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

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.
Speaker Notes:
Introduce the class objectives.
CNMP Core Curriculum

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
Speaker Notes:
Emphasize the importance of good record keeping, while noting that is possibly the hardest part of the CNMP to implement. Discussion of why recordkeeping is necessary should include 1) that it protects the producer by showing that the CNMP or NPDES Permit NPM is being followed, 2) it can save the producer time and money (for example by documenting use of organic nutrients and actual yields), (next page) 3) can help the producer meet state or federal regulatory requirements, and 4) it’s required.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

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.)
Speaker Notes:
Explain that it is the producer’s responsibility to keep good records to document implementation of the CNMP, but suggest that as TSPs it is their responsibility to inform producers about what records should be kept and to assist them with record keeping format and checklists.
On page 54 of the Example Dairy CNMP you can show the attendees where the producer has been provided with a list of required records to keep and with a template for tracking those records.
Required Course Materials:
Example Dairy CNMP
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

5. Annual vs. Frequent Records
Soil tests
Manure analyses
Process water analyses
Nutrient budgeting
Frequent
Containment structure records
Operation and Maintenance
Manure application
Manure transfer
Mortality disposal
Speaker Notes:
Describe that the information in the following slides are sorted by annual and frequent records. Discuss that annual records are those addressed once a year and frequent records are those addressed bi-weekly or bi-monthly as required. List the records that will be discussed.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

6. 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, N, P & K
Use Land Grant University methods
Use certified or LGU accepted lab
NPDES also requires reporting lab procedure and sampling protocol
Speaker Notes:
The required records for soil testing for a CNMP are sampling date and the results. Make sure the students are aware of the Nutrient Management NRCS Code 590 Standard, because soil testing should be performed in accordance with the 590 code. Address what analyses should be tested, and the use of Land Grant Universities as a source for sampling methods and testing.
Point out that if the plan is to be used as a NPDES Permit NMP the producer will also have to record the lab analysis procedure name and the sampling protocol used.
Required Course Materials:
Supplemental Resources:
NRCS national or state 590 Code (as appropriate)
Soil sampling information from the state Land Grant University (if appropriate)
Suggested Learning Exercise:
CNMP Core Curriculum

7. 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
Speaker Notes:
Address the fact that each manure storage unit on the facility needs to be tested and give an example of various potential manure sources. With this slide it would be useful to give a brief description of good sampling procedures emphasizing the need for obtaining a representative sample. Discuss what records should be kept and what analyses should be tested for.
Discuss how the producer can benefit from sampling at every pump-out event. After acquiring consecutive samples from several subsequent pumping events, a producer will be able to very closely approximate the nutrient content of the waste to be pumped before it is applied to a field. This will enable the producer to better manage his nutrients.
Point out that if the plan is to be used as a NPDES Permit NMP the producer will also have to record the lab analysis procedure name and the sampling protocol used.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

8. 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
Speaker Notes:
Determining nutrient budgets for a livestock operation can save the producer money. Crop yields should be documented, and then using the soil and manure/litter analyses and application rate appropriate to the crop can be determined. Documenting the nutrient budget will help a producer use inorganic fertilizer more efficiently. The nutrient budget records are very useful in documenting that the CNMP is being implemented.
If the CNMP is to be used as an NPDES Permit NMP, the calculations used to determine the nutrient budgets need to be documented.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

9. 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
Speaker Notes:
Note that you are now making the switch from annual records to more frequently kept records. The CNMP requires documentation of levels within the holding structure both before and after pump-out events. If overflows occur, levels before and after that event need to be recorded as well.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

10. 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
Speaker Notes:
If the CNMP will be used as an NPDES Permit NMP, the producer also needs to record his required weekly inspections of any waste impoundment structures, the weekly level on a stage marker, and the sites rainfall and temperature data.
Whether for a CNMP or an NPDES NMP, discuss the need for TSPs to add stage markers to waste impoundment structures for liquid level monitoring. Indicate that the stage marker should include marks for the design storm capacity, minimum treatment volume (for anaerobic lagoons) and freeboard. The usefulness of a stage marker will be discussed later in the presentation.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

11. 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
Speaker Notes:
The CNMP requires documentation that shows the implementation and maintenance of Conservation Practices used in the plan. Each NRCS conservation practice standard contains an operation and maintenance section, records of the requirements need to be kept. The following slide provides an example from the Example Dairy CNMP.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

12. 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
Speaker Notes:
If the CNMP is being used as an NPDES Permit NMP describe the additional required records listed above.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

13. Frequent Records CNMP 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
Speaker Notes:
Manure application records are a key part of calculating the nutrient budget. These three slides breakdown the required records dealing with manure application.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

14. 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.
Equipment calibration records
Material flow rates, Application depth,Implement speed
Speaker Notes:
Manure application records are a key part of calculating the nutrient budget. These three slides breakdown the required records dealing with manure application.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

15. Frequent Records CNMP Requirements
Manure Application Records
Speaker Notes:
Manure application records are a key part of calculating the nutrient budget. These three slides breakdown the required records dealing with manure application.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

16. CNMP Core Curriculum Speaker Notes:
A stage curve can be useful in determining volumes of manure to be applied and manure application rates. This stage curve was developed for the Example Dairy CNMP and is located on page 17 of the document. The stage curve can be used to check calibrated application rates by using the calibrated rate to determine total pumped manure volume and then using the state curve to determine actual volume pumped. Use a laser pointer and show class how the curve is used (i.e. if the stage marker reads 4’ there are ~300,000 gallons of waste in the system, if you pump-out to 1.5’, you have removed ~200,000 gallons from the system).
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

17. CNMP Core Curriculum Speaker Notes:
In conjunction with the stage curve, this graph can be developed and used to determine manure application depth to spread an available amount of manure evenly across a crop field. This chart is also on page 17 of the Example Dairy CNMP. Based on the example from the previous slide, an application rate of 0.2 in/acre is necessary to use the ~200,000 gallons available in the system.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

18. Frequent Records CNMP Requirements
Cropping Records
Plant & Harvest dates by field
Crop yields
Commercial fertilizer applications
Biosolids?
Speaker Notes:
Cropping records are also important for calculating nutrient budges. Documentation of planting and harvest dates, as well as crop yields is required. Also, note here that producers also have to document commercial fertilizer applications and if appropriate biosolids applications.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

19. Frequent Records CNMP Requirements
Manure transfer records
Off-site or third party movement
Record nutrient content, volume and date
Record recipient
Speaker Notes:
Discuss with TSPs that not every producer will deal with manure transfer. Manure transfer issues are most likely where dry manure handling is involved (i.e. meat bird facilities or beef feedlots). Discuss the record keeping requirements listed in the slide.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

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
Weekly lagoon level
Annual water usage
This is an example for Large CAFO like SBF

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
Speaker Notes:
Though you have been discussing this throughout the presentation, make sure students are aware that the record keeping requirements for a CNMP and a EPA NPDES Permit NMP are slightly different. In addition to the records already discussed, the information detailed on this slide is also required.
Required Course Materials:
EPA, Managing Manure Nutrients at Concentrated Animal Feeding Operations, Chapter 2, pg 24-25, and Appendix C
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

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
Speaker Notes:
For an NPDES Permit NMP, an annual report is required. This slide is provided to make TSPs aware of its requirements.
Required Course Materials:
EPA, Managing Manure Nutrients at Concentrated Animal Feeding Operations, Chapter 2, pg 24-25, and Appendix C
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

26. Record Keeping Templates
EPA
Nebraska NRCS
Heartland Water Quality
Iowa NMP Operations and Maintenance
Input Forms by Manplan.net (Illinois)
Alabama Cooperative Extension System
Speaker Notes:
These are some sites with available record keeping templates.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum

27. Conclusion Record Keeping IS important
Good documentation for regulatory purposes
Save money by crediting nutrient application
Meet farm CNMP objectives
Speaker Notes:
Reiterate to students how difficult it will likely be to get producers to keep good records. Discuss with TSPs that they need to have a conversation with the producer to show the producer how he/she could benefit from keeping good records. Producers usually keep good records of the production side of their operation because it is the profiting side. They need extra encouragement to keep good records on the side of their operation often viewed as a “sink” for their profits.
Required Course Materials:
Supplemental Resources:
Suggested Learning Exercise:
CNMP Core Curriculum