Mat Rogers Sent: …Mr. Flick The department’s Water Protection Program has received the August...
Transcript of Mat Rogers Sent: …Mr. Flick The department’s Water Protection Program has received the August...
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Caldwell, Greg
From: Mat Rogers <[email protected]>
Sent: Thursday, October 05, 2017 10:04 AM
To: Caldwell, Greg
Subject: CAFO Permit - Valley Oaks Steak Company
Mr. Caldwell:
I am writing because I had an additional question on the CAFO permit for Valley oaks Steak Company and the
Buffer Distance. What is MDNR’s interpretation of what a public building is for the purposes of the Buffer
Distance? The CSR just states that a public building is “A building open to and used routinely by the public for
public purposes” but I don’t know if that is only civic buildings or retail buildings or any businesses? Could you
provide any clarification? Thank you for your help.
Sincerely,
Mat Rogers
Mat Rogers Environmental Engineer
Terra Technologies
www.terratechnologies.com 314.984.0050
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Caldwell, Greg
From: David Flick <[email protected]>
Sent: Wednesday, September 27, 2017 3:18 PM
To: Caldwell, Greg
Subject: FW: Valley Oaks Steak Company CAFO application
Hi Greg. I received your email notification through our company general mailbox and am working on providing you the
required information. You can email me direct at [email protected]. Thanks.
David Flick
Terra Technologies Inc.
913-385-9560
From: John Kahl
Sent: Monday, September 25, 2017 9:28 AM
To: David Flick <[email protected]>
Subject: FW: Valley Oaks Steak Company CAFO application
This was sent to the Terratech email address.
From: Caldwell, Greg [mailto:[email protected]]
Sent: Monday, September 25, 2017 9:22 AM
To: Terra Tech <[email protected]>
Cc: '[email protected]' <[email protected]>
Subject: Valley Oaks Steak Company CAFO application
Mr. Flick
The department’s Water Protection Program has received the August 31, 2017 application for a new Missouri State
Operating Permit for Valley Oaks Steak Company, LLC in Johnson County. After a review of the operating permit
application it has been determined to be incomplete. Please direct your attention to the following comments on the
application.
• The application showed a permit action type for a NPDES General Permit and for a MOGS1 State No-Discharge
General Permit. Please indicate which permit is being applied for and submit the appropriate application fee
($450 for a Class IB NPDES permit or $300 for a Class IB MOGS1 permit.) Please note on the check that it is for
Application #27963.
• Please submit a sealed Part 13 – Engineer Certification of the Form W or provide a document with the name and
seal of a Registered P.E. in Missouri, name and address of the operation, Engineering firm name and address,
date prepared and a statement that the project was designed in accordance with 10 CSR 20-8.300.
• The application indicates that this is not an export only operation. Manure that is planned to be applied to “land
applications areas” which are defined in 10 CSR 20-6.300(1)(B)13 as agricultural land that is under the
operational control of the CAFO owner or operator whether is owned, rented, or leased to which manure is
applied. All land application areas must be included in a Nutrient Management Plan (NMP) developed in
accordance with 10 CSR 20-6.300(3)(G) and submitted to the department. The NMP shall include for each land
application area, planned and alternative crops with realistic yield goal, soil test result that are less than 5 years
old, nitrogen (N) or phosphorous (P) based application, and P index worksheets as appropriate. The NMP must
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also include results of manure analysis used to calculate application rates. If no manure analysis is available,
book values may be used. If the operation is to be export only this is not required.
• If applying for the MOG01 permit, complete and submit “Land Application Information Table” (page 3 of the
Form W).
• Please submit a neighbor notice letter with attachment to the department.
The information listed above may be submitted by mail, email, or on a compact disc. Processing of the application will
resume upon receipt of the requested information. If you have any questions contact me.
Greg Caldwell Environmental Scientist Missouri Department of Natural Resources Water Protection Program P.O. Box 176 Jefferson City, MO 65102 (573)-526-1426 (573)-522-9920 (fax)
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Caldwell, Greg
From: Mat Rogers <[email protected]>
Sent: Friday, October 06, 2017 12:57 PM
To: Caldwell, Greg
Subject: RE: CAFO Permit - Valley Oaks Steak Company
Greg:
Thank you for the response and clarification.
Sincerely,
Mat Rogers
From: Caldwell, Greg [mailto:[email protected]]
Sent: Friday, October 06, 2017 11:12 AM
To: Mat Rogers <[email protected]>
Cc: Faulkner, Jacob <[email protected]>
Subject: RE: CAFO Permit - Valley Oaks Steak Company
Mat,
This definition is pretty general in nature. We consider a public buildings would include publicly owned buildings
(federal, state, or local) such as offices, community or town halls, schools , and nature centers etc... Some privately
owned buildings such as churches that are used for public events could also be considered under this. We have never
considered a privately owned retail business as a public building if is not used for public events. The buffer distance
would not apply but they would be required to receive the neighbor notice.
Greg Caldwell Environmental Scientist Missouri Department of Natural Resources Water Protection Program P.O. Box 176 Jefferson City, MO 65102 (573)-526-1426 (573)-522-9920 (fax)
From: Mat Rogers [mailto:[email protected]]
Sent: Thursday, October 05, 2017 10:04 AM
To: Caldwell, Greg Subject: CAFO Permit - Valley Oaks Steak Company
Mr. Caldwell:
I am writing because I had an additional question on the CAFO permit for Valley oaks Steak Company and the
Buffer Distance. What is MDNR’s interpretation of what a public building is for the purposes of the Buffer
Distance? The CSR just states that a public building is “A building open to and used routinely by the public for
public purposes” but I don’t know if that is only civic buildings or retail buildings or any businesses? Could you
provide any clarification? Thank you for your help.
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Sincerely,
Mat Rogers
Mat Rogers
Environmental Engineer
Terra Technologies www.terratechnologies.com
314.984.0050 [email protected]
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Caldwell, Greg
From: Caldwell, Greg
Sent: Monday, January 29, 2018 11:50 AM
To: Mat Rogers
Cc: Shane Staten; [email protected]; Robert Walquist; 'David Flick'
Subject: RE: Valley Oaks CAFO Submittal
Mat,
I have reviewed the nutrient management plan (NMP) and other documents submitted on 12/26/17 and have some
additional comments.
• In the NMP, field F005Ghas a P-index rating of “High” with manure being applied at the nitrogen rate (page 174).
In accordance with the Missouri Concentrated Animal Feeding Operation Nutrient Management Technical
Standard manure applied to this field must be done at the phosphorous rate. Please change this field to a
phosphorous rate in the NMP and provide the revision.
• The NMP does not address soil testing protocols. Soil must be sampled at a minimum of every five years. Please
address the soil testing in the NMP.
• Please submit proof that neighbor notice was sent to all property owners within 3000 feet. Certified mail
receipts are appropriate proof.
• The western building along the east side of the drainage is within the 100 year flood map boundary. Please
provide proof that the building is located above the 100 year Base Flood Elevation or consider moving the
building upslope and provide a new map showing the building to outside the 100 year flood boundary.
If you have any questions contact me.
Greg Caldwell Environmental Scientist Missouri Department of Natural Resources Water Protection Program P.O. Box 176 Jefferson City, MO 65102 (573)-526-1426 (573)-522-9920 (fax)
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Caldwell, Greg
From: Mat Rogers <[email protected]>
Sent: Monday, February 12, 2018 9:44 AM
To: Caldwell, Greg
Cc: Shane Staten; [email protected]; Robert Walquist; David Flick
Subject: RE: Valley Oaks CAFO Submittal
Mr. Caldwell:
Thank you for your 1/29/18 comments on the CAFO Operating Permit Application for Valley Oaks Steak Company,
LLC. Please allow this email and the revised documents on Sharefile at
https://terratechnologies.sharefile.com/f/fo889af4-a9e4-495d-a792-6ae953e584b9 to serve as the official response to
those comments.
We have addressed your comments as described below:
• When Field F005G was assessed individually for its P-index rating, the results were “Medium” for each year (see
ValleyOaks_Pindex_F005G.pdf). For some reason when the Missouri P-index report generation tool was run for
all fields, erroneous values were reported. When the report generation tool was re-run for all fields, the
erroneous values did not occur again. The correct values are reported in Table E-4-1 of the revised Nutrient
Management Plan.
• Soil testing protocols have been addressed in Section E 1 and Appendix A of the revised Nutrient Management
Plan.
• Neighbor notice letters were sent to all required parties via Certified Mail on January 30, 2018. Please find the
attached file Ward CAFO_Neighbor Notice Letter_Certified Mail Receipts.pdf which has the Certified Mail
Receipt for each letter.
• The building along the east side of the stream in the site plan only appeared to be in the 100 year floodplain
boundary due to a low resolution background image. Please see the file
180201_ValleyOaks_100yrFloodplainFigure.pdf with an improved background image showing the building is out
of the floodplain.
Additionally it should be noted that the MU web-based Nutrient Management Plan document generator
(http://nmplanner.missouri.edu/tools/mo_doc_gen.asp) malfunctioned at the time of the December 2017 submittal and
the Nutrient Management Plan submitted had to be made by hand from reports that could be generated from Manure
Management Planner and those generated by the MU document generator earlier in the Nutrient Management Plan
creation process. We have since consulted with MU staff and found a workaround allowing the Nutrient Management
Plan review document to be automatically generated from the operation’s Manure Management Planner plan file. As a
result several tables in the Nutrient Management Plan, most notably Tables C-1-1, C-1-2, and F-2-1, were noticed to
change. As a result, we are including a revised Nutrient Management Plan
(180209_NMP_ValleyOaksSteakCo_MDNRReviewerDoc.pdf) that reflects those changes. Please utilize this newly
revised Nutrient Management Plan in your review and disregard the previously submitted version.
If I may provide other information or otherwise be of assistance as you review our response to comments, please do not
hesitate to contact me at (314) 984-0050 or [email protected].
Sincerely,
Mat Rogers
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From: Caldwell, Greg [mailto:[email protected]]
Sent: Monday, January 29, 2018 11:50 AM
To: Mat Rogers <[email protected]>
Cc: Shane Staten <[email protected]>; [email protected]; Robert Walquist
<[email protected]>; David Flick <[email protected]>
Subject: RE: Valley Oaks CAFO Submittal
Mat,
I have reviewed the nutrient management plan (NMP) and other documents submitted on 12/26/17 and have some
additional comments.
• In the NMP, field F005Ghas a P-index rating of “High” with manure being applied at the nitrogen rate (page
174). In accordance with the Missouri Concentrated Animal Feeding Operation Nutrient Management Technical
Standard manure applied to this field must be done at the phosphorous rate. Please change this field to a
phosphorous rate in the NMP and provide the revision.
• The NMP does not address soil testing protocols. Soil must be sampled at a minimum of every five years. Please
address the soil testing in the NMP.
• Please submit proof that neighbor notice was sent to all property owners within 3000 feet. Certified mail
receipts are appropriate proof.
• The western building along the east side of the drainage is within the 100 year flood map boundary. Please
provide proof that the building is located above the 100 year Base Flood Elevation or consider moving the
building upslope and provide a new map showing the building to outside the 100 year flood boundary.
If you have any questions contact me.
Greg Caldwell Environmental Scientist Missouri Department of Natural Resources Water Protection Program P.O. Box 176 Jefferson City, MO 65102 (573)-526-1426 (573)-522-9920 (fax)
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Caldwell, Greg
From: Caldwell, Greg
Sent: Monday, September 25, 2017 9:22 AM
Cc: '[email protected]'
Subject: Valley Oaks Steak Company CAFO application
Mr. Flick
The department’s Water Protection Program has received the August 31, 2017 application for a new Missouri State
Operating Permit for Valley Oaks Steak Company, LLC in Johnson County. After a review of the operating permit
application it has been determined to be incomplete. Please direct your attention to the following comments on the
application.
• The application showed a permit action type for a NPDES General Permit and for a MOGS1 State No-Discharge
General Permit. Please indicate which permit is being applied for and submit the appropriate application fee
($450 for a Class IB NPDES permit or $300 for a Class IB MOGS1 permit.) Please note on the check that it is for
Application #27963.
• Please submit a sealed Part 13 – Engineer Certification of the Form W or provide a document with the name and
seal of a Registered P.E. in Missouri, name and address of the operation, Engineering firm name and address,
date prepared and a statement that the project was designed in accordance with 10 CSR 20-8.300.
• The application indicates that this is not an export only operation. Manure that is planned to be applied to “land
applications areas” which are defined in 10 CSR 20-6.300(1)(B)13 as agricultural land that is under the
operational control of the CAFO owner or operator whether is owned, rented, or leased to which manure is
applied. All land application areas must be included in a Nutrient Management Plan (NMP) developed in
accordance with 10 CSR 20-6.300(3)(G) and submitted to the department. The NMP shall include for each land
application area, planned and alternative crops with realistic yield goal, soil test result that are less than 5 years
old, nitrogen (N) or phosphorous (P) based application, and P index worksheets as appropriate. The NMP must
also include results of manure analysis used to calculate application rates. If no manure analysis is available,
book values may be used. If the operation is to be export only this is not required.
• If applying for the MOG01 permit, complete and submit “Land Application Information Table” (page 3 of the
Form W).
• Please submit a neighbor notice letter with attachment to the department.
The information listed above may be submitted by mail, email, or on a compact disc. Processing of the application will
resume upon receipt of the requested information. If you have any questions contact me.
Greg Caldwell Environmental Scientist Missouri Department of Natural Resources Water Protection Program P.O. Box 176 Jefferson City, MO 65102 (573)-526-1426 (573)-522-9920 (fax)
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Caldwell, Greg
From: Mills, Susan
Sent: Tuesday, January 02, 2018 2:17 PM
To: Faulkner, Jacob; Wray, Gorden; Caldwell, Greg
Subject: Valley Oaks Steak Company MOG010872
Not sure who is working on this permit but we received a payment of $450 and I just wanted to let you know I posted it
in MOCWIS so you can proceed with the permit.
Thanks!
♫ Susie Mills ♪ Administrative Unit Chief Operating Permits Water Protection Program Missouri Department of Natural Resources 573-522-4502
Promoting, Protecting and Enjoying our Natural Resources. Learn more at dnr.mo.gov.
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Faulkner, Jacob
From: Caldwell, GregSent: Tuesday, April 10, 2018 7:03 AMTo: Faulkner, JacobSubject: FW: Exhibit ModificationsAttachments: ValleyOaksSteakCo_RevisedFigures180409.pdf
Greg Caldwell Environmental Scientist Missouri Department of Natural Resources Water Protection Program P.O. Box 176 Jefferson City, MO 65102 (573)-526-1426 (573)-522-9920 (fax)
From: David Flick [mailto:[email protected]] Sent: Monday, April 09, 2018 6:24 PM To: Caldwell, Greg Cc: Mat Rogers; [email protected] Subject: Exhibit Modifications Mr. Caldwell: This email correspondence provides you with an updated set of figures prepared by our engineer Matt Rogers for the Valley Oaks Steak Company permit MOG010872. The figures are updated due in part to having the existing buildings surveyed to determine the distance to the occupied residence owned by the Robert M Chamness Trust per your request and in part because of a change in the designed layout for proposed buildings. The updated figures are attached in the file ValleyOaksSteakCo_RevisedFigures180409.pdf. The significant changes are as follows:
1. A 205’ x 150’ portion of the southern-most barn west of the creek will now be used for CAFO purposes. 2. A 470’ x 138’ portion of the barn directly north of the barn in item #1 will be used for CAFO purposes. 3. Portions of the two barns in items #1 and #2 above (90’ x 150’ and 60’ x 138’ respectively) will be used only for
non-CAFO purposes. 4. Two, rather than three, 720’ x 138’ barns west of the creek have been constructed for CAFO purposes. 5. A 200’ x 60’ barn is proposed north of the cattle barns west of the creek for the purposes of manure storage. 6. The position of the two 1600’ x 138’ cattle barns has shifted but remains out of the 100-year floodplain. 7. The position of two proposed ponds and two non-CAFO process water lagoons are shown on the site plan.
The distances from the two closest CAFO buildings to the occupied residence owned by the Robert M Chamness trust is shown in the Figure 3 to be 2030.0 ft and 2014.6 ft. This figure also shows the location of the 2000-ft buffer distance in relation to the house with a high-resolution aerial photograph. We are also now working on revised manure storage computations for your review and expect to have complete within a few days. If I may provide you with additional information or clarification, please contact me at 913-652-9210.
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Caldwell, Greg
From: David Flick <[email protected]>
Sent: Thursday, April 12, 2018 2:39 PM
To: Caldwell, Greg
Cc: Mat Rogers; Shane Staten
Subject: Manure Computation Valley Oaks
The applicant is working to recompute the storage volume of manure for the referenced project. We anticipate the
need for an additional manure barn(s) and will be providing you revised exhibits and supporting computations with
figures on Monday next week.
Please call me at 913-385-9560 with any questions.
David Flick
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Caldwell, Greg
From: Mat Rogers <[email protected]>
Sent: Tuesday, March 13, 2018 12:17 PM
To: Caldwell, Greg
Subject: Valley Oaks permit question
Greg:
I’m trying to make sure we’ve addressed any concerns for the public meeting. One question that came up from a public
comment is construction permits. I read in the Pub 2351 that a construction permit is needed for “construction or major
modification of an earthen storage structure to hold, convey, contain, store or treat domestic, agricultural, or industrial
process wastewater.” This operation handles all of its manure in solid form, this doesn’t need such a structure. There is
a beef slaughterhouse on site and its plan does show two ponds for wastewater. Do these ponds get caught up in the
requirement for a CAFO construction permit? Thank you for your guidance.
Sincerely,
Mat Rogers Environmental Engineer
Terra Technologies
www.terratechnologies.com 314.984.0050
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Caldwell, Greg
From: Mat Rogers <[email protected]>
Sent: Thursday, March 15, 2018 9:46 AM
To: Caldwell, Greg
Subject: RE: Buffer Distance
Greg:
Thank you for the clarification. I realize Mr. Ward and/or Mr. Flick will only have 5-10 minutes on the agenda and won’t
be specifically responding to public comments. I was just doing my homework to make sure they are aware of the full
spectrum of public comments that might come up.
Sincerely,
Mat
From: Caldwell, Greg [mailto:[email protected]]
Sent: Thursday, March 15, 2018 9:08 AM
To: Mat Rogers <[email protected]>
Cc: [email protected]; David Flick <[email protected]>
Subject: RE: Buffer Distance
Mat,
The MDC comment are are Tipton East. I will have them removed.
The buffer distance comments start of Page 44 by Deich.
We usually give the permittee or their representative about 5-10 minutes on the agenda. As I said earlier we will address
all comments at the end of the permitting process and all who commented will get a response. You can address some if
you want but they will receive a rather extensive response to comments.
Thanks,
Greg Caldwell
Environmental Scientist
Missouri Department of Natural Resources
Water Protection Program
P.O. Box 176
Jefferson City, MO 65102
(573)-526-1426
(573)-522-9920 (fax)
From: Mat Rogers [mailto:[email protected]]
Sent: Tuesday, March 13, 2018 10:20 AM
To: Caldwell, Greg
Subject: RE: Buffer Distance
Greg:
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I had a couple questions about the public comments on file and posted at
https://dnr.mo.gov/env/wpp/cafo/docs/G010872_NNComments.pdf
First, on page 502 is a request from Jennifer Campbell of MDC to talk to you about a CAFO application, but the subject
line of her email was “Cooper County CAFO.” Did Jennifer have concerns about the Valley Oaks application and the
subject line was wrong, or was this comment mis-filed and belongs with another CAFO permit?
Second, I could not find public comments from anyone from the Robert Chamness Trust. Did they make a comment
about the buffer issue and if so, could I see that comment?
Thank you very much for your help.
Sincerely,
Mat
Mat Rogers
Environmental Engineer Terra Technologies
www.terratechnologies.com
314.984.0050 [email protected]
From: Caldwell, Greg [mailto:[email protected]]
Sent: Friday, March 09, 2018 1:37 PM
To: Mat Rogers <[email protected]>
Subject: RE: Buffer Distance
The NMP is good. I routed the permit for public notice of the terms of the NMP today.
The main comments are water/environmental quality concerns, odor/air quality, Powell Gardens, and wildlife. We only
have jurisdiction over the Missouri Clean Water Law and the Clean Water Commissions’ regulations.
The application and comment are available at https://dnr.mo.gov/env/wpp/cafo/ just scroll to the bottom of the page
to the links. The comments is nearly 700 pages.
The way we usually do a public hearing is we start with presentation on the regulatory requirements and permitting
process (about 10 min). If David or Mr. Ward would like to do a 5-10 min presentation let me know and we will put that
on the agenda. The remainder of the time is for public comments.
Greg Caldwell
Environmental Scientist
Missouri Department of Natural Resources
Water Protection Program
P.O. Box 176
Jefferson City, MO 65102
(573)-526-1426
(573)-522-9920 (fax)
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From: Mat Rogers [mailto:[email protected]]
Sent: Friday, March 09, 2018 12:27 PM
To: Caldwell, Greg Subject: RE: Buffer Distance
Greg:
Thank you for contacting me with this comment. Since our conversation on the phone the other day I have been
working to get a better set of figures to show the distance between the Valley Oaks buildings and the house owned by
the Robert M. Chamness trust. My boss, David Flick, informed me yesterday that it has been decided for Mr. Ward to
have a survey done to accurately know the position of the CAFO buildings and therefore the distance to the Chamness
house. I will get the results of the survey to you as soon as possible after they are completed.
Did you have any other official comments regarding the revised nutrient management plan I submitted to you on
2/12/18?
Is there anything I should know in preparation for the public meeting on April 3? I will not be attending but David Flick
will be. What are the main objections people are voicing in their comments? Will we have access to those comments in
order to prepare?
Thank you.
Sincerely,
Mat
Mat Rogers
Environmental Engineer
Terra Technologies www.terratechnologies.com
314.984.0050 [email protected]
From: Caldwell, Greg [mailto:[email protected]]
Sent: Friday, March 09, 2018 11:48 AM
To: Mat Rogers <[email protected]>
Subject: Buffer Distance
Matt,
As we discussed earlier, a comment was made concerning the buffer distance to the house owned by the Robert M.
Chamness Trust. The owner did submit a map he used to measure. He measured from an existing building that is not
proposed to be used by the CAFO so the buffer distance does not apply to that building. The neighbor notice and buffer
distance map submitted does appear to show this residence to be just outside the 2000’ buffer distance, but it is
extremely close. Placement of the buildings is very critical in this instance and therefore, we are requesting the buffer
distance to this residence be surveyed and an exact distance be submitted on the aerial map. Any confinement building
that does not meet the buffer distance requirements would not be permitted to confine animals.
If you have any questions contact me.
Thank you,
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Greg Caldwell
Environmental Scientist
Missouri Department of Natural Resources
Water Protection Program
P.O. Box 176
Jefferson City, MO 65102
(573)-526-1426
(573)-522-9920 (fax)
1
Caldwell, Greg
From: David Flick <[email protected]>
Sent: Monday, April 16, 2018 1:05 PM
To: Caldwell, Greg
Cc: Mat Rogers; Shane Staten; [email protected]
Subject: RE: Manure Computation Valley Oaks
Attachments: ValleyOaksSteakCo_RevisedFigures180413.pdf
Please find the attached revised site exhibits for your review. This now completes the applicant submittal. Call me at
913-385-9560 with any questions.
From: David Flick
Sent: Monday, April 16, 2018 11:27 AM
To: 'Caldwell, Greg' <[email protected]>
Cc: Mat Rogers <[email protected]>; Shane Staten <[email protected]>;
'[email protected]' <[email protected]>
Subject: RE: Manure Computation Valley Oaks
Revised manure computations with exhibit as attached. We will submit later today the final modifications to the prior-
revised site exhibits.
From: David Flick
Sent: Thursday, April 12, 2018 2:39 PM
To: 'Caldwell, Greg' <[email protected]>
Cc: Mat Rogers <[email protected]>; Shane Staten <[email protected]>
Subject: Manure Computation Valley Oaks
The applicant is working to recompute the storage volume of manure for the referenced project. We anticipate the
need for an additional manure barn(s) and will be providing you revised exhibits and supporting computations with
figures on Monday next week.
Please call me at 913-385-9560 with any questions.
David Flick
1
Caldwell, Greg
From: David Flick <[email protected]>
Sent: Monday, April 16, 2018 11:27 AM
To: Caldwell, Greg
Cc: Mat Rogers; Shane Staten; [email protected]
Subject: RE: Manure Computation Valley Oaks
Attachments: ValleyOaksSteakCo_RevisedManureStorageCalculations_180416.pdf
Revised manure computations with exhibit as attached. We will submit later today the final modifications to the prior-
revised site exhibits.
From: David Flick
Sent: Thursday, April 12, 2018 2:39 PM
To: 'Caldwell, Greg' <[email protected]>
Cc: Mat Rogers <[email protected]>; Shane Staten <[email protected]>
Subject: Manure Computation Valley Oaks
The applicant is working to recompute the storage volume of manure for the referenced project. We anticipate the
need for an additional manure barn(s) and will be providing you revised exhibits and supporting computations with
figures on Monday next week.
Please call me at 913-385-9560 with any questions.
David Flick
1
Caldwell, Greg
From: David Flick <[email protected]>
Sent: Thursday, May 03, 2018 10:36 AM
To: Caldwell, Greg
Cc: Faulkner, Jacob; Mat Rogers; Shane Staten
Subject: Re: NMP questions
Confirmed. We will thus exclude 34A and 35A.
David Flick
913-385-9560
On May 3, 2018, at 9:25 AM, Caldwell, Greg <[email protected]> wrote:
David,
I don’t believe that any revision is need to the NMP as all the information is already included in it. I will
revise the spreadable acres in Attachment A to match what is in Acres Cov in Table F-1-1. Revising this in
the terms of the NMP does not constitute a “substantial change” as described in 40 CFR 122(e)(6)(iii) so
a second public notice is not required.
If you want to add fields 34A and 35A to the terms of the NMP this is considered a substantial change
and would require a second 15 day public notice. As it is now, these two fields cannot be used for
manure applications, they must be in the terms of the NMP per EPA regulations. If they want them
added let me know.
Thanks
Greg Caldwell
Environmental Scientist
Missouri Department of Natural Resources
Water Protection Program
P.O. Box 176
Jefferson City, MO 65102
(573)-526-1426
(573)-522-9920 (fax)
From: David Flick [mailto:[email protected]]
Sent: Wednesday, May 02, 2018 8:19 PM To: Caldwell, Greg
Cc: Faulkner, Jacob; Mat Rogers; Shane Staten
Subject: RE: NMP questions
The relationship between the maps from section D-1 of the NMP, Attachment A, and the “Acres Cov” of
Table F-1-1 is as follows:
For Fields 1A through 23B the spreadable acres are shown on the map, Attachment A, and Table F-1-1.
2
For Fields 24A through 94E the map and Attachment A shows the total field acreage rounded to the
tenth of an acre by the Manure Management Planner GIS Tools. Table F-1-1 correctly shows the
spreadable acres.
Due to a large quantity of wetlands and associated setbacks , Fields 34B and 34C were intentionally left
out of the NMP for manure application as noted in figure D-2-2.
Staff preparing the table for Form W overlooked including fields 34A and 35A but they were included in
the NMP.
I can instruct our staff to revise the maps and Land Application Information Table to harmonize them
with the correct spreadable acres, subject to your review and approval.
From: Caldwell, Greg <[email protected]>
Sent: Wednesday, May 2, 2018 3:00 PM
To: David Flick <[email protected]>
Cc: Faulkner, Jacob <[email protected]>
Subject: NMP questions
David,
In reviewing comments one was made regarding that the spreadable acres listed on some of the land
app areas in the NMP are not the same as the spreadable acres listed in Attachment A Terms of the
NMP. Is the acreage listed in yellow on those maps the total acres of the field or the spreadable acres of
the field. Spreadable acres being total acres minus the acreage in the setbacks.
The acreages in Attachment as are the same or less than those listed on the map. If it is spreadable acres
on the maps then this is not a problem.
One other question is what does the Acres Cov represent in table F-1-1. Again these are the same or less
that the acreages on the map.
Thank you,
Greg Caldwell
Environmental Scientist
Missouri Department of Natural Resources
Water Protection Program
P.O. Box 176
Jefferson City, MO 65102
(573)-526-1426
(573)-522-9920 (fax)