HomeMy WebLinkAbout990928.tiff V.7.DCOI ':iI
11990 Grant Street, Suite 402
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Northglenn, Colorado 80233
NVNVIR0rr,, Phone (303) 457-4322
IRO (303) 457-4609
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April 15, 1999
Trevor Jiricek
Weld County Health Department
1517 16th Ave. Court
Greeley, CO 80631
Subject: Morwai Dairy, LLC,Manure &Process Wastewater Management Plan
Dear Trevor:
This letter is in response to your review and subsequent letter dated March 10, 1999 regarding the
Morwai Dairy, LLC, Manure and Wastewater Management Plan(MvIP). Each comment is
addressed below in the order received.
1. The MMP submitted on February 18, 1999 included a Final Site Plan with Dimensions
that adequately indicate flow direction and runoff containment features consistent with
plans previously submitted and approved by the Weld County Health Department and
Conditions of Approval identical to USR#1201, 2(A)(4). However, for your
convenience, enclosed are two additional survey copies of pre-construction and post-
construction surface contours.
2. Page 6, paragraph 2, of the section Management Controls—Retention Facilities,
describes the staging, capacities and functions of the solids separation basins, anaerobic
lagoon and storage pond for the Morwai Dairy. The subsequent paragraph reads, "The
retention facilities will be lined with a compacted earthen material to a thickness of at
least 12"or more to a permeability not to exceed 1/32"per day as required by the
Colorado Confined Animal Feeding Operations Control Regulation. The liner
construction and permeability will be verified by a registered professional engineer. The
results will be forwarded to the Weld County Health Department, the Colorado
Department of Public Health and Environment and incorporated within this plan.
These two paragraphs together mean that the separation basins, anaerobic lagoon and
storage pond will be lined and tested to comply with the Colorado CAFO Control
regulation. The Weld County Health Department will be notified of the results.
Serving Environmental Needs of the Livestock Industry
1 990928
The primary application area consists of approximately 560 acres. Morwai Dairy owns
and/or controls an additional 2,080 acres of farmground. Several parcels of the adjacent
farmground are under center-pivot irrigation. The calculations in Appendix B of the MMP
use generalized textbook and national standards for nutrient concentrations of lagoon
water, mineralization and volatization rates. As you are well aware, these standard
references are conservative. When Morwai Dairy is fully operational, managing land
application in accordance with"Tier 2" standards, and performing wastewater, soil and
post-harvest crop analysis, the actual site-specific levels will be determined and application
rates adjusted accordingly. Therefore, the primary acreage may be more than adequate to
assimilate nutrients in the lagoon water during most years. If it becomes necessary, upon
review of site specific data collection in accordance with the regulations, Morwai Dairy
will install additional pipelines to center pivots beyond their primary 560 acres.
3. The MMP does state that no stockpiles of manure are located outside of the pen areas and
we concur with your recommendation to delineate additional manure storage areas in
accordance with the requirements of the Colorado CAFO Control regulation. However,
we strongly disagree with your opinion that any manure stored outside the pen area is a
violation of USR# 1201. A violation would occur only if runoff from a manure stockpile
is not contained in accordance with the Colorado CAFO Control regulation.
The primary alternative manure storage area is located between the two concrete
separation basins and west of the earthen separation basins. However, in the best interest
of Morwai Dairy regarding your opinion of compliance with USR# 1201,the map
revisions now delineate the entire dairy property located upgradient of the stormwater
containment structures as the manure storage area.
4. Pages 7 and 8, Table 1 and Appendix B, outline total manure production at the Morwai
facility. Paragraph 3 on page 8 states that the solid manure calculations are "As
Excreted" and accounts for all of the manure produced at the facility. The MMP further
outlines "a portion of this manure is flushed as process wastewater or collected as
stormwater runoff into the lagoon system. Total calculations from solid manure and
wastewater are not cumulative. A large portion of the total manure generated will be
assimilated in the wastewater system, reduced by anaerobic digestion and subsequently
land applied. The calculations above allow for an extremely conservative estimation for
solid manure management. " The MMP continues on page 8, "The majority of Morwai
Dairy's solid manure will be transported offsite by area farmers for use on their own
land " As long as Morwai Dairy is land applying either wastewater and/or solid manure
in accordance with "Tier 2" land application criteria as outlined in the Colorado CAFO
Control regulation, and documenting the application on property owned or controlled by
Morwai Dairy, total manure production is irrelevant. Morwai Dairy, LLC has voluntarily
agreed in the MMP to sample and analyze solid manure that is removed offsite and
provide an average summary of the results to fanners who take solid manure. Records of
the quantity of solid manure removed from the Morwai Dairy to off-site locations not
owned or controlled by Morwai Dairy will be recorded in the Manure Removal Log forms
included in Appendix D of the MMP. The offsite recordkeeping established in the MMP is
Serving Environmental Needs of the Livestock Industry
a proactive measure that will justify and document the amount of manure retained and
applied onsite, or transported offsite and provide farmers with basic informal:ion about
proper application. However, any additional requirements to list farmers who take solid
manure, outline the acreages, crop rotations or locations of their land, or to obtain
agreements with farmers on property not owned or controlled by Morwai Dairy is not a
requirement and outside the scope of the State CAFO Control regulation, not specifically
required in USR# 1201, and therefore, outside the regulatory authority of the Weld
County Health Department. Morwai Dairy has taken steps to proactively and adequately
address this issue.
5. Page 8 discusses Wastewater and states, in part that "wastewater, soil and crop sampling
will be conducted, analyzed and recorded, and agronomic crop balances used to land
apply wastewater from the facility. " We are aware there are additional sources of
nitrogen, i.e. irrigation water, legumes, etc. The subsequent sentence to your reference
goes on to state, "Forms for land application 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 and are included with
this letter fir your reference. As you can see in items 3 through 6, the forms credit
residual soil nitrate, nitrogen from irrigation water, soil organic matter credits„ and
nitrogen credits from a previous legume crop. The plan reflects this fact and Morwai
Dairy will follow"Tier 2”requirements of the State CAFO Control regulation..
If you have any additional comments regarding final approval of this plan, please call us at (303)
457-4322.
Sincef y, %/AL.
omas Haren Eric W. Dunker
Vice President Environmental Engineer
Enclosures: Surface Contour Maps
Manure Storage Area Map
Agronomic Determination Sheet(s)
Cc: Julie Chester, Weld County Planning Department -
Keith Maxey, CSU Cooperative Extension Service
John Moser, Morwai Dairy, LLC -
Derald Lang, CDPH&E -
John Pickle, Weld County Health Department
Barbara Kirkmeyer, Weld County Commissioner
Serving Environmental Needs of the Livestock Industry
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