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Record Keeping for CNMP and NPDES Compliance

This presentation discusses the importance of good record keeping and the requirements set by NRCS for Comprehensive Nutrient Management Plans (CNMPs) and NPDES permits. It covers the records that should be kept on a daily, weekly, monthly, and annual basis, including soil testing, manure and wastewater testing, nutrient budgets, waste containment structure records, maintenance records, manure application records, cropping records, and manure transfer records. The presentation emphasizes the need for accurate and detailed record keeping to meet regulatory requirements and effectively implement CNMP goals.

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Record Keeping for CNMP and NPDES Compliance

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  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

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

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

  18. 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

  19. Staff Gauge & Rain Gauge

  20. Rainfall Calendar Example

  21. Pump Sheet

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

  23. 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

  24. 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

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

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