Public Comment Sign-In Sheet PUBLIC COMMENT SIGN-IN SHEET
Lewis County Courthouse, 351 N.W. North Street, Chehalis, Wash. Meeting date: 7MT /�1'9/
NAME PHONE REPRESENTING ADDRESS
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SITE SPECIFIC LAND APPLICATION PLAN
FOR NEWAUKUM PRAIRIE UNIT
This Plan is a component of Fire Mountain Farms,
Inc. Application for Coverage Under the
General Permit for Biosolids Management
Permit No. BT9902
RECEIVED
Board of County Commissioners
Location: Lewis County Washington
Site Addresses 349 SR 508 SEP , 2021
(Primary Chehalis, WA 98532
Accesses) :
GPS Coordinates Lat 46° 34' 45.53" N, Long 122° 51 ' 56.31 " W
of Site Entrances:
Sec, Twp, Rge: Sec , 25 & 37, Twp 13N, Rge 02W, WM
Sec 37, Twp 13N, Rge 01W, WM
Water Resource
Inventory Area: 23
County: Lewis
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Fire Mountain Farms,Inc.—Newaukum Prairie Unit SSLAP
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STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
PO Box 47600 • Olympia,WA 98504-7600 •360-407-6000
711 for Washington Relay Service•Persons with a speech disability can call 877-833-6341
April 19, 2021
Dear Interested Party:
The Department of Ecology has entered into an Agreed Order(#19442) with Fire Mountain
Farms on 04/19/2021 to authorize the land application of biosolids at five Lewis County sites:
Big Hanaford(Centralia), Burnt Ridge (Onalaska), Homestead(Onalaska), Lincoln Creek
(Rochester) and Newaukum Prairie (Chehalis). The effective date is 04/19/2021. The agreed
order, appendices and the response to comments can be found on Ecology's website at:
• https://ecology.wa.gov/Regulations-Permits/Guidance-technical-assistance/Biosolids-
permits-forms
You have a right to appeal this Agreed Order to the Pollution Control Hearings Board(PCHB)
within 30 days of the date of receipt of this notice. The appeal process is governed by Chapter
43.21B RCW and Chapter 371-08 WAC. "Date of receipt"is defined in RCW 43.21 B.001(2).
To appeal you must do all of the following within 30 days of the date of receipt of this notice
• File your appeal and a copy of this Agreed Order(#19442)with the PCHB (see addresses
below). Filing means actual receipt by the PCHB during regular business hours.
• Serve a copy of your appeal and this Agreed Order(#19442) on Ecology in paper form -
by mail or in person. (See addresses below.) E-mail is not accepted.
You must also comply with other applicable requirements in Chapter 43.21 B RCW and Chapter
371-08 WAC.
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Fire Mountain Farms, Inc Permit Agreed Order#19442 Issuance
04/19/2021
Page 2
ADDRESS AND LOCATION INFORMATION
Street Addresses Mailing Addresses
Department of Ecology Department of Ecology
Attn: Appeals Processing Desk Attn: Appeals Processing Desk
300 Desmond Drive SE PO Box 47608
Lacey,WA 98503 Olympia, WA 98504-7608
Pollution Control Hearings Board Pollution Control Hearings Board
1111 Israel Road SW PO Box 40903
STE 301 Olympia,WA 98504-0903
Tumwater, WA 98501
To request ADA accommodation for disabilities,or printed materials in a format for the visually
impaired, contact Ecology at(360)407-6831 or ecyadacoordinator@ecy.wa.gov. Persons with
impaired hearing may call Washington Relay Service at 711. Persons with a speech disability
may call TTY at 800-833-6384.
Your name and address appear on the Fire Mountain Farms, Inc interested parties list for
biosolids activities in Lewis County. Thank you for your interest in the health of the
environment.
Sincerely,
lam-
C-8,
Shawnte Greenway
Southwest Regional Biosolids Coordinator
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5/10/2021 Untitled document-Google Docs
May 8th 2021
Department of Ecology
Appeals Processing Desk
300 Desmond Drive St
LaCY, WA 98503
Pollution Control Hearings Board
1111 Israel Road SW
STE 301
Tumwater, WA 98501
Hello to PCHB and Department of Ecology:
I am Allan R Guenther and I reside at 376 State Route 508 Chehalis Wa 98532, Thank you for
giving me the opportunity to comment on the biosolids Agreed Order (19442) with Fire Mountain
Farms.
I have lived here at this address long before Fre Mountain Farms started dumping biosolids at
the Newaukum Prairie Unit. I live just south of the lagoon across the highway from it. My
experience with this site has been less than pleasant for many years, if you look at the records
you will see I have had many conversations with the Department of Ecology , Lewis County and
anyone else that would listen to the problems we have encountered with the dumping of the
material at the site. With these comments I am including four photos that demonstrate some of
the problems I have encountered. I have a lot more photos of the operation however find no
need to send at this time. Folks that have heard me at ecology are Peter Lyon, Lori Davies, Wen
Hoffman, Kyle Dorsey and others. I want YOU to hear that I opposed the way all sites in this
permit are agreed to by the Department of Ecology. Peter Lyon and Laurie Davies have heard
my objections for many years.
It should be known this permit goes towards the issues I have been voicing for many years and
has made significant progress to the many complaints I have voiced to the Department of
Ecology. I will go through the list provided in the permit application
!. STORAGE
I am told that existing storage provisions on the sites will no longer be used, and material will
be accumulated at the site until enough material is at the site to be applied to the fields, the
material CANNOT be stored at the site for more than six weeks. I believe there could be a
schedule devised between Fire Mountain and the producer of the material that would reduce the
need to store it on the application site for six weeks. I know that material stored on the
Newaukum Site stinks to high heaven after staging and fear that six weeks will allow the
material to go anaerobic and stink up the whole area. I am also opposed to being able to apply
the material on top of the surface and am Opposed to the date of application through OCT 31 of
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5/10/2021 1 nti0ed document-GoogieDocs
the year. Take a look at the picture in this package that shows application in mid September at
Newaukum Prairie. Year after year applications have been made when the water was at the
surface this allows the water to run directly into the streams that empty into the Newaukum
River less two mils away. I suggest this material should be tilled into the soil and not applied
after September 1st at any of the sites listed in this permit agreement.
2. LATE SEASON APPLICATION
I appeal the late season application of OCT 31 the growing season is over and material will just
lay on the surface (if not tilled in) and be washed into the streams. Note the picture number five
in this appeal application is in September at Newaukum Prairie. Material should be applied and
tilled into the soil not later than September first.
3. ODORS
I appeal the Item (A) of no action if the orders are bad enough to report than action should be
taken, I have experienced NO action for many years at the Newaukum Prairie Site and have
been told by Peter Lyon that I just live down wind from the site. I appeal and would require
biosolids be tilled into the soil within 6 hours of application. Biosolids delivery can be predicted
to the sites and therefore land applications can be tilled in and reduce any odor quickly
especially if the material has not gone anaerobic from being at the site for more than six weeks.
I am concerned that six weeks storage is too long at the sites.
4. WESTERN WASHINGTON BIOSOLIDS MATRIX
I appeal the the application of biosolids in the timber land unless it can be tilled into the soil,
according to Department of Ecology there is concern about run off into the streams (WAC
173-308-190)
5. TIMBER PRODUCTION
I appeal ANY biosolids application in this application unless it can be tilled into the soil prior to
Sept 1st
6. SOIL SAMPLING
I appeal that soil samples should be done no later than 20 days after application of biosolids by
tilling into the soil. The last biosolids application being no later than September 1st on any of the
sites applied for.
7. GROUNDWATER CHECK
I appeal the ground water check be done by the Lewis County Health Department official or the
Department of Ecology
8. SPILL PREVENTION RESPONSE PLAN
I appeal to see the response plan for each site of this application. Please look at the photos of
spills and tracking on the state highway 508 at the Newaukum Prairie. Picture number 1,2,3 and
4. I am happy that you require a plan but have not seen them , the applicant may have them.
5/10/2021 Untitled document-Google Docs
9. HOLIDAYS
Thank you for the holiday restrictions, this will help the neighborhoods to be able to enjoy their
homes during the holidays. If the procedures are followed that I have appealed odor should be
less around the neighborhoods.
10. TIMING RESTRICTIONS
The restrictions are a benefit of not hearing compression brakes all hours of the night will help.
11. SEPTAGE
I appeal if the septage that is referred to is septage from septic tanks that has not been run
through a sewage treatment plant. I appeal material that has just been treated with lime and
applied to the land. Also appeal if the Septage is not tilled into the soil and applied before Sept
1st at all of these agreed sites.
12. BUFFERS
I appeal the 50 ft buffer be moved to 100 ft and that all material be tilled into the soil prior to
September 1st.
13. NOTIFICATION OF APPLICATION
I appeal that FMF must notify the Lewis County Health Department as well as the Department
of Ecology
14, ANNUAL REPORT
I appeal that each IPL be given an accounting of what material delivered when it was delivered
(date) to a site when it was applied, how applied and how much was delivered.
15. REQUIREMENTS TO SELF REPORT NONCOMPLIANCE
I appeal to the 24 hours if FMF business doesn't know of a non compliance within 12 hours my
opinion is not deligent in their operation. I appeal to a 12 hour notice and that the Lewis County
Health Department would also be notified.
16. BIG HANAFORD UNIT
I appeal the dates of application from April 1st to October 31st at the Big Hanaford site to be
April 1 to Sept 1st and that the biosolids must be tilled into the soi, within six hour of application.
17. BURNT RIDGE UNIT
I appeal the dates of application from April 1 to October 31 at the BR sites to April 1st to Sept 1
and that material must be tilled into the soil within six hours of application.
18. LINCOLN CREEK UNIT
I appeal the dates of April 1 to October 31 at LC unit to April 1 to Sept 1 and that material must
be tilled into the soil within six hours of application.
5/10/2021 Untitled document-Google Docs
19. NEWAUKUM PRAIRIE UNIT
I appeal the dates of April 1 to October 31 at NP unit to April 1 to Sept 1 and that material must
be tilled into the soil within six hours of application.
20. HOMESTEAD UNIT
I appeal the dates of April 1 to October 31 and Homestead Unit to April 1 to Sept 1 and that
material must be tilled into the soil within six hours of application.
In the nearly 20 years of application I have seen and recorded many applications that are being
addressed in this new permit HOWEVER by following my appeals listed,) know our communities
will be better protected. It has been my experience that Ecology has not had enough oversight
and have relied on self management of Fire Mountain Farms. I also believe Ecology must
enforce compliance with the shoreline rules that are now in force in Lewis County and cannot
understand that the county rules that are now in place cannot be followed. The application of
biosolids has to change and this new application has made an attempt to do that.
The rules have changed in Lewis County and I see NO REASON that a grandfathered
applicator should continue to operate for the most part like they have for the past years. KING 5
news came here years ago to report on a violation at Lincoln Creek, Ecology cannot find that
report. The report of the leaks running into peoples yards at Burnt Ridge was tucked away by
Chris Cooper of Lewis County. The County Commissioner upchucking in the ditch of highway
508 next to NP was tucked away. I personally went to Southwest Washington Pollution Control
Board in Vancouver and reported noncompliance; it was tucked away. At that meeting the
board said we don't have a big problem here because the material is tilled into the field when
applied.
Please take a look at the photos included, these are in the past NOW i would suggest that we
get on with the future.
(Sin`��rjely
Guenther---- Allan R Guenther
376 State Route 508
Chehalis, WA
98532
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July 22, 2018
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Lewis County Planning Commission
Chehalis Washington
Dear Commissioners:
Thank you for listening to me at your hearing last week I know you all take your
responsibility serious for the citizens of Lewis County.
In my statements I covered many things about the applications of class B biosolids in our
county. I am sure you know Fire Mountain has about seven application sites in our
county.
I gave you information of what our neighborhood has experienced with the application
application at the Newaukum Prairie located along Hiway 508 and Forest Napavine road.
I believe one of several problems with the application at the Newaukum site is the fact
that class B material has to be stored either in a bunker or now a lagoon until the land
dries out enough to permit application. While the material is stored it continues anaerobic
action when it can be applied the smell is overwhelming to the surrounding area.
A bunker was constructed on the Newaukum site about 2001 with the material being
applied in the late summer the vector smell was so bad it would water your eyes and
cause gagging in one case I ask County Commissioner Dennis Hadler to come out and
observe the operation he proceeded to upchuck in the ditch. My friend was a endontist by
profession and stated to me that is the worst smell I have ever encountered. I live across
the hiway from the Newaukum Prairie site when biosolids were applied during the week
we could not even have a comfortable backyard picnic on the weekend because of the
smell being overwhelming,on several occasions invited guest left because of the smell. I
might add I complained to DOE many times
After several years of application to the fields from the bunker Fire Mountain constructed
a lagoon capacity 3 million gallons I am told. I would ask you to check out if a permit
was ever issued to construct the lagoon. When the lagoon was completed I was ask by
DOE to come down and inspect the lagoon I told DOE I was quite sure it would leak
biosolids into the ground. Wen Hoffman,Lori Davies, Kyle Dorsey from DOE Bob
Thode and myself looked at the lagoon,I stated this lagoon will leak into the aquifer. Bob
Thode stated to the DOE personal present there is no way this will leak because it is lined
with an impervious clay liner. I also made the statement that the Canadian Geese will be
feeding off the fields this fall on the biosolids and grass,
just as pair of geese landed on the field. For several years the goose hunters were
shooting. For several years Fire Mountain continued to apply from the lagoon
applications ranged from big gun sprinklers to liquid tankers and disking in an attempt to
apply under the surface the biosolids just popped up when the clay soil closed back up. I
have to give credit to Fire Mountain they tried several methods of application
HOWEVER the smell was always overwhelming.After several years of operation the
impervious clay liner failed and the ground water was being affected by a leaking lagoon.
(16.1 mg-N/L)THEN Fire Mountain Farms made the decision to install a liner in the
bottom of the lagoon the test at monitoring well before the liner was installed was the
highest ever at test NP-MW025.YOU SHOULD TEST THAT WELL TODAY
I delivered many pictures to the county commission showing these operations and always
got the answer that the DOE was in charge to the operation and the only thing they could
monitor was the health hazards to citizens. I am aware of residents who live near several
to the sites around the county who have complained of the vector(smell)when
application is taking place, (Lincoln Creek,Middle Fork, and Bunker Creek(Tony
Schuller)
This material is applied so thick,I don't believe at an agronomic rate and with only one
person assigned to monitor from DOE,who really knows how many tons per acre are
being applied YEAR AFTER YEAR on the same acreage.The tons applied are reported
by Fire Mountain Farms. I tried to get tonnage reports from DOE many times only
received the reports given too DOE by the applicator.
I can tell you there has been a healthy stand of Douglas Fir trees growing for over fifty
years on the west side of the application site and those trees are all dead now most have
been taken down and cut up for fire wood. On my land 200 feet south of the Lagoon most
of the Cedar trees on my boarder have died. I have observed thousands of birds feeding I
believe on cutworms just north of the lagoon;I believed caused by over application,the
area looked total brown. How many tons on the same ground year after year is applied I
don't think the department of Ecology knows. The reports they get are from the
applicator. (Fire Mountain Farms)
After asking for accountability to our county officials many times Commissioner Shultie
as I understand discovered that Fire Mountain had been putting Kalama Chemical waste
in the lagoon,the DOE said the waste was not a biosolid that could be used for beneficial
use and applied,the lagoon has been shut down for the last three years. I have been told
several times by DOE(Peter Lyon)the contents of the lagoon will not be applied to the
fields and must go to a land fill. The only actions that I have seen at the lagoon are the
pumping of the water that builds up in the winter and is sent to a wastewater facility for
treatment. Thus eliminating the over flow of water to the fields. DOE has required this
action.YOU NEED TO KNOW WHAT IS IN THE KALAMA CHEMICAL
I have documentation that shows Fire Mountain Farms has been receiving Kalama
Chemical since 2001 we have the letter addressed to the DOE Win Hoffman stating they
were receiving the material HOWEVER the report of application and what it is composed
of is not in the report. It shows that year alone they received 2141.6 tons from BF
Goodrich which is now Kalama Chemical. (What is in it and over the years how much
came to Lewis County and NOW the DOE says it cannot be applied to the ground)IT IS
MY UNDERSTANDING THAT FIRE MOUNTAIN FARMS IS APPLYING FOR A
DELISTING OF THE MATERIAL SUPPLIED BY KALAMA CHEMICAL
I believe quite a few of the application sites in Lewis County is on wet ground therefore
application of the material cannot happen until later in the summer, commissioners ask
your self what happens when you get rain all winter 42 "of rain, where does the
remainder of the Class B biosolids go,could it be down stream?An adjoining landowner
said sometimes after a heavy application in the fall of the year the ditch west of the site
after a heavy rain has run black. (Stated by Art Bloom neighbor to the west of Newaukum
site) I invite you to ask the neighbors about the smell in the area during application.
Mr. Bob Thode stated at a hearing on August 7th 2009 that there has been significant
research done on biosolids use over the past 25 years and there is less enviornm ental and
public health risk than with fertilizers and animal manures. I would ask the commission
do you know all the different types of waste that has been applied in Lewis County. It has
not been jus class B biosolids.
I ask why now is the DOE saying Kalama Chemical waste cannot be applied when it has
been applied since 2001.
I testified before the Washington State Senate Committee in the presence of Lori Davies
that I felt ground water was being affected as well as surface water here in our county by
application of biosolids on the several sites that are permitted by DOE for DUMPING in
our county.
I would also like you to know that both Centralia and Chehalis waste water plants
produce CLASS A biosolids from their waste water treatment plants. The dumping of
waste from all over western Washington waste plants is a business and a cost savings to
those plants rather than hauling the material to a dry area in Eastern Washington to be
tilled in. I believe if you look at the profit of using Lewis County as a DUMP the fees out
weigh the profit of the products raised by the farmer on that land.
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