HomeMy WebLinkAbout20013375.tiff 4311 Highway 66, Suite 4
• Longmont, CO 80504
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• Office(970) 535-9318
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• Fax: (970) 535-9854
Environmental Services, LLC
Cindi Etcheverry November 30, 2001
Environmental Health Services
Weld County Department of Public Health& Environment
1555 N. 17th Avenue
Greeley, CO 80631
RE: StroMo, LLC—Certified letter No.: 7001 0320 0004 1518 3601
This letter is in response to your Certified Letter referenced above dated November 19,
2001 regarding the StroMo, LLC compost facility and your inspection on August 20, 2001
to assess the facilities compliance with the "Regulations Pertaining to Solid Waste
Disposal Sites and Facilities" (6 CCR 1007-2) and the development standards set forth in
USR# 1276.
Mr. Roger Doak of the Colorado Department of Public Health and Environment, Solid
Waste Division accompanied you during this inspection.
Your letter lists six potential deficiencies that we will address in the same order.
1. Fly Nuisance You identify our response letter regarding potential nuisance
conditions from flies dated August 31, 2001 and that StroMo, LLC will be
implementing fly abatement measures through the year 2002. Item#1 of your
letter appears to be only a statement and not a deficiency issue at this time since it
has previously been addressed.
2. Stormwater Collection System Since your inspection in August, StroMo has
initiated the necessary grading activities to direct stormwater towards the retention
structure. The grading is ongoing and occurring as compost is moved or removed.
During your inspection on August 20, 2001, it appeared this approach was
practical and acceptable.
The boundaries of the site have been surveyed and staked for construction of
diversions for separation of run on and run off stormwater. If there is additional
concern regarding run on or run off stormwater, we would recommend your review
of the approved 200-acre A-1 Organics, Rattler Ridge Class I Composting Facility,
USR# 1285 which is located on similar sandy soils. The A-1 organics facility
reports stated, due to the soils onsite, no run on or run off stormwater would occur.
Additionally, the site does not have a stormwater containment structure.
Your "Pro-Ag"Environmental Professionals /2L /v.e)
60,45O/7/ q ` Q
--- / 2001-3375
November 30, 2001
Page 2
The StroMo, LLC retention structure was completed prior to your August 20, 2001
inspection and a final survey has since been conducted. "As-built" drawings of the
finished retention structure will be forwarded to the Weld County Health
Department by December 15, 2001.
3. Retention Structure We disagree that there was any evidence in AgPro
Environmental Services' letter of September 15, 2001 that suggests the pond liner
was not constructed according to the DOP. A copy of our September 15 letter is
included which specified that the liner has been constructed, verified and reviewed
by more than one registered professional engineer and included attached reports.
The liner as installed significantly exceeded the minimum standard outlined in the
State Regulations 6 CCR 1007-2 Part A, Section 14.4.2(H)(4) "All leachate
collection structures shall be constructed of low permeability materials to achieve
a hydraulic conductivity of less than or equal to 1x10.5 `m/sec" The Design and
Operations Plan specifies on page 20 that "Bentonite, bentonite well drilling mud
of other suitable clayey soils if found available on site... "will be used for
construction of the liner. Additionally, if a letter and report containing liner
permeability certification stamped and reviewed by more than one registered
professional engineer is not adequate for your department then we have no
additional recourse.
4. Composting The issue of static piles is resolved. We have addressed the static pile
issue, which was poultry manure, by 1) no longer accepting poultry manure onsite,
2) incorporating the existing piles into windrows or 3)removing the poultry
manure for land application to farmland offsite.
5. Groundwater monitoring Three groundwater-monitoring wells were installed,
completed, registered and sampled prior to your inspection of August 20, 2001.
The wells are in the location indicated in the Design and Operation Plan and
Monitoring Well# 1 is centered on the west side of the stormwater retention
structure directly perpendicular to the groundwater flow and directly downgradient
of the stormwater pond. The Colorado Department of Public Health and
Environment and subsequently the Weld County Health Department have
suggested an additional monitoring well, not outlined in the Design and Operation
Plan, be located approximately 'A mile south of Monitoring Well# 1 centered on
the west side of the property. We do not agree with this assessment. The area
where most, if any, groundwater impact could occur is immediately downgradient
from the retention pond.
6. Compliance with the Regulations StroMo, LLC has addressed the issues outlined
in Mr. Doak's letter of May 14, 2001. The retention structure has been
constructed,the groundwater monitoring wells have been installed, signage has
been installed appropriately and records are being maintained at the facility.
Regarding Mr. Doak's letter of September 21, 2001, we believe StroMo, LLC has
met the letter of the regulations and the intent of the Design and Operations Plan.
November 30, 2001
Page 3
There is not a dispute regarding if the standards of the regulations have been met,
but the methodology used to achieve compliance. The methodology is not specific
to the regulations.
We intend to continue to work with your office in good faith and believe all of the issues
in your letter have been addressed or will be completed by December 15, 2001 as outlined
above. We believe any consideration of a Probable Cause Hearing is unwarranted. If you
feel further review is necessary, we would assist in scheduling a work session with the
Weld County Commissioners.
If you should have any questions, we can be reached at (970) 535-9318.
Since e ,
l L�
omas Haren Eric W. Dunker, P.E.
Environmental Consultant Environmental Engineer
Pc: Roger Doak, CDPH&E
Monica Daniels-Mika, Department of Planning Services
Trevor Jiricek, Weld County Department of Public Health and Environment
Board of Commissioners
Lee Morrison, Weld County Attorney's Office
Tim Smith, StroMo, LLC
John Moser, StroMo, LLC
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