HomeMy WebLinkAbout930870.tiff NATIONAL FARMS, INC.
816-221-4501
February 3, 1993
Connie Harbert
Office of Board of County Commissioners
P.O. Box 758
Greeley, Colorado 80632
Dear Ms . Harbert:
This letter addresses the memorandum submitted as well as the
comments made to the Board of County Commissioners by
representatives of Mr. Anschutz at your January 29, 1993 meeting.
The meeting opened with background information given by Mr. Lyons
and Mr. Stovall. The main body of the presentation then got
underway when Mr. McGregor described National Hog Farms ' monitoring
systems . Mr. McGregor quickly focused in on effluent monitoring
well number eleven which he describes in his memorandum to the
Board as " . . . the well closest to the NHF disposal area. " He
showed a graph illustrating elevated nitrate nitrogen levels over
time. This graph came from a set of graphs Mr. McGregor produced
and included in a letter to Mr. Lyons and Mr. Forman dated November
25, 1992 . I have copied and included seven graphs from this
letter. These graphs were all produced by Mr. McGregor's firm for
Mr. Lyons and Mr. Forman and depict nitrate nitrogen concentrations
in the seven wells which are closet to and equidistant from
disposal areas at National Hog Farms . EM 11 is the only one of the
seven indicating any increase. Four others indicate decreases and
the remaining two, while only containing two data points apiece,
also indicate decreases .
Mr. McGregor explained why this "increase" was occurring. He
submitted a graph showing the nitrogen concentrations of the
applied effluent and contrasted this with the concentrations
National Hog Farms projected in its preliminary engineering. The
statement was made that National Hog Farm's effluent was "too hot"
and measures "in excess of 600 ppm nitrogen" . He also noted that
National Hog Farms had originally talked in terms of 180 ppm of
nitrogen. What Mr. McGregor did was to purposely mislead the Board
by mixing two different measures of nitrogen concentration. He
repeated his deception later in his presentation when questioned
by Ms . Kirkmeyer about effluent testing. He did it again in his
Int ' 970870
VI( 0\�3 C A A_ 1600 GENESSEE KANSAS CITY. MISSOURI 64102
NATIONAL FARMS, INC.
816.221-4501
Ms . Harbert
February 3, 1993
Page 2
memorandum to the Board when he said " The IT Operations Plan was
based on a holding tank effluent nitrogen concentration of 180 ppm.
The actual concentration, even after treatment, has averaged in
excess of 660 ppm. " The IT Plan spoke in terms of 180 ppm of Plant
Available Nitrogen (a measure of only the nitrogen which is in a
form the plant can use and which takes into account all of the ways
nitrogen is lost naturally during application) . Mr. McGregor is
using a measure called Total Kjeldahl Nitrogen which is derived in
a chemistry lab by acid extraction and titration and measures all
of the elemental nitrogen in a sample. Both are legitimate ways
of describing nitrogen in a sample but for Mr. McGregor to
repeatedly compare and contract them without explaining the
difference is inexcusable and brings his credibility into question.
In fact, in 1991, the PAN concentration of the effluent at National
Hog Farms was 231 ppm. In 1992, the PAN was 170 ppm.
Mr. McGregor was then asked for his recommendation. He stated that
the only solution was to cut National Hog Farms ' animal population
to one-fourth of its present size. This comment betrays his and
his employer's true intent and concern.
Other points worth noting:
1) Despite the skepticism of Mr. Anschutz 's employees, our tests
during the Spring and Summer of 1992 do indicate a positive
response (in terms of dry matter production and nitrogen
removal) to additional water on our pivots . I am including
four graphs illustrating this .
2) The subject of application rates is one that continually is
revisited. When one speaks on this subject, one needs to
remember there are two components - inches of application and
concentration of the liquid applied. In 1991 National Hog
Farms applied approximately seven inches of effluent with a 231
ppm PAN concentration. In 1992, we applied approximately six
and one-half inches onto fifty per cent more land but using an
effluent with only seventy-four percent of the PAN
concentration (170 ppm) as in 1991 . Contrast this with the
Agreement with Weld County which permits up to 25 . 55 inches
per year (Section V B) .
3) Mr. McGregor stated National Hog Farms has 1700 acres of
application area. The actual amount is 2860 acres .
1600 GENESSEE KANSAS CITY, MISSOURI 64102
NATIONAL FARMS, INC.
816-221-4501
Ms. Harbert
February 3, 1993
Page 3
4) Mr. McGregor speaks of " . . .odor complaints in the area. . . " .
National Hog Farms is unaware of any complaints over the last
four years and would expect to have been made aware of any if
in fact any had been made and registered with Weld County
Health.
5) Bob Stovall noted that if he were to design a program for
National Hog Farms, he would recommend mixing native warm
season grasses with National Hog Farms ' cool season tame
grasses . That program is and always has been in place at
National Hog Farms .
6) National Hog Farms is testing wells and continues its
monitoring process . We have simply gone back to the program
in place prior to December of 1990 as previously discussed with
the Board.
7) In a meeting with John Pickle after the Board meeting, Bill
O'Hare and I introduced Frank Haywood to John. Frank is a new
employee of ours who is a chemist and lab technician. Frank
has worked for the EPA on Superfund cleanups such as the
Southern Pacific's Sacramento spill site.
8) Also discussed at their meeting with John was our plan to add
a water distribution system in the Spring of 1993 to our
northern pivots . From notes of a Weld County Board work
session dated December 14, 1992, I noted the staff were to
write a letter that would " . . .encourage NHF to implement its
remediation plan. " National took this to mean that Weld County
wanted us to add the water system but since no mention of it
was contained in Dr. Gordon's subsequent letter dated December
17 , 1992, clarification is needed. National Hog Farms believes
Section IX of the Weld County/National Hog Farms Agreement
requires Weld County Health to approve any and all revisions
to the waste handling system. John said he would follow up
with a letter clarifying this point.
This latest presentation by Mr. Anschutz 's underlings with its
selective reading of the data and transparent attempts to mislead
the Board illustrates their creative although unethical abilities
and behaviors . It also should put to rest the debate over who is
credible and who is not on this subject. Mr. Anschutz and his
hirelings would like nothing better than to force National Hog
Farms out of business, send two hundred people to the unemployment
1600 GENESSEE KANSAS CITY. MISSOURI 64102
NATIONAL FARMS, INC.
816-221-4501
Ms. Harbert
February 3, 1993
Page 4
lines, and destroy an annual market for over three million bushels
of grain so Mr. Anschutz can expand his hunting range to include
National Farms ' property. Their latest presentation demonstrates
that they will not allow anything as insignificant as honest data or
truthful renderings of the facts to stand in their way.
National Hog Farms appreciates the efforts expended by the Board and
Weld County Health to preserve the environmental integrity of Weld
County while providing a place for economic activity to occur.
National Hog Farms looks forward to our continuing partnership with
Weld County in this endeavor.
Best regards,
NATIONAL FARMS, INC.
Greg Gilsdorf
GG/ps
cc: Bill Haw
Bill O'Hare
Frank Haywood
Barbara Kirkmeyer
Bill Webster
Dale Hall
George Baxter
Dr. Gordon
John Pickle
Patrick Armijo
1600 GENESSEE KANSAS CITY. MISSOURI 64102
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