Document k6B4wnZg3wknJZzmXKa0nNDO

REPORT OF CONCENTRATED ANIMAL FEEDING OPERATION INSPECTION At Rodney Daiker (b) (6) Auburn, Iowa 51433 ON September 12, 2024 BY U. S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division (ECAD) 1.0 INTRODUCTION I performed a Concentrated Animal Feeding Operation (CAFO) inspection at the Rodney Daiker facility on September 12, 2024. This inspection was performed pursuant to Section 308(a) of the Federal Water Pollution Control Act, as amended. This narrative report and Attachments present the findings and observations made during the inspection. 2.0 PARTICIPANTS Rodney Daiker, Owner/Operator U.S. Environmental Protection Agency (EPA): Stephen Pollard, (Lead Inspector) (913) 551-7582 Email: pollard.stephen@epa.gov Zachary Leibowitz, Physical Scientist Email: leibowitz.zachary@epa.gov 3.0 INSPECTION PROCEDURES I contacted Rodney Daiker via telephone on Friday, September 6, 2024, and stated that I was planning to perform an inspection of the Rodney Daiker facility on Thursday, September 12, 2024. Mr. Daiker stated that he would be available, and we agreed to meet at 8:00 am. I also stated that I would have another EPA employee with me during the inspection. Prior to entering the facility, I conducted a visual reconnaissance of the property and its land application areas, searching for areas of concern observable from the county roads such as discharges, drainage patterns, flow directions, distance and direction of nearest perennial waters, visual condition of perennial waters, facility location and layout. The facility is located approximately 2 miles northeast of Auburn, Iowa. The nearest waterbody is the North Raccoon River and is located approximately 0.75 miles north of the facility. The North Raccoon River was 1 The facility is approximately 6 acres in size and consists of three confinement barns with a total capacity of 3,300 head, accompanying feed bins, a 1.4 million gallon (approximate) above ground manure storage tank and a mortality dumpster (deadbox). The facility controls process wastewater by utilizing a scraper system in each barn that pushed process wastewater into sump pits where it is then pumped into the above ground storage tank until it is land applied. Mortalities are placed in a dead box and picked up by River Valley rendering service. The State of Iowa requires the facility to have a manure management plan (MMP) that identifies how and where manure will be land applied. The current MMP identifies 327 acres on 16 fields available for land application. The facility uses commercial applicators for manure application in the spring and fall. 4.2 CAFO Status Mr. Daiker stated that the facility has confined at least 2,500 swine weighing over 55 pounds for more than 45 days during the last 12-month period. All animals are confined in areas where crops, vegetation, forage growth or post-harvest residues are not sustained. Mr. Daiker stated that the number of swine currently at the facility was approximately 3,300 head. A review of inventory records submitted to EPA after the inspection confirmed that the facility has been confining at least 2,500 swine weighing over 55 pounds for more than 45 days during the last 12-month period (Attachment 3). As a result of my observations, I determined that the facility meets the definition of a large CAFO as it is defined in Title 40 of the Code of Federal Regulations (CFR), Part 122.23. 4.3 Regulatory History The facility does not have an NPDES permit and prior to this inspection had never been inspected by EPA. IDNR's last inspection was performed on August 23, 2022, and determined that the facility was not maintaining adequate land application records. A Notice of Violation was issued by IDNR on September 2, 2022, for failure to maintain adequate land application records on site (Attachment 4). IDNR also issued an NOV on July 14, 2020, for failure to submit their annual Manure Management Plan update (Attachment 5). 5.0 FINDINGS AND OBSERVATIONS The weather conditions at the time of the inspection were partly cloudy and mild (80F). I met with Mr. Daiker and discussed operational processes being performed at the facility. I performed a visual inspection of the facility, and reviewed inventory and land application records. The facility had approximately 3,300 head of swine weighing greater than 55 pounds, on site, at the time of the inspection. The facility has been operating as a large CAFO since it began operations in 1997. 5.1 Production Area During the visual inspection of the production area, I observed three confinement barns, the aboveground manure storage tank, deadbox, and feed bulk bins (Photos 1-9). As discussed above, the confinement barns utilize a flushing/scraper system to move swine manure to the sump pit located on the east side of the manure storage tank where it is then pumped into the tank. The side curtains on the barns were raised so I was able to observe the inside of the barns. The flushing/scraper system appeared to be operating correctly. I did observe minimal amounts of manure outside of the access doors located on the west end of each building (Photo #4). I recommended to Mr. Daiker that he clean this manure up. The above ground storage tank appeared in good condition. Mr. 3 Daiker estimated that it was half to three-quarters full at the time of the inspection. There is a sixinch outlet pipe located at the base of the tank on the east side. This outlet is used to transfer manure and process wastewater for land application. I did observe spilled manure around this tank outlet (Photos #6 & #7). Land application records indicate the last time manure was pumped from the tank was on October 19, 2023. I recommended to Mr. Daiker that he clean this manure up. Mortalities at the facility are placed in a dead box/mortality management area located in the southeast corner of the facility and picked up by a rendering company on routine basis. The dead box was not covered and would be exposed to precipitation. There was significant staining around the box associated with animal decomposition and any stormwater runoff from this area would be considered process wastewater (Photo #2). Runoff from this area will flow north into the adjoining gravel parking lot. During significant precipitation events, runoff will continue to flow uncontrolled north and east approximately 150 yards before entering the west road ditch along Zeller Lane. From there it will flow north approximately 0.5 miles before discharging into the Raccoon River. Like the areas described above, I recommended to Mr. Daiker that the areas surrounding the dead box be cleaned up and that process wastewater be managed so that it does not result in a discharge to Water of the United States. I observed the bulk bins used for on-site feed storage and did not observe any issues. The were clear of spilled feed and appeared to be operating normally (Photos #8 & #9). 5.2 Land Application Areas The discharge of manure, litter, or process wastewater from a land application area under the control of an unpermitted large CAFO is a discharge subject to NPDES permitting requirements, unless the discharge is an agricultural stormwater discharge. To be considered an agricultural stormwater discharge, the CAFO must land apply manure, litter, or process wastewater in accordance with site-specific nutrient management practices that ensure appropriate agricultural utilization of the nutrients in the manure, litter, or process wastewater, as specified in 122.42(e)(1)(vi)-(ix). Nutrient management practices and rates of application meet these requirements when they are done in accordance with state technical standards. To ensure that CAFOs meet these technical standards, the State of Iowa requires a site-specific Manure Management Plan (MMP) be developed that identifies the nutrient management practices the CAFO will follow. To determine if precipitation-related runoff from the facility meets the definition of agricultural stormwater discharge and therefore exempt from the NPDES permitting requirements, I reviewed the MMP, pumping/spreading, manure analysis and soil analysis records that were available on site (Attachment 8). I also requested copies of these records and Mr. Daiker referred me to Scott McLaughlin with Smithfield Foods, Inc. to obtain electronic copies. Inventory records were not available onsite, and I was again referred to Smithfield Foods, Inc. for this information. Following the inspection, Smithfield Foods, Inc. provided the inventory and land application records described above via emails received on September 26, 2024, and October 10, 2024 (Attachments 3 & 9). The IDNR requires existing facilities to submit a complete "original" or "long form" version of their MMP every four years to IDNR and an annual update or "short form" each of the remaining three years that identifies any changes to the existing MMP. The facility's last "long form" MMP was received by IDNR on June 21, 2021, and annual updates were submitted for 2022 through 4 2024. Only the 2022 update indicated changes to land application fields and/or crop rotations from the original 2021 MMP. I reviewed both the 2021 MMP and the 2022 update. Based on my review of the above listed documents, I made the following findings: 1. Field "C36-1 Craig Meyer" received manure in crop years 2021 and 2023 but the relevant MMP indicated this field would not receive manure during these years. 2. Field "C36-2" was not part of the MMP submitted in 2021 but was used for manure application in Crop Year 2022. 3. Field "C36-2" had manure applied during crop year 2024 at a rate that slightly exceeded the MMP planned rate (6,070 gal/acre vs. 6,016 gal/acre). 4. Field "J7-1" had Mgt ID "A" (Soybean, Corn, Soybean, Corn) in 2021 MMP. The 2022 MMP update switched the Mgt ID to "B" (Corn, Soybean, Corn, Soybean). Actual land application for crop years 2022-2024 continued to follow Mgt ID "A". 5. Field "J7-2" had Mgt ID "B" (Corn, Soybean, Corn, Soybean) in 2021 MMP. The 2022 MMP update switched the Mgt ID to "A" (Soybean, Corn, Soybean, Corn). Actual land application for crop years 2022-2024 continued to follow Mgt ID "B". 6. The July 14, 2020, NOV (Attachment 5) issued by IDNR was for not submitting the 2020 MMP update. The September 9, 2022, NOV (Attachment 4) issued by IDNR for not maintaining adequate land application records onsite. 6.0 SUMMARY The Rodney Daiker facility is located approximately two miles northeast of Auburn, Iowa. The site has three confinement barns with a total capacity of 3,330 head of swine and a 1.4 million gallon above-ground manure storage tank. The facility is operating as a large CAFO and does not have an NPDES permit. I observed a dead box/mortality management area that was not controlled and determined that during significant precipitation events, uncontrolled manure and process wastewater from this area will flow into the west road ditch along Zeller Lane. From there it will flow north approximately 0.5 miles before discharging into the Raccoon River. I observed spilled swine manure around the access doors on the west side of each confinement barn and around the outlet of the above-ground manure storage tank. During precipitation events, uncontrolled manure and process wastewater from these areas will flow north and east on the property before the west road ditch along Zeller Lane. From there it will flow north approximately 0.5 miles before discharging into the Raccoon River. My review of the MMP and associated land application documentation identified at least five instances where land application was not performed in accordance with the MMP and related updates. IDNR documented MMP violations in 2020 and 2022. 5 STEPHEN Digitally signed by STEPHEN POLLARD _P_O__L_L_A_R__D____1_3:_28_:1_4 _-06_'0_0'_ Date: 2024.11.21 Stephen Pollard Environmental Scientist NICOLE Digitally signed by NICOLE MORAN _M_O__R_A__N______1_4:_25_:1_8 -_06'00' Date: 2024.11.21 Nicole Moran Acting Branch Supervisor ATTACHMENTS: 1. Digital Photograph Image Chain of Custody/Photo Log and Photos #1 - #9 (7 pages) 2. Facility Layout-Photo Locations-Land App Areas (3 pages) 3. Inventory Records (1 page) 4. IDNR Notice of Violation issued on September 2, 2022 (11 pages) 5. IDNR Notice of Violation issued on July 14, 2020 (1 page) 6. 2021 Original Manure Management Plan (99 pages) 7. 2022 Manure Management Plan Update (99 pages) 8. Manure Analysis & Manure Application Records (Onsite) (30 Pages) 9. Manure Analysis & Manure Application Records (Provided by Smithfield, Inc.) (30 Pages) 10. Stream Characteristics Form (1 page) 6