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
Compliance/Enforcement Training – Preparing for 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
Compliance/Enforcement Training – Preparing for Inspections
Compliance/Enforcement Training – Preparing for Inspections
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%
Compliance/Enforcement Training – Preparing for Inspections
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
Compliance/Enforcement Training – Preparing for Inspections
Aerial Photos
2008 2013
Compliance/Enforcement Training – Preparing for Inspections
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
Compliance/Enforcement Training – Preparing for Inspections
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
Compliance/Enforcement Training – Preparing for Inspections
Safety First
Leave Facility if… you feel threatened conditions look unsafe facility representative exhibits
strange or violent behavior
And always document
Compliance/Enforcement Training – Preparing for Inspections
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
Compliance/Enforcement Training – Preparing for Inspections
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
Compliance/Enforcement Training – Preparing for Inspections
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.
Compliance/Enforcement Training – Preparing for Inspections
Does a blind tile intake need to be recorded ?
8%
92% A. Yes
B. No
Compliance/Enforcement Training – Preparing for Inspections
Compliance/Enforcement Training – Preparing for Inspections
This is proper composting.
100%
0% A. True
B. False
LOOK FOR POINTS OF DISCHARGE
Compliance/Enforcement Training – Preparing for Inspections
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
Compliance/Enforcement Training – Preparing for Inspections
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?
Compliance/Enforcement Training – Preparing for Inspections
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
Compliance/Enforcement Training – Preparing for Inspections
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
Compliance/Enforcement Training – Preparing for Inspections
Questions?
Too close of an inspection!