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About 60 cows produce enough manure to fill an Olympic-sized swimming pool. The waste ponds A.J. Bos plans to build for his Tradition Family Dairies would equal the volume of roughly 160 Olympic-sized swimming pools.

IDOA weighs request for 10,000-cow dairy, amid worries over water contamination

by Lauren Williamson
May 20, 2008


Courtesy of People for the Ethical Treatment of Animals

Concentrated animal feeding operations, like this one in California, confine large numbers of animals for extended periods of time. The Tradition Dairies site in Nora, Ill. would house nearly 10,000 cows initially, though community members said they fear the dairy will expand far beyond that size. 

When a sinkhole breached a waste lagoon in Puerto Rico during the early 1980s, scientists described the rupture like a giant toilet flushing 1.4 million gallons of hazardous substances into the earth.

Now a California dairyman wants to build a farm with ponds holding 127 million gallons of livestock waste in northwest Illinois — and the region has a similar geologic makeup to the Puerto Rico site.

The terrane in Jo Daviess County, where A.J. Bos, of Bakersfield, Calif., wants to build Tradition Family Dairy, is karstic. (Terrane differs from terrain in that it includes both surface and subsurface features.)

Karstic means there are vertical fractures in the limestone and dolomite bedrock, said Sam Panno, a senior geochemist the Illinois State Geological Survey.

“There are initial fractures, and then the fractures widen,” he said. “At some point, the width opens up, and you get an aquifer where water moves very quickly.”

The fissures can eventually widen into caves, which make these areas particularly vulnerable to collapsing into sinkholes. Panno mapped a number of sinkholes in Jo Daviess County in his report on the proposed dairy site.

Contaminated ground water

If the waste ponds from the farm overflowed into a fracture or a sinkhole cracked a pond’s lining, groundwater contamination would happen very rapidly, Panno said.

Typically water moves through the ground at a rate of 10 feet per year, hesaid. In karstic conditions, water can flow at several miles per hour.

If the groundwater supply was contaminated by manure, Field said, the public health impact could be disastrous.

E. coli bacteria contaminated three Walkerton, Ontario, wells in the year 2000, sickening 20,000 people and killing seven, said Malcolm Field, a research hydrogeologist with the U.S. Environmental Protection Agency. Raw manure from a field washed down a sinkhole and into the water supply.

“There will be leakage,” Field predicted. “We assume all of these lagoons leak, no matter how well they’re lined.”

The volume of the Tradition Dairy ponds would equal that of roughly 160 Olympic-sized swimming pools.

State official objects

In February, Lt. Gov. Pat Quinn wrote a letter to Marvin Schultz, chairman of the Jo Daviess County Board, urging the board to reject the Bos dairy plan.

“The proposed ‘mega-dairy,’ and the animal waste lagoon that would be created by a facility of this size, would endanger area groundwater and streams,” he wrote. “These wastes, if recycled responsibly as agricultural fertilizer, would cover a massive acreage of farmland; if concentrated over a smaller area, the over-application would result in serious environmental hazards.”

In January, the County Board voted to reject the dairy, but the Illinois Department of Agriculture used that vote only as a non-binding recommendation, said Warren Goetsch, bureau chief of environmental programs at the IDOA.

Quinn still opposes the dairy, said Marc Miller, his senior policy advisor.

“After receiving information that there’s karst in the area,” he said, “it puts more emphasis on our point that this is perhaps not the right place for a large concentrated animal feeding operation.”

“I don’t think anyone disagrees that significant portions of this area are underlined by karst,” said Goetsch, whose unit of the IDOA oversees the Livestock Management Facilities Act.

That act, adopted in 1996, “establishes requirements for the design, construction and operation of livestock waste-handling facilities,” according to the IDOA.

“Certainly karst features in that area require questions we have to answer,” Goetsch said. “Our charge is to determine whether the requirements of the statute are being met.”

In April, the dairy hired geologists to conduct further testing on the site in response to an IDOA order. Those geologists determined through bedrock samples taken through vertical borings that karst was not present in the area.

Boring into the earth is not an adequate test for karst, Panno said. “The rock is predominantly solid. If you drill into it and, say, it’s completely solid, it’s like drilling into a sand grain and saying water couldn’t possibly pass through an area of sand and gravel.”

10,000 cows

The type of farm Bos wants to build is known as a concentrated animal feeding operation. A CAFO, as defined by the U.S. Environmental Protection Agency, is a facility where large numbers of animals are confined for more than 45 days.

The proposed CAFO, located one mile west of Nora, Ill., would house more than 13,000 animal units, said the profile submitted to the Jo Daviess County Office of Economic Development.

One animal unit equals 1.4 dairy cows, based on the Illinois Department of Agriculture conversion system, meaning that the actual number of cows at the site would total near 10,000 animals.

With more than 7,700 head of dairy cows, Jo Daviess is already the fourth biggest county in the state for dairy operations, according to the 2002 Census of Agriculture.

Workers at Bos’ dairy would spread manure across roughly 4,000 acres of farmland each year to help deal with the massive quantity of waste produced. Approximately 23,000 gallons of manure would be spread per acre as fertilizer. About 90 million gallons of the waste produced each year would be removed from holding ponds for this purpose.

A representative for Bos said he declined to comment for this story.

“Concentrated animal waste and associated possible contaminants from IFAP systems pose a substantial environmental problem for air quality, surface and subsurface water quality, and the health of workers, neighboring residents, and the general public,” said the Pew Commission on Industrial Farm Animal Production, in a study released in April.

The amount of manure spread from CAFOs often exceeds the ground’s ability to absorb the nutrients in it, the report said. More than 30 percent of the nitrogen and phosphorous that ends up in fresh-water sources is a result of animal farming.

An excess of these nutrients in waterways promotes algae blooms, which in turn consume too much oxygen, creating dead zones where aquatic life can’t survive, said the EPA.

Environmental calamity in Maryland

In January, 2,400 trout died after pipes burst at a hog farm in Walkersville, Md., spilling thousands of gallons of waste into a creek, reported the Frederick News-Post. Frederick County pumped water into town for two months after the spill because manure contaminated the town’s wells.

The Nora site is near a creek which feeds into the Apple River, one of the most biologically diverse waterways in Illinois, said Danielle Diamond, legal counsel for Illinois Citizens for Clean Air and Water.

“Under the Clean Water Act, livestock operations are required to meet certain standards and undergo inspections,” she said. “The producer has to come up with plans to minimize risks.”

The act sets wastewater standards for industry and regulates the release of pollutants into navigable waters, said the U.S. EPA. Many of the small creeks and well sites the farm could affect do not fall into this category.

Even though CAFOs produce waste at industrial-level quantities, the Illinois EPA is not enforcing the act for them, Diamond said. For the 35,000 livestock facilities in the state, she said, the National Pollutant Discharge Elimination System, which implements the federal CWA, has issued only 40 permits.

“Those charges are just not correct,” said Richard Breckenridge, agriculture and rural affairs advisor for the IEPA. “We have numerous examples over the years where we respond to complaints and spills to minimize the environmental damage.”

At this stage, he said the IEPA does not serve a regulatory role in the Tradition Dairy permitting process.

The IDOA has sole authority until construction begins, at which point he said the IEPA will require permits to control storm water and erosion. After the dairy is complete, the IEPA will regulate it.

“Since there is a high interest and awareness from the public, we will have an added presence at this facility,” he said. “We will monitor their manure-handling practices, and we could monitor their groundwater tests.”

The Illinois Pollution Control Board defines guidelines for manure handling, which focus on the design and construction of waste storage and handling facilities.

“Our rules were set after a great deal of scrutiny from the livestock industry, environmental groups, engineers and scientists,” Breckenridge said. “These large dairies are held to a zero discharge standard. They cannot discharge any liquids into the water system.”

Ponds versus lagoons

Bos plans to construct manure ponds to store waste, said a statement released by the Bos Family of Companies.

Ponds differ from manure lagoons, it said, in that waste is not treated before being removed from the pond and spread on surrounding land.

The only waste storage facilities regulated by Illinois are lagoons, according to a report from the Natural Resources Defense Council.

The state pollution board’s Livestock Waste Regulations require waste ponds to be designed according to specifications from sources such as the USDA. There are no post-construction guidelines for ponds.

The NRDC report said Illinois has become a hot spot for CAFOs constructed by out-of-state corporations wishing to bypass stricter regulations in other parts of the country.

Nontraditional dairies for family of farmers

Bos and several family members have stakes in a number of farms across the United States. Until 2007, he was a partner in Threemile Canyon Farms, a 93,000-acre complex in Oregon that supplies potatoes and dairy to ConAgra, J.R. Simplot Company and other food distributors, the company profile said.

Bos family-owned Windy Ridge Dairy in Indiana was fined $13,000 in 2003 for animal waste-related violations. An Indiana Department of Environmental Management notice said animal manure from the farms reached surface water “in amounts sufficient to be acutely toxic to, or otherwise severely injure or kill aquatic life, other animals, plants or humans, which was in concentrations or combinations that caused or contributed to the growth of aquatic plants or algae to such a degree as to create a nuisance.”

For the Illinois proposal, IDOA has issued three information requests to guarantee that Bos follows required safety specifications, Goetsch said.

“We’re methodically going through a normal review of the application,” he said. “Each project is unique, and it’s our job to review the proposal and ensure no proposal is approved unless it meets our standards.”

But it’s going to take a lot more work to convince some researchers.

“I think there’s a large susceptibility for problems,” Panno said. “I’m very concerned about environmental problems here.”