Alternative EAW Form for Animal Feedlots ENVIRONMENTAL ASSESSMENT WORKSHEET

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2 Alternative EAW Form for Animal Feedlots ENVIRONMENTAL ASSESSMENT WORKSHEET Note to reviewers: The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects. This EAW was prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU), to determine whether an Environmental Impact Statement (EIS) should be prepared. The project proposer supplied reasonably accessible data for, but did not complete the final worksheet. Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor. Comments on the EAW should address the accuracy and completeness of information, potential impacts that are reasonably expected to occur that warrant further investigation, and the need for an EIS. A copy of the EAW may be obtained from the MPCA by calling (651) An electronic version of the completed EAW is available at the MPCA Web site 1. Basic Project Information. A. Feedlot Name: Pig City B. Feedlot Proposer: Denny Holtrop C. RGU: Minnesota Pollution Control Agency Technical Contact Person John Burgers Contact Person Joel Fischer and Title Environmental Consultant Extended Ag Services and Title Project Manager Address P.O. Box 134 Address 520 Lafayette Road North Lester, Iowa St. Paul, Minnesota Phone (712) Phone (651) Fax (712) Fax (651) extag@alliancecom.net joel.fischer@pca.state.mn.us D. Reason for EAW Preparation: (check one) EIS Scoping Mandatory EAW X Citizen Petition RGU Discretion Proposer Volunteered If EAW or EIS is mandatory give EQB rule category subpart number and name: Minn. R , subp. 29 (A) p-ear1-05 TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing 30% fibers from paper recycled by consumers

3 E. Project Location: County Pipestone Township Osborne SE 1/4 NW 1/4 Section 35 Township T105N Range R44W Watershed (name and 4-digit code): Missouri-Big Sioux 1017 F. Attach each of the following to the EAW: Attachment A: County map showing the general location of the project; Attachment B: U.S. Geological Survey (USGS) map indicating project boundaries; Attachment C: Site plan showing all significant project and natural features; Attachment D: Maps of manure application sites; Attachment E: Maps showing all wells, tile inlets, residences, and sensitive receptors within a one-mile radius of the feedlot or on manure land application sites; Attachment F: Map of Proposed Drinking Water Supply Management Area; Attachment G: Letter from the Minnesota Department of Health (MDH); Attachment H: Letter from the Minnesota Department of Natural Resources (DNR); Attachment I: from the Minnesota Historical Society; and Attachment J: Air Quality Modeling Report. The National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Permit Application and associated documents, including the Air Emissions and Odor Management Plan, the Animal Mortality Plan, the Emergency Response Plan, and the Manure Management Plan, are available for review by contacting Mr. George Schwint, of the MPCA s Willmar office, at (320) G. Project summary of 50 words or less to be published in the EQB Monitor. Mr. Denny Holtrop is proposing the construction of a new finishing hog facility in Section 35 of Osborne Township in Pipestone County. The facility will have a maximum capacity of 4,800 finishing hogs (totaling 1,440 animal units) to be housed in two 192-foot by 101-foot barns. Manure will be collected in eight-foot deep concrete pits located beneath each barn. Each fall, the manure will be pumped from the pits and sweep injected at agronomic rates into designated cropland as fertilizer. H. Please check all boxes that apply and fill in requested data: Animal Type Number Proposed Type of Confinement Finishing hogs 4,800 head Total Confinement Sows Nursery pigs Dairy cows Beef cattle Turkeys Layer hens Chickens Pullets Other (Please identify species) Pig City Environmental Assessment Osborne Township, Minnesota 2 Worksheet

4 I. Project magnitude data. Total acreage of farm: 763 Number of animal units proposed in this project: 1,440 Total animal unit capacity at this location after project construction: 1,440 Acreage required for manure application: 329 J. Describe construction methods and timing. The project will consist of constructing two 192-foot by 101-foot by 22-foot total confinement barns in the SE¼ of the NW¼ of Section 35 of Osborne Township in Pipestone County (see Attachments A, B and C). Each barn will be equipped with concrete, slatted floors and a tunnel ventilation system. Eightfoot deep, reinforced concrete pits will be constructed beneath each of the barns to hold the manure generated by the finishing hogs. An inspection tile will be installed at the base of the manure storage pits to help detect any seepage from the pits. The buildings will be constructed according to state of Minnesota building codes and Natural Resource Conservation Service (NRCS) engineering specifications. The anticipated timeline for this project is to commence construction in late summer 2006 and finish in November K. Past and future stages. Is this project an expansion or addition to an existing feedlot? Yes No Are future expansions of this feedlot planned or likely? Yes No If either question is answered yes, briefly describe the existing feedlot (species, number of animals and animal units, and type of operation) and any past environmental review or the anticipated expansion. 2. Land uses and noteworthy resources in proximity to the site. A. Adjacent land uses. Describe the uses of adjacent lands and give the distances and directions to nearby residences, schools, daycare facilities, senior citizen housing, places of worship, and other places accessible to the public (including roads) within one mile of the feedlot and within or adjacent to the boundaries of the manure application sites. The proposed feedlot site is rural in nature and located in an agricultural zone that consists of flat to gently rolling cropland. Corn and soybeans are the primary crops, with some alfalfa. The site is screened to the north and west by an established grove of mixed hardwoods, hedges and conifers. Feedlot: There are a total of ten residences located within approximately one mile of the proposed project site: two that are approximately 5,100 feet to the north; one that is approximately 5,400 feet to the northeast; one that is approximately 3,800 feet to the southeast; one that is approximately 3,600 feet to the south; one that is approximately 5,100 feet to the southwest; three that are approximately 4,400 to 4,500 feet to the west; and one that is approximately 5,200 feet to the northwest (see Attachment E-1). Manure Application Sites: The manure application sites are located within one mile of the proposed feedlot site, and are spread out over two township sections (see Attachment D-1). The residence located at the proposed feedlot site is situated in the middle of the manure application site in Pig City Environmental Assessment Osborne Township, Minnesota 3 Worksheet

5 Section 35, and another residence is located along its southeast border (see Attachment D-2). No residences are located within the boundaries of the manure application site in Section 36, but one is located along its southwest border (see Attachment D-3). 190 th Avenue is approximately one-half mile east of the proposed feedlot site and runs along the eastern edge of the manure application site in Section 35 and the western edge of the manure application site in Section 36. County Road 1 is approximately one-half mile south of the proposed feedlot site and runs along the southern edges of the manure application sites in Sections 35 and th Avenue is approximately one-half mile west of the proposed feedlot site and runs along the western edge of the manure application site in Section 35. B. Compatibility with plans and land use regulations. Is the project subject to any of the following adopted plans or ordinances? Check all that apply: local comprehensive plan land use plan or ordinance shoreland zoning ordinance flood plain ordinance wild or scenic river land use district ordinance local wellhead protection plan Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked? Yes No. If yes, describe the inconsistency and how it will be resolved. Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development)? Yes No If yes, describe the potentially affected use and its location relative to the feedlot, its anticipated development schedule, and any plans to avoid or minimize potential conflicts with the feedlot. Pipestone County has zoned an area along the south and east border of the city of Edgerton as an A1 district designated for residential urban development. The proposed feedlot will be located approximately 3,260 feet from the boundary of the A1 district (see Attachment E-2). Pipestone County zoning officials have indicated that there are no plans at this point for future development of the A1 district, and that the area was zoned as residential urban development to serve as a feedlot buffer for the city of Edgerton. In addition, the provisions of the Air Emissions and Odor Management Plan prepared as part of this project to help avoid or minimize potential conflicts between the proposed feedlot and existing neighbors will be extended to any future neighbors within the A1 district. C. Nearby resources. Are any of the following resources on or in proximity to the feedlot, manure storage areas, or within or adjacent to the boundaries of the manure application sites? Drinking Water Supply Management Areas designated by the MDH? Yes No Public water supply wells (within two miles)? Yes No Archaeological, historical or architectural resources? Yes No Designated public parks, recreation areas or trails? Yes No Lakes or Wildlife Management Areas? Yes No Pig City Environmental Assessment Osborne Township, Minnesota 4 Worksheet

6 State-listed (endangered, threatened or special concern) species, rare plant communities or other sensitive ecological resources such as native prairie habitat, colonial waterbird nesting colonies or regionally rare plant communities? Yes No Scenic views and vistas? Yes No Other unique resources? Yes No If yes, describe the resource and identify any project-related impacts on the resource. Describe any measures to minimize or avoid adverse impacts. Drinking Water Supply Management Area (DWSMA): The MDH has prepared a letter addressing this issue (see Attachment G). The proposed feedlot site and the two proposed manure application sites are located within two miles of a DWSMA that is currently being developed by the village of Leota in Nobles County for its public well. In addition, a third manure application site that was included in the original project proposal would have been partially located within the DWSMA (see Attachment F). The proposer has since decided, however, to not utilize the third manure application site as part of this project. The MDH has indicated that as long as manure is not being applied within the boundaries of the DWSMA, their concerns about the proposed project are mitigated. Endangered Species: The DNR has prepared a letter addressing this issue (see Attachment H). According to a search of the Minnesota National Heritage database conducted by the DNR, one species of special concern is known to occur in the general area of the proposed feedlot project: the Topeka Shiner, a small minnow that primarily inhabits small prairie streams that flow with cool, clear water. The Topeka Shiner is also a federally-listed endangered species. DNR officials have indicated, however, that based on the nature and location of the proposed project, they do not believe that it will adversely affect the Topeka Shiner population. 3. Geologic and soil conditions. A. Approximate depth (in feet) to: Feedlot Manure Storage Area Manure Application Sites Ground Water (minimum) (average) Bedrock (minimum) >10 >10 >10 (average) >10 >10 >10 B. NRCS Soil Feedlot Manure Storage Area Manure Application Sites Classifications (if known) P48A P48A P4A, P5A, P8A, P12B, P28A, P30B, P36A, P37B, P37D, P48A, P48B, P56B Pig City Environmental Assessment Osborne Township, Minnesota 5 Worksheet

7 C. Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot, manure storage area, or manure application sites. Karst features (sinkhole, cave, resurgent spring, disappearing spring, karst window, blind valley, or dry valley); Feedlot Manure Storage Area Manure Application Sites No No No Exposed bedrock; No No No Soils developed in bedrock (as No No No shown on soils maps). 4. Water Use, Tiling and Drainage, and Physical Alterations. A. Will the project involve installation or abandonment of any water wells, appropriation of any ground or surface water (including dewatering), or connection to any public water supply? Yes No If yes, as applicable, give location and purpose of any new wells; the source, duration, quantity and purpose of any appropriations or public supply connections; and unique well numbers and the DNR appropriation permit numbers, if available. Identify any existing and new wells on the site map. If there are no wells known on-site, explain methodology used to determine that none are present. There are currently two shallow wells located at the proposed site that were originally used for domestic purposes (see Attachment C). Because they were constructed prior to MDH well registration requirements, unique well numbers are not available for these wells. The project proposal calls for the west well to be abandoned in accordance with MDH requirements. The east well will be converted for use as the water supply for the new barns. Specific information regarding this well will be forwarded on to the MDH by the well driller at the time the well is converted for barn use. An estimated 2,368,800 gallons of water will be pumped annually from this well. That water will be appropriated under the DNR s Animal Feedlot and Livestock Operations General Permit B. Will the project involve installation of drain tiling, tile inlets or outlets? Yes No If yes, describe. Inspection tiles will be installed at the base of each of the manure storage pits. Each tile system will connect at a corner to a 12-inch riser pipe with cover, and will be used to help detect any seepage from the pits. C. Will the project involve the physical or hydrologic alteration dredging, filling, stream diversion, outfall structure, diking, and impoundment of any surface waters such as a lake, pond, wetland, stream or drainage ditch? Yes No If yes, identify water resource affected and give the DNR Protected Waters Inventory number(s) if the water resources affected are on the PWI. Describe proposed mitigation measures to avoid or minimize impacts. Pig City Environmental Assessment Osborne Township, Minnesota 6 Worksheet

8 5. Manure management. A. Check the box or boxes below which best describe the manure management system proposed for this feedlot. Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids and/or to recover energy Other (please describe) B. Manure collection, handling, and storage. Quantities of manure generated: total 969,337 gallons per year Frequency and duration of manure removal: Number of days per cycle 3 Total days per year 3 Give a brief description of how manures will be collected, handled (including methods of removal), and stored at this feedlot: Manure and wastewater will be collected during the year and stored in the concrete pits under the slatted floors of the barns. Both of the manure pits will utilize fans for ventilation. In the fall, the manure will be agitated in the pits and pumped out into tanker spreaders. A certified custom applicator will incorporate the manure into the soil immediately via sweep injection. C. Manure utilization. Physical state of manure to be applied: liquid solid other, describe: D. Manure application. 1. Describe application technology, technique, frequency, time of year and locations. The manure from this feedlot will be applied during the fall after the crops have been harvested from the designated land application sites. It will be incorporated into the soil immediately during land application via sweep injection. The tanker spreader will be operated by a custom applicator, and will be calibrated by the spreader volume. A flow meter may also be used to calibrate the application rate. The larger of the manure application sites covers the area of Section 35 of Osborne Township, and the smaller of the manure application sites covers the SW¼ of Section 36 of Osborne Township (see Attachment D-1). Pig City Environmental Assessment Osborne Township, Minnesota 7 Worksheet

9 2. Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus. Will there be a nutrient management plan? Yes No Manure will be applied at a nitrogen-based rate. Field priority will be based on phosphorus (P 2 O 5 ) and potassium (K 2 O) soil tests, with the lower levels of these receiving the manure first. Other factors that will determine nutrient needs will be the type of crop grown, the anticipated yield goal, the organic matter content of the soil, the use of manure credits, and other legume credits. Nutrient rates will be determined by utilizing University of Minnesota Extension Service bulletin, Fertilizer Recommendations for Agronomic Crops in Minnesota. Crop Average yield Nitrogen needed Phosphorus needed Corn 200 bu/ac 140 lbs. N/ac 69 lbs. P 2 O 5 /ac Soybeans 50 bu/ac 245 lbs. N/ac 41 lbs P /ac ac = acres bu = bushel lbs = pounds N = nitrogen This procedure has been developed as a means of predicting the amount of nutrients that can be used by plants. Using this method, a Maximum Return to Nitrogen value will be identified and used in determining the appropriate manure application rates. The manure application sites will be sampled every four years to monitor crop needs and to target the specific application acres that will positively respond to manure applications. 3. Discuss the capacity of the sites to handle the volume and composition of manure. Identify any improvements necessary. It is estimated that the finishing hogs at this facility will generate 969,337 gallons of manure per year. In order to achieve a yield goal of 200 bushels of corn per acre, manure will be applied at a nitrogen-based rate of 140 pounds per acre. Accordingly, 329 corn acres will be needed to utilize all of the manure generated at this facility. The proposer currently has approximately 763 acres of land available for manure application. Please note that none of that land has been identified as highly erodible by the Natural Resources Conservation Service. No improvements to either of the manure application sites will be necessary. 4. Describe any required setbacks for land application systems. Pipestone County has adopted the standard MPCA setback distances for manure application. The project proposer will abide by those setbacks, as listed in Table #1 below. Pig City Environmental Assessment Osborne Township, Minnesota 8 Worksheet

10 Feature Table #1: MPCA Animal Waste Land Application Setback Distances (in feet) Winter Non-Winter With Immediate Incorporation (< 24 hours) With P No P Management Management Non-Winter Not incorporated within 24 hours With Vegetated Buffer Lake, Stream Intermittent Stream* DNR protected wetlands** Drainage ditch w/o quarry* Inadequate Vegetated Buffer Open Tile Intake Well, mine or quarry Sinkhole with no diversion Downslope 50 Upslope Down slope 50 Upslope 300 Down slope 50 Upslope 300 * Intermittent streams and ditches pertain to those identified on USGS quadrangle maps, excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways. USGS quadrangle maps can be found at County Soil and Water Conservation District Offices or can be viewed on the internet at (August 17, 2004). ** Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over ten acres). E. Other methods of manure utilization. If the project will utilize manure other than by land application, please describe the methods. None. 6. Air/odor emissions. A. Identify the major sources of air or odor emissions from this feedlot. The surfaces of the barns that come into contact with animals and manure, especially the floor, are sources of odor. The animals themselves are also sources. The manure collection and storage facilities, the feed storage facilities, the dead animal disposal and storage areas, and the manure exposed to the air during land application are also significant sources of odor. Dust generated by truck traffic around the site can also contribute to odor. B. Describe any proposed feedlot design features or air or odor emission mitigation measures to be implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness. Odor management practices implemented for this facility include thorough washing and disinfection of the interior of the finishing buildings at the end of each hog cycle. Special attention will be paid to cleaning the building ventilation fans and pit exhaust fans. Reducing crude protein in the hogs diet, and utilizing synthetic amino acids, such as lysine, in the hogs feed will help to reduce odor. The proposer will maintain clean dry floors, eliminate manure buildup and clean up any spilled feed. Manure will be injected immediately into the soil during application in the fall to minimize the release of odors. Required setbacks for manure application will be observed from nearby residences. Weather Pig City Environmental Assessment Osborne Township, Minnesota 9 Worksheet

11 conditions, primarily wind speed/direction and humidity, will be evaluated before manure is land applied to ensure minimal impacts on neighbors and the public. If dust generated by truck traffic becomes an issue, the proposer will use a dust suppressant to help control it. C. Answer this item only if no feedlot design features or mitigations were proposed in item 6.B. Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards, health risk values, or odor threshold concentrations. The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts. An air emission modeling study has been completed for this project (see Attachment J). The results suggest that the proposed project will comply with the ambient air quality standard for hydrogen sulfide along its effective property lines. The results also suggest that the proposed project and the eight neighboring feedlots included in the model will not create exceedences of the subchronic inhalation health risk value (ihrv) for hydrogen sulfide at the nearest neighbors, will not create exceedences of the acute ihrv for ammonia along the proposed feedlot s effective property lines, and will not create exceedences of the chronic ihrv for ammonia at the nearest neighbors. While the modeling results indicate that detectable concentrations of odorous gases can exist off site, the estimated maximum concentration of total volatile odorous organic compounds for the nearest non-feedlot neighbor included in the model is 9.8 times less than the threshold concentration associated with unpleasant odors. Please note that as part of the air emission modeling study, the proposer obtained an air quality easement from the owner of the residence currently located at the proposed project site (i.e., the proposer does not own the proposed feedlot site or attached residence). This residence will be vacated, however, once the construction of the feedlot facility has commenced. D. Describe any plans to notify neighbors of operational events (such as manure storage agitation and pumpout) that may result in higher-than-usual levels of air or odor emissions. No neighbors are located within a half-mile of the feedlot site. Therefore, there are no plans to notify neighbors of operational events that may result in higher-than-usual levels of air or odor emissions during manure storage agitation and pumpout. In the event of a complaint or a violation, the feedlot operator will follow the protocols outlined in the Air Emissions and Odor Management Plan prepared for this project. E. Noise and dust. Describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. The loudest noises from the proposed project site will come from ventilation fans, which may be detectable up to 500 feet from the barns, and truck traffic entering and leaving the site. In this case, the distance between the proposed project site and the nearest neighbor (approximately 3,600 feet) is a significant factor in mitigating any adverse impacts of noise associated with this project. If particulate matter generated by truck traffic becomes an issue, the proposer will apply a dust suppressant where it is needed. Pig City Environmental Assessment Osborne Township, Minnesota 10 Worksheet

12 7. Dead Animal Disposal Describe the quantities of dead animals anticipated, the method for storing and disposing of carcasses, and frequency of disposal. An eight-foot by eight-foot mortality disposal box will be constructed on the proposed project site. The disposal area will be constructed of ten-inch tongue-and-groove polyvinyl chloride paneling. A swinging door with latch will provide access to the box and security from scavengers. The floor of the disposal area will be poured concrete or an impervious clay pad. The top will be covered with nylon netting. Mortalities will be removed, as discovered, from the barns. A rendering company that services livestock producers will be utilized to pick up mortalities on a per call basis. It is anticipated that the annual mortality rate will be approximately 96 head of hogs from the proposed project site. 8. Surface Water Runoff. Compare the quantity and quality of site runoff before and after the project. Describe permanent controls to manage or treat runoff. Surface water runoff will increase on the proposed project site due to an increase in impervious surfaces, mainly from the construction of two roofed buildings. Because this will be a total confinement facility, with the manure stored entirely under the barns, the runoff will not come into contact with the livestock or its manure. In the event of a heavy rainfall, surface water runoff will be dispersed into the field directly adjoining the site to the south. 9. Traffic and Public Infrastructure Impacts. A. Estimate the number of heavy truck trips generated per week and describes their routing over local roads. Describe any road improvements to be made. A feed truck will visit the proposed project site once per week for regular refilling duties. Ten pickup trucks equipped with gooseneck trailers will come twice per year to deliver new hogs to the facility. Seventy-three semi-tractors and trailers will come annually to deliver finishing hogs from the facility to market. The township road adjoining the site to the west (180 th Avenue) provides access to the site. The road is gravel and carries a five-ton load restriction in the spring. The proposer will repair and maintain the portion of the road used and/or damaged by traffic during the road restrictions. B. Will new or expanded utilities, roads, other infrastructure, or public services be required to serve the project? Yes No If yes, please describe. 10. Permits and approvals required. Mark required permits and give status of application: Unit of government Type of Application Status MPCA NPDES Feedlot/SDS Livestock Production Pending Construction, Operation and Stormwater Permit Pipestone County Conditional use or other land use permit Pending DNR Water Appropriation Will be applied for once the domestic well has been converted for feedlot use Pig City Environmental Assessment Osborne Township, Minnesota 11 Worksheet

13 11. Other potential environmental impacts, including cumulative impacts. If the project may cause any adverse environmental impacts not addressed by items 1 to 10, identify and discuss them here, along with any proposed mitigation. This includes any cumulative impacts caused by the project in combination with other existing, proposed, and reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative impacts. Examples of cumulative impacts to consider include air quality, stormwater volume or quality, and surface water quality. (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form.) Surface Water Quality: Land application of manure can be a concern with respect to water quality. The MPCA s impaired waters database was reviewed to determine if any existing impaired surface waters or Total Maximum Daily Load (TMDL) for surface waters exist in the watershed. The proposed project, including the manure application sites, will be located within a few miles of the Rock River. The Rock River is listed as impaired on the TMDL database for fecal coliform, ammonia, turbidity, and mercury. The project proposer is aware of this condition and has developed the manure management plan accordingly. The project proposer will apply manure in agronomic rates and use sweep injection as the method of land application, which helps to reduce the potential for manure and manure-contaminated runoff waters from reaching the surface waters of the state. The manure management plan for the facility has been reviewed and approved by MPCA staff and will be an enforceable condition of the NPDES/SDS Feedlot Permit. Cumulative impacts to surface water quality are not reasonably expected to occur as a result of this project. Antibiotic Use: The proposed project will produce hogs through the therapeutic use of antibiotics. The proposer is aware of the environmental and public health concerns related to antibiotic use in livestock and will not use any antibiotics without the supervision of a veterinarian. Pests: Manure storage in a deep concrete pit does not facilitate the development of fly infestation. If flies do become a problem, the owner will implement fly control measures. Rodent control is necessary to prevent the spread of diseases carried by the rodents. An effective rodent control will be implemented as part of this project. 12. Summary of issues. List any impacts and issues identified above that may require further investigation before the project is begun. Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues, including those that have been or may be ordered as permit conditions. No additional issues. Pig City Environmental Assessment Osborne Township, Minnesota 12 Worksheet

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15 ATTACHMENT A

16 Proposed Site ATTACHMENT B

17 ATTACHMENT C

18 ATTACHMENT D1

19 ATTACHMENT D2

20 ATTACHMENT D3

21 ATTACHMENT E1

22 S MECHANIC ST Holtrop Site Zone Districts ATTACHMENT E2 A1 EMILLST Industrial 16TH ST Industrial A1 175TH AVE 180TH AVE Proposed Site Industrial ,2301,640 Feet Osborne Section 35 Created: by KK Pipestone County Conservation and Zoning Office

23 ATTACHMENT F

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33 ATTACHMENT J Air Quality Modeling Report Holtrop Hog Feedlot Pipestone County Osborne Township NW Section 35 May 2006

34 Table of Contents Introduction... 1 General Modeling Approach... 4 Site Descriptions... 8 Holtrop Feedlot... 8 Neighbor Feedlot # Neighbor Feedlot # Neighbor Feedlot # Neighbor Feedlot # Neighbor Feedlot # Neighbor Feedlot # Neighbor Feedlot # Neighbor Feedlot # Gas Emission Rates Hog s Manure Storage Basins Hydrogen Sulfide at Property Lines and Neighbors Ammonia at Property Lines and Neighbors Odorous Gases at Property Lines and Neighbors Odor Intensity at South Property Line and Neighbor F Summary... 37

35 Introduction Air quality modeling estimated the atmospheric concentrations of hydrogen sulfide, ammonia, and selected odorous gases at the effective property lines for the hog-finishing feedlot proposed by Dennis Holtrop and at 28 of the proposed feedlot s nearest neighbors. The proposed feedlot consists of two deep-pitted tunnel-ventilated barns. Each barn will house 2,400 head of finishing pigs. An air quality easement has been granted to Mr. Holtrop by the other landowner in Section 35 (Pipestone County, Osborne Township). Thus, for the air quality modeling, the effective property lines for the proposed Holtrop Feedlot were the section line to the north and the road right-of-ways to the east, south, and west. In addition to the proposed Holtrop Feedlot, the modeling also considered the emissions from eight nearby hog feedlots. The locations of the modeled feedlots are provided in Figure 1. The following atmospheric concentrations were calculated: 1. the maximum hourly atmospheric hydrogen sulfide concentration at the proposed feedlot s effective property lines to assess the potential to comply with Minnesota s ambient air quality standard for hydrogen sulfide of 30 ppb (v/v); 2. the maximum 13-week time-averaged atmospheric hydrogen sulfide concentration at 28 of the proposed feedlot s nearest neighbors to assess the potential to exceed Minnesota s subchronic inhalation Health Risk Value (ihrv) of 10 g/m 3 ; 3. the maximum hourly atmospheric ammonia concentration at the proposed feedlot s effective property lines to assess the potential to exceed Minnesota s acute ihrv for ammonia of 3,200 g/m 3 ; 4. the maximum annual-averaged atmospheric ammonia concentration at 28 of the proposed feedlot s nearest neighbors to assess the potential to exceed Minnesota s chronic ihrv for ammonia of 80 g/m 3 ; and 5. the hourly concentrations of selected odorous gases (including n-butyric acid and paracresol) at the proposed feedlot s effective property lines and at 28 of the proposed feedlot s nearest neighbors to access the potential for off-site odor episodes. The above calculations were performed using the CALPUFF air quality model, based on 5 years of historical meteorological data. 1 Holtrop Hog Feedlot Report

36 Figure 1. Modeled hog feedlots. The orange rectangle labeled SITE is the location of the proposed Holtrop Feedlot. The green-bordered square represents the boundaries of the air quality easement granted to Mr. Holtrop. 2 Holtrop Hog Feedlot Report

37 The CALPUFF modeling results suggest that the proposed Holtrop hog feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide. Based on the estimated emissions from the proposed feedlot and the 8 neighboring feedlots, CALPUFF predicted a maximum hourly effective property-line hydrogen sulfide concentration of 7.15 ppb (v/v) for the Holtrop feedlot. When a background concentration of 17 ppb (v/v) is added to the CALPUFF prediction, the maximum effective property-line hydrogen sulfide concentration is ppb (v/v), which is below the ambient standard of 30 ppb (v/v). The CALPUFF results indicate that the combined emissions from proposed Holtrop feedlot and the 8 neighboring feedlots will not create exceedences of the subchronic hydrogen sulfide ihrv at the neighboring residences. The estimated maximum 13-week time-averaged hydrogen sulfide concentration for the feedlots neighbors is 0.37 g/m 3. When a background concentration of 1.00 g/m 3 is added to the CALPUFF estimate, the maximum 13-week neighbor hydrogen sulfide concentration is 1.37 g/m 3, which is below the subchronic hydrogen sulfide ihrv of 10 g/m 3. The modeling results also suggest that the proposed feedlot and the 8 neighboring feedlots will not create exceedences of the acute ammonia ihrvs along the proposed feedlot s effective property lines and will not create exceedences of the chronic ammonia ihrv at the nearest neighbors. CALPUFF predicted a maximum hourly effective property-line ammonia concentration of 1,158 g/m 3. When a background concentration of 148 g/m 3 is added to the CALPUFF prediction, the maximum effective property-line ammonia concentration is 1,306 g/m 3, which is below the acute ammonia ihrv of 3,200 g/m 3. The estimated maximum one-year time-averaged ammonia concentration for the proposed feedlots neighbors is g/m 3. When a background ammonia concentration of 5.72 g/m 3 is added to the CALPUFF estimate, the maximum annual ammonia concentration for a neighbor is g/m 3, which is below the chronic ammonia ihrv of 80 g/m 3. Thus, the modeling results suggest compliance with the hydrogen sulfide air quality standard, no exceedences of the subchronic hydrogen sulfide ihrv, and no exceedences of the acute and chronic ammonia ihrvs. 3 Holtrop Hog Feedlot Report

38 General Modeling Approach The modeling approach considered the proposed hog feedlot and the neighboring 8 hog feedlots as the only significant hydrogen sulfide, ammonia, and odorous gas emission sources within a 3-mile by 3-mile grid. The air quality impacts associated with the 9 hog feedlots were explicitly modeled. The proposed Holtrop feedlot is located in the middle square mile of the grid. The air quality impacts associated any other sources in the 3-mile by 3-mile grid are considered implicitly as contributors to the background hydrogen sulfide and ammonia concentrations that are added to the modeling results. Hence, the background concentrations include the impacts associated with sources such as septic tank vents, wastewater treatment plants, small feedlots, open-lot feedlots, fertilizer and manure application to cropland, and wetlands. The property-line and nearest-neighbor odorous gas concentrations were estimated by the CALPUFF (version 5.711, level ) air quality model. 1,2,3 The estimated concentrations were based on historical wind speeds, wind directions, atmospheric stabilities, and rural mixing heights. The historical weather data consisted of five years ( ) of surface meteorological data from the National Weather Surface station in Sioux Falls, South Dakota and of upper air data for Huron, South Dakota. The surface and upper air weather data sets were combined into an ISC-type 4 meteorological file by the U.S. Environmental Protection Agency s (EPA s) PCRAMMET software. 5 The surface and upper air weather data sets were obtained from the U.S. EPA s Support Center for Regulatory Air Models. Maximum one-hour, 13-week, and annual average concentrations were calculated. Rural dispersion coefficients were used to characterize atmospheric mixing. The modeling assumed no decay of any modeled gas due to chemical reactions. The modeled receptor height was 0 meters, i.e., ground level. A flat terrain was assumed. All modeled property-line and nearest-neighbor receptors were defined as discrete receptors. Effective property-line receptors were less than 25 meters apart. An arbitrary Cartesian coordinate system (x, y) was used with the southwest corner of Section 35 (Pipestone County, Osborne Township) as the origin (0, 0). Positive values 1 U.S. EPA A User s Guide for the CALPUFF Dispersion Model. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-454/B Scire J. S., Strimaitis D. G., and Yamarino R. J A User s Guide for the CALPUFF Dispersion Model (Version 5). Earth Tech, Inc., Concord, MA. 496 pp. 3 U.S. EPA Revision to the Guideline for Air Quality Models. 40 CFR Ch. 1, Part 51, Appendix W (April 15, 2004 Edition). 4 ISC = Industrial Source Complex 5 U.S. EPA PCRAMMET User s Guide. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC. EPA-454-B (Revised June 1999). 4 Holtrop Hog Feedlot Report

39 of x represent distance east of the origin. Positive values of y represent distance north of the origin. To assess the potential for environmental impacts, the atmospheric hydrogen sulfide, ammonia, and volatile odorous organic compound (VOOC) concentrations generated by the air quality modeling were compared to air quality standards, inhalation Health Risk Values (ihrvs), and published odor threshold concentrations. The direct comparison of model-generated concentrations to these environmental threshold concentrations does not consider the impact of different averaging times. U.S. EPA guidelines do not allow concentrations to be time averaged for time periods less than an hour. 6 This is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor threshold concentrations for VOOCs are often based on instantaneous measurements. For example, an hourly model-generated hydrogen sulfide concentration of 29 ppb (v/v) may contain a half-hour average concentration that exceeds the 30 ppb standard. Also, an odor intensity that an odor panelist may find to be merely detectable in a short-term field measurement could be annoying if present for an hour or longer. The background concentrations of hydrogen sulfide and ammonia provided in Table 1 were added to the CALPUFF estimated concentrations as described in U.S. EPA guidelines. 7 The listed concentrations represent background concentrations for rural Minnesota. The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlot s potential to comply with the 30-ppb standard. A background concentration of 18 ppb should be used in assessing the potential to comply with the 50-ppb hydrogen sulfide standard. The background concentrations listed in Table 1 are not the time-averaged concentrations obtained from monitoring. Instead, the listed concentrations reflect the monitored data expressed in the terms of the exceedence or violation condition for the corresponding ihrv guideline or ambient standard. For example, the background 208-ppb ammonia concentration for the acute ammonia ihrv represents the maximum hourly concentration that occurred within the entire length of monitoring. This is the appropriate interpretation of background for the acute ammonia ihrv, because the guidance is concerned with any potential exceedence of the ihrv. Also, the 17-ppb hydrogen sulfide background represents the third highest 30-minute concentration that occurred within any 5-day period. This is appropriate, because the ambient hydrogen 6 U.S. EPA Revision to the Guideline for Air Quality Models. 40 CFR Ch. 1, Part 51, Appendix W (April 15, 2004 Edition). 7 Ibid. 5 Holtrop Hog Feedlot Report

40 sulfide standard defines a violation as the third exceedence of 30 ppb within any 5-day period. Table 1. Background concentrations. Gas Hourly Background Concentration 13-Week Background Concentration Annual Background Concentration Hydrogen Sulfide 17 ppb (v/v) (24.3 g/m 3 ) 0.70 ppb (v/v) (1.00 g/m 3 ) Not Required Ammonia 208 ppb (v/v) (148 g/m 3 ) Not Required 8.07 ppb (v/v) (5.72 g/m 3 ) To assess the potential for odor episodes, the estimated atmospheric concentrations were compared to each gas s reported odor threshold concentration. The odor threshold concentration is defined as the gas-phase concentration at which 50 percent of the population can detect the gas s odor. For this presentation, odor number is defined as the ratio of the estimated atmospheric concentration for a specific odorous gas divided by the gas s odor threshold concentration. An odor number equal to 1 suggests that 50 percent of the population can detect the estimated atmospheric concentration for a specific gas. An odor number greater than 1 suggests that more than 50 percent of the population can detect the gas, while a value less than 1 indicates that less than 50 percent of the population can detect the gas. Typically, an odor number below about 0.1 suggests that less than 1 percent of the population can detect the gas. 8 The odor threshold concentrations used in this assessment are presented in Table 2. 8 Nagy G. Z The odor impact model. Journal of Air & Waste Management Association 41(10): Holtrop Hog Feedlot Report

41 Table 2. Odor threshold concentrations for the modeled gases. 9 Odorous Gas Odor Threshold Concentration (ppb, v/v) Acetic Acid 200 n-propanoic Acid 17 iso-butyric Acid 11 n-butyric Acid 0.69 iso-valeric Acid 4.8 n-valeric Acid 0.28 iso-caproic Acid 7.7 n-caproic Acid 21 n-heptanoic Acid 5.0 Phenol 76 para-cresol 0.25 para-ethyl Phenol 1.2 Hydrogen Sulfide 3.7 Ammonia 1,500 The odor-number assessment of odor intensity does not consider the interactions between gases. Gas mixtures can intensify or mitigate certain odors. The Zahn correlation 10,11 was used to account for the odor intensity associated with the mixture of gases released from the manure pits. The total concentration of volatile odorous organic compounds (VOOCs) required for the Zahn correlation was calculated from the modeled concentrations of the 12 organic gases listed in Table 2. 9 Minnesota Environmental Quality Board A Summary of the Literature Related to the Social, Environmental, Economic and Health Effects: Volume 2. Generic Environmental Impact Statement on Animal Agriculture, Prepared by the University of Minnesota, September Table 1 presents the geometric mean of the lower and upper odor threshold concentrations obtained from this reference. 10 Zahn J. A Swine odor and emissions from pork production. In: McGuire K. (ed.), Environmental Assurance Program, National Pork Producers Council, Des Moines, IA, pp Zahn J. A., Hatfield J. L., Laird D. A., Hart T. T., Do Y. S., and DiSpirito A. A Functional classification of swine manure management systems based on effluent and gas emission characteristics. Journal of Environmental Quality 30: Holtrop Hog Feedlot Report

42 Site Descriptions Holtrop Feedlot The proposed Holtrop Feedlot consists of two hog-finishing barns. The physical characteristics of the proposed hog-finishing barns are provided in Table 3. As illustrated in Figure 2, the setback distances from the proposed barns to the effective property lines range from 1,935 feet to 2,943 feet. The air quality modeling estimated the atmospheric gas concentrations at the 28 neighboring residences shown in Figure 3. Table 3. Dimensions and capacities of the hog-finishing barns at the proposed Holtrop Feedlot. Hog Finishing Length (feet) Width (feet) Height (feet) Number of Housed Pigs East ,400 West ,400 8 Holtrop Hog Feedlot Report

43 5180' 2270' 1935' West East 2943' 5230' 2768' N W E S (50', 50') Figure 2. Modeled gaseous emission sources and effective property lines for the proposed Holtrop Feedlot. The blue squares are the locations of the square volume sources used to characterize the emissions from the tunnel-ventilated hog-finishing barns. The barn separation distance is 100 feet. 9 Holtrop Hog Feedlot Report

44 Figure 3. Modeled locations for 28 of the proposed feedlot s nearest neighbors. Neighbors C, D, E, L, M, Q, R, and S are associated with livestock feedlots. Neighbor F is the neighbor nearest to the proposed Holtrop Feedlot that is not associated with an existing feedlot. 10 Holtrop Hog Feedlot Report

45 Neighbor Feedlot #1 Neighbor Feedlot #1 is located in the SW of Section 34 of Osborne Township and consists of a single nursery barn. The physical characteristics of the barn are provided in Table 4. The modeled location of the barn is provided in Figure 4. Neighbor Feedlot #2 Neighbor Feedlot #2 is located in the NE of Section 34 of Osborne Township and consists of two sow barns and one 65-ft diameter manure storage basin. The dimensions and capacities of the barns are provided in Table 5. The modeled locations of the barns and manure basin are provided in Figure 5. Neighbor Feedlot #3 Neighbor Feedlot #3 is located in the SE of Section 26 of Osborne Township and consists of one hog-finishing barn. The physical characteristics of the barn are provided in Table 6. The modeled location of the barn is provided in Figure 6. Neighbor Feedlot #4 Neighbor Feedlot #4 is located in the SW of Section 25 of Osborne Township and consists of one nursery and two hog-finishing barns. The dimensions and capacities of the barns are provided in Table 7. The modeled locations of the barns are provided in Figure Holtrop Hog Feedlot Report

46 Table 4. Dimensions and capacities of the hog barn at Neighbor Feedlot #1. Hog Length (feet) Width (feet) Height (feet) Number of Housed Nursery Pigs Nursery , ' W 145' 250' 132' N Nursery E 294' 480' S (-2185', 925') Figure 4. Modeled gaseous emission sources for Neighbor Feedlot #1. The shaded squares represent the square volume subsources used to characterize the barn. The green-bordered rectangle surrounding the barn is used to position the barn and does not represent the feedlot s property lines. 12 Holtrop Hog Feedlot Report