HomeMy WebLinkAbout990954.tiff VI=tJCC!..1. i1
11990 Grant Street, Suite 402
8: 36 Northglenn, Colorado 80233
ittiNVIRO CLERK tK Phone(303)457-4322
Fax(303) 457-4609
y q TO TIE
April 15, 1999
Derald Lang
Colorado Department of Public Health &Environment
Water Quality Control Division
4300 Cherry Creek Dr. S.
Denver, CO 80222-1530
Subject: Front Range Feedlots, LLC—Manure and Process Wastewater Management Plan
Dear Mr Lang:
This letter is in response to your letter dated April 7, 1999 regarding Front Range Feedlots, LLC, Manure
and Process Wastewater Management Plan(MMP). Below are responses to your comments in the order
received.
1. The water well referenced was depicted on the Location Map derived from a U.S. Geological Survey
7.5 minute topographical map dated 1968. This well was replaced in a new location approximately
three years ago and is not located within the boundary or immediately adjacent to the proposed pond.
The old well location was plugged and abandoned.
2. The existing 500 gpm dewatering pump is adequate to dewater the 29 acre-feet of water from the
existing stormwater ponds within the 15-day requirement of the CAFO regulations. An additional
pump of similar type and capacity will be used for the additional 29 acre-feet of storage capacity for
the proposed containment pond assuming complete expansion of the facility.
Front Range Feedlots,LLC may select a liner material for the proposed pond of either synthetic or
compacted clay,that will meet the higher 1/32"seepage standards. Therefore, immediate dewatering
within 15 days would not be necessary.
3. A copy of a letter dated December 8, 1998 from Curtiss L. Palin, P.E.,at Earth Environmental
Consultants in Fort Collins, Colorado is included with this letter. Soils analysis for engineering of a
compacted earthen liner as well as detailed pond design plans and specifications will be conducted prior
to any construction. As detailed in the MMP,Figure 4-Diagrams of Existing Retention Ponds depicts
actual field measurements of the existing lagoon structures that have existed for 20 to 30 years.
Several of these ponds have a 1:1 side slope and less in some cases. We agree that a slope of 1:1 on
the new retention pond in Figure 5-Diagram of Proposed Retention Pond may be difficult to
construct. However,no decisions by Front Range Feedlots,LLC regarding final lining materials have
been determined to date and no new construction is underway. The conceptual design and calculations
in the MMP outline the minimum volume standards. The dimensions are based on consistency with the
width of the existing structures. However, Front Range Feedlots, LLC has sufficient area available to
modify the slope of the proposed stormwater pond when and if any new construction is conducted.
C"- '21± 990954
Serving Environmental Needs of the Livestock Industry USRI I5Q
C-IAF"i° A-AL OA 99 PL.0709
Final detailed construction plans and specifications will be completed prior to construction. Front
Range Feedlots, LLC is responsible to meet and verify attainment of the seepage rates and
requirements of the liner standards in the CAFO regulations regardless of liner type or slope. Results
of liner certification will be forwarded to the Colorado Department of Public Health and Environment,
the Weld County Health Department and incorporated within the MMP when and if construction is
completed.
4. Front Range Feedlots, LLC operates under"tier two" (agronomic rate)nutrient application according
to the regulation. According to the regulation,this practice requires annual soil sampling of all
application sites in sufficient number to provide a representative nutrient residual in the soils, as well as
sampling of manure,wastewater and harvested crops.
Front Range Feedlots, LLC manages land application in accordance with"tier 2"standards.We are
aware there are additional sources of nitrogen, i.e. irrigation water, legumes, etc. Forms for land
application record keeping and calculations are included in Appendices C and D of this plan. These
forms were adapted from the Colorado State University,Best Management Practices for Manure
Utilization dated August 1994. The Manure Management Record Sheet, items 3 through 6,credit
residual soil nitrate,nitrogen from irrigation water, soil organic matter credits, and nitrogen credits
from a previous legume crop.
Although the plan states land application assumptions not including soil N credits, atmospheric N
credits or irrigation water N credits, it further states "These factors increase the land application
acres required " Residual soil N credits as well as irrigation water credits are site specific,vary year
to year, and cannot be definitively quantified in the plan. Only site specific sampling and analysis on
an annual basis will determine acceptable agronomic rates in accordance with"tier two"guidelines.
The plan outlines a minimum of 400 acres of irrigated farmgound for land application and recommends
at least 600 acres of irrigated farmground. Front Range Feedyards, LLC has over 750 acres for land
application. All sampling, analysis and record keeping will be evaluated annually, adjusted for
subsequent years application, and incorporated within the MMP in accordance with the CAFO
regulation.
5. The facility will operate as a no-discharge facility under the regulation. Rainfall events will be
recorded on a Rainfall Log to document a 25-year, 24-hour storm event of 3.2 inches or greater in any
24 hour period. A copy of the Rainfall Log is included for your records.
Sinc rely,
AtikA a
omas Haren
Vice President
Enclosures: December 8, 1998 Letter from Earth Environmental Consultants, Curtiss L. Palin
Rainfall Log
Pc: Joe Hoff, Front Range Feedlots,LLC
Ben Patton,Weld County Planning Department
Trevor Jiricek,Weld County Health Department
Barbara Kirkmeyer,Weld County Commissioner
Victor Sainz, Colorado Department of Public Health&Environment,WQCD
Serving Environmental Needs of the Livestock Industry
,.'J ft;--'3 d95
EARTH ENVIRONMENTAL
SERVICES, INC.
December 8, 1998
EnviroStock,Inc.
11990 Grant Street
Suite 402
Denver, Colorado 80233
Attn: Mr. Thomas Haren
RE: Manure and Process Wastewater Management Plan
Front Range Feedlots,LLC
Greeley Facility
15972 County Road 51
LaSalle, Colorado
Mr. Haren:
The purpose of this letter is to respond to your request for review of the Manure and Process
Wastewater Management Plan for the referenced Front Range Feedlots facility. I understand that
the purpose of the review is to evaluate if the proposed expansion to the facility allows for adequate
wastewater collection and retention facilities to handle a 25-year, 24-hour storm event. The runoff
retention facilities are also not to be located in the 100-year floodplain.
Based on the documentation and drawings provided by EnviroStock, it appears that the proposed
stormwater runoff retention pond, as well as a portion of the pen area are located in the 100-year
floodplain according to the Federal Emergency Management Agency (FEMA) map. Though there
does not appear to be base-flood elevation information for this area,the proposed 4-foot berm along
the eastern and southern boundaries of the facility suspected to be in the floodplai.n should be
sufficient to inhibit inundation during a 100-year flood. Therefore, it would appear that adequate
flood proofing has been incorporated into the facility expansion design plan.
626 North Hollywood Street
Fort Collins, Colorado 80521
Tel: 970-472-9863 • Fax: 970-472-9864
Earth t•nvironmcnml Services, Inc.
Front Range Feedlots Review
December 8, 1998
Pace 2
I have also reviewed the calculations for the design of the new stormwater retention facility. Based
on the assumptions and background data used in the calculations, the proposed design of retention
pond should be adequate to handle the typical volumes from the expanded facility during a 25-year,
24-hour storm event. If you need additional information or have questions, please do not hesitate
to contact me.
Respectfully Submitted,
Earth Environmental Services, Inc.
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Curtiss L. Palin, P.E.
RAINFALL LOG
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Rain Gauge Location:
ININICES ENDING RAINFALL
DATE IlliIiiIIMNI DATE
TIME (inches)
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Nutrient Management Pan
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