Record Keeping CNMP Core Curriculum Section 7— Record Keeping

CNMP Development Core Training Curriculum These course materials have been developed as a cooperative effort between five land-grant universities and The Natural Resources Conservation Service. Ames, Iowa 50011, (515) Copyright © , Iowa State University of Science and Technology. All rights reserved. Copyright Information

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.

Required Materials USDA/NRCS. GM 180 Part Element Criteria for CNMP Development, Section (d) Record Keeping. National Planning Procedures Handbook, Amendment _600_E_54.htm 0_600_E_54.htm EPA. Managing Manure Nutrients at Concentrated Animal Feeding Operations, Chapter 2, pages 24-25

Supplemental Materials Koelsch, R Fact Sheet #26: What Records Must I Maintain for Land Application? Livestock and Poultry Environmental Stewardship (LPES) curriculum. MWPS Ames, IA. (Available at: U.S. EPA What Are The Federal Record-Keeping and Reporting Requirements? Concentrated Animal Feeding Operations – Clean Water Act Requirements

Why Recordkeeping? Protection –Documentation that CNMP is being followed Save Time, Money and Energy –Good documentation for regulatory questions –Accurately credit nutrient application ($$$) –Everything is in one place to meet farm CNMP objectives

Why Recordkeeping? Regulatory requirements –Provide record keeping that meets a producers state or federal requirements IT IS REQUIRED!

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.)

To be discussed: CNMP Requirements Additional NPDES Requirements Record Keeping Templates

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

Annual Records CNMP 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, P & K Use Land Grant University methods Use certified or LGU accepted lab NPDES also requires reporting lab procedure and sampling protocol

Annual Records CNMP 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

Annual Records CNMP 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

Frequent Records CNMP Requirements Waste Containment Structure Records –Dates of Emptying –Level Before Emptying –Discharge or Overflow Events Including Levels Before and After Rain Event

Frequent Records CNMP 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

Frequent Records CNMP Requirements Maintenance in accordance with Operation and Maintenance plans –Record maintenance as performed according to plan –Each conservation practice contains associated O&M requirements

Frequent Records CNMP Requirements Example Conservation Practice: Gutters & Downspouts Shall be Periodically Checked: Blockages/debris – Material shall be removed Loose/unconnected hangers – Shall be made secure Leakage – Patching or replacement made Downspouts shall be shielded from livestock access; and shall be checked for: –Damage – Crushed sections shall be removed and replaced –Guards/shields - shall be maintained –Outlets – Water from gutters and downspouts shall be directed away from feedlots and animal holding areas. –Outlets shall be maintained to prevent pooling of water or the occurrence of excessive erosion.

Frequent Records CNMP 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

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 Frequent Records CNMP Requirements

Manure Application Records –Weather conditions Wind, precipitation –General soil moisture condition Wet, dry, saturated –Application method Broadcast, injection, spray field, etc. Frequent Records CNMP Requirements

Manure Application Records –Equipment calibration records Material flow rates Application depth Implement speed Frequent Records CNMP Requirements

Class Exercise Problem Statement Using the information provided in the following records, calculate the mass of manure nutrients applied to Field 5 in the example plan during the spring manure application. Determine N in lbs/acre. Spreadable acreage is 29.7 acres.

Spring Application: , Pumped from 6’3” to 1’5”

Solution Volume: 500,000 gal – 100,000 gal = 400,000 gal Application rate: 400,000 gal ÷ 29.7 acres = 13,468 gal/ac N content from spring analysis: 16 lb N / 1000 gal

Cropping Records –Plant & Harvest dates by field –Crop yields –Commercial fertilizer applications –Biosolids? Frequent Records CNMP Requirements

Manure transfer records –Off-site or third party movement –Record nutrient content, volume and date –Record recipient Frequent Records CNMP Requirements

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

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

What should be provided to the producer? Check lists Record keeping templates

Check Lists Help producer remember to keep records Develop a checklist for a producer Example: –EPA, Managing Manure Nutrients at Concentrated Animal Feeding Operations, Appendix C

Templates Application Record(s) Date Field Applied to Acres Applied to Crop Grown Stage of Crop Growth Start Time Stop Time Quantity of Waste Climatic Condition 24 hours before during 24 hours after Test Information N03 (________units) NH4 (________units) N (__________units) P205 (_______units) K20 (________units) Nutrients Applied / Acre N lb/acre P205 lb/acre k20 lb/acre Provide the easiest possible method for record keeping Find or build templates that meet the facility requirements Utilize what is available to you – Available from the internet – University extension – NRCS/EPA documents

Record Keeping Templates EPA – Nebraska NRCS – Heartland Water Quality – Iowa NMP Operations and Maintenance – Input Forms by Manplan.net (Illinois) – Alabama Cooperative Extension System –

Conclusion Difficult to incorporate new best management practices Record Keeping IS important –Good documentation for regulatory purposes –Save money by crediting nutrient application –Meet farm CNMP objectives Any questions?