP On Site • Mortality Disposal Records

25. Additional NPDES Requirements • NPDES Annual Report • Animal Inventory • Annual Manure Generated • Annual Manure Exported • Annual Acres Utilized • Acreage Covered under NMP • Description of Annual Discharges • Accounting of Certified Nutrient Management Planner Developing and/or Approving NMP

26. Record Keeping Templates • EPA • http://www.epa.gov/npdes/pubs/cafo_permit_guidance_appendixh.pdf • Nebraska NRCS • http://www.ne.nrcs.usda.gov/technical/CNMP/NE_CNMP_Records.html • Heartland Water Quality • http://www.heartlandwq.iastate.edu/ManureManagement • Iowa NMP Operations and Maintenance • http://www.manplan.net/ianmpom.pdf • Input Forms by Manplan.net (Illinois) • http://www.manplan.net/weekly%20records.pdf • Alabama Cooperative Extension System • http://www.aces.edu/department/aawm/DryManureRecords4.pdf

27. Conclusion • Record Keeping IS important • Good documentation for regulatory purposes • Save money by crediting nutrient application • Meet farm CNMP objectives