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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. scia ,43 °° Sd...............Nalualmotott so,.� Curtiss L. Palin, P.E. RAINFALL LOG Year _ Rain Gauge Location: ININICES ENDING RAINFALL DATE IlliIiiIIMNI DATE TIME (inches) SIESEIS ISS sell= ISI IllaSISSIIISII SS SI IIIIESSIIIIIIIINNISal IIIIISSISSIM SISIIIIIIMINNININEEN MallINNIESI SI . SISISI SISIIIIIININISIaNI SIIIIIIIS SSINNININI -- SISIIIINSISSIIINI MISS SI SISSI SISMINIENISSIS IIIMSISISSI ■_SS SIS_-_- IIIIIIIIIISISIIIINSS IIMISISSIIIIINS ISIIIIIIIIIISISIENNINI SESSIONS SISISISIII Nutrient Management Pan Hello