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Home My WebLink About960317.tiff FACISIMILE COVER SHEET Fax To: Ms. Shany Easton Date: 01/25'96 PAGES: 6 (including cover) FROM : WOOD B. EPPELSHEIMER TELEPHONE: 303-732-4643 33500 W.C.R. #16 FAX: 303-732-4643 KEENESBURG, COLORADO, 80643 COMMENT: Dear Ms. Easton, The following is a brief we prepared at Jeff Stolls request addressing the opening proposal for Moark. As a reminder to compare his open-air-concept to Moringfresh. Morningfresh dries 80% of it's manure in a closed building that has odor/gas scrubbers on it's exhaust fans. It does not spread raw manure on local fields, and of the 20% of it's manure that goes into compost, 75% of the compost is of a woodchip filler. Osborne evidently admitted that there was plenty of market to produce and sell his manure in the same manner as Morningfresh. It appears he does not want to make the investment in the early stages. We see no reason that he should not start the right way from the beginning. His staging suggestions means he could get to the level of the Fruita operation near Grand Junction before he implements pelletizing his manure. That is not acceptable for our environment. We have Health department statements that within 3 miles of Fruita today, at times in the summer the odor causes nca. Incidentally, I'm including the article from Washington discussing sealed truck, subsoil application of raw manure. In the early stages if some raw manure spreading is allowed, we encourage you to look closely at requiring this type of application. Moark must buy new trucks for this operation, it would not cost much more to buy closed trucks and sub-soil apply from the start. Thank you for your consideration. I 12) 11 �"� `" / 'JAN. 5 198% P1-1607 L'IW7 -'7C1i ��1 �(1� US 13109P Mr. Jeff Stoll Wood&Barbara Eppelsheimer Weld County Health Dept. Keenesburg, Co. Dear Jeff, Thank you for sending me the opening Moark proposal. I would like to respond to their "Management Plans". This is NOT a Morning Fresh operation as promised. #1. COLLECTION SYSTEM #2. STORAGE In the original application, Moark said manure would be spread on fields, sun dried or composted. In their presentation to the commissioners,they said manure would go into roofed drying buildings before going outside. Now, in the MGT. PLAN, Moark says storage areas will be either roofed structures, outside drying areas, or compost piles. Evidently manure management is at their option and none represent the closed dryer and air filtered process of Momingfresh. As we learned from our research,the drying area in Fruita, Co. has caused such a nuisance condition that Moark is working on plans to move drying areas off the farm,yet it appears that Moark's proposal for the Roggen site is much the same as Fruita. This is unacceptable for the protection of our environment, in an area of more than 200 family units in the 3 miles radius around the site. #3. LAND APPLICATION(of raw manure) How wet will the manure be? Page 1 says "direct land application of raw, dried or composted manure to local farms" What is "raw" and how can they prevent spillage from open trucks? Extreme odors (ammonia gas, and methane gas, etc.)occur during stirring, open hauling, and surface spreading of manure. Manure spilling on roads result in tires picking up manure and taking home odor and fly breeding contaminates. The preferred method to prevent spillage is closed trucks. Sub-surface incorporation of manure from closed trucks will prevent spillage and odor problems from the beginning. Included is the article from Washington about open surface spreading vs.the correction of the problems by closed truck, subsurface spreading. (Momingfresh does not spread, it dries and pellatizes most of it's manure inside an air filtered compound and composts the rest with a high concentration of wood chips for Richlawn) QUESTIONS: (from information gathered about substandard pracitices) (A) What happens if in the winter the manure can't be sold or spread at the rate of accumulation. (1)Does Moark plan to spread raw manure on their surrounding dry land. The dry land is sandy and plants can't process the raw manure. Also the water table is around 20' in the area and the manure can will leach into the water table that is only about 20 feet below the \ surface under Osboumes property. The flash flooding over that broad area will be a concern if manure is broadcast on the surface and not disked in. (B) Does Weld County have spillage regulations? (C) Will Manure Trucks be Washed Daily? (D) Where will the trucks be parked on property? (E) What time of day or night will hauling, spreading, and stirring take place? WATER CONCERNS: There is nothing in his early application that indicates solutions to the surface flash flooding that occurs on the proposed site. Flooding through the area carries directly into Roggen and will contaminate their wells and houses. If manure is surface spread on Osbome's larger surrounding acreage it will be swept into Roggen as well. The EGG WASH DISPOSAL SYSTEM was not addressed. In reference to our phone conversation, does changing the egg wash water plan and not using a drain field system by-pass state water regulations? What is the alternative plan? What is the plan for the large volume of discarded eggs ? What is the final plan for dead chicken disposal? PROACTIVE ODOR AND FLY PROGRAM Use of houses with fans and belt drying still produces the same volumes of odors and gases as sun- drying. Will there be air filters/scrubbers as in Momingfresh to stop the odor inside the buildings? How dry is the Manure? Under the Proactive Odor and Fly Program, Osborne stated"flies will not breed below 25-30%moisture." After manure is run off belts, Osborne estimated moisture content to be 35%-60%at Commission hearing. Will that abate fly breeding? What other measures are proposed. This proposal is vague and inconsistent with previous statements.What are the specific guidelines and requirements to insure solutions of these problems? ODOR ABATEMENT (back-up program) The steps are vague and are the SAME as the proactive program. How will this back up the so-called proactive program? STAGING PHASES BY MANURE AMOUNT: At first hearing the Quantity Phase concept it seemed a reasonable idea. However, before any commitment is made by Moark to approach the technology employed by Momingfresh,the level of manure will be the same quantity that is causing problems in Fruita. The first two phases are 200,000 chickens. Is there any reason not to implement the odor, fly, and drying systems from the beginning of Phase Two to prevent the problems from happening in the first place? Guidelines and process requirements must be specific and should start at the beginning to protect the environment in this part of the County. Barbara Kirkmeyer has recently stated that she expects a Momingfresh level of operation and would not have voted to approve application at a reduced standard. The planning commission has re-affirmed that only the highest standards will be approved. Fred Otis,the Moark attorney said to us early in the process that"this operation will be comparable to Morning Fresh" At the hearings,the Commissioners repeatedly used Momingfresh as the standard for approval. This early indicator of the Moark of process does not represent a substantive change from his Fruita Help us protect the environment and achieve the committed level of quality operation that Osborne implied when he asked for approval. Wood Eppelsheimer Barbara Eppelsheimer v r ,Soca_inc--ip &DA]r/ cc)fl N - Ram the Field ffcC0 g�t�� Q ego u<i Management Program to ontrol Flies and sP -Fa p�(� Odor In Poultry Manure Storage and Disposal?� Marlene R. Guhllsa -. (t r. Abstract ._ .4grrculrural activities often are incompatible with residential areas The der d at the manure storage_Ss. disposal of animal waste, particularly, may produce offensive odors and of employees who were instructed \, re generate flier which a a nuisance and of public health concern to to spray flies with Cygon' and neighbors of the animal waste disposal site. Ravap' insecticides did so only The problems encountered with the disposal of poultry manure on sporadically. As time passed, even agricultural land near a small rural town are described. The legal process sporadic spraying lost effect as Ili used to gain successful control of the problems is described. The advan- seemed to develop resistance to the in- rages of augmented biological control with parasitic chalcid wasps secticides (3). (Pteromaiidaeti and the injection of poultry manure beneath the surface The manure at the feedlot generated of the ground arc demonstrated to be effective management practices for flies as well, and an enormous fly pro- satisfactory control of flies and odors. blem developed when the manure was applied to the ground. Perhaps worse, manure spreading procedures Lincoln County, Washington is the ed, the manure was removed with a created a severe odor problem. second most productive�ieat growing bucket on a tractor, dumped into Before the man was ure applied to the county in the United States. Despite its manure-spreading trucks, and spread ground, the manure that was corn- sparse, rural population. a fly and odor on the fields. Later it was worked into posting in the storage pits had problem developed in 1978 between the the ground with a disc plow. developed a eras;. The crust tended to si community of Sprague and a beef an April 1978, the Lincoln County reduce odors by containing them Lit- feedlot operation approximately two Environmental Health 9 ttt bean beneath it. When the crust was broken y miles north of town. Envirreceiv n entscom rats from xoDle rn by the tractor that was used to lift This feedlot was unusual in that the and neat racer ' eoole id manure into spreader trucks, an intense operators planned to "recycle" poultry seriousness disgusting odor was released. manure from their poultry houses in 0 ors. The frecuenev and serioness When the wind switched to the north- of these complaints escalated. Over a east, the obnoxious odors drifted into na o Spokane County. Some �od of four yeah and two court pro-' the town of Sprague. pro- manure would be mixed with other ceedings, the court declared the opera- products to feed the cattle. Excess a pit tc nuisance and chances_ the Fields were a manor source of fromanure, beyond what could be fed to were made thuist have worked odors because during the manure .-- the cattle, would be applied to local tend- snores' spreading opemthon. the manure tend- farmland as fertilizer. ---- S to slide out of the trucks in large Initially, the manure spreading dumps rather than being spread as a The Problem trucks usedTor transport into-Lincoln thin, even coating. These uneven / At first the poultry manure was County did not contain the minute dumps occurred even though the brought in by truck and—deposited adequately. Manure leaked (rom-the manure was in a semiliquid state, and either at the feedlot for immediate pro- doors, sloshed over the top-of.tttenils, they were from six inches to four feet cessing or dumped in two pits about a or was lodged in the tires. This of fresh, odorous manure. The half mile from the feedlot. The pits deposited considenh!e manure on the disagreeable odor easily carried to were about 60 feet long, 30 feet wide, road, including an interstate freeway Sprague. and 7 to 10 feet deep. The bottom of and state-highways. People traveling These manure dumps intensified the the pits were clay, and there were no these roads %eked u atwrron fly problem. When the disc plow was covers provided. As the pits were fill- their ve tee ti es_She-ataaurs-anct iu used, the manure could not be corn- odor went home with vehicles traveling pletely covered with soil. Later a mold- . m every direction. The manure alsq board plow was used to turn the soil of Environmental Health, V 47 (41 314-117 provided a fly breeding medium in overand cover the manure more effec- \taricna R. Gunikt. R.S. Director of home garages and neighborhoods, Lively, but the manure had been so Envunnmcnni Health. L,n.uin County, adding considerably to the local fly thickly applied mat the plow was will P.O. not ins, oavenpon. WA 99112. population. Also, a severe fly problem not able to completely cover the WA. 47, No. 6 314 Journal of Environmemal }iealth t.i sAiflhieO 44 r a/cutseD -711.44.54.5 �•oe el-in 9 eve y -- - Al/c- I _ r • control program was to be used (2.,;. a manner to minmize the death of during .nversion periods or when wind Aiological fly control was substituted chalcids (1). The chalcids tended to live would ould carry the odor into Sprague.. for chemical control because it was on the periphery of the storage pits . highly effective, compared with spray- where the fly pupae developed. The The manure was removed from the ing the surface of the manure pits, and flies pupated there because the manure storage pits io the cylindrical tank in ii eliminated many of the problems is dryer adjacent to the soil banks of a manner that would minimize odors, normally associated with pesticides (3). the pit. This area was not sprayed with Negative pressure from a vacuum Chemical control measures at the pits insecticides. Instead, insecticides were pump was used to extract the semi- were believed to be detrimental to sprayed on the grass and weeds grow- liquid manure from beneath the crust. biological control. ing around the pits to kill the adult flies grow- When this procedure was not success- that rested in the vegetation. Elimina- tion ful, water was added to the pits and the Parasitic chalcid wasps, tion of these plants made spraying with manure agitated, making a possible to Mua released at x raptor, ,ifuse c endius lurax were an adulticide virtually unnecessary. transfer the manure from the pits to the tamp and Spalangra were The absence of plants also increased air tanker. The agitation and liquefaction Tamil at the pits. These chalcide of the manure also lessened tly produc- I circulation and thus aided the frying of 1 (family puncturing Pteromalidae) kill flies by manure. The employee-monitor sub- Lion. Odors were confined to-the pit either puncturing the puparium and mined records to the Environmental area since most of the manure was sucking out the contents or by laying Health Department on a weekly basis composted by this time. Also, the eggs inside the fly puparium (1,6). The showing wind direction, release of weather was favorable at that time of eggs develop into wasp larvae that feed year to prevent odors from drifting pup fly counts at the traps toward Spragtae and kill the developing pupa. — The parasitic chalcids were very ef- Conclusloa The parasitic chalcids provide con- fective for fly control at the storage pits Now land application of poultry tinual control instead of sporadic con- and did not bother people. Nor did the waste :ram this operation occurs in the trot achieved with spraying insecticides chalcids (smaller than houseflies) fall, spring and early summer as long (4). Also, house `lies, Musca bother the employees who worked near as wind direction arse weather condi- domesrica, have not developed them. The chalcids appeared to remain (ions are favoraole, and without resistance to these parasites. at high population levels at the manure developing fly or odor problems. Land Close supervision is necessary to storage pit for extended periods of application activities are halted during • maintain the control desired because of titn6 holidays such as July 4 and during the fluctuations in the life cycle of the fly. Using the parasitic hynenoptera was wheat harvest season in August, to fur- As the chalcids kill pupae, adult flies economical in comparison with they reduce the possibility of flies or are reduced in number so that very few pesticides for fly control(1,3). Approx- odors annoying people in the area This fly eggs are laid for pupal development. imately 40,000 chalcids were released management program has been in use As the pupal population declines, the every 1e, days at a cost of about S96 per since June 1982 with few complaints chalcid month; compared to about $300 from the community. population also declinesP Per This operation, utilizing injection because these parasites must have fly month for pesticides applied twice a an 3 pupae as hosts. With reduction in week. Labor costs are additional and method of manure disposal rather than numbers of chalcids, eggs, larvae, increase with the use of pesticides,since land spreading has proven successful. pupae and adult flies that arrive with spraying is necessary at least eight The use of parasitic chalcids instead of new manure deposits can increase in times per month, compared to reins- insecticide sprays for fly control is sue- numbers until more chalcids are in- ing parasites only twice a month. cessful, as well. Decreased use ofinsec- troduced in the environment to attack Therefore, the parasites give more ef- odes also allows for populations of successive fly generations. To be effee- fective control and at lower cost than other naturally occurring bio-control live as biological control agents, then pesticide* agents to build up in addition to the. chalcids are "seeded" into the area in Land Application—Good manage- augmentation Lions. These two management practices greater numbers than they°CC'dr under ment practices were crucial not only at should be considered by others who are normal conditions (1,3,6)• the storage pits but also in the fields looking for means to make the disposal The pits were inspected by a respon- where the manure was applied to the of agricultural manure waste environ- vble employee of the company who land for disposal and fertilizer. The mentally tolerable in areas where there monitored the effectiveness of the fly poultry manure was applied to the is nearby population. control measures. Fly traps (Bishopp fields during the fall season. A tractor type) installed around the pits were pulling a cylindrical tank with shanks Adtaoe.wg.aieu helpful in assessing fluctuations in the attached and designed to inject the rte ai.iho,acknowledges the assistance of Or. fly population and in removing adult manure beneath the surface of the Paul Cam. entomolog.0 at wasnin{ton gut. ground was used instead of a manure Untre guy and Gres Simmons Instructor of flies locally attracted to the pits. English m Green River College for their critical of the flies collected indicated spreading truck. This prevented the t ,ew „r has manuscript. D. Gm was in- when to release more parasitic chalcids manure from exposure to the air, thus strumeni al in developing a satisfactory solution at the pits More flies meant more preventing odors. The thin application to me psiultr, .asne disposal problem, and his chalcide with quick incorporation into the soil trust is moo apis aoatad prevented breeding of flies so the use Reforms, On occasion, insecticides such as of parasitic chalcids in the fields was I. Harman. Roland C. 0477), lunar: •d fly Cygon* or Ravapa were used, but in not necessary. Wastes were not applied Contrul is n Gaining. Anry Dig.,36.1 tea, 316 Journal of Environmental Health / vol, 47, . . 6 Hello