Living with your NPDES Permit
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By John D. Lawrence, Iowa State University
Livestock producers and their engineers expend a great deal of time, energy and money to get a construction permit to build or expand a Concentrated Animal Feeding Operation (CAFO). For first time National Pollutant Discharges Elimination Systems (NPDES) permit holders, receiving the permit is seen as the end of the journey, but what they find is that it is only the beginning. Running their operation in accordance with the permit and maintaining the documentation required is a shock to producers that haven’t had a permit. Often times there is a disconnect between the engineer that designed the system and the producer that must operate it. To help producers better understand their obligations and develop strategies to meet them, Iowa State University Extension in conjunction with Heartland Water Coordination Program conducted two workshops entitled Living With Your Permit.
The target audience was Iowa NPDES permit holders and those who are in the process of receiving a permit. The Iowa Department of Natural Resources (IDNR) provided a mailing list of these operations and each was sent a personalized letter inviting them to attend one of two workshops. A letter also was sent to consultants operating in Iowa that service these producers. IDNR field staff that inspects these operations also attended to hear what producers were told regarding management and reporting. In total over 120 people attended the 10 a.m. to 2 p.m. workshops.
The workshop walked participants through the permit and discussed what is required to be monitored with records kept on site and what is required to be submitted to DNR. Participants received a notebook that included:
- Two checklists with requirements stated in their permits:
- one for daily and weekly monitoring and recording to be kept on site
- one for reports that must be submitted to DNR
- Record and report forms for each activity stated in their permit.
- Steps and timeline for developing a nutrient management plan and records required to implement and maintain an NMP.
- Resource materials and information to support their environmental management.
The checklists, forms and other materials are available at: ISU's April 2007 Feedlot Meetings at http://www.agronext.iastate.edu/immag/ppr.html#of.
The purpose of the workshop was to educate producers and their consultants on responsibilities identified in their permit, provide them the forms to complete, and discuss strategies for managing within their permit. The checklists provided a management framework. A sample of the monitoring checklist is shown in Figure 1. It lists the activity, how often it must be done, who is responsible, and how the data will be captured and recorded. The forms identified can be found on the IMMAG Web page at the above link.
The reporting checklist is similar but identifies when reports are due and where to send them as well as the form number and who is responsible for completing and sending the report, see Figure 2.
The objective is to make the monitoring and reporting for the permit part of the regular management of the feedlot. The checklist clearly identifies what needs to be done and when. An individual within the operation is assigned responsibility for the task and the procedure is defined to assure consistency in how the data are recorded. If the person responsible is gone, instructions are written for the next person Likewise, the reporting checklist has the dates, forms and addresses all in one place to simplify the reporting. Examples procedures were provided and participants offered suggestions on how they did things in their operation. For example, is weather data collected from an on-site electronic weather station or the nearby school-net station? Who inspects and reports water lines, the feed truck driver or the pen-checker?
The participants were also were provided a set of recommended forms to use in their operation. IDNR has two required forms for the reports that must be submitted. There are no official forms for monitoring activities, yet producers are required to monitor certain activities and with specified frequency and have evidence that they did so. The forms in the notebook provide producers an acceptable format that can be used as is or can be modified to fit their operation.
Participants were also walked through the process for developing, receiving and reporting on a nutrient management plan. In Iowa, the deadline for having a NMP is July 31, 2007. A timeline was presented working backwards from July 31 that included time for departmental review, public notice, plan development, including development of the Iowa P-Index and RUSLE2 calculations, and soil sampling. The key message is that there is a series of activities that have to occur in a set order and that the clock is ticking.
At the end of the day participants had a much better understanding of their responsibilities under their NPDES permit. They had a checklist of daily, weekly, monthly, quarterly and annual activities to monitor and record and they have the forms to use. Participants also better understand the process and time required for developing an NMP. The measure of success of the workshop will be how effectively participants manage their operations to stay in compliance with their NPDES permits.
|The monitoring and recordkeeping checklist and the reporting checklist, along with the form numbers referenced in the checklists can be found on the IMMAG Website at: http://www.agronext.iastate.edu/immag/ppr.html#of. Except for the required IDNR forms, forms 1-11 may be downloaded to your computer and modified as necessary for your operation.|