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From: TSS ()
Subject: Re: WATER BOARD FLOUNDERS WITH CWD SAFETY, risk long term exposure to humans
Date: May 30, 2005 at 2:12 pm PST

In Reply to: WATER BOARD FLOUNDERS WITH CWD SAFETY, risk long term exposure to humans posted by TSS on May 27, 2005 at 6:44 am:


----- Original Message -----
From: "Jim Woodward"
To: "CAREN Johannes"
Sent: Sunday, May 29, 2005 11:24 PM
Subject: RE: FWRF composting facility


> Dear Ms. Johannes,
>
> Thanks for your reply. When will you be inspecting the FWRF? Am I correct in assuming
> that the FWRF has never submitted a permit application to the CDPHE for onsite disposal of
> animal carcasses, feces, and other solid wastes?
>
> Sincerely,
>
> Jim Woodward
>
>
>
>
> > -----Original Message-----
> > From: CAREN Johannes [mailto:Caren.Johannes@state.co.us]
> > Sent: Monday, May 09, 2005 9:53 AM
> > To: jbw@frii.com
> > Cc: jblehm@larimer.org; CHARLES JOHNSON; ROGER Doak
> > Subject: Re: FWRF composting facility
> >
> >
> > Dear Mr. Woodward:
> > Thanks for your e-mail letter concerning the Foothills Wildlife
> > Research Facility in Fort Collins, Colorado.
> >
> > The purpose for the Division's upcoming site inspection is to determine
> > the facility's compliance with the "Solid Waste Disposal Sites and
> > Facilities Act" (C.R.S. 30-20-100 et. seq.) and the "Regulations
> > Pertaining to Solid Waste Disposal Sites and Facilities" (6 CCR 1007-2,
> > "the Regulations"). This would include evaluating the appropriate
> > classification for the facility under the "Solid Waste Composting"
> > section (Section 14) of the Regulations.
> >
> > If you have additional questions, please feel free to call or e-mail.
> >
> >
> > ...................................
> > Caren Johannes
> > Colorado Department of Public Health and Environment
> > HMWMD-CP-B2
> > 4300 Cherry Creek Drive South
> > Denver, CO 80246-1530
> >
> > (303) 692-3347
> > (303) 759-5355 fax
> >
> > >>> "Jim Woodward" 05/06/05 11:13PM >>>
> > May 6, 2005
> >
> > Caren Johannes
> > Colorado Department of Public Health and Environment
> > HMWMD-CP-B2
> > 4300 Cherry Creek Drive South
> > Denver, CO 80246-1530
> >
> > Subject: Composting activities at the Colorado Division of Wildlife's
> > Foothills Wildlife
> > Research Facility
> >
> > Transmitted via Electronic Mail
> >
> > Dear Ms. Johannes,
> >
> > I am working with Rita Anderson on the Foothills Wildlife Research
> > Facility solid waste matter. As you know, the FWRF conducts chronic
> > wasting disease experiments on live animals in outdoor laboratories.
> > Thank you for your assistance with respect to the state regulations
> > governing composting facilities.
> >
> > After reviewing Section 14 "Solid Waste Composting", it appears that
> > the FWRF's composting site may be a Class IV facility. This is assuming
> > the composting activity comprises less than 2 acres and that it contains
> > 5,000 cubic yards or less of feedstock at any one time. I have no data
> > to verify these assumptions. If the assumptions are incorrect, it may
> > actually be a Class III facility. Class III facilities must submit both
> > a Designs and
> > Operations Plan and an Annual Report to the CDPHE.
> >
> > Both Class IV and Class III facilities must comply with subsection
> > 14.2.1 "Minimum Standards of Operation for All Composting Facilities."
> > Subsection 14.2.1 states:
> >
> > "All composting facilities shall operate in a manner to:
> > (A) Control surface water flowing onto the site and
> > prevent surface water from leaving the site;
> > (B) Control onsite and prevent offsite nuisance
> > conditions such as noise, dust, odors, vectors and
> > windblown debris;
> > (C) Prevent water pollution at or beyond the site
> > boundaries"
> >
> > The FWRF is not in compliance with paragraph 14.2.1(A) "Control surface
> > water flowing onto the site and prevent surface water from leaving the
> > site". According to a May 2, 2005 news report in the Fort Collins
> > Coloradoan, the Soldier Canyon Filter Plant regularly discharges
> > backwash water into the FWRF facility. These discharges occur "every
> > couple of months". Photographs of the FWRF clearly show the drainage
> > swale from the Soldier Canyon Plant traversing the FWRF from south to
> > north. Composting activities are conducted near this drainage swale.
> >
> > In a September 2001 memo from the Colorado Division of Wildife's Animal
> > Care and Use Committee, inspectors note:
> >
> > "Options for the disposal of CWD contaminated material need to be
> > addressed. The biowaste pile is not adequately contained and the
> > inspectors were concerned that the pile was located immediately adjacent
> > to a drainage."
> >
> > In a March 14, 2005 letter from Earlie Thomas, Colorado State
> > University Director of Environmental Health Services, to Dr. Mike
> > Miller, Colorado Division of Wildlife veterinarian, Mr. Thomas advises:
> >
> > "Please consider relocating waste composting well away from facility
> > drainage swales and contained to the extent possible."
> >
> > In a December 5, 2004 email from Brian Janonis, Fort Collins Water
> > Resources & Treatment Services Department Manager, Mr. Janonis states:
> >
> > "The water drains north from the water treatment facilities
> > across the State's Wildlife Facilities. Likewise the water from the
> > Wildlife Facilities continues to drain north." Mr. Janonis is
> > referring to how the surface water leaves the northern boundary of the
> > FWRF site.
> >
> > The FWRF is likely in violation of paragraph 14.2.1(B) "Control onsite
> > and prevent offsite nuisance conditions such as noise, dust, odors,
> > vectors and windblown debris".
> >
> > The September 2001 DOW-ACUC memo explains:
> >
> > "The inspectors were of the opinion that strong winds, which are common
> > at this site, could disperse the contaminated material into the
> > uncontaminated pens."
> >
> > Winds strong enough to spread infective material from one pen to
> > another would surely result in offsite contamination. A September 2002
> > DOW-ACUC memo explains that an open pile of contaminated material has
> > been "contained" with hay bales, and that this should reduce the amount
> > of material blown about by the wind. Photographs show a couple of rows
> > of hay bales surrounding the pile on three sides. The pile remains
> > uncovered.
> >
> > Lastly, the FWRF may be violating paragraph 14.2.1(C) "Prevent water
> > pollution at or beyond the site boundaries".
> >
> > The March 2002 memo from the DOW-ACUC warns that:
> >
> > "Options for the disposal of CWD contaminated material still need to be
> > addressed. Options, such as a disposal pit, silo, or possible
> > incineration, are being considered. However, if a pit is dug, it will
> > need to be placed on higher ground to avoid or at least minimize
> > possible contamination of the ground water."
> >
> > It is unclear if the current composting operation has been "placed on
> > higher ground", or if this precaution would in fact prevent ground water
> > contamination.
> >
> > In addition, it is likely that surface water leaving the facility
> > contains some level of CWD infectivity. Unfortunately, there is
> > currently no practical technology for testing this water for CWD.
> >
> > I understand the CDPHE will be inspecting the FWRF in the near future.
> > Will the inspection report include a composting facility classification
> > as well as a determination regarding compliance with subsection 14.2.1?
> >
> > Sincerely,
> >
> > Jim Woodward
> > P.O. Box 599
> > Wellington, CO 80549
> > 970-897-3028
> >
> >
> >
> >
> > -----Original Message-----
> > From: CAREN Johannes [mailto:Caren.Johannes@state.co.us]
> > Sent: Wednesday, April 27, 2005 9:20 AM
> > To: guardianship@aol.com
> > Cc: CHARLES JOHNSON; Derek Boer; John Pape; ROGER Doak
> > Subject: Request for information, Regulations Pertaining to Solid
> > WasteSites and Facilities
> >
> >
> > Ms. Anderson:
> > Thank you for contacting me on April 26, 2005 concerning your
> > questions
> > regarding the State composting regulations in Colorado and composting
> > being conducted at the Foothills Wildlife Research Facility in Fort
> > Collins, Colorado. The regulations can be found at the following
> > website:
> > http://www.cdphe.state.co.us/op/regs/solidwasteregs.asp
> >
> > As I noted in our conversation yesterday, the requirements specific to
> > composting facilities are found in Subsection 14 of the Regulations.
> > Please contact the Division if you have additional questions or are
> > not
> > able to access the Regulations through the link.
> >
> > ...................................
> > Caren Johannes
> > Colorado Department of Public Health and Environment
> > HMWMD-CP-B2
> > 4300 Cherry Creek Drive South
> > Denver, CO 80246-1530
> >
> > (303) 692-3347
> > (303) 759-5355 fax
> >
> >
>
>



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