Loading...
HomeMy WebLinkAbout1.15 Submittal Comment Response Letters1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com An Employee-Owned Company MEMORANDUM To: Garfield County Community Development Dept. From: Matthew Langhorst Revised: May 29th, 2015 Project: 482 County Road 315, Silt. Eagle Springs Meat Processing Center Subject: Submittal Comment Reponses Letter The purpose of this letter to is to review the comments received from Chris Hale, Colorado River Fire Rescue, Melvin Gore (USDA), Dan Goin Garfield County Road and Bridge and Steve Anthony Garfield County Vegetation Manager. I. Chris Hale Comments from May 15th 2015 Letter: MIPA 8246 1. If the facilities were not able to obtain potable water from a municipal water source, due to water conservation or other conditions, the facility would either have to terminate operations or find an acceptable water source to replace the current truck delivery system of water supply. The facility owner is in discussions with the City of Rifle to bring City water from the Jail location on Airport Road down to Mamm Creek Road where he could then bring the water up to this facility and home. 2. The USDA certification for the potable water system is a twice a year test for coliforms. This test is currently being completed at the facility for its USDA Custom Exempt status. The current facility is also set up to provide sterilization through a 185 degree water bath/spraying process. 3. Currently the building is not set up with a fire sprinkler system. The fire department has asked for the road from this facility to the owners other greenhouse facility on the adjacent property to be improved to a 20’ all weather road so that they can shuttle water from that facilities fire suppression pond to this location. A secondary fire protection water tank may be necessary to add to this facility once the fire department has finished their full review and we receive formal comments. 4. Per the zoning on the property animals can be raised on the property, but they are not currently being raised there. If pasture land is required in the future a fence will be installed around the three septic system fields on the site to protect the infiltration galleries from possible damage from hooves. 5. The current building permit that is into the county accounts for the Onsite Water Treatment System (OWTS) design for the proposed facility. Currently the facility is functioning under USDA Custom Exempt; this designation requires nearly the same facility guidelines as the USDA Graded facility. The site is already set up for production and is providing USDA Exempt meat. 6. The existing house OWTS system and water supply line are shown on the provided site plan set and discussed within the Utility Report provided to the County. The OWTS system providing service to the home was recently design by Garfield County and installed as the site. The Civil engineering Land surveying 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com waterline is a shared line with the main facility that tee’s off the mainline and run to the house location. 7. The current planned operation hours for the facility in question do no correlate with standard ITE peak hours along collector roads, 7:00am to 9:00am and 4:00pm to 6:00pm. It reasons that if the facilities staff is not arriving during the peak hours on the roadway that they will not add to the peak hour counts. If the County would like, the staff traffic can be added to the Peak Hour traffic as a conservative look at the local traffic conditions. Traffic Counts on Mamm Creek Road were taken from County ADT counts; no physical peak hour traffic counts were available. The ADT per ITE guidelines was then calculated out to an average Peak Hour based on 10% of the overall ADT. II. Colorado River Fire Rescue from May 18th and May 21st, 2015 Letters: 1. The pending building permit packet will need to be supplied to the CRFR for review. 2. The main access road from Eagle Springs Ranch Road will be upgraded to a fire truck rated 20’ wide all weather driving surface. The road needs to be improved from the solar panel farm location on the adjacent property to the processing facility, the remaining existing roads from Eagle Springs Ranch Road are oil pad roads and meet the fire department requirements and are maintained year round. A geotechnical road section design will be completed for the new road surface and subgrade requirements. A map showing the road location has been provided in this packet. 3. A Knox Box per the CRFR requirements will not need to be added to the Mamm Creek Road driveway entrance with the existing electric gate. The addresses for both the house and the processing facility will be changed to Eagle Spring Ranch Road addresses for emergency services purposes. The existing driveway off of Mamm Creek Road will be only used by staff members when the weather conditions allow. All other access will be from the Eagle Springs Ranch Road access point which has a farm gate with a sling chain, no lock. 4. Addresses for both house and facility will be changed to Eagle Springs Ranch Road for emergency service purposes. 5. The CRFR fire marshal as of May 30th, 2015 was still considering a tank and hydrant design requirement for the facility. We are expecting a formal request on Monday the 1st of June, after this submittal packet deadline. III. Melvin Gore Response Email to Kathy Eastley Email: 1. No response comments on items 1-10 within the email, the facility will meet all of the guidelines and requirements that are mentioned with the email. IV. Garfield County Road and Bridge, Dan Goin Email May 26th, 2015: 1. The concrete driveway apron meets the R&B Department’s requirements. V. Garfield County Vegetation Manager, Steve Anthony Letter May 26th, 2015: 1. A professional landscaper will be hired and a weed inventory of the 35 acres will be completed along with a weed map created for County review. This work will be completed as soon as possible, but was not possible to have done by the 29th of May due to the request date. 2. It is estimated that 18,000 SF of area will be disturbed with the installation of the two new OWTS systems for the facility. This will include the construction access across the site to complete the installation. 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com VI. Garfield County Community Development, Planner Kathy Eastley Email, May 28th, 2015: 1. Answers to subsections per comment email: a. The facility will have the ability to butcher the meat onsite and package the product as a final product to send out. This was a new consideration for the site but does not affect the traffic from the site, water usage or facility set up of the site. All USDA guidelines for the butchering process will be met. b. Once the water tank manufacture was verified, the tank sizing could be 100% confirmed. The tanks are Darco 2,000 gallon potable water tanks that are set up in a module system. The tanks are 2,000 gallons; the Utility report will be adjusted to correct this mistake prior to final acceptance of the facility. The plan sheets call out the 2,000 gallon tanks correctly. A detail of this tank system has been attached in the exhibit section. c. The facility will have the ability to process under USDA guidelines Sheep, Goats, Pigs and Cows. If the facility is processing any of these animals under the USDA Exempt status no other work can occur until that product is cleared from the facility and the facility has been sanitized. Only one type of animal can be process at any one time, there will not and cannot be per USDA any processing of different animals at any one time. There are minimum holding times for each type of animal and processing procedures. Please see attached detailed descriptions of each animals processing and flow diagrams within the exhibit section. d. Please see attached processing and flow diagrams for facility project narrative within the exhibit section. 2. Answers to subsections per comment email: a. The following water draws from the facilities 6,000 gallons of potable water storage are conservative numbers for the site. These numbers are per the state water usage guidelines for the OWTS system designs and the Poultry production numbers provided by the owner. House, facility and facility bathroom water consumption will depend greatly on production rates and days of operation per week. These numbers are based on maximum capacity with daily operations, which per the owner’s representative will never occur. i. The single family home on the facilities property per the State of Colorado OWTS system design requirements will utilize 300 gallons per day (2 bedrooms, 2 people per bedroom at 75 gallons per day per person) per State guidelines. ii. The bathrooms within the facility have been designed to 100 gallons per day OWTS system maximum capacity per State guidelines. iii. The butchering room facility drains have been designed to a 500 gallon per day OWTS system maximum capacity per State guidelines. iv. The chicken processing facility on the adjacent property that utilizes water from the storage tanks can process up to 100 chickens a day at a rate of 100 gallons of potable water per day per the owners supplied information. v. Total water consumption per day maximum capacity is 1000 gallons per day. This will allow for 6 days of full capacity operation and house water usage prior to the next water delivery. A float alarm system will be installed within the first main tank that will let the operator know that he has reach the 2,000 gallon limit on the tanks. This will provide for enough operating time after the alarm has gone off to allow for another water delivery. This water system is being considered temporary; the owner is in conversation with the City of Rifle on providing public water to this location along Airport Road. b. A noxious weed inventory map will be provided to the County as soon as possible. The client is aware that there are several type of weeds on the property currently and a detailed plan will need to be laid out to identify the weed types and appropriate spray 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com methods. These methods will need to consider that an organic farm is within proximity of this location, thus this mapping information will take a bit of time to provide. c. Please see attached overall site map from Mamm Creek Road, Eagle Springs Ranch Road and onsite facility roads for access to the property. d. A plan and profile map to accompany the Overall Access map is being worked on at this time. The map will be provided so that the County and CRFR can approve the road grades from Mamm Creek Road to the facility. These roads will all be 20’ wide all weather roads appropriate for semi-truck and fire truck access. Due to the date of the request this information was not available at this comment review submittal date, but is being worked on. e. Easement information for access across Eagle Springs Ranch property from Eagle Springs Ranch Road has been attached within the exhibit section. VII. City of Rifle Comment Letter, Nathan Lindquist May 29th, 2015: 1. The City of Rifle looks to be in support for this facility at this location. We feel that the owner of the facility is providing a greatly needed service to the Garfield County farms that they are missing due to the loss of the old processing plant in Rifle. This facility will save those farmers’ hours of driving time to other locations and substantial financial hardships due to those remote locations. Please let me know if you have questions pertaining to this Land Use comment response letter. All materials stated as being added to the original submittal packet will be completed as quickly as possible and submitted to the County. Thanks, Matthew Langhorst, P.E. High Country Engineering, Inc. 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Mountain Cross Engineering, Inc. (Chris Hale) May 15th Comment Letter: May 15 , 2015 Ms. Kathy Eastley Garfield County Planning 108 8111 Street, Suite 401 Glenwood Springs, CO 81601 MOUNTr\IN CROSS fN<ilNff RING, INC. Civil and Environmental Consulting and Design RE: Review of the Ken Sack Animal Processing Facility: MIP A 8246 Dear Kathy: This office has performed a review of the documents provided for the Major Impact Review application for the Ken Sack Animal Processing Facility. The submittal was found to be thorough and well organized. The following comments were generated: 1. The water system is proposed to be supplied by third party hauling _of water purchased from licensed municipal sources. This source is not typical but the proposed operation is lower than thresholds listed in the LUDC. The concern is that hauling water may not be a reliable source under drought conditions. A condition of approval that operations would terminate if water hauling ceases may be warranted. 2. The Applicant should discuss what means and methods will be employed to test, treat, and maintain the water system to mitigate any contamination. 3. The Applicant should discuss how water for fire suppression is separate and preserved from the potable water storage. 4 . The application materials mentions that animals are raised on the prope1iy. The site plan shows pasture areas where the OWTS are located. The Applicant should discuss how animals will be kept off of the OWTS. 5. The application materials do not mention what existing equipment is on-site compared to what will be necessary. The Applicant should discuss if building pe1mits will be necessary for interior building remodeling for new/additional plumbing, electrical equipment, refrigeration, etc. 6. There is an existing house that shows no connection to the water system or an existing OWTS. The Applicant should identify how this existing house is served with water and verify the location and status of the existing OWTS to mitigate potential conflicts . 826 % Grand Avenue , Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.com Animal Processing Page 2of2 May,2015 7. The Traffic Repmi assumes that the increased traffic would not occur at peak hours and based on this assumption states that increased traffic has no impacts to the peak traffic calculations. This assumption should be elaborated upon. It seems incongruent that increased traffic would not generate some increase in peak hour counts also. The Applicant should explain this in greater detail or revise the calculations to account for increased peak hour traffic. Feel free to call if you have any questions or comments. Sincerely, (§11:: Enginee ing, Clu·is Hale, PE Mountain Cross Engineering. Inc. Civil and Environmental Consulting and Design 826 '!.Gr and Avenue, Glenwood Spri ngs, CO 8160 1 P : 970.945.5544 F: 970.945.5558 www.mountaincross-eng .com 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Colorado River Fire Rescue (Orrin Moon, Fire Marshal) May 18th and 21st Comment Letters: Colorado River Fire Rescue Page | 1 Kathy Eastley May 18,2015 108 8th Street, Suite 201 Glenwood Springs, CO 81601 RE: Ken Sack Animal Processing Kathy: This letter is to advise you that I have reviewed File Number: MIPA-8246, Ken Sack Animal Processing, located at 482 CR 315. After reviewing the application and doing a site visit, I have the following comments to the proposed animal processing facility: 1. The application makes reference to Fire Protection in the application PDF, page 32, item d. 7-109-Fire Protection for building is addressed in the pending building permit application. I do not have access to pending building permit and nothing is shown in this referral packet. Information is needed on proposed fire suppression and or suppression water for the facility. 2. In the application the reference is made of two access roads for the facility. The reference is a main access road that is too steep and narrow for trucks and trailers, and the secondary road which appears to access from Eagle Springs Ranch Road. Nothing in the packet shows the entire secondary road or addresses the width or grade of the road. I attended a site visit last summer with the Ranch Manager and I drove through the ranch this morning to refresh my memory. The access road from Eagle Springs Ranch Road starts out as a 20’ + gravel road that accesses some area well pads. At the solar panels a two track road travels to the west and ties into another road that accesses the existing house and proposed animal Processing Building. The access road from the solar panels to the intersection of the Main road to the buildings is not adequate for a fire department access road. The fire department access road shall be able to support the weight of a fire truck and be all weather driving surface. More information is needed on the proposed secondary access road. Colorado River Fire Rescue Page | 2 3. The Main access road has an electric gate at the bottom of the driveway. We (CRFR) do not have access to that gate at this time in case of an emergency. If this access is to be used for emergency access, then we will require the owner to purchase a Knox Box or Knox padlock for the gate. If the secondary access is gated and locked we will also need Knox box or padlock installed on gate. 4. The existing home has an address of 482 CR 315. Depending on access roads as noted above we will need to establish an address for the Animal Processing Building and possibly the existing house as to the best access road, (Eagle Springs, Mamm Creek Rd). Emergency response could be delayed if we are responding to a Mamm Creek address but actually end up accessing the address from Eagle Springs Ranch Road. This issue needs to resolved. Thank you for allowing me to review this referral and please feel free to contact me with any questions or concerns. . Thank You, Orrin D. Moon, Fire Marshal CRFR. From:Orrin Moon To:Kathy A. Eastley Cc:Mike Morgan ; Orrin Moon Subject:File # MIPA8246, Sack Animal Processing Facility Date:Thursday, May 21, 2015 11:03:39 AM Attachments:image001.png Kathy, I just wanted to let you know that I have reviewed the buildings plans for the existing building and addition of the processing facility. I have determined that based on my referral comments about emergency access and unknown fire suppression outlined in the PDF packet, that fire suppression water up to 18,000 gallons of stored and accessible water may be required. This suppression water is calculated according to NFPA 1142, Water Supplies for Suburban and Rural Fire Fighting. This NFPA calculation is determined by the construction type, building cubic feet, and exposure hazards. Please consider this an addition to my referral comments. Please feel free to contact me with any questions or concerns. thank you, orrin d. moon fire marshal colorado river fire rescue 970-625-1243 orrin.moon@crfr.us 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com USDA (Melvin Gore) May 14th Response Email: From: Gore, Melvin - FSIS [mailto:Melvin.Gore@fsis.usda.gov] Sent: Thursday, May 14, 2015 2:04 PM To: Kathy A. Eastley Subject: RE: Ken Sack Slaughterhouse Yes, I can try to shed some light on our activities. I will answer your questions by in-putting my response after the question. Melvin Gore, DVM, SPHV c/o Colorado Homestead Ranches 741 West 5th St. Delta, CO 81416 Office: (970) 874 - 8637 Cell: (970) 371 - 8093 OFO -- Verifying Food Safety and Animal Welfare every day From: Kathy A. Eastley [mailto:keastley@garfield-county.com] Sent: Thursday, May 14, 2015 12:17 PM To: Gore, Melvin - FSIS Cc: Garner, Roger - FSIS Subject: Ken Sack Slaughterhouse Dr. Gore, As you are aware I am reviewing the land use permit for the ‘animal processing facility’ on Ken Sack’s property. I am interested in understanding the USDA inspection process associated with this use, as well as the general activities that take place during this process. Any response you could provide to the following questions would be great. 1. My understanding is that part of the USDA process is to ‘certify’ that the facility meets certain requirements – can you briefly let me know what those physical requirements are? Our standards were re-issued in 1997/1998. The Agency had regulations that were very stringent if not micro-managing. I will send you a copy of what we currently go by. Our guidelines now are “Each official establishment must be operated and maintained in a manner sufficient to prevent the creation of insanitary conditions and to ensure that product is not adulterated.” There is broad discretion as to what constitutes an “insanitary” condition. 2. Is a USDA inspector required to be on-site for the slaughter/processing in order to be USDA compliant? The USDA inspection appears to be twofold – the facility and the process are part of the inspection, is that correct? Actually, in the interest of sanitation, our duties are one fold: to assure that product(s) are prepared in a manner that prevents adulteration and the product is wholesome. Now to the first part of your question. For the slaughter process to be an inspected product, the Inspector must be on-site for each animal to be harvested so that we can look for diseases in the animal that would be unwholesome and to assure a safe and humane slaughter. Fabrication or the cutting up and preparation of the meat and poultry products, the Inspector does not have to be there the whole time but needs to stop in and assess the sanitation and handling of the meat and poultry. After the slaughter process is completed, the USDA mark of Inspection can be applied. If the carcass of whatever species is not wholesome, it is condemned and disposed of, in this case I saw ESO would be using the landfill. 3. Does the inspector remain on-site for the entire process or are there only certain stages of the process that are inspected? Please see answer #2. The slaughter process, the Inspector is on- site. The further processing or fabrication of products, the Inspector may come by and observe the sanitation performance of the plant. 4. A comment was made that in-edible by-products will be properly disposed of by Waste Management, does any agency regulate the storage of those by-products prior to pick-up for disposal? We regulate storage to the extent that the waste material products do not contaminate or adulterate the inspected and passed product. This Agency used to require a letter from the state stating that transport of inedible materials could be transported to local landfills. The Colorado Department of Agriculture State Veterinarians Office no longer issues these letters to official establishments in Colorado. The local health department, at their discretion, would be responsible to address the transport of inedible and condemned products off-site. 5. Does the USDA regulate by-products – those that may be used for human consumption (the viscera, blood, intestines, etc) and those by-products that may not be consumed but utilized for other products (such as the rendering process, tallow, hides, etc)? Yes, we regulate any meat and poultry product that is produced at an official establishment that is intended for human consumption to assure the products are wholesome and unadulterated. We do regulate some processes such as rendering if it is done on-site as well as edible fats and tallow which may be used in the cosmetic industry. Hides are not in our regulations unless they are prepared for human consumption (fried pig skin or chicherones). There is an outfit from Scottsbluff, NE currently buying and picking up hides from slaughter plants. 6. Are liquid by-products typically disposed of in the septic system? Some research describes the paunch as being disposed, in whole, in the sewer, is this standard? Others describe a process of washing out the paunch and screening the solids for disposal – any comments on these processes and what the county may need to consider? Blood is mostly disposed of in western Colorado. It may go to the local landfill. Paunch contents from ruminants typically go to landfills or used as fertilizer. The paunch, after being washed, can be used as edible by-product. Our interest would be if the holding or storage would create reservoirs of flies or pests. We would assure that this situation would be rectified immediately. 7. How large a role does potable water play in this process? I understand the need for water to clean up after the process but how is the water utilized in the slaughtering? This is a critical question due to the hauling of water to the site for storage in tanks which could result in possible contamination. It is of paramount concern to USDA-FSIS as well. During the slaughter process and in all departments producing food for human consumption, only potable water may be used. There is continual washing of hands, aprons, tools and equipment that may come in contact with edible product. See 416.2(g). In the case of private water systems and wells, we require testing of water for coliforms twice per year. Connection to domestic water entities, we request the test results yearly from that source. We are aware that Eagle Springs Organics (ESO) will be hauling water to the site. They will be required to test the water at a water site in the plant, such as faucet, hoses used for washing, etc, at a minimum of twice per year. If an Inspector suspects an insanitary condition resulting from the water, additional testing may be requested. 416.2(g)(1). 8. Some of the research I’ve done states that sterilization is required for cleaning purposes, any idea on how the sterilization may be affected if the plan is to use hauled water stored in outdoor tanks? Yes, there are some equipment and tools that must be sanitized frequently, especially during the slaughter process. The establishment can either use water that is at 180°F at the nozzle or a chemical sanitizing agent that is acceptable in food producing establishments. Sodium hypochlorite (bleach) or an organic iodine are also used at recommended concentrations. I must emphasize again, USDA-FSIS would only use potable water to formulate an acceptable sanitizing agent. 9. Refrigeration would appear to be necessary. You are correct. The carcasses after slaughter must be held at ≤45°F to prevent any outgrowth of pathogens. 10. My understanding is that they plan on processing cows, but they also want to retain the ability to use the facility for custom cut orders. Is there an issue with slaughtering multiple types of animals in one facility – cows, pigs, elk and deer? Cattle, swine, goats, and sheep can all be slaughtered there if ESO applied for those species in their application for inspection. Deer, elk, and bison (buffalo) may also be slaughtered if ESO has an approved application for “Voluntary Inspection.” These would be ranch raised game animals. We are required to observe all slaughtered animals when the animal is alive to detect some disease conditions. As you may expect, big game animals harvested in the wild state would not qualify for the Federal mark of Inspection because an Inspector does not have the opportunity to observe the animal prior to slaughter. An official establishment may also apply to conduct “custom-exempt” slaughter operations. This situation would be in the case of a person bringing in an animal for slaughter and processing for their own use. In this case, the animals are identified as “custom” animals and the Inspector is not on-site during the total process. In such cases, an USDA-FSIS Inspector also performs a yearly review to check the water certificates, verified handling of the inedible products, written plans that address that all bovines were able to stand and move on their own, and some other items to assure that an official establishment is not handling animals that are unfit for human consumption. This is a record review process mostly but facilities are checked over as well. Any assistance you can provide in this review would be very helpful in understanding the land use. Thank you. I have included the section from our Regulations that are discussed in this email. The Regulation is 9 CFR 416. I also high-lighted some of the concerns you asked about. Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 keastley@garfield-county.com 9 CFR § 416.1 General rules. Each official establishment must be operated and maintained in a manner sufficient to prevent the creation of insanitary conditions and to ensure that product is not adulterated. § 416.2 Establishment grounds and facilities. (a)Grounds and pest control. The grounds about an establishment must be maintained to prevent conditions that could lead to insanitary conditions, adulteration of product, or interfere with inspection by FSIS program employees. Establishments must have in place a pest management program to prevent the harborage and breeding of pests on the grounds and within establishment facilities. Pest control substances used must be safe and effective under the conditions of use and not be applied or stored in a manner that will result in the adulteration of product or the creation of insanitary conditions. (b) Construction. (1) Establishment buildings, including their structures, rooms, and compartments must be of sound construction, be kept in good repair, and be of sufficient size to allow for processing, handling, and storage of product in a manner that does not result in product adulteration or the creation of insanitary conditions. (2) Walls, floors, and ceilings within establishments must be built of durable materials impervious to moisture and be cleaned and sanitized as necessary to prevent adulteration of product or the creation of insanitary conditions. (3) Walls, floors, ceilings, doors, windows, and other outside openings must be constructed and maintained to prevent the entrance of vermin, such as flies, rats, and mice. (4) Rooms or compartments in which edible product is processed, handled, or stored must be separate and distinct from rooms or compartments in which inedible product is processed, handled, or stored, to the extent necessary to prevent product adulteration and the creation of insanitary conditions. (c) Light. Lighting of good quality and sufficient intensity to ensure that sanitary conditions are maintained and that product is not adulterated must be provided in areas where food is processed, handled, stored, or examined; where equipment and utensils are cleaned; and in hand-washing areas, dressing and locker rooms, and toilets. (d) Ventilation. Ventilation adequate to control odors, vapors, and condensation to the extent necessary to prevent adulteration of product and the creation of insanitary conditions must be provided. (e) Plumbing. Plumbing systems must be installed and maintained to: (1) Carry sufficient quantities of water to required locations throughout the establishment; (2) Properly convey sewage and liquid disposable waste from the establishment; (3) Prevent adulteration of product, water supplies, equipment, and utensils and prevent the creation of insanitary conditions throughout the establishment; (4) Provide adequate floor drainage in all areas where floors are subject to flooding-type cleaning or where normal operations release or discharge water or other liquid waste on the floor; (5) Prevent back-flow conditions in and cross-connection between piping systems that discharge waste water or sewage and piping systems that carry water for product manufacturing; and (6) Prevent the backup of sewer gases. (f) Sewage disposal. Sewage must be disposed into a sewage system separate from all other drainage lines or disposed of through other means sufficient to prevent backup of sewage into areas where product is processed, handled, or stored. When the sewage disposal system is a private system requiring approval by a State or local health authority, the establishment must furnish FSIS with the letter of approval from that authority upon request. (g) Water supply and water, ice, and solution reuse. (1) A supply of running water that complies with the National Primary Drinking Water regulations (40 CFR part 141), at a suitable temperature and under pressure as needed, must be provided in all areas where required (for processing product, for cleaning rooms and equipment, utensils, and packaging materials, for employee sanitary facilities, etc.). If an establishment uses a municipal water supply, it must make available to FSIS, upon request, a water report, issued under the authority of the State or local health agency, certifying or attesting to the potability of the water supply. If an establishment uses a private well for its water supply, it must make available to FSIS, upon request, documentation certifying the potability of the water supply that has been renewed at least semi-annually. (2) Water, ice, and solutions (such as brine, liquid smoke, or propylene glycol) used to chill or cook ready- to-eat product may be reused for the same purpose, provided that they are maintained free of pathogenic organisms and fecal coliform organisms and that other physical, chemical, and microbiological contamination have been reduced to prevent adulteration of product. (3) Water, ice, and solutions used to chill or wash raw product may be reused for the same purpose provided that measures are taken to reduce physical, chemical, and microbiological contamination so as to prevent contamination or adulteration of product. Reuse that which has come into contact with raw product may not be used on ready-to-eat product. (4) Reconditioned water that has never contained human waste and that has been treated by an onsite advanced wastewater treatment facility may be used on raw product, except in product formulation, and throughout the facility in edible and inedible production areas, provided that measures are taken to ensure that this water meets the criteria prescribed in paragraph (g)(1) of this section. Product, facilities, equipment, and utensils coming in contact with this water must undergo a separate final rinse with non- reconditioned water that meets the criteria prescribed in paragraph (g)(1) of this section. (5) Any water that has never contained human waste and that is free of pathogenic organisms may be used in edible and inedible product areas, provided it does not contact edible product. For example, such reuse water may be used to move heavy solids, to flush the bottom of open evisceration troughs, or to wash antemortem areas, livestock pens, trucks, poultry cages, picker aprons, picking room floors, and similar areas within the establishment. (6) Water that does not meet the use conditions of paragraphs (g)(1) through (g)(5) of this section may not be used in areas where edible product is handled or prepared or in any manner that would allow it to adulterate edible product or create insanitary conditions. (h) Dressing rooms, lavatories, and toilets. (1) Dressing rooms, toilet rooms, and urinals must be sufficient in number, ample in size, conveniently located, and maintained in a sanitary condition and in good repair at all times to ensure cleanliness of all persons handling any product. They must be separate from the rooms and compartments in which products are processed, stored, or handled. (2) Lavatories with running hot and cold water, soap, and towels, must be placed in or near toilet and urinal rooms and at such other places in the establishment as necessary to ensure cleanliness of all persons handling any product. (3) Refuse receptacles must be constructed and maintained in a manner that protects against the creation of insanitary conditions and the adulteration of product. § 416.3 Equipment and utensils. (a) Equipment and utensils used for processing or otherwise handling edible product or ingredients must be of such material and construction to facilitate thorough cleaning and to ensure that their use will not cause the adulteration of product during processing, handling, or storage. Equipment and utensils must be maintained in sanitary condition so as not to adulterate product. (b) Equipment and utensils must not be constructed, located, or operated in a manner that prevents FSIS inspection program employees from inspecting the equipment or utensils to determine whether they are in sanitary condition. (c) Receptacles used for storing inedible material must be of such material and construction that their use will not result in the adulteration of any edible product or in the creation of insanitary conditions. Such receptacles must not be used for storing any edible product and must bear conspicuous and distinctive marking to identify permitted uses. § 416.4 Sanitary operations. (a) All food-contact surfaces, including food-contact surfaces of utensils and equipment, must be cleaned and sanitized as frequently as necessary to prevent the creation of insanitary conditions and the adulteration of product. (b) Non-food-contact surfaces of facilities, equipment, and utensils used in the operation of the establishment must be cleaned and sanitized as frequently as necessary to prevent the creation of insanitary conditions and the adulteration of product. (c) Cleaning compounds, sanitizing agents, processing aids, and other chemicals used by an establishment must be safe and effective under the conditions of use. Such chemicals must be used, handled, and stored in a manner that will not adulterate product or create insanitary conditions. Documentation substantiating the safety of a chemical's use in a food processing environment must be available to FSIS inspection program employees for review. (d) Product must be protected from adulteration during processing, handling, storage, loading, and unloading at and during transportation from official establishments. § 416.5Employee hygiene. (a) Cleanliness. All persons working in contact with product, food-contact surfaces, and product- packaging materials must adhere to hygienic practices while on duty to prevent adulteration of product and the creation of insanitary conditions. (b) Clothing. Aprons, frocks, and other outer clothing worn by persons who handle product must be of material that is disposable or readily cleaned. Clean garments must be worn at the start of each working day and garments must be changed during the day as often as necessary to prevent adulteration of product and the creation of insanitary conditions. (c) Disease control. Any person who has or appears to have an infectious disease, open lesion, including boils, sores, or infected wounds, or any other abnormal source of microbial contamination, must be excluded from any operations which could result in product adulteration and the creation of insanitary conditions until the condition is corrected.   1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Garfield County Road and Bridge (Dan Goin, Dist. 3 Foreman) May 26th Comment Letter: From:Dan Goin To:Kathy A. Eastley Subject:RE: Ken Sack Animal Processing Date:Tuesday, May 26, 2015 7:17:26 AM Kathy This driveway has been updated with a concrete apron so it meets standards so I they should be good to go on this one. Dan Goin District 3 Foreman Garfield County Road and Bridge 0298 CR 333A, Rifle CO 81650 970-625-8601 From: Kathy A. Eastley Sent: Thursday, May 21, 2015 10:46 AM To: Dan Goin Subject: Ken Sack Animal Processing Good morning Dan, Have you had a chance to look at the application for the slaughterhouse on CR 315? You should have received an email in late April asking for comments from Road & Bridge on the request. Please let me know if you have any questions. Thank you. Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 keastley@garfield-county.com 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Garfield County Community Development (Steve Anthony, County Vegetation Manager) May 26th Comment Letter: Garfield County Vef.!efation Manaf.!ement May 26, 2015 Kathy Eastley Garfield County Community Development Department RE : Ken Sack Animal Processing Facility MIPA-8246 Dear Kathy , Thank you for the opportunity to comment on this permit. Noxious weeds map & inventory Staff requests that the applicant provide a nox ious weed map and inventory of all Garfield County listed noxious weeds for the 35 acre parcel to also include the easement with the water tanks. The current county noxious weed list is attached. Of particular concern on this site is Russian knapweed . On the site plan the applicant states that the "site weed analysis and mitigation to be reviewed with the County Vegetation Manager in the spring of 2015. Current site conditions are not conducive to a accurate analysis and remediation efforts." Weed management plan Please provide a weed management plan that will address the treatment of any inventoried nox ious weeds found on site. Revegetation Please quantify the surface area of disturbance , in terms of acres or square feet , created by this project that will require immediate reseeding . Please let me know if you have any questions. Sincerely , Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 2060 Rifle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970-625-5939 GARFIELD COUNTY NOXIOUS WEED LIST Common name Leafy spurge Russian knapweed Yellow starthistle Plumeless thistle Houndstongue Common burdock Scotch thistle Canada thistle Spotted knapweed Diffuse knapweed Dalmatian toadflax Yellow toadflax Hoary cress Saltcedar Saltcedar Oxeye Daisy Jointed Goatgrass Chicory Musk thistle Purple loosestrife Russian olive Also State Listed species: Absinth wormwood Scientific name Euphorbia esula Acroptilon repens Centaurea solstitalis Carduus acanthoides Cynoglossum officinale Arctium minus Onopordum acanthium Cirsium arvense Centaurea maculosa Centaurea diffusa Linaria dalmatica Linaria vulgaris Cardaria draba Tamarix parviflora Tamarix ramosissima Chrysanthemum leucantheum Aegilops cylindrica Cichorium intybus Carduus nutans Lythrum salicaria Elaeagnus angustifolia Artemsia absinthium 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Garfield County Community Development (Kathy Eastley, Senior Planner, May 29th Email Comment Letter: 1 Matt Langhorst From:Kathy A. Eastley <keastley@garfield-county.com> Sent:Thursday, May 28, 2015 12:19 PM To:Matt Langhorst; Karl J. Hanlon Cc:Tamra Allen Subject:Ken Sack Good afternoon Matt,  Thank you for the site visit, it was very informative.  I have a few comments based upon what we learned yesterday:    1. The application must be amended based upon the following information:   a. The product will be butchered and packaged at the site as opposed to what is described in the  application which states that the product will be transported to the butcher shop in the City of Rifle  where it would be cut and packaged;  b. The water tanks are 2,000 gallons each as opposed 2,500 gallons are erroneously noted in the  application;  c. The site will process swine, sheep and goat as well as cattle (fowl is processed on the adjacent property  and is not USDA certified);  d. Revise and expand the project narrative to accurately describe the activities on the property as well as in  the animal processing facility;    2. Supplemental materials  a. Provide water usage numbers from the facility, the single family home and any other activity that is  proposed to use water from the water storage tanks (page 4 of the utility report indicates that “These  manifolds send water out to the steel building, irrigation system and the home on the site.”), and fire  protection if any is proposed.  The numbers provided in the application materials related to the  processing appear to be low,and the addition of different animals for processing may affect the amount  of water utilized, particularly the fowl.  This information is critical in determining that adequate physical  water can be provided to serve the proposed use.  b. Provide a noxious weed inventory;  c. Provide a map which indicates the proposed access to the facility;  d. Provide plans and profiles of the proposed access to the facility;  e. Provide easement documentation regarding Eagle Springs Ranch Road.    Staff is currently unable to determine that the proposed use meets the minimum standards contained in the LUDC,  particularly regarding access and water.    We are awaiting updated fire district comments (regarding water storage for fire protection and access issues), as well  as comments from the Environmental Health department.  As you are aware the Planning Commission hearing is on  June 10th therefore any information to be considered in the review needs to be submitted no later than May 29th.    Thanks and let me know if you have any questions.    Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 Phone: 970-945-1377 ext. 1580 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com City of Rifle (Nathan Lindquist) May 29th Email Comment Letter: city of Rifle From: Nathan Lindquist [nlindquist@r1fleco.org] sent: Friday, May 29, 2015 1:26 PM To: Kathy A. Eastley Cc: Tamra Allen subject: RE: Ken sack Animal Processing Thanks Kathy, we don't have any specific comments on this. It's a good use of the property_.if its done the right way, obviously, which we trust the county will ensure. Page 1 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com EXHIBITS Manway Extensions, Blank Cover, and Interconnect Details NOTES: 1. MODULES MAY BE FITIED WITH A MANWAY EXTENSION, OR A SPOOL EXTENSION WITH A BLANK CO VER. 2. TANK TO EXTENSION CONNECTION INCORPORATES A FOAM RUBBER GASKET AND 12 STAINLESS STEEL BOLTS. 3. HINGED MANWAY COVER IS SUPPLIED WITH A DUST SEAL AND LOCKING HASP ASSEMBLY. MANWAY EXTENSION WITH HINGED LOCKING COVER 11" 90 " TALL 90" WIDE Darco Inc. All Rights Reserved Reviision 03/25/09 40" TO BOTTOM OF OVERLAPPING COVER ATTACHED DUST SEAL BLANK COVER SS BOLT SS CUPPED WASHER~ RUBBER SEAL WASHER~ MANWAY SPOOL EXTENSION FLANGE GASKET RUBBER INTERCONNECT SEALING SLEEVE BRASS NUT ~ SS BOLT SS CUPPED WASHER I BLANK COVER & SPOOL FLANGE SEAL WASHER---- MANWAY FLANGE GASKET TANK BRASS ---------I INSERT MANWAY FLANGE NUT & OCTANK UPPER & LOWER MODULE INTERCONNECT DETAIL HEAVY BLACK LINE INDICATES MIDPOINT OF PIPE MODULE 1 MODULE 2 8" SCH. 40 INTERCONNECT PIPE Eagle Springs Meats Answers to questions    Cows – Beef   See attached flow Diagram  Cows shall be walked over to facility from Eagle Springs Organic herds.  If we are processing cattle for other ranchers, the cattle will be brought  to Eagle Springs via Eagle Springs main entrance.  The animals shall be  placed into our pens (pens can hold up to 20 head).    Since we are dry aging our beef, beef will hang for min of 14 days.  The maximum number of hanging cattle is 40 every 14 days.  It takes 40 minutes to process a cow from live to hanging, with 2 to 4  employees.  Further processing shall be done off site at Eagle Springs  Meats in Rifle.  We anticipate using 3‐4 gallons of water per cow. Our 6,000 gallons of  water will be refilled as needed.  Pigs, Goats or Sheep  See attached Flow Diagram  Pigs, goats or sheep will be walked to the facility from Eagle Springs  Organic herds.  If we are processing  pigs. Goats or sheep for other ranchers, they will  be brought to Eagle Springs via Eagle Springs main entrance.  The  animals shall be placed into our pens (pens can hold up to 40 head).    It takes 20 minutes to process a pig, goat or sheep with 2 employees.  We anticipate using 4 gallons to process a pig, 3 or less for goat and  sheep.    Poultry Processing  We can process 100 chickens a day using 100 gallons of water.  Two to 3 employees.    We expect that initially we will have USDA inspection 1 to 2 days a  week.  Will increase if our meat sales warrant.  The 6,000 gallons of water is more than sufficient to meet our needs for  a long time.  We would like to eventually get City of Rifle water brought  to our property from the County.  We are now discussing renewal of an easement across the ranch by  URSA, which will include their improving the “slaughterhouse road” to  accommodate their trucks or their improvement of existing roads near  solar.  Either way, the roads will be improved per Oren’s request.  Under USDA, we are considered a small plant.  We anticipate that all  processing will be done under USDA inspection.          Eagle Springs Meats 05/04/2012 Version; Supersedes all other versions Process Flow Diagram 1. Receiving Live Cattle 2. Stunning / Bleeding OR Shooting/Bleeding 3. Head / Shank Removal 5. Skinning 8. Splitting 9. Trim Zero Tolerance 10. Final Wash 12. Chilling 6. Evisceration 4. Head Discard Head Meat Not Saved 7. Variety Meats Processing 9. Trim Zero Tolerance (Performed concurrently with step 7) 11. Lactic Acid Spray 11. Lactic Acid Spray CCP 1B CCP 2B CCP 2B Process Category: Slaughter Product: Beef 13.Receiving lactic acid 14 Storage Lactic acid Pork, Sheep, Goat Slaughter Model 01/26/2006 Version; Supersedes all other versions Process Flow Diagram Process Category: Slaughter Product: Pork, sheep, goats 1. Receiving Live Animals 2. Stunning / Bleeding OR Shooting/Bleeding 3. Head Removal (optional) 5. Skinning 9. Splitting (optional) 10. Trim Zero Tolerance 11. Final Wash 12. Chilling 7. Evisceration 8. Variety Meats Processing (optional) 10. Trim Zero Tolerance (Performed concurrently with step 8) CCP 1B 6. Scalding / Dehairing CCP 1B Slaughter, Poultry Model 09/12/2008 Version; Supersedes all other versions Process Flow Diagram Process Category Slaughter Products: Chicken, Roasters, Pheasants, Turkeys,duck, geese 2. Receiving/Holding Live Poultry 3.Unloading/hanging/ stunning/killing/bleeding 5. Scalding/picking/ singeing & washing/hock 8. Evisceration/ presentation 7. Oil gland removal/neck breaking/venting/opening/ feet removal 14. Packaging and labeling 15. Finished product storage 1. Receiving Packaging Materials and wax 13. Storage of packaging materials and wax 16. Shipping or retail 9.Lung/crop /head /neck removal removal/harvest 11. Final wash/ Zero Tolerance 10. Liver/heart/ gizzard: harvest/peel 12 Chilling & cold- storage: carcass/neck/giblets 6. Neck cutting 4. Waxing for feather removal CCP 1B CCP 2B 85777912/31/2014 09:21:16AM Page 1of4 Jean Alberico, Garfield County, Colorado Rec Fee: $26.00 Doc Fee: $0.00 eRecorded Recording requested by: After :recording, return to: Karl Jo Hanlon, Karp Neu 1-fanlon PC 201 14th Street, Suite 200 Glenwood Springs, CO 81601 ACCESS EASEM lj:NT AGREKl\1ENT AND DEED This ACCESS EASEMENT AGREEMENT AND DEED ("Deed") is made this 16th day of December, 2014 by Eagle Springs Organic, LLC ("Eagle Springs") in favor of Ken Sack ("Sack"). WHEREAS, Eagle Springs is the owner of certain real property located in Garfield County, Colorado as is more particularly described on Exhibit A attached hereto and incorporated herein by this reference ("ES Parcels"); and WHEREAS, Sack is the mvner of adjacent real property located in Garfield County, Colorado known as Garfield County Assessor parcel number 2179-181-00-681 ("Sack Parcel"); and WHEREAS, Sack desires to operate a rneat processing facility on the Sack Parcel and to have legal right to access the ES Parcel to move livestock kept thereon to the meat processing facility on the Sack Parcel; and ·wHEREAS, Eagle Springs desires that Sack and his employees and agents benefit from a non-exclusive easement for ingress to, egress from, and travel over and across the ES Parcels to access the meat processing facility on the Sack Parcel. NOW THEREFORE, for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties agree as follows: 1. K~£it§.}§. The foregoing recitals are incorporated by reference herein. 2. Grant of Easement Eagle Springs hereby grants and conveys to Sack his heirs and assigns for so long as a meat processing facility is operated on the Sack Parcel a non- exclusive easement for reasonable ingress, egress, and travel upon and across the ES Parcels including but not limited to delivery of livestock in furtherance of the meat processing facility operations on the Sack Parcel (the "Easement"). 3. I~rm..in~tj_g_n. In the event that Sack ceases to operate a meat processing facility on the Sack Parcel, the Easement shall tenninate. If requested by Eagle Springs, a Tennination of Easement shall be executed and recorded by Sack. Page 1 of2 857779 12/31 /201409:21:16 AM Page 2 of 4 Jean Alberico, Garfield County, Colorado Rec Fee: $26.00 Doc Fee: $0.00 eRecorded 4. NeceS§.fil.Y_""'&_(fts and Further Assurances. Eagle Springs agrees to negotiate grant of a like easement to any successor or assign of the meat processing operations on the Sack Parcel with any such successor or assign. 5. Autho[iJy_,_ The undersigned for Eagle Springs represents and warrants that he has the full right and lawful authority to enter into this Deed and to bind Eagle Springs. IN \VITNESS WHEREOF, the Parties have executed this easement on the date set forth above. STATE OF COLORADO ) ) SS. COUNTY OF GARFIELD ) Subscribed and sworn to before me this ~day of December, 2014, by Ken Sack as a Member of Eagle Springs Organic, LLC. WITNESS my hand and official sea1. STATE OF COLORADO ) ) SS. COUNTY OF GARFIELD ) Subscribed and sworn to before me this \~\iay of December, 2014, by Ken Sack. Page 2 of2 857779 12/31 /201409:21:16 AM Page 3 of 4 Jean Alberico, Garfield County, Colorado Rec Fee: $26.00 Doc Fee: $0.00 eRecorded Kxh.ibit A Access East.:rru:nt Agn::ement and Deed Garfield County Assessor Parcel Nos: 2179-174-00-686 Section: 17 Township: 6 Range: 92 SEC 16: PT OF THE SWSW EXCEPT A TR CONT 6.28 AC. SEC 17: SvVNE, SENW, E2SW, SEl/4 SWSENE. EXCEPT A TR CONT 57.80 AC AS DESC IN BK 1231 PG 38.SEC 17 S\VNW W1/2S\V EXCEPT A TR CONT 15.37 AC AS DESC IN BK 1231 PG 38. EXCEPT A TR CONT 8.479 AC AS DESC IN WEINRErS SUB EXEMPTION BK 1362 PG 291. SEC 18: SENE(NET 38.05 AC) LYING NE OF lVIULTI TRINA_ DITCH, N2SE(NET 46.85 AC) LYING NE OF CO RD 315, S\VNE(NET 37,94 AC) LYING N OF CO RD 315, EXCEPT A TR OF LAND CONT 9,39 AC AS DESC IN BK 1231 PG 38. SEC 18 S\VNE (NET 37.94 AC) LYING N OF CO RD 315; SENE (NET 1.95 AC) LYING SW OF THE NE\V MULTI TRINA DITCH. EXCEPT A TR OF LAND CONT 35.95 i\C AS DESC IN BK 1432 PG 61. ALSO A TR OF LAND SITUATED IN THE SWNE AND THE SENE OF SEC 18 AND THE SWNW SENW SWNE SWSENE SE OF SEC 17. EXCEPT ATR OF LAND CONT 41.80 AC AS DESC IN BK 1441PG16 AND CORRECTED BK 1464 PG 279. EXCEPT A TR OF LAND CONT 35.15 AC AS DESC JN BK 1531 PG 39L ALSO A TR OF LAND CONT 19.05 AC THAT O\VNER WANTS TO KEEP WITH THE LARGER PART OF RANCH, THIS STRIP RUNS DOVv'N THE EAST SIDE OF SEC 20 TO CONNECT THE POND TO THE REST OF THE REMAINING RANCH. EXCEPT A TR OF LAND CONT 35.11 AC AS DESC IN BK 1578 PG 334 AND CORRECTED IN BK 158.5 PG 331. EXCEPT A TR OF LAND DESC IN BK 1784/431. EXCEPT THREE TRACTS OF LAND CONT] 10,701+/-AS DESC IN BK 1821/687 AND SURVEY PLAT 2179-174-00-731 Quarter: SE Section: 17 Township: 6 Range: 92 A TR OF LAND IN SESW, EXCEPT A TR. OF LAND CONT .. 266 AC.+/-AS DESC. lN BOUNDARY LINE ADJUSTMENT AFFIDAVIT REC. #791735 AND QCD REC.#791736. 2179-173-00-732 Quarter: SW Section: 17 Township: 6 Range: 92 A TR OF LAND IN THE S\V & NWSE & S2SE Section: 18 Township: 6 Range: 92 A TR OF LAND IN THE NESE Section: 20 Township: 6 Range: 92 A TR OF LAND IN THE SENE & NESE 857779 12/31 /201409:21:16 AM Page 4 of 4 Jean Alberico, Garfield County, Colorado Rec Fee: $26.00 Doc Fee: $0.00 eRecorded 2179-172-00-710 Section: 17 Township: 6 Range: 92 A TRACT OF LAND SITUATED IN SECTION 17 AND 18 CONTAINING 35.11 ACRES 2179-181-00-691 Section: 18 Township: 6 Range: 92 A TR OF LAND SITUATED IN SEC 18 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com An Employee-Owned Company MEMORANDUM To: Garfield County Community Development Dept. From: Matthew Langhorst Revised: June 30th, 2015 Project: 482 County Road 315, Silt. Eagle Springs Meat Processing Center Subject: Submittal Comment Reponses Letter The purpose of this letter to is to review the comments received from Chris Hale, Colorado River Fire Rescue, Melvin Gore (USDA), Garfield County Environmental Health Department and a water usage email from Homestead Meats in Delta Colorado. I. Chris Hale Comments from June 29th, 2015: Email Correspondence 1. The fire suppression pond, location and access will be reviewed by the CRFR. They have requested some small changes to the intake location and hydrant location, but nothing that will affect the overall design of the facility or quantity of water available to them. 2. The site wells will need to be augmented through a West Divide contract to allow for water usage out of the wells for pond/above ground usage. This process is in the works through the permitting and augmentation process. 3. If the County and County Engineer are requesting a fence around the OWTS system fields at this time, the owner of the property will abide by this condition. II. Colorado River Fire Rescue from June 26th, 2015: Email Correspondence 1. More detailed fire hydrant and pond drawings will be worked through with CRFR. The current plans allow for 45,000 gallons plus of water to be located 2’ to 3’ above the intake per the CFRF details for a pond intake structure. HCE will work with CRFR to provide the detailed information that they require for final pond approvals. 2. As per the Access Report a Geotechnical Engineer will be onsite during the construction of the road to make sure that the proposed road section is 100% appropriate with the existing onsite soils. The roadway section design was compiled from a sampling of site soils that were available and consistency in the soils along the entire roadway will need to be verified as will the compaction of the placed material during construction. HCE will also provide a Design Engineer onsite as needed to assure that drainage, alignment and width of roadway are being maintained as per the design and as field conditions regulate. Civil engineering Land surveying 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com 3. There will be no lock added to the main entrance gate. This gate/access is utilized by multiple parties and a lock would hinder that use. If a lock were ever added to the gate it would be a CRFR approved Knox Lock. III. Melvin Gore Response to Kathy Eastley Email, June 23rd, 2015: 1. The sewage disposal system for the waste water leaving the processing room is to be directed to a OWTS system designed to handle the flow from this room, estimated at 300 gallons per day at maximum processing requirements. The BOD/Effluent quality from this room has been confirmed and the information has been sent to All Service Septic. Prior to the Final OWTS system permitting an updated design packet will be submitted and approved through Garfield County. A final system design acceptance letter will be provided to the USDA-FSIS. IV. Garfield County Environmental Health Development, Morgan Hill Letter, June 26th, 2015: 1. Answers to subsections per comment letter: a. The facility owner agrees that the water tank storage and water hauling method is not the ideal situation for the facility. If the facility were to run out of water for any reason the facility would have to shut down until water was made available again, which is not ideal for a business thus the alarms on the tank levels. The water delivery service can have water to the facility within one days’ time, which with the tank alarms for half full tanks, provides enough security in timing that the water delivery company can make their need delivery and the facility can maintain a reliable operation. A long term potable pressurized piped water supply is being investigated for feasibility with the City of Rifle. The extension of the Cities mainline at the airport is being discussed and worked out if possible with the City. b. As stated above, if the facility uses more water than the estimate due to unforeseen circumstances and the facility runs out of stored water, they will have to shut down the facility until water is delivered. Due to the tank alarms, no matter what amount of water is being utilized that day, the alarms will sound and the plant manager will order more water. The owner can only predict the water usage that they see on a standard day; all other usages will be outside of a normal day and will be handled with a water delivery if necessary. Water usages were lowered when the overall water requirements shifted from a combination of the kill room and production room to individual water usages for each room, not a combined number. 2. Answers to subsections per comment email: a. To my knowledge All Service Septic has not requested the effluent information from Mark (plant manager) or Ken Sack (owner) directly. The effluent quality information has now been provided to All Service Septic as of this date. Any revision to the OWTS system design that may follow with the information that was provided will be caught up in the Building Permit process when the OWTS system is officially permitted for. 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com b. The MicroFast system is required by the State of Colorado to have a service contract for the life of the system to ensure that the system is functioning properly. Garfield County does not have a system for regulation on the MicroFast system or other second level treatment systems available to the public. The Owner of the property will need to supply the County the initial 2 year contract for the system that Valley Precast provides upon installation of the system and then also provide the year to year contracts to the County for the remainder of the life of the system. c. A hard pipe connection that is detachable via a union or other method of construction will be attached to the solid waste disposal piping flowing from the building to the tank as per the County request. V. Water usage email provided to Kathy Eastley from Dale Dexter at Homestead Meats in Delta Colorado, June 26th, 2015: 1. Kathy Eastley had requested Homestead Meats provide a water usage quantity for their similar processing procedures from Dale Dexter. a. The response from Dale on their water usage is fairly unusable for a comparison to this facility. As per Dale’s comments they utilize approximately 50,000 gallons of water at their facility during a single month to process 100 head of beef, 65 hogs and 20 lambs. This amount of processing is above and beyond the agreed upon numbers for the proposed facility. Dale also states that they produce other items such as sausage. Upon review of the Homestead Meats website the facility also provides custom cuts on a daily basis for store customers in addition to their actual processing facility in the shop. They also have a store to sell their product to the public. This appears to be a larger facility than the proposed facility with more staff, restrooms for staff in the store, restrooms for the plant staff and other facility options that this processing plant is not requesting or providing for. The Homestead Meats processing facility has machinery onsite for grinding meat, sausage packing, smoking meats, etc. Grinding and packing machines require significant water to clean and the process of producing the sausage also requires water. This facility is hooked to a municipal water supply and Mark the Plant Manager at the proposed facility has stated that if they were hooked to a municipal facility they would be less conservative with their water usage. Maybe all facilities should have limited water so water conservancy is a must. A more defined water usage chart from this facility would need to be reviewed prior to making a comparison or a comparable facility that is run from a limited water supply should be reviewed for comparison. Please let me know if you have questions pertaining to this Land Use comment response letter. Thanks, Matthew Langhorst, P.E. High Country Engineering, Inc. 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Mountain Cross Engineering, Inc. (Chris Hale) June 29th Comment Letter: From:Chris Hale To:Kathy A. Eastley Subject:RE: Ken Sack Animal Processing Date:Monday, June 29, 2015 9:53:30 AM Kathy: I have reviewed the additional material provided for Ken Sack Animal Processing. The review generated the following comments: - The fire suppression pond, location, and access should be reviewed by the Fire Department. - The Applicant should discuss if the site wells allow fire suppression as a use; the Applicant should provide well permits to be used for filling of the fire suppression pond. - A condition should be included to fence off the OWTS from pasture/animal grazing areas. Feel free to call or email with any questions or comments. Sincerely, Mountain Cross Engineering, Inc. Chris Hale, P.E. 826 1/2 Grand Avenue Glenwood Springs, CO 81601 Ph: 970.945.5544 Fx: 970.945.5558 From: Kathy A. Eastley [mailto:keastley@garfield-county.com] Sent: Monday, June 22, 2015 12:48 PM To: Chris Hale; Morgan Hill; Orrin Moon; Gore, Melvin - FSIS Cc: Tamra Allen; Kelly Cave Subject: Ken Sack Animal Processing Good afternoon, Ken Sack has submitted additional materials related to the request for a USDA Animal Processing Facility. You had all reviewed and commented upon the application therefore I would appreciate it if you could review the attached documents to see if your concerns and comments have been adequately addressed. There is a short timeframe for your review so I would appreciate it if you could respond with any comments at your earliest convenience. I do need comments by the end of the day Friday, June 26 th . Thank you and feel free to contact me with any questions. Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 keastley@garfield-county.com 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Colorado River Fire Rescue (Orrin Moon, Fire Marshal) June 26th Comment Letter: From:Orrin Moon To:Kathy A. Eastley Cc:Mike Morgan ; Rob Jones Subject:RE: Ken Sack Animal Processing Date:Friday, June 26, 2015 8:17:47 PM Kathy, I have reviewed the latest changes to the Animal Processing Facility and have the following comment; 1. The latest changes cover my concerns for this facility. I will request that engineered plans be submitted to me on the Fire Pond and Dry Hydrant. I have concerns on the fire hydrant location and the location of the suction pipe and would like to see further detail. 2. The access road from Eagle Springs Ranch Road looks to be adequate in design and structure. I would like to have insurance that the road is built as designed. I am assuming that the engineering firm will have an inspector. 3. I noticed that the entrance gate at the intersection to the entrance road showed no lock. I want to be clear that if this gate locked that we need to have a Knox lock installed for access. Thanks again for allowing me to comment on this referral. Thank you, Orrin D. Moon Fire Marshal Colorado River Fire Rescue 970-625-1243 orrin.moon@crfr.us From: Kathy A. Eastley [mailto:keastley@garfield-county.com] Sent: Monday, June 22, 2015 12:48 PM To: Chris Hale; Morgan Hill; Orrin Moon; Gore, Melvin - FSIS Cc: Tamra Allen; Kelly Cave Subject: Ken Sack Animal Processing Good afternoon, Ken Sack has submitted additional materials related to the request for a USDA Animal Processing Facility. You had all reviewed and commented upon the application therefore I would appreciate it if you could review the attached documents to see if your concerns and comments have been adequately addressed. There is a short timeframe for your review so I would appreciate it if you could respond with any comments at your earliest convenience. I do need comments by the end of the day Friday, June 26 th . Thank you and feel free to contact me with any questions. Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 keastley@garfield-county.com 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com USDA (Melvin Gore) June 23rd Response Email: From:Gore, Melvin - FSIS To:Kathy A. Eastley Subject:RE: Ken Sack Animal Processing Date:Tuesday, June 23, 2015 12:33:37 PM USDA-FSIS is concerned that Federal Regulations are followed, and specifically in this case 9 CFR 416.2(f) “Sewage disposal. Sewage must be disposed into a sewage system separate from all other drainage lines or disposed of through other means sufficient to prevent backup of sewage into areas where product is processed, handled, or stored . When the sewage disposal system is a private system requiring approval by a State or local health authority, the establishment must furnish FSIS with the letter of approval from that authority upon request.” It was the high-lighted sentence that eventually brought Garfield County Planning and Health Departments into review of this project. Without approval of the septic sewerage disposal system by a State or local health authority, USDA-FSIS could not grant inspection of meat and poultry products privileges to Eagle Springs Organics. This being stated, I see two areas of clarification for USDA-FSIS: 1) Will Garfield County require connection of the processing (slaughter and product fabrication) facility to the OWTS prior to issuing a permit for use? and 2) Will the chicken processing facility be connected to the OWTS as part of the permit of use? When Eagle Springs Organics presents your letter of approval of the sewerage/septic system, USDA-FSIS review will start over to ascertain that Federal sanitary standards will be met. One final observation: The engineering reports stated upon occasion that the USDA-FSIS Inspector will be “grading” the carcasses. This is a semantic issue. USDA-FSIS does not grade the slaughtered animals which would place the USDA “Prime,” “Choice,” grades on the carcasses. USDA-FSIS inspects the carcasses for wholesomeness and no adulteration to insure food safety; USDA-FSIS does not involve inspection for quality grades. Have a great day! Melvin Gore, DVM, SPHV c/o Colorado Homestead Ranches 741 West 5th St. Delta, CO 81416 Office: (970) 874 - 8637 Cell: (970) 371 - 8093 OFO -- Verifying Food Safety and Animal Welfare every day From: Kathy A. Eastley [mailto:keastley@garfield-county.com] Sent: Monday, June 22, 2015 12:48 PM To: Chris Hale; Morgan Hill; Orrin Moon; Gore, Melvin - FSIS Cc: Tamra Allen; Kelly Cave Subject: Ken Sack Animal Processing Good afternoon, Ken Sack has submitted additional materials related to the request for a USDA Animal Processing Facility. You had all reviewed and commented upon the application therefore I would appreciate it if you could review the attached documents to see if your concerns and comments have been adequately addressed. There is a short timeframe for your review so I would appreciate it if you could respond with any comments at your earliest convenience. I do need comments by the end of the day Friday, June 26 th . Thank you and feel free to contact me with any questions. Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 keastley@garfield-county.com 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Garfield County Environmental Health Development, Morgan Hill, June 26th, Letter: Garfield County Public Health Department – working to promote health and prevent disease Public Health Garfield County Community Development 108 8th Street Glenwood Springs, CO 81601 Attn: Kathy Eastley June 26, 2015 Hello Kathy, My comments for the Ken Sack Animal Processing facility amendments are as follows: 1. Water Supply a. I stand in support of my earlier comments regarding the supply of water using holding tanks that must be filled on a regular basis. i. The current water supply system of three storage tanks that requires water to be hauled to the slaughterhouse is not a good long-term solution for the life expectancy of this operation. Garfield County Land Use Code requires that a potable water supply be provided that is adequate and of a high enough water quality for consumption by employees; and in this case the processing of meat. We recommend a well be drilled, if possible, that would be tested using the “Deluxe Colorado Package” of the CDPHE Lab Services Division. b. The new estimate on water usage per animal is even lower in the revised updates, indicating that only two gallons per cow of water will be required. While I understand it might be physically possible to use that little of water, this does not allow for the potential to need extra cleaning in the event that animals might be dirty or for other processes requiring water. I recommend significantly increasing the amount of water per animal needed to ensure adequate supply for cleanliness during slaughtering and processing. 2. Wastewater Treatment a. In All Service Septic’s Design Specifications, Carla Ostberg indicates that the applicant still has not provided information regarding effluent quality from the Butchering room. This should be provided to both Carla and the Community Development Department. i. It is unclear as to what sort of materials will actually be entering the second OWTS designed for the actual animal processing facility. On our site visit, we were made aware that the blood, intestinal, and other waste coming from the kill room would not be sent into the OWTS but rather stored and hauled to the landfill. However, our understanding was that the room where meat is processed into various cuts for clients will drain to the septic system. Before we approve the system designed by All Service Septic, all parties involved should be aware of exactly what will be entering the system to know how large it should be sized and what level of secondary treatment is necessary. 195 W. 14th Street Rifle, CO 81650 (970) 625-5200 2014 Blake Avenue Glenwood Springs, CO 81601 (970) 945-6614 Garfield County Public Health Department – working to promote health and prevent disease b. The MicroFAST treatment system proposed for use in the OWTS from the butchering room requires an operation and maintenance contract that they will have with the client. Copies of this contract and maintenance records should be submitted to Garfield County Public Health and Community Development. 3. Solid Waste Disposal a. The piping that comes from the kill room should be connected fully to the tank that will be used to haul solid waste to the landfill, rather than an open air spout that empties into the tank. This will reduce the potential attraction of flies and other pests to this area, as well as the potential for spills. 4. Product Labeling and Sale a. I did not see an update in the application revisions answering my questions about the names of the various components of Mr. Sack’s operations. Several of their listings online indicate that there is a “USDA Meat and Poultry Processing Plant on site” which is not correct as of this date. This must be removed and all mislabeling addressed. b. Eggs that are produced at the farm are being sold in the Farm Fresh Café. Eagle Springs must be a certified egg dealer through the USDA in order to sell eggs at a retail food establishment. Please contact Heather Nara, the current retail food establishment inspector for the Rifle area, with questions at (970) 683-6648. Thank you, Morgan Hill Environmental Health Specialist III Garfield County Public Health 195 W. 14th Street Rifle, CO 81650 (970) 665-6383 1517 Blake avenue, suite 101 Glenwood Springs, CO 81601 970-945-8676  phone 970-945-2555  fax www.hceng.com Water usage email provided to Kathy Eastley from Dale Dexter at Homestead Meats in Delta Colorado, June 26th, 2015: From:ddexter@homesteadmeats.com To:Kathy A. Eastley Subject:Re: Meat Processing and water usage Date:Friday, June 26, 2015 9:12:24 AM Kathy, I don’t have numbers by species. In general, we slaughter and process about 100 head of beef, 65 hogs and 20 lambs per month. On average we use about 50,000 gallons of water per month. We also make other products, such as sausage—these products are not related to the slaughter of these animals. So some of that water is used for those unrelated activities. Hope this helps, Dale 970-874-1145 From: Kathy A. Eastley Sent: Thursday, June 25, 2015 1:25 PM To: ddexter@homesteadmeats.com Subject: Meat Processing and water usage Mr. Dexter, I am a land planner for Garfield County and we are currently reviewing a proposal for a USDA inspected animal processing facility. I am interested in understanding the amount of water used in the process – for holding of the animals to slaughter, clean-up and butchering for cows, goats, sheep, pigs and chickens. Could you provide me any estimates on how much water it takes to process one of each of these animals? I have received varying information – anything from 1 gallon of water to process a chicken to 2 gallons of water to process a cow and am just trying to get a ball- park amount of water needed for a facility. Any information you could provide would be greatly appreciated. Thank you. Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 keastley@garfield-county.com