Preparing for and Conducting Compliance Inspections County Feedlot Officer Compliance/Enforcement...

Preparing for and Conducting Compliance Inspections

County Feedlot Officer Compliance/Enforcement Training

Ed Uhlenkamp, Todd County SWCD/Feedlot Officer

Compliance/Enforcement Training – Preparing for InspectionsCompliance/Enforcement Training – Preparing for Inspections

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

Which sites should I inspect?

Consult your most recent Work Plan

Complaints

Facility construction

Sensitive/ TMDL Areas

Recent Land Application

Enforcement related inspections


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


What type of inspection would you use to

document?

A. Compliance

B. Complaint

C. Land Application Level III

D. Construction Compliance

Complaint

Land Applic

ation Leve

l III

Constructi

on

69%

0%

31%

0%


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


Aerial Photos

2008 2013


What to bring with you

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


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

http://www.bah.state.mn.us/bah/emergency_planning/biosecurity.html

http://www.epa.gov/agriculture/tbis.html


Safety First

Leave Facility if… you feel threatened conditions look unsafe facility representative exhibits

strange or violent behavior

And always document


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


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

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


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.


Does a blind tile intake need to be recorded ?

8%

92% A. Yes

B. No


This is proper composting.

100%

0% A. True

B. False

LOOK FOR POINTS OF DISCHARGE


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


MinnFARM uses what rainfall event in the modeling?

A. one inch event

B. 25 year/24 hour

C. four inch event

D. one foot of snow

one inch

event

25 year/

24 hour

four i

nch event

one foot o

f snow

31%

0%8%

62%

Pumpkin pie anyone?


Conductinga Full Inspection

Level 1 Land Application of Manure Inspection (If facility is 100 to 299 AU AND not in a DWSMA, use questions 1, 3, 5, 8, and 9 only.)

1. General Information: Date of Inspection: Inspector Name: Facility Name: Number of Animal Units: Facility Representative: Year(s) Checked:

2. MMP available for the next crop year?( crop one year from now) Yes No Not Required1

3. Recent manure analyses? NOTE: CAFOs must sample each year Yes No Not Required2

If YES, fill in Part I. at bottom of sheet.

4. Is all or some of the manure transferred? Yes Not Applicable

Are there manure transfer records with these items? Manure amounts transferred Yes No

Dates transferred Yes No

Recipient names and addresses Yes No Tra

nsf

erre

d

Ow

ner

ship

Field ID (minimum: County, Township, Section) Yes No

5. Are there application records with these items?

Field IDs and acres for each field Yes No Not Applicable

Amounts of manure applied per acre for each field Yes No Not Applicable

6. Are records kept of application dates? Yes No Not Applicable

7. Are soil phosphorus test results less than four years old?3 Yes No Not Applicable

Highest P soil test ppm. Bray Olsen Year sampled

8. Is manure incorporated within 24 hours near sensitive features?4 Yes No Not Applicable

9. Are records kept of plant-available N per acre, including carry-over N, (and if >300 AU, are records also kept of plant-available P2O5 per acre released from manure and commercial fertilizers)?5

Yes No Not Applicable

Non

–Tra

nsf

erre

d O

wn

ersh

ip

If YES, fill in Part II. at bottom of sheet.

Inspector: In box below, Explain any “No” answers and corrective actions.

Inspector: If possible, make sure facility has copy of “Applying Manure in Sensitive Areas”. Part I. Analysis from manure storage area or stockpile with the two highest number of animal units: Livestock species N: P: K: Solid Liquid Year of Sample: Livestock species N: P: K: Solid Liquid Year of Sample: Part II. Application rate information: Highest rate of crop available N applied: lb/a Crop: Previous Crop: Highest rate of crop available P2O5 applied: lb/a Crop: Previous Crop: 1 MMP is not required in the following three cases: 1. Less than 100 animal units; 2. 100-299 AU, unless applying for permit; and 3. 300+ AU (non-CAFO) and ALL manure applied by certified applicator. 2 Manure testing not required if 100 AU or less contribute to manure storage area or stockpile. 3 In transferred manure (from 300+ AU) cases, the facility generating manure might not have soil tests. 4 If can’t be determined from records, ask about incorporation practices near sensitive features. 5 If less than 300 AU, just N records are usually required. Assumes incorporation timing records are kept. See rules (DWSMA).

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


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


Questions?

Too close of an inspection!

Preparing for and Conducting Compliance Inspections County Feedlot Officer Compliance/Enforcement...

Documents

Transcript of Preparing for and Conducting Compliance Inspections County Feedlot Officer Compliance/Enforcement...