Keeping Records for your Concentrated Animal Feeding Operations (CAFO) Permit - Michael Heaton, Environmental Scientist, Missouri DNR, from the 2016 Missouri Pork Expo, February 9-10, 2016, Columbia, Missouri, USA. More presentations at http://www.swinecast.com/2016-missouri-pork-expo

1. 2016 Missouri Pork Expo
Keeping Records for your
CAFO Permit
Michael Heaton
Environmental Scientist
Northeast Regional Office
660-385-8000
michael.heaton@dnr.mo.gov

2. Why Keep Records?
• Helps ensure protection of human health and
the environment
• More responsive to deficiencies
• Documentation of self inspections
• Required by permit, laws, and regulations

3. What if I Don’t Keep Records?
• Increases potential for environmental or
health impacts
• Possible increased liability in lawsuits
• Increased inspection frequency
• Violation of permit, laws, and regulations
• Possible penalties

4. Increases the Potential to Find Issues

5. Two Forms of Records to Maintain
• Annual Report
• CAFO Record Keeping Forms

6. Annual Report
Annual Report-Required to be submitted to
the department by February 15th for the
information from the previous year

7. Annual Report

8. Annual Report

9. CAFO Record Keeping Form
CAFO Record Keeping Form-Conducted
daily or weekly. Keep for five years and be
readily available upon request.

10. Permit Requirements
The permit does not allow an unauthorized
discharge of manure, litter, process wastewater, or
mortality by-products to surface waters of the
state. Any discharge of manure, litter, process
wastewater, or mortality by-products to surface
waters of the state or a release crosses property
boundaries shall be reported to the department as
soon as practicable but no later than 24 hours after
the permittee becomes aware of the discharge.

11. Record Keeping Requirements
Records of the date, time, location, duration, estimated volume and corrective
actions taken for any discharge of manure, litter, process wastewater, or
mortality by-products to surface waters of state or release that crosses property
boundaries. Monitor a discharge at the point immediately prior to entering the
receiving stream or a release at the property boundary.

12. Record Keeping Requirements
Weekly records of the depth of process wastewater in the liquid impoundments
as indicated by the depth marker. Report the liquid level as feet below the
emergency overflow level.

13. Record Keeping Requirements
Records of where CAFO generated manure, litter, process wastewater, or
mortality by-products is sold, given away, or applied on land not under the direct
control of the CAFO.

14. Record Keeping Requirements
Records of the inches of precipitation received daily near the production site.
CAFOs may use nearby weather reporting station data to satisfy this
requirement but must maintain this information on-site (for open liquid manure
storages only).

15. Record Keeping Requirements
Records of mortalities management and practices used by the operation to
verify compliance.

16. Record Keeping Requirements
Records of the testing results from manure, litter, process wastewater or
mortality by products (required annually).

17. Record Keeping Requirements
Records of the soil sampling (required once every five years).

18. Record Keeping Requirements
• Weekly inspections of all Best Management Practices, including storm
water diversion devices, runoff diversion structures, and devices that
channel contaminated storm water in the process wastewater storage,
and divert storm water runoff away from the production area.
• Daily inspections must be conducted of water lines including wastewater,
drinking water, and cooling water lines that can be visually observed
within the production area. The inspection of the drinking water and
cooling water lines shall be limited to the lines that possess the ability to
leak or drain to wastewater storage structures or may come in contact
with any process waste.
• Weekly inspections of the manure, litter, process wastewater, or mortality
by-products impoundments.

27. Record Keeping Requirements
• Periodically conduct leak inspections on equipment used for land
application.
• Monitoring of the perimeter of the application fields to ensure that applied
wastewater does not run off the fields where applied.
• Monitor for drifting from spray irrigation.
• Hourly inspections of aboveground irrigation pipelines when in use.

28. Land Application
• 90 plus percent of discharges from CAFOs occur during
land application.
• All land application records must be maintained and
readily available for inspection (even if conducted by
contract applicator).
• Permittee is responsible for discharges from the land
application area (even if applied by contract applicator).

29. • The Land Application Area is agricultural land which is
under the control of the CAFO owner or operator,
whether it is owned, rented, or leased, to which manure,
litter, process wastewater, or mortality by-products from
the production area is or may be applied.
• If manure, litter, process wastewater, or mortality by-
products is applied to land that is not a Land Application
Area then it should be considered a transfer.
• If the manure, litter, process wastewater, or mortality by-
products is transferred to another person and recorded,
then the permittee is not responsible.
Land Application

30. Not Monitoring

31. Not Monitoring

32. Record Keeping Requirements
Records documenting any actions taken to correct deficiencies. Deficiencies
not corrected within thirty (30) days shall be accompanied by an explanation of
the factors preventing immediate correction.

33. Record Keeping Requirements
• Source and type of manure
• Field ID
• The date(s) and rate(s) of manure, litter, process wastewater or
mortality by-products is applied to each field.
• Weather and soil conditions at time of application and for twenty-four
(24) hours prior to and following application.
• The method used to apply the manure, litter, process wastewater or
mortality by-products.
• Calculations showing the total nitrogen and phosphorus to be applied to
each field, including sources other than manure, litter, or process
wastewater or mortality by-products.

35. Record Keeping Requirements
• Expected and actual crop yields
• Explanation of the basis for determining
manure application rates.
• Total amount of nitrogen and phosphorus
actually applied to each field, including the total
amount applied.

38. Permit Requirements
• Have a current copy of the Missouri State Operating
Permit on-site.
• Have the current Nutrient Management Plan on-site.
• Export Only facilities must maintain the current permit
application Form W on site that meets the requirements
of a Nutrient Management Plan.
• Nutrient Management Plans must be updated on a
routine basis which usually coincide with soil samples.

39. Permit Requirements
Nutrient Management Technical Standard
• Manure applications shall comply with all manure application
setbacks defined in Table A1.
• No surface application of manure is allowed if precipitation, likely to
create runoff, is forecasted to occur within 24 hours of the planned
application.
• Manure will not be applied on land with a slope greater than 20
percent.
• Manure will not be surface applied to frozen, snow-covered or
saturated soils.

40. Wastewater and liquid manure applications must be conducted so as to prevent
surface runoff of wastewater and liquid manure beyond the edge of the field
during land application. Steps to insure no runoff of manure during land
application include:
• Adjusting surface application rates to meet infiltration rate and water holding
capacity of the soil.
• Irrigation systems must have automatic shut-off devices in case of pressure
loss and/or an operator on-site at all times during operation to monitor
application equipment.
• All land application equipment should be calibrated at least annually.
• The perimeter of all fields receiving manure should be checked regularly
during operation of land application equipment to confirm manure is not
running off the field or entering waters of the state.
Nutrient Management Technical Standard

42. • Stockpiling of uncovered solid manure within the production area,
without runoff collection, is not allowed.
• Temporary stockpiling of solid manure within the land application
areas shall be in accordance with 10 CSR 20-8.300(10)(B). No
location shall be used for stockpiling for more the two weeks unless
the stockpile is covered.
• The liquid level in the storage structure should be lowered on a
routine schedule based on the design storage period and Nutrient
Management Plan. Typically this should be accomplished prior to
expected seasonal wet and winter climate periods.
Permit Requirements

43. Helpful Reminders
• Pick a day of the week to fill out the records
• Keep records together in a binder/folder
• Keep records for five years
• Keep records at or near your facility
• Keep copy of permit and Nutrient
Management Plan with your records
• Keep records safe from mice, fire, water
• Use forms provided by the department

44. Forms
• Annual Report
http://dnr.mo.gov/forms/780-1953.pdf
• CAFO Record Keeping Forms
http://dnr.mo.gov/forms/780-2153-f.pdf

45. Questions
Michael Heaton
Environmental Scientist
Northeast Regional Office
660-385-8000
michael.heaton@dnr.mo.gov