Moore Lean, LLP, Environmental Assessment Worksheet · Moore Lean LLP Environmental Assessment...

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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) 297-8510. An electronic version of the completed EAW is available at the MPCA Web site http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Basic Project Information.

A. Feedlot Name: Moore Lean, LLP B.

Feedlot Proposer:

Randy Koehl, Managing Partner

C.

RGU:

Minnesota Pollution Control Agency

Technical

Contact Person Jared Anez

Contact Person

Randy Hukriede

and

Title President, Anez Consulting Inc.

and Title

Project Manager

Address 1025 19th Avenue Southwest, Suite A

Address

7678 College Road, Suite 105

Willmar, MN 56201 Baxter, Minnesota 56425 Phone (320) 235-1970 Phone (218) 828-6076 Fax (320) 235-1986 Fax (218) 828-2594 E-mail [email protected] E-mail [email protected]

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: 4410.4300, subp.

29 (A), Animal Feedlots

http://www.pca.state.mn.us/news/eaw/index.html#open-eaw

mailto:[email protected]

mailto:[email protected]

Moore Lean LLP Environmental Assessment Stevens County, Minnesota 2 Worksheet

E. Project Location: County Stevens City/Twp Stevens SE 1/4 SE 1/4 Section 17 Township 123N Range 44W Watershed (name and 4-digit code):

23039 and 23028 of the Pomme de Terre Watershed

F. Attachments to the EAW:

• Attachment A: County map showing the general location of the project • Attachment B: U.S. Geological Survey 7.5 minute, 1:24,000 scale map indicating project

boundaries • Attachment C: Site plan showing all significant project and natural features • Attachment D: Map of manure application sites and all wells, tile inlets, residences, and sensitive

receptors within a one-mile radius of the feedlot or on manure land application sites • Attachment E: Air Emission Modeling Report The National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Permit Application and associated documents, which include the Air Emission Plan, Emergency Response Plan and the Manure Management Plan (MMP) are available for review at the following locations:

• MPCA Detroit Lakes Office, 714 Lake Avenue, Detroit Lakes, MN 56501 • Hancock Community Library, 662 Sixth Street, Hancock, MN 56244 • Morris Public Library, 102 East Sixth Street, Morris, MN 56267

G. Project summary of 50 words or less to be published in the EQB Monitor.

The proposed project (Project) will include two buildings for gestation and farrowing of swine. The gestation building will include 2,768 swine over 300 pounds, and the farrowing building will include 482 swine over 300 pounds. Both barns will be total confinement and have underfloor reinforced concrete manure storage. Manure will be land applied at agronomic rates to cropland. The total number of animal units proposed for the site is 1,300. A compost facility will be constructed to handle on-site animal mortalities. The site is located in Stevens County in the SE¼ of the SE¼ of Section 17 of Stevens Township.

H. Please check all boxes that apply and fill in requested data:

Animal Type Number Proposed Type of Confinement Finishing hogs

Sows 3,250 (1,300 AUs) Total confinement Nursery pigs Dairy cows Beef cattle Turkeys Layer hens Chickens Pullets Other (Please identify species)


I. Project magnitude data.

Total acreage of farm: Approximately 31 acres Number of animal units proposed in this project: 1,300 Total animal unit capacity at this location after project construction: 1,300 Acreage required for manure application: 740 acres

The Proposer has 1,099 acres of land available for application each year.

J. Describe construction methods and timing.

Moore Lean LLP plans to begin dirt work in the spring of 2007, assuming all applicable permits have been obtained. The manure storage areas will be constructed using reinforced concrete. The buildings will contain concrete slat floors and metal gating. The manure storage areas will have pit ventilation. The animal holding areas will be constructed for tunnel ventilation. Construction methods will follow building design engineer recommendations.

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. An additional 1,750 sows had been anticipated to be added to the site within 5 years. However, since submission of the EAW, the plan for this site has changed. Moore Lean LLP, now has no intentions or plans for expansion of this proposed site beyond the 3,250 sows in the EAW and NPDES permit application. The partners have exercised an option to purchase an existing site 75 miles away. This purchase will negate the need for any expansion of the proposed site.

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. Land surrounding the site is zoned and utilized for agriculture. There is a residence on the Project site, which is owned by the proposer that will be used for staff housing.

There are three residences within one mile of the proposed site. One residence three quarters of a mile north of the site, one residence one quarter mile southwest of the site and one residence one mile southeast of the site. There are two additional residences located within the manure application areas. One residence is one and a quarter miles north of the site and one residence is one and a half miles northwest of the site.


County State Aid Highway (CSAH) 15 is directly adjacent to the site on the east side. CSAH 8 is directly adjacent on the south side of the site. 300th Street (a township road) is three quarters of a mile north. 290th Street is one and three quarters miles north of site. 630th Avenue is one half mile west of site and 610th Avenue is one mile east of site. The manure application sites are adjacent to CSAH 15, CSAH 8 and Township Roads 62 & 75. Please see Attachment D for a map of the manure application acres.

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.

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 Minnesota Department of Health? 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 • 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.

There is a US Fish and Wildlife Protection Area located in the southwest quarter of Section 18 in Stevens Township that is adjacent to a portion of the manure application area. Several measures will be taken to ensure that this area will be protected. These include immediate injection or incorporation


of manure, utilizing the proper setbacks from waters, applying manure at agronomic rates, and the effective management of soil phosphorus. As a result of these measures, no impacts to the Wildlife Protection Area are anticipated.

3. Geologic and soil conditions.

A. Approximate depth (in feet) to: Feedlot Manure Storage Area Manure Application Sites Ground Water (minimum) 3.5’ 3.5’ 0.0’ (average) 3.2’ Bedrock (minimum) >8.5’ >8.5’ >8.5’ (average)

B. NRCS Soil Feedlot Manure Storage Area Manure Application Sites Classifications (if known) NhA,

Nutley-Hattie Complex 0-2%

NhA, Nutley-Hattie Complex 0-2%

NhA, Nutley-Hattie Complex 0-2%; Do, Dovray Clay; HnB, Hattie-Nutley Clay 2-6%; Dv, Dovray Clay

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. Feedlot Manure Storage Area Manure Application Sites Karst features (sinkhole, cave, resurgent spring, disappearing spring, karst window, blind valley, or dry valley);

No No No

Exposed bedrock; No No No Soils developed in bedrock (as shown on soils maps).

No No No

For items answered yes (in C), describe the features, show them on a map, and discuss proposed design and mitigation measures to avoid or minimize potential impacts.

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 Department of Natural Resources (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 will be a well abandoned and sealed on the western portion of the site.

The Project will include the installation of a new well, which will be installed by a licensed well driller. The total estimated water use of the Project at full production will be approximately 7.84 million gallons per year. MPCA has discussed the water usage proposed for the Project with the Minnesota


Department of Natural Resources (DNR) Area Hydrologist. Based on this conversation, the MPCA believes that the water supply is adequate for the Project and that there will not be any significant impacts related to water supply from the Project. In addition, a DNR Water Appropriations Permit will be applied for following well construction. The purpose of the DNR permit program is to ensure water resources are managed so that adequate supply is provided to long-range seasonal requirements for domestic, agricultural, fish and wildlife, recreational, power, navigational, and quality control. The permit program balances competing management objectives including both the development and protection of water resources. Minn. Stat. § 103G.261 establishes domestic water use as the highest priority of the state’s water when supplies are limited. If a well interference arises, the DNR has a standard procedure for investigating the matter. If a commercial operator is found to be causing the problem, the operator must correct it.

B. Will the project involve installation of drain tiling, tile inlets or outlets? Yes No If yes, describe.

As part of the engineered design plans, each of the proposed barns is to have a perimeter drain tile around them that flows to a dedicated sampling port. The perimeter tile is designed to protect the liquid manure storage areas from damage due to ground water. The MPCA has reviewed the plans and specifications for the liquid manure storage areas and determined that they comply with the requirements of Minn. R. ch. 7020, which were established to protect water quality. As an added precaution, the Project’s NPDES permit will require that the ground water from the perimeter tile be monitored weekly for signs of discoloration or odor. The weekly examinations will be recorded and any discoloration or odor changes in the tile line discharge will be reported immediately to the MPCA. The MPCA will then conduct an assessment to determine the source of the discoloration and/or odor change. Based on results of this assessment an appropriate course of action will be taken which could include ground water monitoring and inspection/repair of the concrete manure storage areas.

There will be surface intakes installed between the barns for the collection of rainwater from the roofs of the barns. Since all manure will be stored in concrete pits beneath the barns, none of the water should come in contact with manure prior to entering the surface intakes. These surface intakes will be connected to a stormwater basin, which will allow solids to settle out of the stormwater before it is discharged to Stevens County Tile #21. Stevens County Tile #21 outlets to Stevens County Ditch #21 approximately one mile from the site. County Ditch #21 connects to Artichoke Creek, which connects to Artichoke Lake approximately five miles from the site. Water from Artichoke Lake ultimately discharges to the Pomme de Terre River approximately 16 miles from the site.

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.

A small wetland was identified on the National Wetland Inventory map. Stevens County Environmental Services and a representative of the Minnesota Board of Water and Soil Resources conducted a site visit and identified the wetland to be a combination of a Type 1 and Type 2 wetland,


less than two acres in size. Since the definition of “Agricultural Land” in the Minnesota Wetland Conservation Act includes animal feedlots, these wetland types would qualify for an exemption as indicated in MN Rules 8420.0122, Subp1-D.

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 4.7 million gallons per year by swine over 300 lbs Frequency and duration of manure removal: number of days per cycle Up to 10 days Total days per year Up to 20 days

Give a brief description of how manures will be collected, handled (including methods of removal), and stored at this feedlot: All manure will be collected and stored in underfloor reinforced concrete pits. Manure will drop directly into the pits through slatted floors in the barns and be stored in the liquid form. Manure will be agitated and pumped via a towed hose or tank system to the land application sites. Manure will be incorporated using immediate injection or broadcast application with incorporation within 24 hours. All manure will be land applied by a Licensed Commercial Animal Waste Technician.

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 is planned to be removed once per year in the fall, after the crops have been harvested. Manure will be agitated and pumped via a towed hose or tank system to the land application sites. Manure will be incorporated using immediate injection or broadcast application with incorporation within 24 hours. All manure will be land applied by a Licensed Commercial Animal Waste Technician.

A map showing the location of land application areas for manure is shown in Attachment D.


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 applications rates will be based on the nitrogen needs of the crop. University of Minnesota recommendations will be used for determining allowable nitrogen application rates. Each manure applicator will be equipped with a flow meter to accurately measure the amount of manure being applied and ensure the desired manure application rate is achieved. Calibration of equipment used

for manure application will be conducted on a regular basis. Fields receiving manure will only receive commercial fertilizer when the nutrients from the manure are below crop needs (i.e., starter

fertilizer). Soil nitrate testing will be incorporated into the management of fields receiving manure. Soil

samples will be collected to a depth of two feet for soil nitrate testing, as recommended by the University of Minnesota document “Using the Soil Nitrate Test in Minnesota.” This document contains a flow chart that explains when the soil nitrate test can be used reliably for making nitrogen recommendations. Samples will be collected after harvest and results obtained prior to manure application so that adjustments can be made to planned application rates, as needed.

A certified crop advisor will interpret the results of soil nitrate testing and determine the manure application rates needed to satisfy crop nitrogen needs.

Soil phosphorus levels will be monitored. Soil samples will be collected prior to manure

application. Samples will be taken using the methods described by the Natural Resource Conservation Service document titled, “Soil Sampling and Fertilizer Recommendations” (Fact Sheet MN-NUTR3).

A certified crop advisor will oversee the soil sampling. Results of the analysis will be reviewed to determine if soil phosphorus levels are increasing over time. In special protection areas, as identified in the MMP, if soil phosphorus levels are greater than 21 parts per million (ppm) Bray, manure must be applied at rates that do not allow soil phosphorus levels to increase over a six-year period. Where field average phosphorus soil test levels exceed 75 ppm within 300 feet of an open tile intake, lake, stream, intermittent stream, drainage ditch without protective berms, or a public waters wetland, or exceed 150 ppm on any other land, then Manure must not be applied unless both a) and b) are met below:

a) Manure is managed so that phosphorus additions do not exceed crop phosphorus removal through such practices as dietary management, reduced rates, reduced frequency of applications, or other controls, as follows:

i. For surface applications without incorporation within 24 hours, annual phosphorus

application rates must not exceed crop phosphorus removal in the subsequent crop; and

ii. For injected or incorporated Manure (within 24 hours) Manure can not be re-applied

until phosphorus from the previous Manure application is removed by subsequent crops (based on MPCA estimates of crop phosphorus removal); and

b) Phosphorus transport is controlled by runoff and soil erosion prevention practices in

accordance with a phosphorus strategy documented in the MMP that achieves either:


i. A “very low” or “low” rating with the Minnesota Phosphorus Index originally developed for the animal agriculture GEIS and now found at www.mnpi.umn.edu; or

ii. Meets the NRCS Technical Standard 590 (May 2001) for soils exceeding the

phosphorus thresholds defined above (item 3.b.2).

If a soil phosphorous test exceeds 150 ppm outside of a special protection area, the MMP must be modified to reduce soil phosphorous levels over time. The proposer must reapply for coverage under an NPDES permit every 5 years. As part of that application, the proposer must submit an updated MMP, which includes the results of the most recent soil nutrient analysis.

3. Discuss the capacity of the sites to handle the volume and composition of manure. Identify any

improvements necessary. Annual manure generation is estimated at 4.7 million gallons at the completion of the Project based on previous experience with similar operations under the same management. The farrowing barn has an estimated storage volume of 2.0 million gallons and the gestation barn has an estimated volume of 3.6 million gallons, giving a total of 5.6 million gallons. The Project will have approximately 14 months of manure storage capacity. The MMP estimates that each year 740 acres of land will be required for the land application of manure, whereas the proposer has 1,099 acres of land available for application each year.

4. Describe any required setbacks for land application systems.

All MPCA and Stevens County manure land application setbacks will be observed. These setbacks are summarized in Table 1.

Table 1: MPCA and Stevens County Land Application Setback Distances (in feet) Non-Winter

With Immediate Incorporation (<24 hours)

Non-Winter Not incorporated within 24 hours

Feature Winter

With P Mgmt.

No P Mgmt. With Vegetated

Buffer

Inadequate Vegetated Buffer

Lake, Stream 300 25 300 100 300 Intermittent Stream* DNR protected wetlands** Drainage ditch w/o quarry*

300 25 300 50 300

Open Tile Intake 300 0 0 300 300 Well, Mine, or Quarry

50 50 50 50 50

Sinkhole with no Diversion

Downslope -50

Upslope -300

50 50 Downslope - 50

Upslope - 300

Downslope - 50 Upslope - 300

http://www.mnpi.umn.edu


* 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 http://www.terraserver.microsoft.com [January 28, 2005].

** 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.

Not Applicable.

6. Air/odor emissions.

A. Identify the major sources of air or odor emissions from this feedlot.

Manure collection and storage facilities, feed storage facilities, animal mortality composting facilities, and manure exposed to the air during land application, are the major sources of odor. Dust generated by truck/tractor traffic around the site can also be an odor vector.

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. Air mitigation measures will include: Stored manure will only be agitated immediately prior to the manure being removed for land application and the pit ventilation will be cleaned and serviced on a regular basis to reduce dust accumulation and discharge. During manure application: 1) A Commercial Animal Waste Technician licensed by the Minnesota Department of Agriculture will be used and all manure will be injected immediately or incorporated within 24 hrs to minimize the release of odors; 2) The number of days during which manure is applied will be kept to a reasonable minimum; and 3) Good manure application sanitation practices such as properly operating manure handling equipment to reduce/eliminate spillage. In addition, the proposer will maintain clean, dry floors; eliminate the buildup of manure; and clean up any spilled feed.

Recommended best management practices to be implemented for animal mortality compost facility include: utilizing sufficient carbon source (12” minimum cover over carcass); maintaining adequate temperature; and keeping compost material inside proper bunkers.

C. 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.

http://www.terraserver.microsoft.com


An air emission modeling study has been completed for this Project (Attachment E). The results suggest that the Project will comply with the ambient air quality standard for hydrogen sulfide. The results also suggest that the Project will not exceed the subchronic inhalation health risk value (iHRV) for hydrogen sulfide, the acute iHRV for ammonia and the chronic iHRV for ammonia. While the modeling results indicate that detectable concentrations of odorous gases can exist off site (e.g., ammonia), the estimated maximum concentration of total volatile odorous organic compounds for the modeled neighbor locations is 33 times less than the threshold concentration associated with unpleasant odors.

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. The proposers will avoid land application of manure during holidays and weekend and will notify neighbors when pumping and/or agitating manure storage areas if odor problems occur.

E. Noise and dust. Describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. Noise and dust from day to day activities within the facilities will not be significant beyond the property lines of the facilities. If dust from truck traffic and/or manure application becomes an issue, the proposer will use a dust suppressant to curb further dust emissions from the Project site.

7. Dead Animal Disposal

Describe the quantities of dead animals anticipated, the method for storing and disposing of carcasses, and frequency of disposal. When in full production, the anticipated number of mortalities will be between 225 and 260 mature sows per year. Each building will be inspected multiple times per day and dead animals will be removed immediately upon discovery. Composting will be the preferred method of mortality disposal. Construction of the compost facility is planned simultaneously with the construction of the other facilities. It will be constructed on an impervious weight bearing pad of sufficient size to service the mortalities from the site, as well as allow machinery to access the building to turn the compost pile. The heat from the compost pile, as well as the daily cover that will be applied should prevent rodents and scavengers from removing dead animals from the compost pile. All composting will be conducted according to Minnesota Board of Animal Health requirements. If rendering is utilized, a dead animal storage unit will be constructed that keeps mortalities from the view of the general public and prevents rodents and scavengers from reaching the dead animals. The rendering company will be called as needed as soon as mortalities are discovered.

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.

The quantity of stormwater runoff will increase as a result of the additional buildings and impervious surfaces at the site. The construction of the Project will require an NPDES Stormwater Construction Permit, which includes stormwater and erosion controls during construction, and a permanent stormwater


management system once the facility is constructed. The quality of the runoff leaving the site should improve based on the erosion control measures and removing the land from a crop production system and replacing it with permanent ground cover.

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. The proposer anticipates 5-7 heavy truck arrivals per week at the site. No road improvements are needed as there are County State Aid Highways adjacent to the Project site.

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/SDS Livestock Production Construction,

Operation and Stormwater Permit Pending

Stevens County Conditional use or other land use permit Pending Stevens County Septic System Permit Pending DNR Water Appropriation Pending

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. 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 whether the facility would contribute to any existing impaired surface waters or add to the total maximum daily load (TMDL) for surface waters in the watershed. The Project (proposed facility and land application areas) lies within the Pomme de Terre Watershed. There are two water bodies that appear on the TMDL 303d Impaired Waters List (TMDL List); Artichoke Lake and the Pomme de Terre River. Artichoke Lake is impaired for mercury and is approximately five miles form the site. The Pomme de Terre River, which is impaired for dissolved oxygen, fecal coliform bacteria and turbidity, is approximately 16 miles from the site.

The Project operators will follow the MPCA-approved MMP, which is designed to protect water resources and will be an enforceable part of the Project’s NPDES Permit. Because of the existing concern with dissolved oxygen, fecal coliform bacteria and turbidity, it is important to understand that even if a very small fraction of the manure that is land applied is washed off in some fashion, water quality standards may be violated. This highlights the importance of identifying all conduits to surface water and making sure setbacks and other protective measures are observed. The protective measures include: construction


of a permanent stormwater basin that will allow sediment to settle out prior to discharge; direct manure injection or incorporation within 24 hours, rather than surface application without incorporation; land application at rates that do not exceed crop nutrient needs, thereby reducing or eliminating the possibility that excess nutrients will reach the water resources; and setback distances to sensitive receptors. Table 1, in Section 4 of the EAW, shows the applicable MPCA and Stevens County land application setback distances, which, if properly implemented, will prevent the operation of the Project from resulting in a significant environmental impact on water quality. Hog manure is not a source of mercury contamination, so no significant impact is expected from the Project related to mercury contamination. In addition, the below barn manure storage areas are specifically designed to completely confine the manure and prevent any seepage into ground or surface waters.

Air Quality: The air modeling study that was conducted included one other swine feedlot nearest to the Project in the calculations. The study results suggest that the Project will comply with ambient air quality standards. Air quality computer modeling was performed that estimated concentrations in the air of Hydrogen Sulfide (H2S), Ammonia (NH3), and selected odorous gases from the existing offsite feedlots and the proposed facility. The model estimated pollutant concentrations from the facility and ambient H2S and NH3 background concentrations at the property line and nearest neighbors. A background concentration is the amount of pollutants already in the air from other sources and is used in this evaluation to address cumulative air impacts. Air emissions from other emission sources (e.g., other feedlots or land application activities) may affect the compliance status of the Project, or impact downwind human and environmental receptors. The background level for H2S that was used in the computer model was derived from ambient air quality monitoring at other feedlot facilities in Minnesota. The modeling adds the background air pollutant concentration to the emission concentration predicted from the Project. The results of the modeling study indicate that no significant air quality impacts are expected from the Project (Attachment F).

Antibiotic Use: Antibiotics will only be used therapeutically at this facility, and then only under the direction of a veterinarian. Flies and Other Insects: This facility will utilize a system where liquid manure is stored in underfloor pits. This method of manure storage does not promote the generation of flies because a crust is not likely to form in the pits. If flies do become a problem, the operators will implement industry standard control measures. Rodents and Scavengers: Bait stations will be utilized in close proximity to all buildings to control rodents. As described in Item 7 above, heat and covering the compost with sawdust will deter rodents and scavengers from reaching mortalities in the composting facility.

ATTACHMENT A

ATTACHMENT B

ATTACHMENT C

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LegendWetland Inventory

Wetland

Surface Water

Waterway / Ditch

Ownership of Manure Application Sites

Decamp

Fitzgerald

Carlson Hubert

A. Mumm

Brethorst

W. Mumm

L. Foss

Moore Lean

Wells/IntakesG Intake!( Well? Well to be Sealed

±1025 19th Ave SW - Suite AWillmar, MN 56201Office: 320-235-1970

ATTACHMENT D

Air Quality Modeling ReportMoore Lean LLP Sow Unit

Stevens CountyStevens TownshipSE ¼ Section 17

March 2006

ATTACHMENT E

Table of Contents

................................................................................................................Introduction 1

......................................................................................General Modeling Approach 3

..........................................................................................................Site Description 7

.......................................................................................Moore Lean Sow Site 7

...........................................................................................Neighbor Feedlot 10

....................................................Gas Emission Rates for the Modeled Hog Barns 12

.....................................................................................Moore Lean Sow Site 12

...........................................................................................Neighbor Feedlot 12

................................................Hydrogen Sulfide at Property Lines and Neighbors 14

............................................................Ammonia at Property Lines and Neighbors 17

....................................................Odorous Gases at Property Lines and Neighbors 20

...........................................Odor Intensity at South Property Line and Neighbor F 23

..................................................................................................................Summary 25

IntroductionAir quality modeling estimated the atmospheric concentrations of hydrogen sulfide, ammonia,

and selected odorous gases at the property lines for Moore Lean’s proposed sow feedlot and at 13 of the proposed feedlot’s nearest neighbors. The modeled emission sources for the proposed feedlot consisted of a gestation barn and a farrowing barn. The feedlot’s manure will be stored in concrete pits located beneath the hog barns. The modeling also considered the emissions from a nearby hog feedlot.

The following atmospheric concentrations were calculated:

1. the maximum hourly atmospheric hydrogen sulfide concentration at the proposed feedlot’s 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 13 of the proposed feedlot’s nearest neighbors to assess the potential to exceed Minnesota’s subchronic inhalation Health Risk Value (iHRV) of 10 µg/m3;

3. the maximum hourly atmospheric ammonia concentration at the proposed feedlot’s property lines to assess the potential to exceed Minnesota’s acute iHRV for ammonia of 3200 µg/m3;

4. the maximum annual-averaged atmospheric ammonia concentration at 13 of the proposed feedlot’s nearest neighbors to assess the potential to exceed Minnesota’s chronic iHRV for ammonia of 80 µg/m3; and

5. the hourly concentrations of selected odorous gases (including n-butyric acid and para-cresol) at the proposed feedlot’s property lines and at 13 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.

The CALPUFF modeling results suggest that the proposed Moore Lean sow site will comply with the Minnesota ambient air quality standard for hydrogen sulfide. CALPUFF predicted a maximum hourly property-line hydrogen sulfide concentration of 4.55 ppb (v/v). When a background concentration of 17 ppb (v/v) is added to the CALPUFF prediction, the maximum property-line hydrogen sulfide concentration is 21.55 ppb (v/v), which is below the ambient standard of 30 ppb (v/v).

1 Moore Lean Sow Unit Report

The CALPUFF results indicate that the proposed Moore Lean sow site 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 feedlot’s neighbors is 0.03 µg/m3. When a background concentration of 1.00 µg/m3 is added to the CALPUFF estimate, the maximum 13-week nearest-neighbor hydrogen sulfide concentration is 1.03 µg/m3, which is below the subchronic hydrogen sulfide iHRV of 10 µg/m3.

The modeling results also suggest that the proposed sow site will not create exceedences of the acute and chronic ammonia iHRVs. CALPUFF predicted a maximum hourly property-line ammonia concentration of 1,491 µg/m3. When a background concentration of 148 µg/m3 is added to the CALPUFF prediction, the maximum property-line ammonia concentration is 1,639 µg/m3, which is below the acute ammonia iHRV of 3,200 µg/m3. The estimated maximum one-year time-averaged ammonia concentration for the proposed feedlot’s neighbors is 3.70 µg/m3. When a background ammonia concentration of 5.72 µg/m3 is added to the CALPUFF estimate, the maximum annual ammonia concentration for a neighbor is 9.42 µg/m3, which is below the chronic ammonia iHRV of 80 µg/m3.

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.


General Modeling ApproachThe modeling approach explicitly considered the emissions from the proposed sow feedlot and

an existing hog feedlot. The air quality impacts associated with any non-modeled sources were implicitly considered as the background concentrations that are added to the modeling results. Hence, the background concentrations include the impacts associated with sources such as septic tank vents, small 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 040716) 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 (1987-1992) of surface meteorological data and upper air data from the National Weather Surface station in Huron, South Dakota. The surface and upper air weather data sets were combined into an ISC-type meteorological file4 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. Property-line receptors were ≤ 25 meters apart. An arbitrary Cartesian coordinate system (x, y) was used with the southwest corner of Section 17 (Stevens Township) as the origin (0, 0). Positive values of x represented distance east of the origin. Positive values of y represented 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


1 U.S. EPA. 1995. 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-95-006.

2 Scire J. S., Strimaitis D. G., and Yamarino R. J. 2000. A User’s Guide for the CALPUFF Dispersion Model (Version 5). Earth Tech, Inc., Concord, MA. 496 pp.

3 U.S. EPA. 2003. 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. 1999. PCRAMMET User’s Guide. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC. EPA-454-B-96-001 (Revised June 1999).

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 sulfide standard defines a violation as the third exceedence of 30-ppb within any 5-day period.




Table 1. Background concentrations.

Gas

HourlyBackground

Concentration

13-WeekBackground

Concentration

AnnualBackground

Concentration

Hydrogen Sulfide 17 ppb (v/v)(24.3 µg/m3)

0.70 ppb (v/v)(1.00 µg/m3)

Not Required

Ammonia 208 ppb (v/v)(148 µg/m3)

Not Required 8.07 ppb (v/v)(5.72 µg/m3)

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.

The odor-number assessment of odor intensity does not consider the interactions between gases. Gas mixtures can intensify or mitigate certain odors. The Zahn correlation9,10 was used to account for the odor intensity associated with the mixture of gases released from the manure pits.


8 Nagy G. Z. 1991. The odor impact model. Journal of Air & Waste Management Association 41(10): 1360-1362.

9 Zahn J. A. 1997. Swine odor and emissions from pork production. In: McGuire K. (ed.), Environmental Assurance Program, National Pork Producers Council, Des Moines, IA, pp. 20-122.

10 Zahn J. A., Hatfield J. L., Laird D. A., Hart T. T., Do Y. S., and DiSpirito A. A. 2001. Functional classification of swine manure management systems based on effluent and gas emission characteristics. Journal of Environmental Quality 30: 635-647.

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.

Table 2. Odor threshold concentrations for the modeled gases.11

Odorous Gas

Odor Threshold Concentration

(ppb, v/v)

Acetic Acid 200n-Propanoic Acid 17iso-Butyric Acid 11n-Butyric Acid 0.69iso-Valeric Acid 4.8n-Valeric Acid 0.28iso-Caproic Acid 7.7n-Caproic Acid 21n-Heptanoic Acid 5.0

Phenol 76para-Cresol 0.25para-Ethyl Phenol 1.2

Hydrogen Sulfide 3.7Ammonia 1,500


11 Minnesota Environmental Quality Board. 1999. 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 1999. Table 1 presents the geometric mean of the lower and upper odor threshold concentrations obtained from this reference.

Site Description

Moore Lean Sow SiteThe proposed Moore Lean sow site is a 28-acre parcel of land that is 1,676-ft long (east/west

direction) and 727-ft wide (north/south direction). The modeled emission sources consisted of a gestation barn and a farrowing barn. The physical characteristics of the barns are provided in Table 3. As shown in Figure 1, setback distances from the barns to the property lines range from 175 feet to 676 feet.

The air quality modeling estimated the atmospheric gas concentrations at the 13 neighboring residences shown in Figure 2.

Table 3. Dimensions and capacities of the proposed sow barns.

Barn

BarnLength(feet)

BarnWidth(feet)

BarnHeight(feet)

Number ofHousedSows

Gestation 354 162 28 2,768Farrowing 264 145 26 482


N

E

S

W

650'

672'

175'

165'

762'

80'

727'

1676

'

Ges

tatio

n Ba

rn

Farr

owin

g Ba

rn

(3,5

54',

50')

Figure 1. Modeled gaseous emission sources and property lines for the proposed Moore Lean sow site. The shaded squares represent the square volume subsources used to characterize the barns.


Figure 2. Modeled locations for 13 of the proposed feedlot’s nearest neighbors.


Neighbor FeedlotThe Neighbor Feedlot is located about 1.5-miles northeast of the proposed Moore Lean sow

site and consists of 7 hog barns: one gestation barn (GEST), two farrowing barns (FRW-1 and FRW-2), two nursery barns (NUR-1 and NUR-2), and two finishing barns (FIN-1 and FIN-2). The physical characteristics of the barns are provided in Table 4. The modeled locations of the barns are provided in Figure 3.

Table 4. Dimensions and capacities of the existing barns at the Neighbor Feedlot.

Barn

BarnLength(feet)

BarnWidth(feet)

BarnHeight(feet)

ModeledNumber of

Housed Pigs

GEST (gestation) 120 26 12 119s

FRW-1 (farrowing) 48 24 12 20s

FRW-2 (farrowing) 48 24 12 20s

NUR-1 (nursery) 42 8 10 150p

NUR-2 (nursery) 48 15 11 220p

FIN-1 (finishing) 114 30 13 450f

FIN-2 (finishing) 100 41 14 500f

s = sowsp = pigletsf = finishing pigs


165'

165'

165'

165'

150'

90'

125'

N

E

S

W

(9,832', 6,591')

739'

GEST

FRW-1

FRW-2

NUR-2NUR-1FIN-1

FIN-2

395'

Figure 3. Modeled gaseous emission sources and property lines for the existing Neighbor Feedlot. The shaded squares represent the square volume subsources used to characterize the barns. The green-bordered rectangle surrounding the barns is used to position the barns and does not represent the feedlot’s property lines.


Gas Emission Rates for the Modeled Hog Barns

Moore Lean Sow SiteThe sow barns at the proposed Moore Lean feedlot were modeled as sources of hydrogen

sulfide, volatile odorous organic compounds (VOOCs), and ammonia. The emission rates for hydrogen sulfide and 12 VOOCs were estimated based on the emission flux rates obtained from a hog-breeding site near Hancock, Minnesota12 and on the floor surface area of the modeled barn.

The ammonia emission rates from the 2 proposed sow barns were based on the “stable + manure” ammonia emission factor of 8.09 kg NH3/sow/year (Tables 2-1 and 2-9, Battye et al., 1994).13 This emission factor represents ammonia emissions on an annual basis. To account for the reported temperature effects on ammonia emissions, the annual ammonia emission rates were multiplied by the monthly scalars developed by the Minnesota Pollution Control Agency.

Neighbor FeedlotThe gestation barn, the two farrowing barns, the two nursery barns, and the two finishing barns

at the Neighbor Feedlot were modeled as sources of hydrogen sulfide, VOOCs, and ammonia. All seven of the barns will be treated as having a manure pit beneath the entire barn, although four of the barns have partial pits. For the gestation, farrowing, and nursery barns, the emission rates for hydrogen sulfide and the VOOCs were estimated based on the emission flux rates obtained from a hog-breeding site near Hancock, Minnesota14 and on the floor surface area of the modeled barn. For the finishing barns, the emission rates of hydrogen sulfide and the VOOCs from the manure pit were estimated using the PitEmissions software (version 4.1) based on the chemical characteristics of manure stored in pits located beneath the hog-finishing barns. PitEmissions is based on the mass-transfer algorithms recommended by the U.S. EPA to estimate emission rates.15 For west-central Minnesota, the typical characteristics of stored hog manure are provided in Table 5.


12 MPCA. 2003. Hancock Pro-Pork Hog Feedlot Project. Final Environmental Impact Statement. Minnesota Pollution Control Agency, September 15, 2003.

13 Battye R., Battye W., Overcash C. and Fudge S. 1994. Development and selection of ammonia emission factors. Final Report. Prepared by EC/R Incorporated, Durham, NC for the U. S. Environmental Protection Agency, Office of Research and Development, Washington D.C., 112 pp.


15 U.S. EPA. 1994. Air Emissions Models for Waste and Wastewater. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-453/R-94-080A.

Table 5. Chemical characteristics of manure in pitted hog-finishing barns.16

Parameter Units Value

Temperature °C 10.5pH -log10[H+] 7.2Volatile acids mg HOAc/L 19,0004-AAP phenolics mg/L 64.1Total dissolved sulfide mg S/L 13.8

The annual ammonia emission rates for the gestation and farrowing barns at the Neighbor Feedlot were based on the “stable + manure” ammonia emission factor of 8.09 kg NH3/sow/year (Tables 2-1 and 2-9, Battye et al., 1994).17 Battye et al. (1994) does not provide an ammonia emission factor for nursery pigs. However, an emission factor of 2.42 kg NH3/hear/yr for breeding sows of 20-50 kg is provided. This lower value was used as the ammonia emission factor for nursery pigs. For the finishing barns at the Neighbor Feedlot, the ammonia emission rate was based on the finishing-pig ammonia emission rate factor of 3.7 kg NH3/head/yr.18 The three emission factors represent ammonia emissions on an annual basis. To account for the reported temperature effects on ammonia emissions, the annual ammonia emission rates were multiplied by the monthly scalars developed by the Minnesota Pollution Control Agency.



17 Battye R., Battye W., Overcash C. and Fudge S. 1994. Development and selection of ammonia emission factors. Final Report. Prepared by EC/R Incorporated, Durham, NC for the U. S. Environmental Protection Agency, Office of Research and Development, Washington D.C., 112 pp.

18 U.S. EPA. 2002. Review of Emissions Factors and Methodologies to Estimate Ammonia Emissions from Animal Waste Handling. U.S. Environmental Protection Agency, Office of Research and Development, Research Triangle Park, NC, EPA-600/R-02-017.

Hydrogen Sulfide at Property Lines and NeighborsThe CALPUFF results suggest that the proposed Moore Lean sow feedlot will comply with the

Minnesota ambient air quality standard for hydrogen sulfide. The estimated maximum hourly property-line concentrations for the proposed feedlot are provided in Table 6. When a background concentration of 17 ppb (v/v) is added to the CALPUFF-generated concentrations, the maximum estimated property-line hydrogen sulfide is 21.55 ppb, which is below the standard of 30 ppb.

Table 6. Maximum hourly property-line hydrogen sulfide concentrations.

Property Line

H2S ConcentrationWithout Background

(ppb, v/v)

H2S ConcentrationWith a 17 ppb (v/v)Background Value

(ppb, v/v)

North 4.19 21.19East 2.30 19.30South 4.55 21.55West 2.22 19.22

The maximum CALPUFF-generated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 4. The plotted 3-ppb concentration isopleth overestimates the maximum extent of detectable hydrogen sulfide odors without background, because the reported odor threshold concentration for hydrogen sulfide is 3.7 ppb (Table 2). Figure 4 suggests that detectable concentrations of hydrogen sulfide will exist off-site.

The CALPUFF results also suggest that the emissions from the proposed Moore Lean feedlot will not cause exceedences of the subchronic hydrogen sulfide iHRV at the neighboring residences. The estimated maximum 13-week time-averaged hydrogen sulfide concentrations for each of the 13 modeled nearest neighbors are provided in Table 7. When a background concentration of 1.00 µg/m3 is added to the CALPUFF-generated concentrations, the maximum


13-week hydrogen sulfide concentration is 1.03 µg/m3, which is below the subchronic iHRV for hydrogen sulfide of 10 µg/m3.

3

3

6

-1

0

1

2

-1 0 1 2

Nor

th/S

outh

Dis

tanc

e (m

iles)

East/West Distance (miles)

Figure 4. Maximum CALPUFF-generated hourly hydrogen sulfide concentrations in ppb (v/v) for the proposed Moore Lean sow feedlot and the existing Neighbor Feedlot. The contour lines represent 3 and 6 ppb (v/v) of hydrogen sulfide. The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration. The point (0, 0) is the southwest corner of Section 17.


Table 7. Maximum 13-week time-averaged hydrogen sulfide concentrationsfor 13 of the feedlot’s nearest neighbors.

Neighbor

Maximum 13-week H2SConcentration Without

Background(µg/m3)

Maximum 13-Week H2SConcentration With a

1.00 µg/m3 Background(µg/m3)

A 0.01 1.01B 0.01 1.01C 0.01 1.01D 0.01 1.01

E 0.02 1.02F 0.03 1.03G 0.01 1.01H 0.01 1.01I 0.01 1.01

J 0.03 1.03K 0.00 1.00L 0.01 1.01M 0.01 1.01


Ammonia at Property Lines and NeighborsThe CALPUFF-generated maximum hourly property-line ammonia concentrations are

provided in Table 8. The highest estimated property-line concentration with a background concentration of 148 µg/m3 is 1,639 µg/m3, which is below the acute iHRV for ammonia of 3,200 µg/m3. Thus, the modeling results suggest that the proposed Moore Lean feedlot will not result in exceedences of the acute ammonia iHRV.

Table 8. Maximum hourly property-line ammonia concentrations.

Property Line

NH3 ConcentrationWithout Background

(µg/m3)

NH3 ConcentrationWith a 148 µg/m3

Background Value(µg/m3)

North 1,491 1,639East 1,046 1,194South 1,386 1,534West 1,036 1,184

The maximum CALPUFF-generated hourly ammonia concentrations (without background) are plotted in Figure 5. The reported odor threshold concentration for ammonia is 1,067 µg/m3 or 1,500 ppb v/v (Table 2). The plotted 1,000-µg/m3 isopleth overestimates the maximum extent of detectable ammonia odors. Figure 5 indicates that detectable concentrations of ammonia will be limited to immediate vicinity of the proposed feedlot.

The CALPUFF-generated annual-average ammonia concentrations for the proposed feedlot’s 13 nearest neighbors are provided in Table 9. The highest annual ammonia concentration with a background concentration of 5.72 µg/m3 is 9.42 µg/m3, which is below the chronic ammonia iHRV of 80 µg/m3.


500

500

1000

1000

-1

0

1

2

-1 0 1 2

Nor

th/S

outh

Dis

tanc

e (m

iles)


Figure 5. Maximum CALPUFF-generated hourly ammonia concentration in µg/m3 for the proposed Moore Lean feedlot and the existing Neighbor Feedlot. The contour lines represent 500 and 1000 µg/m3 of ammonia. The plotted concentrations do not include the 148 µg/m3 background ammonia concentration. The point (0, 0) is the southwest corner of Section 17.


Table 9. Maximum annual nearest-neighbor ammonia concentrations.

Neighbor

NH3 ConcentrationWithout Background

(µg/m3)

NH3 ConcentrationWith a 5.72 µg/m3

Background Value(µg/m3)

A 0.62 6.34B 0.68 6.40C 0.92 6.64D 0.84 6.56

E 1.70 7.42F 1.62 7.34G 0.78 6.50H 0.78 6.50I 0.77 6.49

J 3.70 9.42K 0.38 6.10L 0.62 6.34M 0.52 6.24


Odorous Gases at Property Lines and NeighborsThe CALPUFF modeling effort estimated the ground-level atmospheric concentrations of

selected odorous gases at the property lines for the proposed Moore Lean feedlot and at 13 of the feedlot’s nearest neighbors. The estimated maximum property-line concentrations for the 6 gases with the highest concentrations relative to their odor threshold concentration are provided in Figure 6. The highest property-line concentrations are for ammonia (2,295 ppb, which includes a background concentration of 208 ppb), hydrogen sulfide (21.55 ppb, which includes a 17 ppb background concentration), propanoic acid (0.42 ppb), n-butyric acid (0.22 ppb), para-cresol (0.07 ppb), and n-valeric acid (0.04 ppb).

The corresponding odor numbers for the maximum property-line concentrations are provided in Figure 7. The gases with an odor number greater than 0.1 were hydrogen sulfide (5.82), ammonia (1.53), n-butyric acid (0.32), para-cresol (0.29), and n-valeric acid (0.13). The other modeled gases are assumed to be non-detectable as individual gases, because their individual odor numbers were less than 0.1. Population response curves suggest that 98 percent of the population could detect the estimated maximum property-line hydrogen sulfide concentration, 73 percent the property-line ammonia concentration, 6 percent the n-butyric acid concentration, 5 percent the property-line para-cresol concentration, and 1 percent the n-valeric acid.

The estimated maximum hourly nearest-neighbor concentrations for the 6 gases with highest concentrations relative to their odor threshold concentration are provided in Figure 8. The highest maximum estimated neighbor concentrations were for ammonia (790 ppb, which includes a background concentration of 208 ppb), hydrogen sulfide (18.15 ppb, which includes a background concentration of 17 ppb), propanoic acid (0.17 ppb), n-butyric acid (0.10 ppb), para-cresol (0.05 ppb), and n-valeric acid (0.02 ppb).

The calculated odor numbers corresponding to the maximum nearest-neighbor concentrations are provided in Figure 9. The individual gases with an odor number greater than 0.1 were hydrogen sulfide (4.91), ammonia (0.53), para-cresol (0.19), and n-butyric acid (0.15). The other modeled gases are assumed to be non-detectable, because their individual odor numbers were less than 0.1. Population response curves suggest that 98 percent of the population could detect the estimated maximum nearest-neighbor hydrogen sulfide concentration, 18 percent the ammonia concentration, 2 percent the para-cresol concentration, and 1 percent the n-butyric acid concentration. The population response curves assume the presence of individual gases.


Propanoic

Acid

Butyric

Acid

Valeric

Acid

para-

Cresol

Hydrogen

Sulfide

Ammonia

0.01

0.1

1

10

100

1,000

10,000

Gas

Con

cen

trati

on

(p

pb

, v/v

)

Figure 6. Maximum hourly property-line concentrations.

Propanoic

Acid

Butyric

Acid

Valeric

Acid

para-

Cresol

Hydrogen

Sulfide

Ammonia

0.01

0.1

1

10

100

Od

or N

um

ber

Figure 7. Maximum hourly property-line odor numbers.


Propanoic

Acid

Butyric

Acid

Valeric

Acid

para-

Cresol

Hydrogen

Sulfide

Ammonia

0.01

0.1

1

10

100

1,000

10,000

Gas

Con

cen

trati

on

(p

pb

, v/v

)

Figure 8. Maximum hourly nearest-neighbor concentrations.

Propanoic

Acid

Butyric

Acid

Valeric

Acid

para-

Cresol

Hydrogen

Sulfide

Ammonia

0.01

0.1

1

10

100

Od

or N

um

ber

Figure 9. Maximum hourly nearest-neighbor odor number.


Odor Intensity at South Property Line and Neighbor FThe empirical Zahn correlation relates the total gas-phase volatile odorous organic

concentration (VOOC) for the gases emitted from manure storage facilities to the perceived odor intensity as determined by odor panels. The sum of the individual maximum VOOC concentrations from the CALPUFF modeling effort was multiplied by 1.18 to account for all of the VOOC gases included in the Zahn correlation. As indicated in Figure 10, the maximum VOOC concentrations (with the 1.18 correction) obtained from CALPUFF are 5.8 µg/m3 for the proposed Moore Lean feedlot’s south property line and 2.1 µg/m3 for Neighbor F.

1

3

5

7

9

0.1 1 10 100 1,000 10,000

Odo

r In

tens

ity

Total VOOC Concentration (!g/m3)

Zahn

SouthProperty-Line

Neighbor F

Unbearable

Very Unpleasant

Unpleasant

Neutral

Pleasant

Figure 10. Comparison of CALPUFF-generated maximum hourly total VOOC concentrations for the proposed Moore Lean feedlot’s south property line and for the modeled location of Neighbor F. The modeling results suggest that the proposed feedlot will not create offensive off-site odors.

The Zahn correlation suggests that a total VOOC concentration of about 10 µg/m3 corresponds to a detectable but “neutral” odor intensity. Total VOOC concentrations have to exceed about 70 µg/m3 before the odor intensity is “unpleasant.” At the proposed feedlot’s south property-line,


the maximum CALPUFF-generated total VOOC concentration is 12 times less than the total VOOC concentration associated with “unpleasant” odor intensities. At the modeled Neighbor-F location, the CALPUFF-generated total VOOC concentration is 33 times less than the total VOOC concentration associated with “unpleasant” odor intensities. Thus, the CALPUFF modeling results suggest that the proposed feedlot’s property-lines and nearest neighbors will not be subjected to offensive odors.

The maximum CALPUFF-generated hourly total VOOC concentrations (with the 1.18 correction factor) are plotted in Figure 11. The Zahn correlation suggests that a total VOOC concentration of about 10 µg/m3 can be considered as the odor detection threshold. Figure 11 suggests that detectable total VOOC concentrations (greater than 10 µg/m3), if present, are limited to the proposed Moore Lean sow site.

3

3

10

-1

0

1

2

-1 0 1 2

Nor

th/S

outh

Dis

tanc

e (m

iles)


Figure 11. Maximum CALPUFF-generated hourly total VOOC concentrations in µg/m3 for the proposed Moore Lean feedlot and the existing Neighbor Feedlot. The plotted concentrations do include the 1.18 correction factor. The point (0, 0) is the southwest corner of Section 17.


SummaryThe CALPUFF modeling results suggest that the proposed Moore Lean sow feedlot will

comply with the ambient air quality standard for hydrogen sulfide. The CALPUFF results also suggest that the feedlot will not create exceedences of the subchronic iHRV for hydrogen sulfide, the acute iHRV for ammonia, and the chronic iHRV for ammonia. While the CALPUFF modeling results indicate that detectable concentrations of odorous gases can exist off site, the estimated maximum concentration of total VOOCs for the modeled neighbor locations is 33 times less than the threshold concentration associated with unpleasant odors.


Moore Lean, LLP, Environmental Assessment Worksheet · Moore Lean LLP Environmental Assessment...

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