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Mr. Rick Reed - 2 - -! 8 September 1999 <br /> assure that the wastewater is applied at agronomic rate. Application of the wastewater at an agronomic <br /> rate should not result in an increase in compound concentration in groundwater samples from the <br /> monitoring wells. <br /> This board was created to protect the quality of our water and I feel you would be neglectful in <br /> issuingg-a permit only to add to the river and ground water's already fragile and contaminated <br /> state. I have listed my concerns and hope you would mandate the slaughterhouse to implement <br /> them before a permit is considered. <br /> We do not believe that issuance of WDRs (a permit) is neglectful. Issuing a permit, to the contrary, is <br /> proactive. The permit for the Stagno facility contains adequate safeguards to protect water quality. <br /> 1. Directly behind the slaughterhouse property is a property owned by a family member which is <br /> a former manure dumping site for the former chicken farms. We do not want them dumping <br /> any manure on this property. Please put a dumping requirement on Stagno's, stating that they <br /> will have to transport their manure at least two miles away from this site. <br /> Past waste disposal practices by a different operation do not imply that Stagno will dispose of the <br /> manure in the same manner as the previous operators. The WDRs for the Stagno facility will <br /> prohibit the application of the manure to the cropland if the nutrient levels (i.e., nitrogen, <br /> phosphorus, and potassium) in the soil are high. If Stagno can demonstrate from the previous year of <br /> operation that the cropland soil is deficient in nutrients, then application of the manure in the <br /> following year will be permissible. The WDRs also require that records of any off-site manure <br /> transactions be provided in an annual report. We do not have the authority to prohibit where the <br /> manure solids may be placed. <br /> 2. Discarded animal wastes must be removed and transported off-site daily. <br /> The WDRs state in Finding Nos. 4 and 7 that discarded portions of the carcasses (offal), and fats, <br /> oils, and greases that accumulate in the grease trap will be collected by a tallow operation. Offal will <br /> be collected on a daily basis. Our agency does not have the jurisdiction to require daily removal of <br /> solid animal wastes, rather we have the authority to prohibit the discharge of these wastes to the <br /> pond or cropland(Prohibition A.6). <br /> 3. Wastewater ponds and fields shall be monitored and tested for as long as the slaughterhouse is <br /> in business. <br /> We concur with your statement. The WDRs will regulate the operation of a slaughterhouse at this <br /> location and will remain if effect as long as there is waste discharge from the facility. Should the <br /> facility be transferred to another operator or owner, the WDRs will still be in effect and require that <br /> our agency be notified of such changes (Provision F.3 in the Tentative WDRs). <br /> 4. The faculative treatment pond's location has been changed and now is directly adjacent to <br /> neighbor's two homes, approximately one-hundred feet. This pond should be placed away <br /> from homes. <br /> c:kkwfiles\agriculture%agletters\agltr006 ' <br />