What is the Difference Between a NMP and an CNMP by NASSdocs


									Natural Resources Conservation Service
6200 Jefferson NE
Albuquerque, New Mexico 87109

6200 Jefferson NE
Albuquerque, New Mexico 87109-3734
Phone: (505) 761-4400 Fax: (505) 761-4462
Web site: www.nm.nrcs.usda.gov
                                                       New Mexico AFO/CAFO Fact Sheet 5
                                                                           August 2006
_________________________________________________________________________________________________ ________

Six Components of an NRCS                 Nine Minimum Practices of              Key Differences
Comprehensive Nutrient                       an NPDES Nutrient
Management Plan                               Management Plan

Manure and Wastewater                    Adequate Storage Capacity.        NRCS CNMP includes
Handling and Storage. This               This element addresses 1)         planning elements relative to
component addresses the                  planning sufficient storage       air quality, pathogen, and
components and activities                capacity for manures, process     issues associated with
associated with the production           waters, and contaminated          production facilities (animal
facility, feedlot, manure and            runoff, 2) prevention of runoff   housing) issues not
wastewater storage and                   from dry manure, 3) matching      specifically identified under
treatment structures and areas,          storage capacity to nutrient      NPDES NMP.
and any areas used to facilitate         plan, and 4) ensuring proper
transfer of manure and                   operation and maintenance of
wastewater. It includes review           storage facilities.               NPDES NMP emphasizes
of issues associated with air            Proper Management of              as distinct planning
quality, pathogens, and                  Mortalities with objective to     components for the topics of
mortality.                               prevent contamination of          1) mortality planning, 2)
                                         waters of the US.                 diversion of clean water, and
                                         Diversion of Clean Water.         3) prevention of animal
                                         Planning to divert roof water     contact with waters of the
                                         and runoff from adjacent land     US. These components are
                                         is recommended. If not, this      included in an NRCS CNMP
                                         clean water must be collected     but not emphasized as a
                                         and stored.                       separate component.
                                         Prevention of Direct Contact
                                         of Animals with Waters of
                                         the US. Develop and
                                         implement appropriate
                                         controls to prevent access of
                                         animals to waters of the
                                         United States.
                                         Chemical Handling. Develop        This component is unique to
                                         and implement controls to         the NPDES NMP. A
                                         prevent the inappropriate         supplement to an NRCS
                                         introduction of chemicals into    CNMP may need to be
                                         the manure, wastewater, and       included addressing
                                         storm water storage and           chemical handling to satisfy
                                         handling system.                  the NPDES program.
Six Components of a NRCS           Nine Minimum Practices of               Key Differences
Comprehensive Nutrient                 an NPDES Nutrient
Management Plan                         Management Plan

Land Treatment Practices.          Conservation Practices to         Expectations of both plans
This element addresses             Control Nutrient Loss. For        are very similar.
evaluation and implementation      land application areas under
of appropriate conservation        the control of the CAFO
practices on sites proposed for    operator develop and
land application of manure and     implement practices that are
organic by-products. A             sufficient to minimize the
conservation plan to address       discharge of pollutants to
runoff and soil erosion and        waters of the US. These
allow for plant uptake of these    practices may include residue
nutrients is accomplished          management, conservation
through this component.            crop rotation, grassed
                                   waterways, strip cropping,
                                   vegetated buffers, riparian
                                   buffers, setbacks, terracing,
                                   and diversions.

Nutrient Management. This          Protocol for Manure and
component addresses the            Soil Testing. Identify and
requirements for land              implement specific manure,
application of all nutrients and   wastewater and soil sample
organic by-products to             collection and analysis
minimize environmental risk        protocols to be used in
associated with nutrient. Plan     developing and implementing
would include a nutrient budget    the nutrient management
for N, P, and K. Plan would        plan. At a minimum the
address crop plans and yield       protocol is to specify the
goals, soil and manure testing,    collection and analysis of
and timing and method of           manure, litter, and other
application. In addition to        process wastewaters annually
nutrients, plan must address air   for nutrient content and the
quality, pathogens, and salts      collection and analysis of soil   An NRCS CNMP is inclusive
and heavy metals.                  samples for phosphorus            of all nutrient management
                                   content at least once every 5     issues required in an
                                   years for all fields where        NPDES NMP.
                                   manure and wastewater may         NRCS CNMP includes
                                   be applied.                       planning elements relative to
                                                                     air quality, pathogens, and
                                                                     heavy metals not critical to
                                                                     an NPDES NMP.
                                   Protocol for Land
                                   Application of Manure and
                                   Wastewater. Develop and
                                   implement protocols to apply
                                   manure, litter, and process
                                   wastewater in accordance
                                   with the technical standard for
                                   nutrient management
                                   established by the Director.
Six Components of a NRCS            Nine Minimum Practices of                Key Differences
Comprehensive Nutrient              an NPDES Nutrient
     Management Plan                Management Plan

Record Keeping. The                 Record Keeping. Maintain all       Expectations of NRCS
purpose of this component is to     records necessary to               CNMP and NPDES NMP are
document implementation and         document the development           very similar.
management activities               and implementation of the
associated with an AFOs             nutrient management plan and
CNMP to allow adjustment of a       compliance with the minimum
CNMP to meet production and         practices defined in the permit.
conservation objectives.            In addition, records must be
Recommended records focus           maintained that document
on those required for nutrient      compliance with the effluent
management planning,                limitations specified in the
emergency response,                 permit.
maintenance, and third party

Feed Management. Feed                                                  Feed management activities
management activities                                                  are not recognized by the
designed to reduce the nutrient                                        NPDES permit process as
content of manure and land                                             being required for a permit.
requirements for nutrient                                              However, an AFO may want
management is the focus of                                             to identify implemented
this component. Feed                                                   technologies and
management is suggested as a                                           management practices
planning consideration, but not                                        contributing to reduced N
as a specific requirement for                                          and P excretion.
individual AFOs.

Other Utilization Activities.
Environmentally safe
alternatives to land application
of manure, manure use for                                              Other utilization activities are
energy production, methods to                                          not specifically recognized
reduce the weight, volume, or                                          by the NPDES permit
form of manure, manure mixing                                          process as being required
with industrial or municipal by-                                       for a permit.
products to produce value-                                             However, other utilization
added material, and                                                    activities that relate to
transportation and marketing                                           manure export or availability
options for moving manure                                              of N and P should be clearly
from areas of over supply to                                           defined for an NPDES NMP.
areas with nutrient deficiencies,
and treatment technologies are
potential options.
The table includes text taken directly from (or summarized from) EPA’s NPDES Permit Writers’ Guidance Manual
(http://www.epa.gov/npdes/pubs/cafo_permit_guidance_chapters.pdf) and NRCS Comprehensive Nutrient
Management Planning Technical Guidance (http://policy.nrcs.usda.gov/scripts/lpsiis.dll/H/H_180_600_E_5.htm).

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