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3 <br />Page 1 of 2 <br />a <br />Garrett T. Backus [EH] <br />From: Madison -Johnson, Mary [Mmadison@ciwmb.ca.gov] <br />Sent: Friday, August 03, 2007 2:11 PM <br />To: Garrett T. Backus [EH] <br />Cc: Robert McClellon [EH] <br />Subject: RE: SKS Enterprises carcass composting <br />Thanks for the background info! <br />From: Garrett T. Backus [EH] [mailto:gbackus@sjcehd.com] <br />Sent: Friday, August 03, 2007 12:06 PM <br />To: Madison -Johnson, Mary <br />Cc: Robert McClellon [EH] <br />Subject: SKS Enterprises carcass composting <br />Hi Mary, <br />Here are the details regarding the SKS carcass compost: <br />1) What was the original notification for? <br />The notification was for a chicken manure compost operation. Manure from the onsite chicken houses is mixed <br />with wood shavings. The compost windows and feedstocks are kept inside a building on a concrete slab and <br />mixed with a compost turner that is mounted on two rails. The finished compost is sold to a local farmer or <br />wholesaler. <br />2) What were the circumstances that led up to the N&0? <br />I was doing a routine vector control inspection at the facility and I asked the operator how they were handling <br />the dead chickens when they depopulate a chicken house. This facility will keep hens laying eggs for two years. <br />After two years the hens are no longer productive enough and an entire house of 120,000 chickens are killed at <br />the same time. <br />The operator said that when house 7 was depopulated, they decided to compost the carcasses instead of hauling <br />them to the landfill. He showed me the "bunker" building where the carcasses and wood shavings were mixed <br />and placed in windrows. I told the operator that the carcass composting operation was not covered by their <br />notification to compost manure since the carcasses are a different feedstock. <br />I left the site and consulted with my Program Coordinator a few days later. Since the carcass composting was not <br />covered by the current Notification Tier, we issued the notice and order to cease and desist the operation, dispose <br />of the compost and cleanup the "bunker" building. <br />3. What were the reasons it was decided that a full permit was needed? <br />I reviewed the compost regs and did not find specific information regarding avian composting. My Program <br />Coordinator, Robert McClellon, contacted Bob Holms regarding this issue and was told it was a permitting issue <br />and to contact Mark de Bie. I consulted with CIWMB staff including Reinhard to determine what type of permit <br />would be required to compost bird carcasses. Reinhard stated that composting mortality requires a full permit. <br />His email to me regarding this issue is attached. <br />8/3/2007 <br />