A request was made by Mr. Charles Guntley, 5010 Hwy. 20, Ukiah, CA, property owner and Mr. Martin Mileck, M&M Feed, 74540 Hill Rd., Covelo, applicant, for a Use Permit to establish a Composting Facility for agricultural, residential and commercial wastes.
The location of the site is about 1 and 1/4 mile northeast of the intersection of Eastside Potter Valley Road and Highway 20, or about 5 miles South of Potter Valley town center. Areas other than Mendocino County from where wastes will be imported are Sonoma, Humboldt, Yolo and Napa Counties.
These wastes are anticipated to consist of manure produced by one or more of the following: chicken ranches, dairies, turkey farms and other agricultural facilities. Some other sources of agricultural biomass are, but not limited to, grape pomace, fly ash from wood waste burners or co-generation facilities, race track bedding, grocery store food waste, restaurant food waste, fishery waste and municipal green waste. The percentage of feed stock may vary on a daily or weekly basis, except that ash, fishery, grocery and restaurant waste shall not exceed 10% each.
The operations area is located on top of a northwest trending ridge line about 700 ft. higher than, and one mile distant from, the east fork of the Russian River to the west and Cold Creek to the south. The compost pad will encompass about 5.5 acres of the 12.5 acre operations area. Under regulations proposed by the California Integrated Waste Management Board, the facility is a "mixed solid waste composting facility."
The facility design capacity is a maximum 50,000 tons per year incoming material, an average of 200 tons per day, producing approximately 133.2 tons of compost per day. Other existing operations indicate that within one to five years expansion of the facility's capacity will occur coinciding with market development.
The composting operation will be a windrow process. Material is processed on an incoming basis. Windrows are anticipated to be approximately 20 ft. wide, 8 ft. high and 250 ft. long. When windrow construction is complete, process water is added to obtain optimum moisture conditions. Experience has shown that a minimum of 2 months to a maximum of 3 months is required to complete the composting process. Testing is then performed to certify that the finished product is within specification with respect to environmental and health standards. Product that meets the requirements is then ready to sell to wholesale customers. [Note: No mention was made about end use of product that doesn't meet requirements.]
Water Quality Issues:
According to the Mendocino Landfill Siting Study Final Report, Potter Valley has the shallowest groundwater (27ft.) of all approved sites with one to ten ground water wells located within 1/2 mi. of the potential site and seasonal springs and creeks located upslope and downslope of the landfill site.
Geotechnical Reports (Patrick Conway: April 1994, September 1994) characterize the site as mountainous terrain, elevation about 1,550 ft., with natural slopes varying from moderate to nearly flat at the composting site, dropping off rapidly into drainage ravines at inclinations between 6:1, 4:1 and steeper. The ravines eventually merge into creeks which drain into the east fork of the Russian River. Water Quality Control Board staff and the County Water Agency commented that rainwater or process water may leach chemicals from feedstock and amendments (some of which are water soluble or toxic), thereby potentially contaminating ground or surface waters. [Note: No mention that the East Fork of the Russian River feeds directly into the Lake Mendocino Reservoir was made in any report pertaining to the project.]
I visited the site 1/2/95. The already constructed pad located on a shale ridge with steep canyons on either side is already stocked with several hundred yards of pomace and other compostable materials. On the site were many orange and brown puddles of leachate. This was several days before our recent 15 inches of rainfall. On the NW edge of the pad (on the edge of a steep bank), was approximately 20 to 50 yards of chicken manure. This once pristine area of ridges and canyons is a WATERSHED. I observed winter streams and run-offs flowing into the river below.
The composting pad will drain into collection ditches around its perimeter. The interior of the pad will be elevated a minimum of 2% above the top of the ditch and collection pond elevations. These ditches will drain two small sediment collection ponds, which in turn drain into two main ponds. Pond sites exhibit 9% to 29% slopes.
The Sept. 1994 Investigation concludes that the revised pond locations appear to be feasible from a geotechnical standpoint but due to "weak and compressible colluvial soils and the potential for downhill creep," stabilization will require excavation, recompaction and drainage. Pond storage capacity is 1.75 times the anticipated storage required for a 25 yr./24 hr. event, almost double the volume necessary to contain all precipitation from a 25 yr/ 24 hr. storm event.
A 100 yr. event has not been anticipated and would require that leachate be discharged after 48 hrs. by irrigating the already rain saturated Guntley land. A 100 yr. event means an event that has a 1% chance of happening each year, not necessarily that the event will only happen every 100 years. Such an event can happen several years in a row.
The compost pad, ditches and ponds will all be lined with one foot of material (obtained on site) having a maximum permeability of 1 millionth cm/s. When conditions are appropriate (i.e. dry weather) it is anticipated that insignificant quantities of leachate will be generated and any drainage will be recycled onto the windrows for moisture conditioning.
Maximum water requirement per ton of feedstock would be approximately 125 gals. At a maximum operation capacity of 200 TPD, total demand (25,000 gals.) at the worst condition including some additional volume (16,000 gals.) for dust control would be approximately 0.126 ac-ft/day. This volume of water would be obtained from water rights presently held by the Guntly Ranch for the East Fork of the Russian River. However, operation of the facility during the rainy season will create a situation where mixing of storm water with the inherent liquids in the windrows will occur. It would be a conservative assumption that at some time storm water will saturate the windrows and begin to carry certain constituents of composting material in suspension.
The design of the compost pad precludes any significant amount of water penetrating the pad itself, consequently surface runoff conditions will occur that have to be adequately managed since it is not anticipated that the windrows will be covered to keep them dry. [Note: at the Board of Supervisors hearing Mr. Mileck stated that the windrows will not be covered due to prohibitive costs.] In addition, during the rainy season, daily inspections will be made of stormwater/leachate collection and containment systems by M&M employees. Dave Koppel, from Dept. of Environmental Health, stated that his office will conduct monthly samplings.
Questions about noise and odor have been raised by neighbors. The Staff Report basically states that most noise and odors will be mitigated due to the distance of residences from the site. "The remote location reduces the number of potential receptors of odors, dust, vectors, noise or visual effects."
The Staff Report For Use Permit in the section under Noise (item 6) says, "Several houses are located on top of the westerly ridge opposite the property entrance, more than 3/4 of a mile (+4,000 feet) from the site." [Note: The Russian River is between the site and the neighbors houses. The Staff Report states the river is 1 mi. from the composting site. There appears to be a discrepancy here. I believe that the River's distance from the site is more accurately 1/2 mi.]
Biological Resources:
The Dept. of Fish and Game and Army Corps of Engineers did not comment on the impacts of road construction on drainages discharging to the Russian River or Cold Creek. Although the Dept. of Fish and Game did not identify adverse impacts to wildlife resources or habitats, The Mendocino County Landfill Siting Study - Final Report states that the Guntly Ranch is inhabited by an elk herd originally "planted" by the Dept. of F&G on public lands to the east. They believe that potential impacts will be mitigated by requiring fencing around the site.
The Planning Commission further finds that, pursuant to the Fish and Game Code, Section 711.4, the project may have a potential adverse impact on wildlife; therefore, the $1275 Dept. of Fish and Game mitigation fee is required.
I have some serious problems here. First, there isn't a farmer in Potter Valley that has been able to "fence-out" the Elk, who simply push over anything in their way. Second, The County Landfill Siting Study states, "rare, threatened, or endangered species were not identified on site." This was established by flying over the site. Cache Creek (less than 30 mi from the site) is the largest winter nesting site, south of the Klamath Basin, of the Bald Eagle. Bald Eagles are regularly seen in Potter Valley. Wild Turkeys love to scratch in compost, no fence will keep them out.
In the hills of Potter Valley live Mountain Lion, Bob Cat, Black Bear, coyote, raccoon, deer, wild pigs, Red Tail Hawk, Coopers Hawk, Sharp-shinned Hawk, Golden Eagles, muskrat, opossum, squirrels and a myriad of rodents. Along the Russian River live osprey, blue heron and snowy egret. Seasonal visitors include mallard, merganser, canvas back ducks and Canadian Geese.
I have personally seen every one of these creatures on my homestead which is less than three miles up-stream from the site. How does a Fish and Game fee of $1275 "mitigate" the impact, or a fence protect these creatures? This seems to be a good place to mention that our County, which has required EIRs for much smaller projects, including compost operations, does not feel it necessary to require an EIR for the M&M Composting Project.
Archaeological/Historical
Sonoma State Archaeological Inventory found the proposed project has the possibility of containing archaeological resources and recommend a survey. The County Archaeological Commission determined that no survey is required.
Having spoken to Indian people, I've learned that Potter Valley was once densely inhabited by the Pomo People, who tended to reside close to the river. Mr. Mileck chose to commence his project without the benefit of permits. He leveled the ridge top, constructed the composting pad, and dumped several hundred yards of compost without the County's blessing. ["Oh Gosh, I'm so sorry, here's my hand, why don't you give it a little slap."] The amount of Valley Oak, or Archaeological Resources on the site will never be known as they have been scraped away and buried under six to twelve inches of an "impermeable" compost pad.
Concerns
Cumulative impacts are my main concern. Parnum Paving has applied for a use permit to extract shale from the site using the already constructed Guntley/Mileck road. More noise, more dust, and more traffic will have to be endured by the neighbors if Parnum's permit is approved.
The City of Ukiah has given International Paper/Masonite Ukiah notice that after 1996 they will no longer accept scrubber and boiler ash at the Ukiah dump site (approximately 20 tons per day). This ash comprises over half the solid waste now accepted at the Ukiah site. Although no agreement has been made with IP/Masonite yet, Mr. Mileck stated to me that he would be willing to take IP/Masonite ash, which would not be composted but added as a soil amendment.
I have read many lab reports on IP/Masonite ash. All chemicals and heavy metals seem to be within limits. However, all samples were collected by IP/Masonite and sent by them to the independent lab. There was no mention of the possibility of these chemicals and metals accumulating at the dump site. But the City of Ukiah is puzzled about the ground water contamination around their dump site.
I have serious concerns about this ash being stored above the Russian River. After attending the Board of Supervisors hearing (1-4-94) I left feeling that the Board was going through the motions to pacify the public on an already done deal. They seem to look at the M&M project as an answer to their solid waste reduction problems.
Mr. Mileck, conducting a private business venture, has no contract with the County to accept municipal wastes and can refuse to do so. He will, however, be importing more waste into this County to make compost. After spending hours doing research on this project, I fear that pristine Potter Valley is being sacrificed as a good place to stash the trash and that this composting project is phase one to a Mega-Regional Dump. Hundreds of tons of compost should not be made on a mountain top above a river. As any plumber will tell you, "Shit runs downhill".
Copyright Mendocino Environmental Center 1995