Big Stone Hutterite Brethren Feedlot Expansion - Minnesota Pollution

Big Stone Hutterite Brethren Feedlot Expansion - Minnesota Pollution

Alternative EAW Form for Animal Feedlots ENVIRONMENTAL ASSESSMENT WORKSHEET Note to reviewers: The Environmental Assessment Worksheet (EAW) provides...

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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:

B.

Feedlot Proposer:

Big Stone Hutterite Brethren Feedlot Expansion

Big Stone Hutterite Brethren

Technical Contact Person

Dennis Johnson, P.E.

C.

RGU: Contact Person

Jim Sullivan

and Title

Civil Engineer Wenck Associates, Inc.

and Title

Planner

Address

P.O. Box 453, 440 10th Street

Address

520 Lafayette Road North

Windom, Minnesota 56101

D.

Minnesota Pollution Control Agency

St. Paul, Minnesota 55155-4194

Phone

507-831-2703

Phone

651-297-1788

Fax

507-831-5271

Fax

651-297-2343

E-mail

[email protected]

E-mail

[email protected]

(check one)

Reason for EAW Preparation: EIS Scoping

Mandatory EAW

X

Citizen Petition

If EAW or EIS is mandatory give EQB rule category subpart number and name:

RGU Discretion

Proposer Volunteered

Minn. R. 4410.4300, subp. 29A

p-ear1-05 TDD (for hearing and speech impaired only): 651-282-5332 Printed on recycled paper containing 30% fibers from paper recycled by consumers

E.

Project Location: NW SW

¼ ¼

Big Stone

County Section Section

Watershed (name and 4-digit code):

29 20

Township

City/Twp T106N

Graceville Range

R45W

Bois de Sioux 54032

F. Attach each of the following to the EAW: Exhibit 1. Map of the Big Stone County, showing general location of the project Exhibit 2. Site plan, showing significant project and natural features, including wells, tile inlets, manure storage basin, and stormwater sedimentation and erosion control basins Exhibit 3. United States Geological Survey (USGS) topographic map showing neighbors in the one-mile radius of the feedlot Exhibit 4. Map showing location of manure acres and USGS topographic maps showing manure acres Exhibit 5. Minnesota Department of Natural Resources (DNR) map showing wildlife and public recreation areas Exhibit 6. Air Emission Modeling Report Exhibit 7 DNR Natural Heritage database letter Exhibit 8 Minnesota Historical Society letter Exhibit 9 Cumulative Potential Effects Map The National Pollutant Discharge Elimination System (NPDES)/State Disposal System (SDS) Permit Application and associated documents, which include the Air Emission Plan, Emergency Response Plan, and MMP are available for review at the following locations: • •

The MPCA’s St. Paul Office, 520 Lafayette Road North, St. Paul, Minnesota The MPCA’s Willmar Office, 1601 Highway 12 East, Suite 1, Willmar, Minnesota

G. Project summary of 50 words or less to be published in the EQB Monitor. Big Stone Hutterite Brethren (Project Proposer), is proposing an expansion to their existing facility, which will include three 600-foot long by 68-foot wide turkey barns, one 132- foot long by 60-foot wide starter turkey barn expansion, one 573-foot long by 154-foot wide by 3-foot deep hog barn, two additions to an existing 58-foot by 462-foot hog barn (1 – 73-foot by 41-foot addition, 1 – 74-foot by 46-foot addition), and one 32-foot long by 32-foot wide by 16-foot deep sump pit. The Project Proposer will be abandoning an existing 54-foot by 490-foot hog barn. Manure from the hog buildings will be pumped to an existing two-cell earthen storage basin. The 160-foot long by 240-foot wide turkey manure compost bunker and 100-foot by 20-foot mortality compost bunker were constructed in the fall of 2007, which was designed and constructed to meet the needs of the proposed expansion. When completed, there will be 21,200 starter turkeys (less than 5 pounds), 48,755 finisher turkeys, 1,010 sows, 2,908 nursery pigs, 4,835 finish pigs, 500 layer chickens, and 2,000 broiler chickens at the facility, for a total of 2,995.99 animal units (AUs).

Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

H. Please check all boxes that apply and fill in requested data: Animal Type Finishing hogs Sows Nursery pigs Dairy cows Beef cattle Turkeys Layer hens Chickens Pullets Other (Please identify species) I.

Number Proposed 5,090 876 2,450

Type of Confinement

70,800

Project magnitude data. 5,495.0 Total acreage of farm: 947.49 Number of AUs proposed in this project: Total AU capacity at this location after project construction: 4,924.0 Acreage required for manure application:

2,995.99

J. Describe construction methods and timing. The Project Proposer plans to begin dirt work in the spring of 2008, assuming all applicable permits have been obtained. Dirt work will include hauling in base gravel for the barns and driveways. The three proposed turkey barns, expansion of the existing starter turkey barn will begin in early summer 2008. Operation of these barns will begin in the fall of 2008. When all the turkey barns are completed, the turkey capacity will be 21,200 starter turkeys (less than 5 pounds) and 48,755 finisher turkeys (over 5 pounds). Construction on the hog barn will begin in the spring of 2009. When all of the hog barns have been completed, the hog capacity will be 1,010 sows, 2,908 nursery pigs, and 4,835 finisher pigs. The compost and animal mortality facility was constructed in the fall of 2007 to provide immediate storage for existing turkey litter, chicken litter, and all dead animal storage. This facility was designed and constructed to meet the needs of the proposed expansion. 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 AUs, and type of operation) and any past environmental review or the anticipated expansion. The Project Proposer plans to expand their existing facility. The site currently has three hog barns (east side of road), seven turkey barns (four on the east side of the road and three on the west side of the road), one chicken barn (west side of road), an earthen basin (east side of road), a compost and mortality bunker (east side of road), and several other building and bins. The three turkey barns on the west side of the county road will be abandoned.

Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

The three hog barns currently house 2,300 nursery pigs, 3,500 finisher pigs and 650 gestating sows. The existing barns are 54 feet by 490 feet, 58 feet by 166 feet, and 58 feet by 462 feet. Manure from the existing hog buildings is pumped to an existing two-cell earthen basin. The existing two-cell earthen basin has a holding capacity of 3,388,955 cubic feet. The existing hogs produce 415,370 cubic feet of waste per year and have an anaerobic digestion volume needed of 1,616,250 cubic feet, for a total volume needed of 2,031,620 cubic feet. The Project Proposer is proposing an expansion to their existing facility, which will include one 573foot long by 154-foot wide by 3-foot deep hog barn, which will discharge into a 32-foot long by 32-foot wide by 16-foot deep sump pit with pumps capable of pumping to the existing earthen basin. There will be two additions to an existing 58-foot by 462-foot hog barn, a 73-foot by 41-foot addition, and a 74foot by 45-foot addition. Manure from these additions will discharge into the existing underground pumping system and pumped to the existing lagoon. The existing 54-foot by 490-foot pig barn will be abandoned. The existing and proposed hogs will produce 595,644 cubic feet of waste per year. Based on the animal weight capacity and volatile solid production, the anaerobic digestion volume needed is 2,306,775 cubic feet, for a total volume needed of 2,902,419 cubic feet, which is less than the 3,388,955 cubic feet of storage available. The seven turkey barns currently house 9,500 starter turkeys and 32,000 finisher turkeys. The existing barns are 400 feet by 80 feet, 400 feet by 76 feet, 432 feet by 70 feet, 260 feet by 60 feet, 2 – 350 feet by x 60 feet, and 213 feet by 50 feet. The 2 – 350-foot by 60-foot and 213-foot by 50-foot barns will be abandoned. Manure from the existing turkey barns are stockpiled in the recently completed manure composting bunker. The Project Proposer is proposing an expansion to their existing facility, which will include three 600foot long by 70-foot wide turkey barns, and one 132-foot long by 60-foot wide starter turkey barn expansion. The existing and proposed turkey barns will be scraped after every flock and stored in the recently completed manure composting bunker. The existing chicken barn currently houses 500 layer chickens and 2,000 broiler chickens. The existing barn is 50 feet by 90 feet. The primary function of the barns is for non-commercial use. Manure from the existing barn is stockpiled on the recently completed manure composting bunker. The existing 166-foot long by 240-foot wide turkey manure compost bunker and 100-foot by 50-foot mortality bunker were constructed in the fall of 2007. This facility was designed and constructed to meet the needs of the proposed expansion. When completed, there will be 21,200 starter turkeys (less than 5 pounds), 48,755 finisher turkeys, 1,010 sows, 2,908 nursery pigs, 4,835 finish pigs, 500 layer chickens, and 2,000 broiler chickens at the facility, for a total of 2,995.99 AUs. 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 one-mile area surrounding the project site and all land for spreading manure is zoned agricultural. There are two residences within one mile of the site. The first residence is approximately 1,893 feet southeast of the site. The second residence is 2,951 feet southeast of the site. There is a county road on the west side of the site. The Project Proposer maintains housing on the site, which accommodates approximately 85 people.

Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

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 plan1 land use plan or ordinance2 shoreland zoning ordinance3 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 No. ordinance or plan checked? Yes If yes, describe the inconsistency and how it will be resolved. The existing feedlot is within the 1,000-foot jurisdiction of the shoreland zoning ordinance. The proposed expansion is not in the shoreland zone. OFFSET Evaluation The amount of odor emitted from a particular farm is a function of animal species, housing types, manure storage and handling methods, the size of the odor sources, and the implementation of odor control technologies. However, the impact of these odors on the surrounding neighborhood or community is a function of both the amount of odor emitted and the weather conditions. Weather conditions strongly influence the movement and dilution of odors. Odor impact includes the strength of the odors and the frequency and duration of the odor events. OFFSET combines odor emission measurements with the average weather conditions to estimate the strength and frequency of odor events at various distances from a given farm. OFFSET is intended to determine the estimated odor frequencies occurring at various distances from an animal production site. The odor emission factor includes both animal buildings and/or manure storage units at a particular site. The procedure accounts for species, housing types and sizes, manure storage types and sizes, and odor control technologies used at the site. Once the total emission factor is established, an additional step is needed to determine the setback distance using an odor frequency curve. Different odor annoyance-free frequencies result in different setback distances for the same TOEF (Total Odor Emissions Factor). Odor annoyance-free frequencies of 99 percent, 98 percent, 97 percent, 96 percent, 94 percent, and 91 percent correspond to 7, 15, 22, 29, 44, and 66 hours/month of annoying odors during the months of April through October. During the winter months, less frequent odor events can be expected due to the reduced odor emissions during cold weather. Since these predicted frequencies are based on "average" weather conditions, actual frequencies of odor events may be different. The proposed site has an annoyance free factor of 94 percent, which complies with the applicable Big Stone County ordinance.

1

See generally the Draft Big Stone County Draft Comprehensive Plan adopted September 16, 2002. The Project Proposer is in compliance with the applicable provisions of the comprehensive land use plan. 2 See generally the Big Stone County Ordinance Section IV regarding area regulations for new feedlots. The evaluation is required to maintain a nuisance odor-based setback distance using the OFFSET evaluation tool. The Project Proposer is in compliance with the applicable provisions of the comprehensive land use plan. 3 Big Stone County Ordinance Section IV, A.7. (2003) requires a livestock operation to maintain a setback of “Two miles from the Ordinary High Water Level of Big Stone Lake.” The Project, as proposed, is in compliance with this setback. Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

Are there any lands in proximity to the feedlot that are officially planned for or zoned for future Yes No uses that might be incompatible with a feedlot (such as residential development)? 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 Yes No Health (MDH)? 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 Yes No colonies or regionally rare plant communities? 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. According to Joyce Hedlin of the Marshall MDH office, there are six Drinking Water Supply Management Areas within three miles of the site. 1) Toqua County Park (located northeast of site) 2) Graceville County Golf Course (located northeast of site) 3) City of Graceville – four community wells (located northeast of site) A search of the DNR Natural Heritage database revealed that the following rare plants or animal species or other significant natural features are within an approximate one-mile radius of the proposed facility: o o o o

Double-Crested Cormorant Great Blue Heron Eared Grebe Prairie Mimosa

The Project Proposer will not be disturbing any existing natural habitat for the species identified above. The acres used for land application have been farmed for decades. The proposed livestock unit will be constructed on land that is currently under agricultural production. The Endangered Species Environmental Review Coordinator for the DNR stated in her letter that, “based on the nature and location of the proposed project I do not believe it will affect any known occurrences of rare features.” A copy of the DNR Natural Heritage database correspondence is found in Exhibit 7. A letter was also received from the Minnesota Historical Society stating no archaeological sites were identified in the project area. A copy of the letter is found in Exhibit 8.

Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

3. Geologic and soil conditions.4 A. Approximate depth (in feet) to: Ground Water (minimum) (average) Bedrock (minimum) (average) B. NRCS Soil

Feedlot 2-4 3 > 150

Manure Storage Area 2-4 3 > 150

Manure Application Sites 2-4 3 > 150

Feedlot

Manure Storage Area CL-ML

Manure Application Sites

CL-ML

Classifications (if known)

Various

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) Exposed bedrock Soils developed in bedrock (as shown on soils maps)

Feedlot No

Manure Storage Area No

No No

No No

Manure Application Sites No

No No

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. The Project Proposer currently operates two wells, one located in the NE¼ of the NE ¼ of Section 30, T124N, R46W, which is west of the proposed site. This well is approximately 291 feet in depth and is cast to a depth of 276 feet, screened to a depth of 291 feet and a static water level depth of 60 feet. The casing diameter is 8 inches. This well is identified through a MDH Unique number (543946). The second well is located in the SE¼ of the SE¼ of Section 19, T124N, R46W, which is west of the proposed site. This well is approximately 274 feet in depth and is cast to a depth of 254 feet, screened to a depth of 274 feet and has a static water level depth of 59 feet. The casing diameter is 8 inches. This well is identified through a MDH Unique number (513026). The Project Proposer indicates that they will require approximately 8 million gallons of water per year, or 200 million gallons for the 25-year service life of the project. The current use of the wells provides approximately 3 million gallons of water per year, or a total of approximately 75 million gallons over a 25-year service life. The combined total amount of water withdrawn per year from these wells is 4

The depth to ground water at the feedlot/manure storage area was assessed from soil boring data collected at the site. The depth to ground water at the land application sites was determined from the Big Stone County soil survey. Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

projected to be 11 million gallons of water per year, or 275 million gallons over the 25-year service life of the existing and proposed project. Based on MPCA information, the area obtains ground water “…from three principal sources: near surface sand and gravel aquifers, buried sand aquifers, and aquifers within Cretaceous deposits.”5 (sic). Recharge of the three sources is considered to be predominantly precipitation. Average precipitation is reported as between 22 to 24 inches a year, which is suitable for recharging the aquifer based on projected appropriation in the area.6 The Project Proposer has an existing DNR Water Appropriations Permit (Permit # 894097). Under this permit they can use up to 11.4 million gallons per year (31,200 gallons per day). The existing use is 8,300 gallons per day. The additional use is 21,700 gallons per day, for an overall total of 30,000 gallons per day for the entire project. In addition, the Project Proposer will be installing drain tile around the proposed sites for dewatering. B. Will the project involve installation of drain tiling, tile inlets or outlets? If yes, describe.

Yes

No

The project will require the use of a perimeter tile to control hydrostatic pressure as there is a greater than two-foot separation distance between the bottom of the manure storage structure and the water table. Specifically, the perimeter tile will be installed as the 16-foot deep day pit-transfer point to the existing earthen storage basin will be within the seasonal water table. 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 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)

5

Gunderson, L. (2006). Minnesota Pollution Control Agency – Minnesota River Basin – Upper Minnesota River Watershed. St. Paul, Minnesota. 6 Gunderson, L. (2006). Minnesota Pollution Control Agency – Minnesota River Basin – Upper Minnesota River Watershed. St. Paul, Minnesota. Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

B. Manure collection, handling, and storage. Quantities of manure generated: total

Hog (liquid) 4,500,000 gallons per year

Turkey Pile 3,115 tons per year

Frequency and duration of manure removal: number of days per cycle 10 Total days per year

Chicken Pile 35 tons per year 10

Give a brief description of how manures will be collected, handled (including methods of removal), and stored at this feedlot: The hog barns have an underground piping system that pumps manure to the earthen manure storage structure. In addition, the proposed hog barn will be equipped with an air cooling system that will help remove odor. The proposed hog barn will have all roof fans (no pit fans), which will help control odor. The manure from the turkey barns will be scraped and placed in the compost building. Saw dust will be used in the barns, which will create a crust on the compost. The crust will help to reduce odor. 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. Hog manure will be injected and turkey manure will be broadcast in the fall following forage harvest. Harvest will be completed by September 15. Manure will be applied 24 hours per day. The Project Proposer has 5,494.66 acres available for manure application. Course textured soils do not exist for any acres being used for manure application. The Project Proposer will protect ground-water quality in these areas by delaying manure application until the soil temperatures are less than 50° Fahrenheit. Nitrate leaching from hog manure, which has a relatively high percentage of organic nitrogen, is minimized when soil temperatures are less than 50° Fahrenheit. The location of the land to be used for manure application is shown in Exhibit 4. To ensure safety during nighttime operation, all equipment will have adequate lighting and all operators will get adequate rest. In addition, pressure gauges and flow meters will be used on each applicator. A hose break will be immediately detected because of a loss of pressure and volume. A remote kill switch will be stationed at each pump site, so if a hose breaks or other problems occur, the pumps can be immediately shut down. There will be one pump used during application, with pumping at a rate of 390 gallons per minute (gpm). Assuming four hours down time per pump per day, for moving hoses and any problems that arise, pumping will be completed in approximately 6 days (20 hours with 1 applicator pumping 900 gpm equals 3 days). Turkey manure will be broadcast and will take approximately 7 days. University of Minnesota, Morris weather data indicates that there is an average of 6.4 days in the month of October that receive at least .01 inches of rain. The earliest soil freeze date in Morris, Minnesota is November 7 and the average is November 24, according to University of Minnesota Extension Service weather statistics. This provides sufficient time from September 15 until freezeup to apply manure and compensate for down time due to wet weather. Surface application in the

Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

spring will only be used if weather conditions do not allow the earthen manure storage structure to be completely emptied in the fall. However, the Project Proposer has never had to surface apply manure in the spring due to inclement weather. There will be no manure applied in June, July, or August. 2. Describe the agronomic rates of application (per acre) to be used and whether the rates are Yes No based on nitrogen or phosphorus. Will there be a nutrient management plan? Manure application 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, to 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 not have commercial fertilizer applied. 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. Soil samples will be taken by a certified crop advisor from Glanzer Consulting, who will interpret the results of soil nitrate testing and determine the manure application rates needed to satisfy crop nitrogen needs. It is not anticipated that soil phosphorus will build up in soils using the prescribed management and application rates proposed. Phosphorus management begins before it is land applied. The Project Proposer has an existing two-cell earthen basin that reduces the phosphorus to a very low percentage. Soil phosphorus levels will be monitored. Soil samples will be collected in the fall, after harvest and before manure application. Samples will be taken using the methods described by the following document: “Soil Sampling and Fertilizer Recommendations”( Fact Sheet MN-NUTR3). Glanzer Consulting, located in Alexandria, Minnesota, will be used to take soil samples. Results of 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 will be applied at rates that do not allow soil phosphorus levels to increase over a six-year period. If fields are identified that have soil phosphorus levels greater than 75 ppm Bray, the history of the field will be reviewed and the potential for soil erosion evaluated before making a decision on whether the field will be used for manure applications. 3. Discuss the capacity of the sites to handle the volume and composition of manure. Identify any improvements necessary. The earthen manure storage structure and compost pile used to store manure and process wastewater has 12 months of storage capacity. To apply the manure at proper agronomic rates, 4,924.0 acres of land are needed. The Project Proposer currently has 5,495.0 acres of land available for manure application.

Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

4. Describe any required setbacks for land application systems. All of the setbacks described in Minn. R. ch. 7020 (see Table 1) and the Big Stone County feedlot management ordinance (see Table 2) will be followed. In addition, application of manure will be avoided when precipitation is likely within 24 hours, and no manure will be applied to frozen ground. Table 1. MPCA Setback Distances for Land Application of Manure (in feet) Feature Winter Non-Winter Non-Winter With Immediate Not incorporated Incorporation within 24 hours (< 24 hours) With P No P With Inadequate Mgmt. Mgmt. Vegetated Vegetated Buffer Buffer Lake, Stream 300 25 300 100 300 Intermittent Stream* 300 25 300 50 300 DNR protected wetlands** Drainage ditch w/o quarry* Open Tile Intake*** 300 0 0 300 300 Well, mine or quarry 50 50 50 50 50 Sinkhole with no diversion Downslope 50 50 50 Downslope 50 Downslope 50 Upslope 300 Upslope 300 Upslope 300 Source: Minn. R. ch. 7020 (Feedlot Rules) *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).

Table 2. Big Stone County Setback Distances for Land Application of Manure (in feet) Feature Surface or Irrigation Incorporated Injected Applied within 24 hours Watercourses, streams, rivers, 300 100 feet OHWL 50 lakes, drainage ditches Municipal well 1,000 1,000 1,000 All neighboring wells 200 200 200 Residential area (10 or more 500 200 100 homes) or municipality Residence, neighboring 300 200 100 residence Field tile intakes 300 25 25 Public road rights of way 25/300 (irrigated) 10 10 Additional elements of the Big Stone County Ordinance include: • No application of animal waste shall be conducted within a 10-year floodplain (Big Stone County Animal Feedlot Ordinance (2003) §VI. 8.). • All liquid manure must be injected or incorporated except during frozen soil conditions. Winter application of liquid manure must have prior approval from the Environmental Office (Big Stone County Animal Feedlot Ordinance (2003) §VI. 9E.).

Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

E. Other methods of manure utilization. If the project will utilize manure other than by land application, please describe the methods. 6. Air/odor emissions. A. Identify the major sources of air or odor emissions from this feedlot. The barns, manure storage basin, and the compost bunker will be the major sources of air and odor emissions from the proposed site. The types of materials emitted will include dust, non-odorous gases, and odorous gases. These types of emissions are common to farms with liquid storage basins. Some odorous gases (e.g., ammonia) will be emitted during the land application of manure. Injecting the manure into the soil below the surface will minimize the release of odorous gases. Spilled feed and dead animal carcasses can also be a source of odor. The compost site for dead animals will be covered with saw dust to reduce odors. The confinement barns and the manure storage basin will be the sources of potential air and odor emissions from the proposed facility. The types of materials emitted will include dust, non-odorous gases, and odorous gases. These types of emissions are common to animal production facilities with liquid storage basins. Some odorous gases (e.g., ammonia, hydrogen sulfide and volatile organic compounds) will be emitted during the land application of manure. Injecting the manure into the soil below the surface will minimize the release of odorous gases. The Project Proposer intends to compost mortalities from the site at their nearby turkey production facility. Composting may be a source of odor if improperly conducted or managed. The Project Proposer will follow the Minnesota Department of Agriculture guidance on livestock composting to ensure that the process is properly managed.7 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. The proposed site has operational and design features that will be implemented to avoid and minimize adverse air and odor emissions. These include good housing-keeping practices, an air cooling system, a mortality compost site, and a properly functioning two-stage earthen manure storage structure. These features are described below. Odor-control-related good housekeeping practices that will be incorporated into the operation of the facility plan include:

7



Spilled food will be promptly cleaned up. This will prevent the fermentation of the spilled feed and reduces the emission of odor.



Mortalities will be composted on site and will be covered with saw dust to reduce odors.



The existing manure storage basin will be agitated for the minimum amount of time during pumpout. Reducing the agitation time reduces the total mass of odorous gases emitted during pumpout.

http://www.mda.state.mn.us/composting/compostguide.pdf (July 24, 2006)

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Manure will be injected beneath the soil surface during land application. Subsurface incorporation of manure helps retain the nutrient value of the manure (e.g., reduces ammonia volatilization) and reduces the emission of odorous gases (e.g., ammonia).



The land application of the manure will be performed by in house personal that have the proper equipment for the subsurface incorporation of the manure.



The existing pig barns will be flushed each day. Frequent cleaning prevents the accumulation of manure in the barn, reduces the potential for excessive fermentation, and, hence, mitigates emission of adverse odors.



The proposed hog barn will have an air cooling system in place to control odor emissions.



The proposed hog barn will have all roof fans (no pit fans), which will help control odor.



The turkey barns will be dry packed, which helps reduce odor. The barns will be cleared between flocks and composted in the bunker.

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. Air quality modeling estimated the atmospheric concentrations of hydrogen sulfide, ammonia, and selected odorous gases at the property lines for the proposed project and at seven of the proposed feedlot’s nearest neighbors. A complete report of the air quality modeling findings is found in Exhibit 6. The table, below, is provided as a summary of the air quality modeling findings. Project Modeling Results Property Boundary

State ambient hydrogen sulfide air quality standard. (30ppb half-hour average)

Acute inhalation health risk value for ammonia. One hour average of 3,200 µg/m3

Chronic inhalation health risk value for ammonia. One year average of 80µg/m3.

17 ppb background

148 µg/m3 background

5.72 µg/m3 background

26.24

703

16.10

22.19

27.53

920

47.41

11.17

22.80

407

13.52

15.18

22.15

581

18.02

13.25

30.93

920

41.67

14.19

1,288

53.33

22.30

Odor impact assessment based on odor units (OU). A value of 72 odor units is considered to be a faint odor detectable by most people.

North Northeast East South Near South West 26.44 ppb = parts per billion

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It is important to note that each modeling exercise took into account the nearby feedlots to better represent the potential air quality impacts. One property-line concentration value exceeded the numeric value of the five-day state ambient hydrogen sulfide air quality standard; however, as only one value exceeded 30 ppb, a violation of the state ambient hydrogen sulfide standard was not predicted. In summary, the CALPUFF modeling results suggest that the proposed project will comply with the ambient air quality standard for hydrogen sulfide and will not exceed the applicable inhalation health risk values for ammonia or hydrogen sulfide. 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 operators will notify all neighbors within one-half mile of the manure storage basin and owners of the application sites prior to land application of manure to determine if this will interfere with activities in the neighborhood. Land application of manure will take place in the fall, after harvest, by injection. Cooler weather will minimize the release of odor. E. Noise and dust. Describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. The project will be located on an asphalt road, so dust will not be created by traffic going to and from the facility. There may be some dust created from truck traffic within the site. This should be minimal since truck speed and the number of trucks in the yard will be low. If it becomes an issue, a dust suppressant will be used to eliminate the problem. Sources of noise will be a feed truck, tractors in the feedlot area, and truck traffic entering and leaving the site. The truck traffic will primarily be during the day, and the majority of the equipment will be running inside of the barns. This will keep noise problems to a minimum. 7. Dead Animal Disposal Describe the quantities of dead animals anticipated, the method for storing and disposing of carcasses, and frequency of disposal. The estimated number of dead animals is 673 hogs (about 8 percent), 8,496 turkeys (about 12 percent) and 200 chickens (about 8 percent) per year. All mortalities will be composted in an animal mortality bunker with concrete side walls and floors. The facility is designed after a similar structure that is used for composting. Composting procedures outlined by the Minnesota Board of Animal Health will be followed. If there is a catastrophic die-off, the State of Minnesota Emergency Response Plan will be followed. 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. Project Site The construction of the facility will require an NPDES Permit, which addresses the need for temporary and permanent erosion control measure. The present site of the swine expansion is primarily graveled with row crop north of this area. The present runoff coefficient is 0.40 (0.7 for gravel and 0.2 for row crop). It is predicted that the runoff coefficient will be about 0.6 after construction. The soils in this area are slightly erodible. The area to be disturbed by the swine expansion will be 1.74 acres. There will be an earthen embankment to collect stormwater before it discharges to the wetlands. Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

The present site of the turkey starter barn expansion is gravel. The present runoff coefficient is 0.7, with a predicted runoff coefficient of about 0.85 after construction. The area to be disturbed by the turkey starter barn expansion is 0.2 acres. This area is already graveled and has little effect on the runoff in this area. The area of the proposed turkey barn expansion is crop land. The runoff from this area would be about 0.2, with a predicted runoff coefficient of about 0.40 after construction. The soils in this area are slightly erodible. The three new turkey barns will disturb about four acres. There will be an earthen embankment (road) to collect stormwater before it discharges to the wetlands. The area of the compost/dead animal facility is cropland. The runoff from this area would be about 0.2. It is predicted that the runoff coefficient will be about 0.40 after construction. The soils in this area are slightly erodible. The area to be disturbed by the compost/dead animal facility will be 0.75 acres. There will be an earthen embankment (road) to collect stormwater before it discharges to the wetlands. The quantity of stormwater generated at the site will increase as a result of the construction of barns and other impervious surfaces at the site. However, the rate of runoff will be reduced as all stormwater will be collected in the small basin. Outlets will regulate the discharge. This will spread the release of water over a long period of time. These basins also allow any sediment to settle out before the water enters the wetlands. In addition, it is most likely that the quality of the runoff will improve as the land charges from cultivated cropland to land that is covered by grass and trees. All of the animals will be housed inside a building and all of the manure will be contained within the barns or storage basin. Therefore, no contaminated runoff will be generated at the site from the feed, manure, or animal holding areas. Land Application Areas The land application of manure if improperly applied can adversely impact surface-water resources through manure-laden runoff or manure residue leaching into drain tile lines that outfall to surface waters. The project contains land application areas that are located within the Shakopee and Hawk Creek subwatersheds. The subwatersheds have been farmed for several decades. The change in stormwater runoff characteristics (physically and chemically) from the project land application areas is expected to remain the same and under certain circumstances, may improve as a result of the regulated land application activities (e.g., agronomic rate, injection of manure) under the MPCA NPDES/SDS Permit. The improvements would occur by developing better soil tilth8 through the use of organic fertilizer and the uniform practice of injecting manure over the acres identified in the MMP. The potential impact to surface water resources from the project’s land application activities is not expected to create a significant impact as it will be regulated by an NPDES/SDS Permit that operates under a “no discharge” standard. The “no discharge” standard is managed through the following practices. Manure will be injected into the soil at agronomic rates, meaning that only the amount of manure which can be used by the growing crop as nutrient will be applied. The agronomic rate is based on the type of crop grown, the soil type, and the soil chemistry. In addition, land application will occur during the fall of the year after crops are removed from the field, rather than in the spring when runoff potential is greater due to increased precipitation and soil moisture. Additional details or land application activities are found in Item 5 of the EAW. The information presented in Item 5 will be incorporated into the MMP for the proposed project. The MMP will be an enforceable provision of the NPDES/SDS Feedlot Permit for the project.

8

Good tilth is a sign of healthy soil organisms. While digesting organic material, bacteria secrete gum and slime-like matter in the soil. This works like glue, binding soil particles and humus together to form aggregates. The aggregates are crumb-like and allow for good air circulation and water drainage in the soil. Well-aggregated soil is regarded as having good tilth. The addition of organic material will feed micro-organisms and thus improve tilth. www.earthandtable.com/glossary/soil/qualities.html (retrieved May 2, 2007).

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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. When the project is operating at full capacity, there will be nine semi loads of turkeys every six to eight weeks and two semi loads of hogs a week. There will be an average of one semi load of feed delivered each week. These trucks will use County Road 35 south to County Road 54 east to get to U.S. Highway 75. No road improvements are needed as a result of this project. The Big Stone County Highway Engineer has noted that they “…do not expect this amount of extra truck traffic to have any undue or unexpected impacts to [county] roads. Increased hazards and extra wear and tear are expected to be normal and manageable…”9 The Minnesota Department of Transportation (MNDOT) noted that the proposed increase in traffic would not impact traffic on Highway 75.10 B. Will new or expanded utilities, roads, other infrastructure, or public services be required to serve the project? Yes No If yes, please describe. No new or expanded utilities, roads, infrastructure, or public services are needed as a result of this project. 10. Permits and approvals required. Mark required permits and give status of application: Unit of government MPCA

Type of Application NPDES/SDS Feedlot/Stormwater Permit

Big Stone County DNR

Conditional Use Permit Water Appropriation

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. The MPCA is required to inquire whether a proposed project, which may not individually have the potential to cause significant environmental effects, could have a significant effect when considered along with other projects. This type of impact is known as a cumulative potential effect. In order to assess the proposed project’s “cumulative potential effects of related or anticipated future projects,” the MPCA conducted an analysis that addressed other projects or operations in context to the potential direct or indirect impacts of the proposed project that: (1) are already in existence or planned for the future; (2) are located in the surrounding area; and (3) might reasonably be expected to affect the same natural resources. The following is a review of the analysis conducted to determine if the proposed project would contribute to an adverse cumulative potential effect.

9

E-mail from Nicholas Anderson, Big Stone County Engineer, regarding potential traffic impacts from the Project. E-mail from Jody Martinson, MNDOT District 4 Planning Director, regarding potential traffic impacts from the Project.

10

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The MPCA reviewed existing public data to identify the number of feedlots and other projects within the same subwatersheds of the proposed project. The public data reviewed included the most recent MPCA feedlot registration database and related project or permit databases for other operations that may hold an air quality, water quality, hazardous waste, or solid waste permit. A total of 14 livestock operations, three wastewater treatment facilities (City of Barry WWTF, City of Graceville WWTF, and Big Stone Colony WWTF), and two landfills were identified from the search of public records. The proposed livestock production facility and land application acres are located in six minor catchments that drain into two major rivers – the West Branch of the Twelve Mile Creek and the Bois de Sioux – which are part of the Red River basin. A total of 5,762 AUs exist within the six minor catchments, representing various sectors of livestock production. Lastly, the MPCA reviewed the proposed and existing projects to determine whether collectively they might reasonably be expected to affect the same natural resources. The natural resources of concern included ground water, surface waters, air quality, and land use. The following is a brief discussion of each. Ground-water Appropriation Based on information provided by the Project Proposer, the proposed livestock operation will extract ground water from the surficial aquifer (see Item 4.A.). Based on information reviewed from the Bois de Sioux Watershed District Overall Plan:11 In general, ground-water recharge occurs normally in the morainal areas and discharge occurs in the lake plain area. This is evidenced by a number of flowing wells in the lake plain and by the numerous springs that feed Lake Traverse. The quality and quantity of ground water available varies depending on the formation in which it is found. Ground water is found in both surficial and buried aquifers within the glacial drift. It is also found in the cretaceous sediments and, to a limited degree, within the bedrock. The MPCA reviewed the County Well Index (CWI) to explore the nature of well depth and type to account for other users of the same or nearby resources identified within approximately a one-mile radius of the project.12 The following table is a summary of selected findings from the CWI data: Name Nellie Drewicke

Unique Well # 583820

James Drewicke

174423

Big Stone Colony TW-2-92 Big Stone Colony TW-3-92

247585 247586

Well Depth/Unit

Well Use

The well is drilled to a depth of 190 feet and finishes in unconsolidated sand. The casing is constructed of stainless steel to a depth of 180 feet. The well is finished to a depth of 260 feet in a finetextured sand layer. The well casing is stainless steel to a depth of 250 feet. The well extends to 423 feet where it is finished in a shale unit. The well extends to 289 feet where it is finished in a shale unit.

Domestic Domestic Domestic and agriculture Domestic and agriculture

11

Bois de Sioux Watershed District, Overall Plan. May 2003. Page 28. The MPCA used the MDH CWI – June 2006. The one-mile radius was employed based on the working assumption of a one-mile zone of depletion for a livestock production well.

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Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Environmental Assessment Worksheet

Aquifers in the project area are composed of glacial sediment from all phases of the Des Moines lobe and the Big Stone Phase of the Red River lobe along with older glacial advances.13 Most drinking water wells in the area extend through the glacial lake sediments into a water-bearing sand layers or into bedrock layers. The aquifers are recharged through infiltration of precipitation and subsurface ground-water movement. Some surface water bodies and wetlands may also act as points of aquifer recharge.14 The existing ground-water use is domestic with an assumed consumption rate of 100 gallons per person per day.15 As previously discussed in Item 4.A., the project is designed to consume 11 million gallons of water a year, for a total of 275 million gallons over the 25 year service life of the proposed facility. A review of published geologic and hydrogeologic data indicates that the water-bearing characteristics of the surficial aquifer (including recharge) and the nature of its existing use as a ground-water source, water use for this project is not expected to interfere with other ground-water users. It is important to note that the local ground-water users in and around the proposed project area are domestic users. Minn. Stat. § 103G.261 establishes domestic water use as the highest priority of the state's water when supplies are limited.16 In addition, the proposed project will be required to obtain a Water Appropriation Permit from the DNR for the use of more than 10,000 gallons per day or one million gallons per year, which includes agricultural uses. The purpose of the 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 program exists to balance competing management objectives, including both the development and protection of water resources. In light of the projected project water use, aquifer characteristics, existing water uses, and the water appropriation statute, the proposed project is not expected to contribute to an adverse or irreversible cumulative potential impact of ground-water resources. Ground-water Quality Ground-water resources can be adversely impacted by land application activities where ground-water resources are at or near the surface or are accessible through conduits and fractures commonly associated with karst topography or through the texture and structure of soils and sediment. The 1989 Minnesota Groundwater Protection Act authorized the DNR to map geographic areas defined by natural features where there is risk to ground water from activities conducted at or near the land surface.17 The MPCA has reviewed information compiled by the DNR to determine whether the proposed project has the potential to contribute pollutants to the underlying aquifer creating to an adverse cumulative potential effect. Based on a review of the published information related to pollution sensitivity potential, the project area and two subwatersheds (Mustinka and Bois de Sioux) are designated as having a moderate risk to ground-water pollution, meaning that the infiltration time of a pollutant is expected to be years to decades.18 The designation reflects the surficial geology of the area, which is, in this case, primarily glacial lake sediment and till associated with the moraine. The risk to ground-water quality is further reduced by the land application practices that will be employed by the Project Proposer (see Item 5 of the EAW). In light of the potential risk of contamination to ground-water resources and the manner in which land application will be managed for the facility, the project will not contribute to an adverse cumulative potential effect to groundwater resources in the area.

13

Harris, K.L., 1999. Surficial geology. Regional Hydrogeologic Assessment Series, Traverse-Grant Area, West Central Minnesota. RHA-6. Part A, Plate 1 of 1 (Surficial Geology). 14 Bradt, R., Berg, J., 2000. Surficial hydrogeology. Regional Hydrogeologic Assessment Series, Upper Minnesota River Basin. RH-4. Part B, Plate 3 of 4. 15 See Minn. R. 7080.0125, subp. 2. 16 http://www.dnr.state.mn.us/waters/watermgmt_section/appropriations/interference.html (retrieved April 25, 2007). 17 See generally Minn. Stat. §103H. 18 Bradt, R., 2000. Geologic sensitivity to pollution of near-surface ground water. Regional Hydrogeologic Assessment Series, Upper Minnesota River Basin. RH-4. Part B, Plate 4 of 4. Big Stone Hutterite Brethren Feedlot Expansion Graceville Township, Minnesota

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Surface-water Impacts The land application areas are located within six minor catchments: two within the Boix de Sioux (BdS) subwatersheds and four within the West Branch of Twelve Mile Creek (WBTM) subwatershed (Exhibit 9). The BdS drains a land area of approximately 150 square miles with approximately 95 percent of the land engaged in agricultural production. Surface-water management problems within this watershed include: flooding, drainage, erosion, water quality, water supply, wildlife issues, and cropland irrigation. Flooding, particularly in the spring of the year, is an almost annual occurrence. The river has been identified as an impaired water body for ammonia. A total maximum daily load (TMDL) has been established for this stretch of the BdS.19 The WBTM subwatershed drains a land area of approximately 179 square miles with 92 percent of the land engaged in agricultural production. The WBTM experiences frequent flooding with spring flooding an almost annual occurrence. The water quality is generally considered to be poor within the subwatershed due to nutrient and sediment loading.20 The activities related to the surface-water impairments in both subwatersheds are a combination of point source (e.g., wastewater treatment plants) and nonpoint source (e.g., agricultural activities) discharges. The proposed project is not expected to contribute to the existing water quality issues discussed above. The project will minimize its potential impact to surface-water quality through the land application activities discussed in Item 5 of the EAW, which include storage in an engineered concrete structure, fall land application, injection of manure, and observation of setback distances, as well as the use of an agronomic rate for land application. These practices will be included in the project’s NPDES/SDS Permit, which requires a producer to operate a facility under a “no discharge” standard. As a result, the MPCA concludes that the project will not contribute to an adverse cumulative potential effect of surface water quality. Air Quality Impacts Air quality computer modeling was performed that estimated ambient air concentrations for hydrogen sulfide, ammonia, and selected odorous gases from the proposed project. The model estimated pollutant concentrations from the proposed project, along with an ambient hydrogen sulfide and ammonia background concentration to account for any off-site air emission sources or activities. 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 effects. Hydrogen sulfide and ammonia may be present from other feedlot barns, the agitation, pump out and land application activities of a neighboring feedlot or the pumping of a municipal wastewater treatment facility. Air emissions from other emission sources may affect the compliance status of the proposed facility, or impact downwind human and environmental receptors. The background level for hydrogen sulfide that was used in the computer model was derived from monitoring at other feedlot facilities in Minnesota. The modeling adds the background air pollutant concentration to the emission concentration predicted from the proposed project. The results of the modeling study indicate that no significant air quality impacts are expected from the proposed project and that the proposed Project will not contribute to any adverse cumulative potential effects of air quality (Exhibit 6). Land Use The land identified for the purpose of this project includes the site of the project proper along with the land application acreage. The overall project, including land application sites are reviewed in context to other existing or proposed projects within the watershed. Three issues have been identified with respect to land resources – wildlife habitat, row crop agriculture and traffic.

19 20

Bois de Sioux Watershed District, Overall Plan. May, 2003. Pages 52-53. Bois de Sioux Watershed District, Overall Plan. May, 2003. Pages 85-86.

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