Field Office Compliance - Field Activity: Staff Action ID - 147384

Fremont Farms of Iowa LLP - LAOP - 311719952
3868 110th Street Malcom, IA 50157
Poweshiek County

FO 5

Activity Report
Document Name Type File Date Note
Cooley Pumping - Emergency Application.pdf
Inspection Report (public)
10/06/2020 Letter to Cooley Pumping
Fremont water samples.pdf
Inspection Report (public)
10/06/2020 laboratory results
Kern Farm.pdf
Inspection Report (public)
10/06/2020 Aerial photograph of land application field
State of Iowa Mail - Permission for Cooley Pumping to land-apply.pdf
Inspection Report (public)
10/06/2020 Email to Paul Cooley - 102220
File Name File Type File Date Note
Comments
10/22/2020 On October 21, 2020 I called Paul Cooley. I told Paul I had gone over the situation about the certified manure applicator with Ted Petersen and Ted was OK with Cooley Pumping doing the land application in light of the laboratory analytical results. I told Paul I would still like to look at an aerial map of the field. Paul said he would get me the location. He called me back shortly afterwards and gave me the location of SE 1/4 of Sec. 2, T85N, R15W (Crystal Twp.) in Tama County. The field is owned by the Kerns and their house is on the parcel with the address 1663 K Avenue, Traer Iowa. Paul said the field was approximately 160 acres, there is a creek going through it but he said there would be no problem meeting the 750 feet separation distance from the Kern residence and the 200 feet distance from the creek. Paul said they would also incorporate after application. I told him the field looked relatively flat and they needed to make sure there was no runoff. Paul said the construction company and Fremont Farms wanted something in writing that we (Iowa DNR Field Office 5) were OK with Cooley Pumping land-applying the manure. I told Paul I would put together an email to that effect and send it to him. I sent a aerial photo of the land application field to Ted Petersen. BILL GIBBONS
10/22/2020 On October 21, 2020 I received the following reply from Ted Petersen: Based on the analytical results of the wash water, and the backlog of applicators, I'd be okay with them moving forward without a certified applicator. BILL GIBBONS
10/22/2020 On October 21, 2020 I sent the following email to Ted Petersen about Paul Cooley (Cooley Pumping) not able to find a certified manure applicator: Hi Ted, Sorry I missed your message. I received the laboratory results for the water in those shallow pits. They sampled each one separately. There is not enough N or P in the water to even calculate an application rate. It comes down to making sure there is no runoff and that they meet all separation distances. I told Paul Cooley we did not want any runoff coming off the field. Paul Cooley has not been able to hire a certified manure applicator due to the fact harvest is already taking place and they are all saying they have previous committments. I did a little looking on-line when this all started and this Cooley Pumping is a pretty big outfit with some pretty modern looking equipment. Paul has located a field in Tama County where he believes they can meet all the separation distances for surface application without incorporation. He is going to send me an aerial photo of the field. There is the owner of the field in this area and one other neighbor and Paul said they could talk to the neighbor to let them know what they will be doing. If the field looks appropriate I guess the question is whether we are going to absolutely insist they find a certified manure applicator. Sincerely, Bill Gibbons BILL GIBBONS
10/22/2020 On October 20, 2020 I received the laboratory analytical results from Paul Cooley for three shallow pits at Fremont Farms that will be pumped out and the water land-applied. The nutrient values for N and P were such that the important factor is preventing runoff and observing the required separation distances. I talked to Paul Cooley and he said he was not able to hire a certified manure applicator since they all have prior commitments and it is already manure application season. He said he has a field lined up in Tama County. It is in a fairly remote area and there is only one neighbor. Paul said there would be no problem meeting the required separation distances and they would talk to the neighbor before land-applying. I told Paul I would talk over the situation with Ted Petersen (Supervisor - Field Office 5) about not being able to obtain a certified manure applicator. I asked Paul to give me the information about the location of the field and he said he would get that for me. BILL GIBBONS
10/8/2020 On October 8, 2020 we mailed the letter to Cooley Pumping after it was reviewed and signed by Ted Petersen (see attached) and I emailed the letter to Paul Cooley. I also called Paul Cooley to let him know we sent the letter. He said he found a field in an isolated area, there were no tile intakes and no nearby waterways. He asked if they could incorporate the liquid manure. I told him if they incorporated within 24 hours it would be the same as direct injection as far as separation distances were concerned. We also discussed finding a certified manure applicator. Paul was concerned since many of them were already busy. I told him to call me if there was a problem. BILL GIBBONS
10/8/2020 On October 7, 2020 I discussed the matter with Ted Petersen (Supervisor FO5) and Trent Lambert (Supervisor FO2 & AFO Coordinator). We determined this could be done however the material would be classified as liquid manure, it would have to be land-applied at an agronomic rate and they must meet all required separation distances (depending on the method of application), and create and maintain a record of the land application. They would need to collect a sample and have it analyzed for Total N and Total P. Since the site sells their manure under IDALs 200 A they do not have a MMP however they have a Animal Unit Capacity >500 and they should use a certified manure applicator (preferably a certified commercial applicator) to do the land application. I told Ted and Trent I would write a letter to Cooley Pumping authorizing an emergency application of liquid manure and have them review it before mailing it. BILL GIBBONS
10/8/2020 On October 6, 2020 I was contacted by Paul Cooley with Cooley Pumping (319) 640-8511, paul@cooleypumping.com) about pumping water from shallow pits at the Fremont Farms of Iowa, LLP site. Manure storage buildings were damaged during the Derecho storm and the construction company hired to construct the new buildings wanted Cooley Pumping to pump water from former manure storage areas (3 shallow pits 50' x 50' x 2' deep). The manure had been removed but there was water from recent rains. They wanted Cooley pumping to pump out and dispose of the water, all debris would be removed and then Cooley Pumping would power wash the pits. The water had come in contact with residual manure nutrients and solids. Cooley Pumping proposed to land-apply the contact water (approximately 44,000 gallons) as a means of disposal on a farm field. I told Paul Cooley I needed to discuss the matter with my supervisor and the AFO Field Office Coordinator (Trent Lambert) and I would get back to him. BILL GIBBONS
Compliance Tracking
Action Type Date Completed Date Comment
State of Iowa DNR Home Site Policy
Leading Iowans in caring for our natural resources
Version: 2.3.0.23170
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