Help with Spill Plans, CWA Issues, What Nutrient Density Means to GHGs, and Converted Vegetarian

Spill Plan Help: You are likely aware of the controversy over whether or not to include milk as a regulated substance in the Spill Prevention Control and Countermeasure (SPCC) rules.  While this is an important issue, what cannot be “lost” in the process is the current requirement for SPCCs at many farms (based on oil and fuel storage alone).  To encourage compliance with the SPCC rules, The National Milk Producers Federation (NMPF) recently announced the release of an “industry specific” SPCC self-certification template for dairy producers. The template can be found at

Regardless of the Environmental Protection Agency’s current considered extension and potential for exemptions, and whether you can self-certify your SPCC or you need an individual plan certified by a Professional Engineer, compliance with the current SPCC rules should be a priority issue.  The costs for noncompliance (financial and otherwise) are too great.  If you have specific questions relating to the SPCC rules, you can contact Christopher Paré ( or Matthew Schroeder ( at 248.932.0228.  

Comment on CWA: We were recently asked to contribute an article to Manure Manager in regard to the potential impact of the recent Clean Water Act (CWA) Ruling.  If you would like to read this article, you can find it here.

Additionally, we encourage you to become familiar with S. 1816 introduced by Senator Cardin relating to the Clean Water Act.  This is potentially VERY significant as it relates to the Clean Water Act, not just for the Chesapeake Bay Area. 

Nutrient Density and GHGs: The final issue we wanted to mention relates to Global Climate Change.  As you are aware, there has been plenty of press on this issue over the last few years.  Livestock agriculture has been on the receiving end of bad public relations as it relates to this issue, much of it beginning with the 2006 UN report Livestock’s Long Shadow. Dr. Frank Mitloehner (Professor at the University of California, Davis) later criticized this report because the UN looked at the lifecycle analysis for agriculture’s impact, but did not do the same for Transportation.  Livestock agriculture is still fighting an uphill battle as it relates to their real “carbon impact.” 

This said, a recent study (Nutrient density of beverages in relation to climate impact) looks at nutrient density of beverages in relation to climate change and provides some additional insight in the debate over climate change. According to the report, “This study is the first to estimate the composite nutrient density, expressed as percentage of Nordic Nutrition Recommendations (NNR) for 21 essential nutrients, in relation to cost in GHG emissions of the production from a life cycle perspective…” 

The article, while positive for the dairy industry, does have limited application based on the test parameters. Nevertheless, it appears to be a good scientific assessment that may help clarify this often times controversial issue relating to global climate and agriculture.  You can read the article here

Former Vegetarian Hippie Says Eat Meat: One more final point is this story we found interesting. In the early 1970s a young vegetarian hippie, Simon Fairlie, was faced with a dilemma, what to do with the male goats on the communal farm.  They were not good for milk – the answer: goat stew.  Mr. Fairlie has some unique viewpoints and while not exactly an advocate for today’s large farm, Mr. Fairlie provides an interesting perspective on the issue of farming and the consumption of meat as part of our diets.  His book, Meat: A Benign Extravagance, should be an interesting read.  To read a recent article about Simon Fairlie in “Mail Online” click here.


Is Your Environmental Remediation Over-Engineered?

When a site is not properly characterized, it’s pretty tough to complete environmental remediation (unless you are real lucky!).  In our recent “Environmental Minute,” we take a brief look at this very issue.   

Environmental Minute Remediation September 2010

SPCC Template Available for Dairy Producers

Today the National Milk Producers Federation announced they have “completed the development of a self-certification template tool to assist dairy producers in developing Spill Prevention, Control, and Countermeasure (SPCC) plans that covers all fuel and oil storage on the farm.”  This tool is available on the NMPF website (

NMPF recognized the need for an SPCC template designed specifically for dairy producers.  Early in 2010, NMPF asked The Dragun Corporation to develop the template so they could assist producers in complying with the SPCC requirements.

Seminars for Dairy Producers

We just finished the first in a series of three seminars relating to application of the SPCC regulations at dairy farms. The seminar just completed was for Michigan Milk Producers Association in Cadillac, Michigan.  We will be traveling to Chicago next week to speak with the National Milk Producers Federation – Environmental Task Force and to Columbus, Ohio the following week to speak with Dairy Farmers of America – Mideast Council. 

I was a last minute fill in to co-present in Cadillac.  It was a very attentive group with some great questions.  I’m very excited to see how co-ops are integrating environmental issues into the training of their field staff and subsequently to their member producers. 

We will post another update here next week following our presentation for NMPF with some additional news for dairy producers.

Enbridge Spill – Reprise

Another Enbridge Oil Spill…this time in Romeoville, IL. Accordingly to Waste Information & Management Services, Inc. (WIMS), “Initial assessments indicate that crude oil from the pipeline flowed through sewers into a retention pond at 719 Parkwood Avenue near Route 53.”

Will a SIC/NAICS specific enforcement be forthcoming? Who knows…certainly, it would be prudent to make sure your SPCC, FRP, NPDES, and other CWA related plans and permits are up-to-date so you are not the “low hanging fruit!”

Ten Tips from USEPA for CAFOs

Is this an indication of future enforcement initiatives?

The United States Environmental Protection Agency (EPA) Region 7 recently issued a “Fact Sheet” entitled, Ten Tips to Prepare for EPA Concentrated Animal Feeding Operations Inspections. They state in their introduction, “…you have probably heard about EPA’s inspection and enforcement activities in Region 7. These activities are part of an increased national emphasis aimed at ending harmful discharges of pollutants from CAFOs into rivers and streams.”

With this as a background, the EPA offers the following ten tips to help “ensure operations are in compliance.”

  1. Are you discharging? Answering this question is one of the primary purposes of an EPA CAFO inspection. Owners and operators of CAFOs should evaluate their facilities to determine if any runoff is getting into nearby rivers and streams. If you are discharging, contact the state regulatory agency to determine waste controls and permit requirements.
  2. Are you controlling runoff from feed storage areas? CAFOs are required to control runoff from all production areas, including feed storage areas.
  3. Are you controlling runoff from manure/bedding stockpiles? These stockpiles are considered part of a facility’s production area even if they are located outside the facility’s footprint. Care should be taken to prevent runoff from discharging into nearby rivers and streams.
  4. Is your facility medium sized? If your operation conveys runoff from the production area through a man-made ditch, flushing system or other similar man-made device, then you need to obtain a permit or stop the discharge.
  5. It is important to read your National Pollutant Discharge Elimination System (NPDES) permit and implement its requirements.
  6. Are you counting animals correctly? Both EPA and state regulatory agencies require that species in open lots be counted together with similar species in confinement for the purposes of determining your size status as a CAFO. Also, if your operation confines enough animals of one species to be considered a large CAFO, then all animals at the operation must be counted and runoff from these areas must be contained.
  7. Maintain complete and accurate animal inventory records. One of the first things an inspector does is determine your CAFO status by looking at the number of animals that have been confined at your facility. This determination can take time if the right records are not readily available.
  8. If you have an NPDES permit, you cannot expand operations beyond the capacity listed in your current permit without authorization from the state regulatory agency.
  9. Maintain lagoon berms free of trees, shrubs and erosion features and follow pump-down level requirements for lagoons to maintain adequate storage levels.
  10. Maintain records for land application of manure solids and liquids and follow a nutrient management plan/manure management plan in the application of any manure. These records are vital to demonstrating that you are implementing appropriate land application practices.


While it is nice that the EPA is offering helpful hints to CAFO owners, I am reminded of something an “old salesman” was fond of saying, “You’re telling me that for a reason.”

If you have any questions or need assistance with an environmental issues contact Matthew Schroeder, P.E. ( or Christopher Paré ( at 248.932.0228.