Strobel Farms - Alton 30 site: Signature document (p-ear2-102b)

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STATE OF MINNESOTA

MINNESOTA POLLUTION CONTROL AGENCY IN THE MATTER OF THE DECISION ON THE NEED FOR AN ENVIRONMENTAL IMPACT STATEMENT FOR THE PROPOSED STROBEL FARMS – ALTON 30 SITE, ALTON TOWNSHIP WASECA COUNTY, MINNESOTA

FINDINGS OF FACT CONCLUSIONS OF LAW AND ORDER

Pursuant to Minn. R. ch. 4410.1000, the Minnesota Pollution Control Agency (“MPCA”) staff has prepared an Environmental Assessment Worksheet (“EAW”) for the proposed Strobel Farms – Alton 30 Site Feedlot. Based on the MPCA staff environmental review, comments, and information received during the comment period, and other information in the record of the MPCA, the MPCA hereby makes the following Findings of Fact, Conclusions of Law, and Order.

FINDINGS OF FACT

Project Description 1. Strobel Farms (“Proposer”) proposes to construct and operate two new 110-foot by 200-foot total

confinement, power-ventilated swine finishing barns (“Project”). 2. The Proposer will locate the barns in the SW¼ of Section 30 of Alton Township in Waseca County. 3. The Project will house a maximum capacity of 1,440 animal units (“AUs”) in the two barns. 4. The Proposer will land apply all of the manure produced by the Project. Four of the manure

application sites are in Waseca County and one site is in Blue Earth County. All five sites are within approximately eight miles from the Project site.

5. The Proposer will begin construction in late summer 2016 with top soil stripping and stockpiling.

The Proposer will use stormwater erosion prevention and sediment control best management practices (“BMPs”) during top soil stripping and stockpiling.

6. The Proposer will excavate soil from the future location of the reinforced concrete pits, and then

construct eight -foot deep, reinforced concrete pits beneath each barn to hold the manure generated by the finishing hogs.

7. The barns are equipped with concrete slatted floors. The slatted floors allow manure to pass

through to the reinforced concrete pit located beneath the floor of each barn. 8. The Proposer will place a perimeter drain tile around the base of the manure storage pits. The

perimeter drain tile relieves seasonal saturation and limits hydrostatic pressure on either perched groundwater or following precipitation events. The Proposer will install inspection ports on the

On the Need for an Environmental Impact Statement Findings of Fact Strobel Farms – Alton 30 Site, Alton Township Conclusions of Law Waseca County, Minnesota And Order

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perimeter tiles for observation of the drain tile to ensure these are functioning properly and to identify seepage from the pits if a leak were to occur.

9. The Proposer will attach bulk feed storage bins to the barns. The bins are fully contained and re-

filled from a top hatch.

10. The Proposer applied for coverage under the State of Minnesota General Animal Feedlot National Pollutant Discharge Elimination System (“NPDES”) General Permit (“Feedlot Permit”) on January 7, 2016.

11. The Proposer will construct a permanent stormwater retention pond to capture and infiltrate runoff

from the site. This water will not contact animals or manure storage areas and thus contamination from manure is not likely. The Feedlot Permit requires the Proposer to install permanent stormwater treatment. Since the Project adds an acre or more of new impervious surface, the Proposer must retain on-site the water volume of one inch of runoff from the new impervious surface. The Proposer will construct an infiltration basin approximately 400,000 gallons in size.

12. The Proposer will complete construction of the buildings, install equipment, conduct final

grading using BMPs, and then establish a permanent vegetative cover. 13. The Project site is currently zoned for agriculture use and in crop production.

Environmental Review of Project

14. An EAW is a brief document designed to set out the basic facts necessary for the Responsible

Governmental Unit (“RGU”) to determine whether an Environmental Impact Statement (“EIS”) is required for a proposed project or to initiate the scoping process for an EIS (Minn. R. pt. 4410.0200, subp. 24). The MPCA is the RGU for this Project.

15. Minn. R. 4410.4300, subp. 29, Item A requires preparation of an EAW for the Project because it is

the construction of an animal feedlot facility with a capacity of 1,000 AUs or more. 16. The MPCA provided public notice of the Project as follows:

a. The Environmental Quality Board (“EQB”) published the notice of availability of the EAW for public comment in the EQB Monitor on May 30, 2016, as required by Minn. R. 4410.1500.

b. The EAW was available for review on the MPCA website at http://www.pca.state.mn.us/news/eaw/index.html.

c. The MPCA provided a news release to media in the southwest region of Minnesota, and other interested parties on May 30, 2016.

17. During the 30-day comment period ending on June 28, 2016, the MPCA received comments from

the Minnesota Department of Natural Resources (“MDNR”), the State Historic Preservation Office, and six comments from citizens. A list and copies of the comments received and the response to comments are in Appendix A and B to these Findings. The MPCA received one comment letter outside of the comment period.


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18. The Feedlot Permit was open for comment from June 2, 2016, through July 5, 2016. The MPCA received two comment letters on the Feedlot Permit.

Criteria for Determining the Potential for

Significant Environmental Effects 19. The MPCA shall base its decision on the need for an EIS on the information gathered during the

EAW process and the comments received on the EAW (Minn. R. 4410.1700, subp. 3). The MPCA must order an EIS for projects that have the potential for significant environmental effects (Minn. R. 4410.1700, subp. 1). In deciding whether a project has the potential for significant environmental effects, the MPCA must compare the impacts that may be reasonably expected to occur from the Project with the criteria set forth in Minn. R. 4410.1700, subp. 7. These criteria are:

A. Type, extent, and reversibility of environmental effects.

B. Cumulative potential effects. The RGU shall consider the following factors: whether the

cumulative potential effect is significant; whether the contribution from the project is significant when viewed in connection with other contributions to the cumulative potential effect; the degree to which the project complies with approved mitigation measures specifically designed to address the cumulative potential effect; and the efforts of the proposer to minimize the contributions from the project.

C. The extent to which the environmental effects are subject to mitigation by ongoing public

regulatory authority. The RGU may rely only on mitigation measures that are specific and that can be reasonably expected to effectively mitigate the identified environmental impacts of the project.

D. The extent to which environmental effects are anticipated and controlled as a result of other

available environmental studies undertaken by public agencies or the Proposer, including other EISs.

The MPCA Findings with Respect to Each of These Criteria

Are Set Forth Below Type, Extent, and Reversibility of Environmental Effects 20. The first criterion that the MPCA must consider when determining if a project has the potential for

significant environmental effects is the “type, extent, and reversibility of environmental effects” Minn. R. 4410.1700, subp. 7. A. The MPCA findings with respect to this criterion are set forth below.

21. The types of impacts that are reasonably expected to occur from the Project include the following:

· Surface water and groundwater quality impacts; · Groundwater appropriation impacts; and · Air quality impacts related to hydrogen sulfide, ammonia, and odor emissions.

22. Comments received during the EAW comment period raised the following issues:


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· Water quality (this issue is addressed in the Findings on Surface Water and Groundwater Quality Impacts);

· Land application of manure (this issue is addressed in Findings on Surface Water and Groundwater Quality Impacts); and,

· Traffic and road issues. With respect to the extent and reversibility of impacts that are reasonably expected to occur from the Project, the MPCA makes the following findings. Surface Water and Groundwater Quality 23. The Project is not located in a designated floodplain or in a shoreland area, which meets the

requirements of Minn. R. 7020. 24. The Feedlot Permit requires that the Proposer develop and maintain on-site a stormwater pollution

prevention plan (“SWPPP”) that includes erosion prevention and sediment control BMPs for the construction and operation of the Project.

25. The Feedlot Permit requires the Project to meet a zero discharge standard. 26. The Feedlot Permit requires housing of all livestock in total confinement barns with no access to

surface waters, and storage of manure in below-ground reinforced concrete pits that meet the design criteria of Minn. R. 7020.2125.

27. The Proposer will install perimeter drain tiles around the base of the reinforced concrete pits. The Proposer will install inspection ports on the perimeter tiles to allow for observation of the drain tiles to ensure these are functioning properly and to identify seepage from the pits if a leak were to occur.

28. The Feedlot Permit also requires the Proposer to develop a manure management plan (“MMP”)

that meets the requirements of Minn. R. ch. 7020.2225. A MMP shows how manure generated at a feedlot is used during the upcoming growing season(s) in a way that maximizes the benefits of applying manure to cropland, meets all rules and regulations, and protects surface water quality.

29. The Proposer indicated that between 260 and 316 acres of land are required for manure

application, and has identified 371 acres of cropland available for manure application. 30. The Proposer will retain ownership of all manure generated from the Project. State and local

requirements require all applicators of manure, whether transferred or applied at permittee-owned sites, to follow testing, application limits, restrictions, setbacks, keep records, and report spills.

31. Minn. R. 7020 and the Feedlot Permit include requirements that the Proposer must meet for

manure application. The Proposer must satisfy state requirements concerning soil testing, rate limits, seasonal restrictions, setbacks, keeping records, reporting spills, conduct manure management planning and recordkeeping that are specific to the fields and crops to which the


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manure is applied, and sample soil from fields receiving manure once every four years. The Proposer must provide this information to the MCPA in an annual report.

32. The Proposer must keep records for the six most recent years, including the amount and nutrient content of manure delivered, the name and address of any commercial hauler or applicator who received the manure, the location where the manure is applied, and the rate of application.

33. The commercial animal waste technician (“CAWT”) spreading the manure must keep records for six years, and submit a copy of the records to the Proposer no later than 60 days following each land application.

34. In order to avoid contaminating the groundwater at the manure application sites, manure must be

applied at agronomic rates based on the type of crop grown, the soil type, and the soil chemistry to minimize the potential for nitrate leaching into the groundwater. The MMP requires the applicator spreading manure to observe MPCA and/or county water supply well setback requirements, whichever are the more restrictive. As a result, the MPCA does not expect incorporated manure to adversely impact water quality.

35. The Proposer will notify the County Feedlot Officer before operational events such as manure agitation and application. However, the County Feedlot officer is not required by rule or permit to notify affected residences.

36. The MPCA finds that these measures will mitigate the potential for adverse impacts on groundwater

quality related to manure incorporated at the manure application sites. 37. The land application of manure, if done improperly, can not only adversely impact groundwater, but

can adversely impact surface-water resources through manure-laden runoff or manure residue leaching into drain tile lines that outfall to surface waters. Therefore, the MMP requires the manure applicator to observe MPCA and/or county setback requirements, as well as all other applicable federal and state rules, whatever are the most restrictive, around drain tile intakes located within and adjacent to manure application areas, and near other surface water resources.

38. The MMP requires the manure application associated with the Project to occur in the spring after

the ground has thawed and before planting, or during the late fall after harvest. The timing reduces the likelihood of significant rain events and allows manure incorporation into the soil as soon as time and field conditions allow.

39. The MMP requires application to follow all applicable required setbacks from sensitive features and

waterways. The land application practices in the MMP, once approved by the MPCA, become an enforceable provision of the Feedlot Permit.

40. Minnesota’s “Final Animal Agriculture Generic Environmental Impact Statement” (2002) and the

University of Minnesota Agriculture Extension program state that manure not only supplies nutrients, but can also improve the biological and physical properties of soil, making it more productive and less erosive.


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41. Manure, when properly used as part of a soil management program, improves soil quality, builds soil structure, and increases the level of soil organic matter. Commercial fertilizers do not provide these same improvements to soil properties.

42. When cropland receives manure, the CAWT only applies commercial fertilizer to supplement manure nutrients up to agronomic rates. The combined total of nitrogen from manure and commercial fertilizer cannot exceed rates as prescribed in Minn R. 7020.2125.

43. The Proposer will hire a CAWT licensed by the Minnesota Department of Agriculture to land apply the manure. The CAWT applies the manure via direct injection or by broadcast application and incorporates it within 24 hours. Manure application takes place when fields are accessible in the fall after harvest.

44. The Proposer will treat the soil with Nitrapyrin (a nitrification inhibitor) prior to land application of

manure, although the rule and permit do not require the Proposer to treat the soil. 45. The MPCA finds that the requirements of the Feedlot Permit and MMP minimize the potential for

manure applied at manure application sites to come in contact with runoff and enter surface waters.

46. The MPCA finds that quality of runoff from land application areas for the manure will not

significantly change if managed in accordance with the MMP required by the Feedlot Permit. Nutrients from manure tend to replace nutrients provided by other fertilizers, and improve soil tilth due to the use of organic fertilizer. The immediate incorporation of manure alleviates the potential for runoff from the acres receiving manure under the MMP.

47. A number of groups including the MDNR, Ducks Unlimited, the MPCA, the Sentinel Lake Monitoring Project, and the Citizen Lake Monitoring Program have been sampling water quality parameters nearby Buffalo Lake since at least 2004. Some of the sampling parameters include: total suspended solids, pH, dissolved oxygen, inorganic nitrogen, chlorophyll, Kjeldahl nitrogen as N, phosphorus, sulfate, and chloride. The MPCA and local partners (counties) have sampled portions of the Le Sueur River in 2009-2009; this river is scheduled for sampling again in 2018-2019.

48. The Blue Earth County Environmental Services Department (“BECES”) discontinued private water

well testing in 2010. However, interested persons can pay a fee for Blue Earth County worked out to provide water testing services through Minnesota Valley Testing Laboratories (“MVTL”) for certain fees.

49. The Minnesota Department of Agriculture (“MDA”) and Minnesota Department of Health (“MDH”)

monitor groundwater throughout the State and have data available to the public regarding nitrate levels and other readings.

50. The MPCA finds that information presented in the EAW and other information in the environmental

review record is adequate to assess potential impacts to water quality that are reasonably expected to occur from the Project. The Proposer has developed measures to prevent or mitigate these impacts.


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51. The MPCA finds the Project, as proposed, does not have the potential for significant environmental

effects based on the type, extent, and reversibility of impacts related to groundwater or surface-water quality that are reasonably expected to occur.

52. The Feedlot Permit addresses the prevention of adverse effects on water quality due to manure storage and application.

53. Although the MPCA does not expect significant adverse impacts to water quality, if water quality impacts were to occur, the Proposer will modify the operation and management of the Project. The MPCA would then modify the Feedlot Permit and impacts to waters would be reversed. Therefore, the MPCA finds any water quality impacts that may occur from the Project are reversible.

54. The MPCA finds that information presented in the EAW and other information in the environmental review record are adequate to assess potential impacts to the quality of surface water and groundwater that are reasonably expected to occur from the Project.

Groundwater Appropriation

55. The Proposer will construct a new well as a source of water for the Project. The Proposer estimates

the Project to consume approximately two million gallons of water per year. 56. The Proposer must obtain from MDNR a Water Appropriation Animal Feedlots and Livestock

Operations Individual Permit (“Water Appropriations Permit”) for the Project. The MDNR reviews the permit application upon approval of the Feedlot Permit, which determines final animal numbers and, hence, water consumption.

57. The purpose of the MDNR Water Appropriation Permit Program is to ensure water resources are

managed so that adequate supply is available for long-range seasonal requirements for domestic, agricultural, fish and wildlife, recreational, power, navigational, and water quality control.

58. The Proposer has not installed the well as of the time of this review. Thus far in the process, the Proposer has coordinated with the MDNR to obtain a Preliminary Well Construction Assessment. Receipt of a Well Construction Preliminary Assessment does not constitute an authorization or guarantee permit approval by the Project Proposer.

59. The Proposer will use this preliminary assessment approval to decide whether to proceed in constructing a well, but the preliminary approval does not act as a notification to the MDH, nor is it a MDNR water use permit. The Proposer intends to register the well with the MDH following well construction, and obtain permission to use of the well through the MDNR permit.

60. The MDNR requires a water appropriation permit for all users withdrawing more than 10,000 gallons of water per day or one million gallons per year. The purpose of the MDNR Water Appropriation Permit program is to ensure the Proposer manages water resources so that adequate supply is available for long-range seasonal requirements for domestic, agricultural, fish and wildlife, recreational, power, navigational, and quality control.


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61. The MDNR Water Appropriations Permit is intended to prevent any adverse effects on water

appropriation due to increased usage of water by the Proposer. This permit program balances competing management objectives, including 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 MDNR has a standard procedure for investigating the matter. If MDNR identifies that a commercial operator is causing the problem, the operator must correct it.

62. Following the completion of environmental review, the Project Proposer may pursue the water appropriation permitting process with MDNR. Unauthorized pumping or use of the well or other water resource is subject to enforcement under Minn. Stat. 103. Upon completion of a permit review period, the MDNR may limit, amend, or deny a permit for water appropriation in accordance with applicable laws and rules for the protection of the public interest and the sustainability of Minnesota’s water resources.

63. Due to the MDNR oversight and permitting of water appropriations, the MPCA does not expect

significant adverse impacts to water quantity. However, if the MDNR determines there is well interference based on concerns or well interference claims, the operator must fix the causes of the interference. The impacts to water appropriations would then be reversed. Therefore, the MPCA finds that any water appropriation impacts that may occur from the Project are reversible.

64. The MPCA finds that the Project, as proposed, does not have the potential for significant

environmental effects based on the type, extent, and reversibility of impacts related to water appropriations that are reasonably expected to occur.

Air Quality

65. The Proposer conducted air dispersion modeling, required for feedlots undergoing environmental

review, which estimated the atmospheric concentrations of hydrogen sulfide and ammonia, and the intensity of odorous gases at the Project property lines and at the nearest neighbors. The MPCA reviewed and approved the modeling protocol and report.

66. The Proposer used the AERMOD model developed by the American Meteorological Society and the

U.S. Environmental Protection Agency, which is a widely used and accepted model in determining air quality. AERMOD includes conservative assumptions, which means that the model results are conservative predictions of future performance. The model evaluated the air quality impacts of the Project.

Air Quality Related to Hydrogen Sulfide Emissions 67. The modeling results predict the Project will comply with the 30 parts per billion (“ppb”) hydrogen

sulfide Minnesota ambient air quality (“MAAQ”) standard. Under the MAAQ standard, the third exceedance of the MAAQ within any five-day period is a violation. The AERMOD modeled results demonstrate compliance when the high-third-high (“H3H”) concentration (added to background


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concentration) for any five-day period at each property-line receptor is less than 30 ppb MAAQ standard.

68. AERMOD-predicted maximum H3H property-line hydrogen sulfide concentration of 6.37 ppb for the

Project. When a background concentration of 17 ppb is added to the AERMOD predictions, the H3H hydrogen sulfide concentration is 23.37 ppb, which is below the ambient standard of 30 ppb. Thus, the MPCA finds that hydrogen sulfide emissions from the Project do not pose a threat to the hydrogen sulfide ambient air quality standard.

69. The AERMOD modeling results also indicated that the Project will not cause an exceedance of the

subchronic (13 week) hydrogen sulfide inhalation Health Risk Value (“iHRV”) at neighboring residences. iHRVs are concentrations of chemicals emitted to air. At certain concentrations, these chemicals may pose a significant risk of harmful effects when humans are exposed over a specified period of time. The estimated maximum monthly hydrogen sulfide concentration result for the Project’s neighbors is 0.49 micrograms per cubic meter (“μg/m3”). When a background concentration of 1.00 μg/m3 was added to the AERMOD estimate, the maximum monthly neighbor hydrogen sulfide concentration is 1.49 μg/m3, which is below the subchronic hydrogen sulfide iHRV of 10 μg/m3.

70. Based on the AERMOD modeling results discussed above, the MPCA does not expect violations of

the hydrogen sulfide ambient air quality standard or exceedances of the subchronic hydrogen sulfide iHRV as a result of the Project. The MPCA expects the Project to comply with the applicable air quality standards and iHRVs for hydrogen sulfide.

Air Quality Related to Ammonia Emissions 71. The modeling results also indicate that the Project will not create exceedances of the acute

ammonia iHRV at the property line. AERMOD predicted a maximum hourly property-line ammonia concentration of 48.60µg/m3. When a background concentration of 148 μg/m3 was added to the AERMOD prediction, the maximum property-line ammonia concentration is 196.60 μg/m3, which is below the acute ammonia iHRV of 3,200 μg/m3.

72. The AERMOD results indicate that the Project will not create exceedances of the chronic ammonia

iHRV at the neighboring residences. The estimated maximum one-year time-averaged ammonia concentration at the neighbors is 27.66 µg/m3. When a background ammonia concentration of 5.72 µg/m3 is added to the AERMOD estimate, the maximum annual ammonia concentration at the neighboring residence is 33.38 µg/m3, which is below the chronic ammonia iHRV of 80 µg/m3.

73. The MPCA finds that ammonia emissions expected from the Project, including the modeled

exceedances of the acute ammonia iHRV, do not present the potential for significant effects.

Air Quality Related to Odor Emissions 74. Although the state of Minnesota has not established ambient air quality standards to regulate odor,

the Proposer did complete AERMOD modeling for odor. The AERMOD results show the Project will not contribute to odor concentrations (OU/m3) above an odor intensity defined as a “faint odor” at


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the property line. The modeled maximum hourly odor intensity was 4 OU/m3 on the Project site’s north boundary line.

75. The modeling results also predict the Project will not contribute to odor concentrations above an

odor intensity of 72 OU/m3, defined as a “faint odor” at nearby non-feedlot residences. With the addition of the Project, the maximum hourly odor intensity for a non-feedlot neighboring residence was 29 OU/m3.

76. The MPCA finds that odor at the Proposer’s property line and at nearby residences, projected as a

“faint odor”, does not present the potential for significant environmental effects. 77. The Proposer has submitted an air emissions and odor management plan with the Feedlot Permit

application for the Project. Under the plan the Proposer will empty below-ground reinforced concrete manure storage pits once per year in the fall. The Proposer will inject all of the manure into the soil upon land application, thus reducing odor potential at the time of application. Although manure is a source of odor, the total confinement facility design will also help to mitigate odors by limiting exposure to the atmosphere.

Type, Extent and Reversibility of Air Quality Impacts

78. With respect to the reversibility of air quality impacts expected to occur from the Project, air

emissions from the Project will continue while it remains in operation and would cease only if the Project were temporarily or permanently closed. While the Project is in operation, the MPCA expects the Project to meet applicable air quality standards and criteria.

79. If excessive air emissions or violations of the ambient hydrogen sulfide air standards were to occur,

or if the Proposer exceeded iHRVs for ammonia, air quality impacts are likely to be correctable. The MPCA could initiate an investigation and require the Proposer to make operation and maintenance changes. Therefore, the MPCA finds that any impacts on air quality that may occur from the Project are reversible.

80. The MPCA finds that information presented in the EAW and other information in the environmental

review record are adequate to assess the impacts on air quality that are reasonably expected to occur as a result of the Project. The Proposer has methods to prevent significant adverse impacts.

81. The MPCA finds the Project, as proposed, does not have the potential for significant environmental effects based on the type, extent, and reversibility of impacts on air quality reasonably expected to occur from the Project.

Traffic and Road Issues 82. The Proposer will conduct feedlot operations in a manner that no disturbance greater than normal

agricultural operations during daylight hours will result.

83. Trucks will deliver feed and supplies to the Project site twice a week. Nine pick-up trucks with trailers will come to the Project site two-and-a-half times per year to refill the barns with nursery


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pigs, using County Road 14 for access. Each re-stocking period for the barn will take approximately two weeks to complete, averaging four to five loads per week.

84. The Proposer will use approximately 28 semi-tractors and trailers, two-and-a-half times per year, to

load the finished hogs from the site to take to market. These periods of heavier traffic will occur over an approximate time period of one month, averaging about 4 to 6 semi-trucks per week for each load out. The trucks will use County Road 14 north to State Highway 14.

85. The MPCA has determined that the truck traffic, as described above, will not have a significant

impact on traffic safety or congestion.

86. The MPCA finds the Project, as proposed, does not have the potential for significant environmental effects based on the type, extent, and reversibility of impacts reasonably expected to occur to traffic and any road systems in the Project area from construction and operation of the Project and application of manure from the Project.

Cumulative Potential Effects 87. The second criterion that the MPCA must consider when determining if a project has the potential

for significant environmental effects is the “cumulative potential effects.” In making this determination, the MPCA must consider “whether the cumulative potential effect is significant; whether the contribution from the project is significant when viewed in connection with other contributions to the cumulative potential effect; the degree to which the project complies with approved mitigation measures specifically designed to address the cumulative potential effects; and the efforts of the proposer to minimize the contributions from the project.” Minn. R. 4410.1700 subp.7.b. The MPCA findings with respect to this criterion are set forth below.

88. The EAW, public comments, and MPCA follow-up evaluation did not disclose any related or

anticipated future projects that may interact with this Project in such a way as to result in significant cumulative potential environmental effects.

89. The EAW addressed the following cumulative potential effects of the proposed Project:

· Surface water and groundwater quality, and · Air quality.

Surface Water and Groundwater Quality 90. The Project and the proposed manure application sites are located within three minor watersheds

of the Le Sueur River major watershed. Land use in the Le Sueur River Watershed is primarily agricultural, dominated by animal and crop production.

91. The MPCA reviewed the MPCA’s impaired waters database to determine if the Project would

contribute to any existing impaired surface waters. The Le Sueur River is on the 2012 MPCA Impaired Waters list for problems including turbidity, low dissolved oxygen, and excess nutrients, requiring a Total Maximum Daily Load (“TMDL”). The Le Sueur River is located approximately 650


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feet to the south-southwest of the Project site. Strategies outlined in the TMDL implementation plan approved to restore waters in the Le Sueur River Watershed include:

· No-till or strip till conservation tillage; · Cover crops and grassed waterways; · Nutrient, manure, and animal management; · Water retention and increased evapotranspiration for the landscape (basins, wetlands,

extended retention); · Field and riparian vegetated buffers; · Drainage volume reductions by system design; · Drainage water pollutant reductions through edge-of-field treatments (bioreactors, saturated

buggers, treatment wetlands); · Citizen education; · Urban stormwater BMPs; · Changes in policy and increased funding and other support; and · Protect currently higher quality areas.

92. Typical strategies identified for preventing and managing impairments related to manure include buffer strips and buffer set-aside acreage in the Conservation Reserve Program, nutrient and manure management, and residue management. The Proposer is currently utilizing the most applicable measures that are required in the MMP for the manure generated at the Project. The Proposer is also required to use the most applicable measures in the MMP that are incorporated as an enforceable part of the Feedlot Permit for the Project once issued.

93. As TMDLs move forward, implementation plans will include measures for preventing and managing

manure, including those already required through the Feedlot Permit and MMP requirements. 94. The Feedlot Permit requires that the Project meet zero discharge standards. As a result, there

should be no discharge of manure or manure-contaminated runoff to any waters of the state. 95. All manure application sites must also comply with MPCA or county manure application setback

requirements as well as all other applicable federal and state rules, whatever are the more restrictive.

96. The MMP, in order to prevent impacts to any waters of the state, is designed specifically for the

manure that the Proposer expects to generate at the Project and the Proposer-controlled manure application sites.

97. The Project design is intended to assure that manure will not come in contact with any stormwater;

therefore, the MPCA does not expect any manure-contaminated stormwater runoff from the Project. (See Finding 11). Further, proper operation and management of the Project will prevent any runoff of manure and/or manure-contaminated stormwater runoff, if any contamination should occur, from impacting waters of the state, whether or not those waters are impaired.


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98. Adherence to appropriate manure land application practices in the MPCA-approved MMP will prevent the runoff of manure and/or manure-contaminated stormwater runoff from impacting waters of the state, whether or not waters are impaired.

99. Since the MMP and Feedlot Permit require preventative measures to protect water quality, the

MPCA does not anticipate the Project will contribute to any potential adverse effect on water quality. Therefore, the MPCA does not expect the Project to contribute significantly to adverse cumulative potential effects on water quality.

Air Quality

100. The MPCA evaluated cumulative potential effects on air quality by comparing the Minnesota ambient air quality standards for hydrogen sulfide, iHRVs for ammonia, and odor intensity thresholds with concentrations in the air predicted by air modeling. The modeling analysis included the estimated emissions from the Project and incorporated conservative background concentrations to account for the potential impacts of air emissions from other feedlots in the area of the Project. The Proposer estimated air concentrations for these pollutants at the 57 residences closest to the Project.

101. All modeled concentrations were below the health-based and nuisance odor criteria used in the

analyses. Therefore, the MPCA has determined no significant cumulative potential effects on air quality in the Project area, and the Project will not contribute significantly to adverse cumulative potential effects on air quality.

Cumulative Effects – Summary

102. Based on information on the Project obtained from air modeling reports and feedlot permit application processes, information on water quality in the Project area presented in the EAW, and consideration of potential effects due to related or anticipated future projects, the MPCA does not expect significant cumulative effects from this Project.

103. The MPCA finds the Project, as proposed, does not have the potential for significant environmental

effects related to cumulative potential effects that are reasonably expected to occur. The Extent to Which the Environmental Effects Are Subject to Mitigation by Ongoing Public Regulatory Authority

Unit of government Permits and Approval Required MPCA Minnesota Feedlot Permit, including a MMP and a NPDES

Construction Stormwater Permit MDNR Water Appropriation Permit MDNR Well Construction Preliminary Assessment MDH Well Construction Permit Alton Township Conditional use or other land use permit

104. MPCA Feedlot Permit. The MPCA requires the Proposer to obtain a Feedlot Permit for the Project.

The Feedlot Permit incorporates construction and operation requirements, including stormwater,


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and includes operating plans that address manure management, emergency response protocols, and odor/air quality management. The attachments are an enforceable condition of the Feedlot Permit. The Feedlot Permit incorporates provisions of the Construction Stormwater (“CSW”) Permit pertinent to livestock operations. Thus the Proposer is not required to apply separately for coverage under the CSW Permit.

105. MDNR Water Appropriation Permit. The Proposer must obtain a MDNR Water Appropriation Permit, as the Project will withdraw more than 1,000,000 gallons per year. The Proposer estimates an approximate use of two million gallons per year for the Project. The Proposer will hire a licensed well driller to install a new production well.

106. MDNR Well Construction Preliminary Assessment. The Proposer received preliminary approval to construct a well by the MDNR. This preliminary approval to construct a well contains information provided by MDNR to the Proposer to use to decide whether to proceed in actual construction of a well and is based largely on information provided by the Proposer. It is not notification to the MDH, and is not a MDNR water use permit.

107. MDH Well Construction Permit. The Proposer must obtain a well construction permit from the

MDH. The Proposer must construct the well in accordance with Minn. Stat. 1031 and Minn. R. 4725. 108. Alton Township Conditional Use Permit. The Proposer must obtain all required building and

conditional use permits required by local units of government to ensure compliance with local ordinances. The conditional use permit will address local zoning, environmental, regulatory, and other requirements needed to avoid adverse effects on adjacent land uses.

109. The above-listed permits include general and specific requirements for mitigation of environmental

effects of the Project. The MPCA finds that the environmental effects of the Project are subject to mitigation by ongoing public regulatory authority.

The Extent to Which Environmental Effects can be Anticipated and Controlled as a Result of Other Available Environmental Studies Undertaken by Public Agencies or the Project Proposer, Including Other EISs

110. The fourth criterion that the MPCA must consider is “the extent to which environmental effects can be anticipated and controlled as a result of other available environmental studies undertaken by public agencies or the project proposer, including other EISs.” Minn. R. 4410.1700, subp. 7. D. The MPCA findings with respect to this criterion are set forth below.

111. Although not an exhaustive list, the MPCA reviewed the following documents as part of the

environmental impact analysis for the proposed Project:

· Data presented in the EAW; · Feedlot Permit application, with attachments; · Air Quality Modeling Report, and updated information for the report; and · Permits and environmental review of similar facilities.


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112. The MPCA also relies on information provided by the Project Proposer, persons commenting on the EAW, staff experience, and other available information obtained by staff.

113. The environmental effects of the Project are addressed by the design and permit development

processes, and by ensuring conformance with regional and local plans. There are no elements of the Project that pose the potential for significant environmental effects

114. Based on the environmental review, previous environmental studies by public agencies or the

Proposer, and staff expertise and experience on similar projects, the MPCA finds that the environmental effects of the Project that are reasonably expected to occur are anticipated and controlled.

115. The MPCA adopts the rationale stated in the attached Response to Comments (Appendix B) as the

basis for response to any issues not specifically addressed in these Findings.

CONCLUSIONS OF LAW

116. The MPCA has jurisdiction to determine the need for an EIS for this Project. The EAW, the permit development process, and the evidence in the record are adequate to support a reasoned decision regarding the potential significant environmental effects that are reasonably expected to occur from this Project.

117. The MPCA identified areas for potential significant environmental effects. The Project design and

permits ensure the Proposer will take appropriate mitigation measures to address potential effects. The MPCA expects the Project to comply with all environmental rules, regulations, and standards.

118. Based on a comparison of the impacts that are reasonably expected to occur from the Project with

the criteria established in Minn. R. 4410.1700 subp. 7, the Project does not have the potential for significant environmental effects.

119. An EIS for the proposed Strobel Farms – Alton 30 Site (Alton Township) Project is not required. 120. Any findings that might properly be termed conclusions and any conclusions that might properly be

termed findings are hereby adopted as such.

APPENDIX A

Minnesota Pollution Control Agency (MPCA)

Strobel Farms – Alton 30 Site (“Project”) Environmental Assessment Worksheet (“EAW”)

List of Comment Letters Received

1. Jerry Jo Finley, Jr. Email received May 31, 2016.

2. Chad Bleess. Email received June 6, 2016.

3. John Beckwith. Email received June 16, 2016.

4. Cindy Beckwith. Email received June 22, 2016.

5. Sarah Beimers, State Historic Preservation Office. Letter dated June 22, 2016.

6. Denise Baer. Email received June 27, 2016.

7. Kevin Mixon, Minnesota Department of Natural Resources. Letter received June 27, 2016.

8. Denise Baer. Email received June 28, 2016.

From: Jerry Jo Jr. Finley [mailto:[email protected]] Sent: Tuesday, May 31, 2016 7:39 PM To: Jensen, Patrice (MPCA) Subject: Strobel Farms Alton 30 site, public comment

Dear Patrice J. and the MPCA as well, I am hoping that you have some engineer, or yourself, to address these interests and concerns,

I do not know if the MPCA and other pollution control agencies, ever considered how wind in our environment can move around the effects of concentrated animal-waste and gray water and methane, to across the lands far-beyond where the animal-sewage and gray water is spread. It would be not unlike how our scientists know that radioactive fall-out from nuclear disasters, is proven to have SUBJECTED others considerable-distances away, to the same detrimental affects and causation of problems as locals who experienced radioactive fall-out. When we consider a larger livestock operation proposed to spread animal-waste and gray water over a relatively small range though, detrimental affects (especially when prolonged subjection is going to happen) likely will be much-more serious than anyone can realize I am afraid! What scientist has compiled a study of subjects subjected to prolonged exposure to methane generated from concentrations of animal-waste and gray water spread in close proximity to subjects??? The methane produced is not like cowshit or hogshit from a gutter or barn where a few animals are being raised. You are discussing the proposed thousands of animals in one location and the real methane being produced with so much animal-wastes and gray water held in ponds and being proposed to be spread on a relatively small range of land I am afraid.

Unless I am confused and mistaken the MPCA notice of this project and your work on it, was just emailed out today. And the closing date for sending in public comment ends June 28th? That's less than 30 days, a relatively-short period of time for something that could adversely affect so much I think, a pretty short notice for citizens to have any ample opportunity to learn about this project and maybe interview others who have likewise been faced with such notices and later probably been seriously disaffected.

Abit on raising feeder livestock to finishing weights: To put weight on hogs quicker, make them eat more, and eat more often, believe-it. (Like dairy cattlemen are nowdays feeding the animals more more-often and milking the animals more times per day, forcing production). Getting back to marketing hogs now, the more hogs are fed, the more they poop make. We can put weight on them quicker by like force-feeding them, getting them to market in less time, but at a cost of having a LOT more poop to haul out (probably double what the animals would've pooped-out if they had been fed normal rations! So MPCA, I think you should double your estimates on the amount of animal-wastes and gray water this is going to be generated by such a facility as is proposed! I would compare the amount of animal waste and gray water, that 4,800 force-fed hogs generate, to ATLEAST what 4,800 over-eating humans would generate. SO PLEASE the numbers the MPCA will use for analyzing the proposed facility's impact on the environment, must be based on truth, not some down-played version of what really is going to be produced in animal-waste and gray water!

So I was also, wondering, just what do the owners of such large livestock facilities do for "treatment procedures" before all that raw sewage is spread-out on our earth????

We are not discussing placing such a facility in the middle of a 20,000 acre ranch out in the middle of nowhere out west somewhere. AND WE ARE NOT DISCUSSING SMALL FARMERS WITH 15 OR 25 CATTLE AND A FEW HOGS THEY MIGHT HAVE ON 160 ACRES, spreading an acceptable and tolerable amount of animal waste on their farmland. NO, THIS KIND OF MPCA WORK IS ABOUT LARGE INVESTORS INSTEAD COMPOUNDING THE NUMBERS OF LIVESTOCK-ANIMALS THEY WISH TO HAVE & KEEP IN RELATIVELY VERY, VERY, SMALL SPACES, AND IT IS ABOUT SPREADING A

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mailto:[email protected]

"CONCENTRATION" OF ANIMAL-WASTES THEN IN CLOSE PROXIMITY TO THEIR LIVESTOCK-FACILITY/IES AND POTENTIAL FOR DETRIMENTAL IMPACTS TO LAND, WATER, AND AIR!!! ATTENTION:::When we concentrate larger numbers of PEOPLE, creating communities, cities, towns, metro areas, all are forced to spend millions-upon-millions of dollars to build sewage-treatment-plants designed to treat the raw sewage and gray water produced when large numbers of people are living in closer proximity to one-another, to protect the environment. However the growing numbers of owners operating and proposing to operate, larger & larger & larger livestock facilities, do not need to likewise treat all that animal waste before it is spread in a concentrated fashion out on a relatively small spread (a few miles X a few miles in size? Instead these owners of larger & larger & larger livestock facilities get by concentrating hundreds and even-thousands of animals at a single site, and (without treating the sewage and gray water first) can just just take all the accumulated animal waste they generate, add some water to it, and spray it out on top of the ground, or inject it into the ground without that product ever being treated like our human waste must be treated??? Then the crop-producers produce crops for livestock, where all that CONCENTRATED animal waste was spread! I am afraid this is like "animal-waste-concentrate" being applied to the earth where people's wells are, where people live-around, and, where livestock-feed is being grown! I am afraid if these kinds of enormous operations are going to be permitted, it it going to cause detrimental damage to our environment, damage all the pollution-control-agencies on earth apparently could not recognize. Let the large corporations have thousands of animals at a facility if they wish-to, but require them owners and their families be the SUBJECTS (instead of the unfortunate homesteaders and residents living in the general area of such proposed facilities and their wells and environments becoming the subjects)! Require all the owners and partners in these proposed facilities/operations, to be required-to live ON SITE and drink all their water from the well on site where all that animal waste is saturating the earth around their home, and then see what happens. Why isn't the MPCA using the words "air quality" these days? When studying the affects and what goes into like an Environmental Impact Statement, it now looks like the MPCA has stopped terming "air quality" and is instead just stating "air". Last year I drove out of Alma, Wisconsin, thinking we were on a drive to enjoy the rural area surrounding Alma, Wisconsin. We traveled in a direction I think was NE, got to the top of the hills there and drove NE a ways. The air along that blacktop road was so terribly strong with METHANE like odor, it pretty-much RUINED OUR IMPRESSION OF RURAL AMERICA at least there!!!!!!! I am sorry but I can not support anything that would contribute to concentrated methane from animal wastes like that was there, and I am afraid the proposede Strobel Farms Alton 30 site will be bad to our environment regardless of how the MPCA's information is interpreted. Sincerely, Jerry F. Jr.

From: Chad Bleess [mailto:[email protected]] Sent: Monday, June 06, 2016 11:20 AM To: Jensen, Patrice (MPCA); Hohenstein, Desiree (MPCA) Subject: Public Comnment for Strobel Farms - Alton 30 Site

I am a landowner a couple miles from this proposed hog barn site and although I should not be directly affected according to the study. I did noticed some descrepencies in the report.

First of there are three (3) building sites that are not noted in the study that are adjacent to this proposed property. I attached an image which has the two occupied residential sites and 1 vacant site. It is troubling as to why these sites were not noted on the study as Mr. Strobel is a long time area resident and is quite aware of them I am sure.

The vacant site is in Waseca County and has a tax parcel id of 010300910. The two properties in Blue Earth County have a tax id of R45.15.25.400.005 and R45.15.25.400.007.

Also of concern for me is the fact that the Le Sueur River high water comes to within the 300' of the proposed site. The river has flooded multiple times in the few years I have lived in the area. As someone who utilizes the river for recreational purposes I am greatly concerned about the environmental imapcts that may occur during a time of heavy flooding/rain.

I believe that the barns will still meet setback requirements but it is troubling as to why those sites were not listed if they are the closest residences to the site.

Chad Bleess 35482 W County Line Rd Janesville, MN 56048

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From: John Beckwith [mailto:[email protected]] Sent: Thursday, June 16, 2016 11:05 AM To: Card, Dan (MPCA) Subject: Strobel Farms EAW, comments

These comments are presented in regard to the Strobel Farms EAW open for public comment through June 28, 2016. Although it is clear that Waseca County and Strobel farms see MPCA permitting as mere formality since construction is underway as I write these comments.

First, I reiterate my concerns regarding safety of the access to County Line Road. Although the feedlot technician stated that access across form 172nd Lane is the safest point, I doubt that anyone with knowledge of highway safety would concur. The line of sight at this location is extremely limited and increasing traffic access here is a safety concern, especially trucks with slow acceleration rates. With the hill crest and slight dip just north of the access point, traffic from north and south have a very limited line of sight. To say it provides the most safe access point is not correct, although it may be the most cost effective. I recommend this access point be required to be moved to a point south where the line of sight is extended.

I want it known that I am not opposed to traditional farming operations. We own a farm ourselves that has been in the family for well over 100 years However, this project is the third such site of corporate hog complexes constructed nearby in the short time since we built our home. To suggest there is no cumulative impact of such operations ignores the real world situation. There is significant impact to the environment and to the people of the community.

The maps and descriptions of neighboring residences in the EAW are not consistent, nor are the related analyses referring to these maps and descriptions. I think each map presented to indicate the location of neighboring residences show different locations. I believe the only consistency between them is that they all fail to show the residence closest to the site. So any analyses related to the social and environmental impact on the nearby residents is invalid. I suggest the permit be denied until these discrepancies are addressed, and then only if the results are within MPCA regulations.

I further believe the air quality study is inadequate and misleading.

First, the use of annual accumulation of various toxins fails to warn or identify the daily health warnings that nearby residents should be aware of. Use of models reflecting average weather and barometric data does not reflect the variables of actual daily conditions. Knowing that with normal conditions the neighbors won’t be exposed to excessive toxins over an average year’s time period is not adequate disclosure in my opinion. We should be made aware of when real time conditions warrant concern for our health, similar to the metrics used in urban air pollution indexes. This complex is nearer our home than the other sites and breathing is already difficult from them under certain conditions. I can’t see how this site will be better than the others. And from a cumulative standpoint it no longer makes much difference which way the wind is blowing, there is a smell of industrialized hog complexes and the toxins associated with it in the air most days.

It seems too that an economic assessment should be a part of this process. There are venues in the neighborhood whose customers are encouraged to be out of doors. Our own farm is one of them, and Indian Island Winery another. The air quality definitely has an impact on number of customers and length of stay of those customers.

As for the odor assessment, either the science is lacking or the descriptors of events were developed to be totally misleading. When the model used states that there is a zero percent “frequency at which the “faint” odor threshold is exceeded”, there is no reliability in the model. With the existing complexes, which are further from our home than the proposed complex, we “frequently have to go indoors, close the windows and turn off the air exchanger.” We seldom think to ourselves “what is that faint odor? Could it be the pigs in the corporate hog complex upwind of us?” Don’t take my word for it. Just drive down here and travel any of the roads of the area. When you detect an odor take note as to whether you describe it as “faint” and then determine if its source is one of the hog complexes, as is proposed. Either the model is inaccurate, or the descriptors are totally misleading. In addition, they once again failed to address the nearest residence to the proposed site. At least the project should be denied until that residence is considered.

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As I stated earlier, the applicant is already moving dirt at the site. With that in mind I see no reason to believe that the other requirements of the permit will be adhered to; be it additives to limit odor, or the spreading of the waste on land that is directly connected to what MPCA frequently sites as one of the MN Rivers most polluted tributaries. John E. Beckwith

From: Cindy Beckwith [mailto:[email protected]] Sent: Wednesday, June 22, 2016 9:08 PM To: Card, Dan (MPCA); Jensen, Patrice (MPCA); Hohenstein, Desiree (MPCA) Subject: Strobel Farm comment

These comments are presented in regard to the Strobel Farms EAW open for public comment through June 28, 2016.

After reading through the Strobel Hog Feedlot Report I noticed that our home was not located on one of the Odor Intensity Maps. The home directly across the road was also not located on the map. On another map our home was located, the one across the road was not. It appears the hog barn could be within 1,000 feet of the home across the road.

We deal with unpleasant odor almost daily from the existing hog barns around our home. I grew up on a hog farm in McPherson Township and a mile away there was a dairy farm, we did not have manure odor on a daily basis. These very large hog barns with thousands of animals cause too much odor and produce too much manure. I do not understand how these maps can indicate minimal odor. I live here and that is NOT what is happening.

The following is copied directly from the Strobel Hog Feedlot Report. It does not state that the County Feedlot Officer will notify the people affected. How can ‘The Processor’ or ‘County’ possibly coordinate with any planned events when no one is notified?

{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. There are twelve neighbors within one (1) mile of the Project site. The Proposer will notify the County Feedlot Officer before operational events such as manure agitation and application. The Proposer will check weather conditions before manure application to lessen impacts on neighbors and the public, and will work around planned social events in the neighborhood. Additionally, the Proposer will implement the air emission plan in the Feedlot Permit in the event that an odor event occurs. The air emission plan is an enforceable provision of the Feedlot Permit}

I understand there are rules regarding the application of the manure. After talking to a large dairy farmer in Waseca County I was told that in 20 years he had never had any officials check on the land that he applied the manure, no tests were run. I strongly suspect this will be the case with the hog manure.

Strobel Farms will do what they want, when they want, and how they want. This was shown by the recent construction of the driveway to the proposed hog barn. After several phone calls to Waseca County Agencies and the MPCA I was told that the driveway construction was ‘not legal’. While making these phone calls I felt that Waseca County was hesitant to intervene in the driveway construction, stating that it was up to the MPCA. MPCA is the agency that told me the driveway construction was not legal. I have not seen continued construction on this driveway and will continue to be observant. I also

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did not see erosion control practices being used. Later some erosion control was installed. From the road it does not look like much. In closing, the issue of odor is sadly understated in the Strobel Hog Feedlot Report and there are several errors. Strobel Farms has shown a complete disregard in the need for proper permits before beginning driveway construction. There are enough large hog barns in this area and it is time to end this trend and deny the construction of yet another. Sincerely, Cynthia Beckwith 63005 172nd Lane Janesville, MN 56048 612-599-7772

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From: Denise Baer [mailto:[email protected]] Sent: Monday, June 27, 2016 7:44 AM To: Jensen, Patrice (MPCA) Subject: Stobel Farms Alton 30 Site

Hi Patrice, looking at the worksheet on the site sheet, page 31. Our residence is not listed on there and I need the distance from our property from the barns. They are saying the nearest neighbors are 1835 away and the number is not accurate due to our property to the east and wasn't calculated in the proposal. Our home is right off 631st Ave and 172nd Lane and our driveway meets the driveway of the barns. I would need to have the distant of the location from the barns and our property to further get a accurate numbers on my research. I believe we would be the closest property to the project.

Regards, Denise Baer

17150 631st Ave Janesville, MN 56048

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From: Denise Baer [mailto:[email protected]] Sent: Tuesday, June 28, 2016 4:36 PM To: Jensen, Patrice (MPCA) Subject: Strobel Farms Slton 30 site

To whom this may concern,

Regarding Strobel Farms Alton 30 site

After reviewing the Environmental Assessment Worksheets and Environmental Impact, there is great potential negative environmental effects of a proposed development. My concern is that we are the closest residents to the proposed feedlot and our property wasn’t acknowledged on the one mile radius map including numbers in the air quality report. The approximant distant between our property and the feedlot is 1690 feet (according to google earth). I would like an accurate distance and numbers from our property to the proposed feedlot.

The site this would be located (straight east of our property) concerns me due to the 11 other feedlots surrounding our property (4 to the north, 5 to the west and 2 to the south/southwest) and our neighbors, with in a 2.5 mile radius. The effect on the air quality is concerning, considering my three young children play outside all year round. We are not able to play and enjoy the outdoors from time-to-time due to the odor and potential health hazards this has known to cause, especially to young children. This impacts the quality of life in rural communities.

“Emissions including hydrogen sulfide and ammonia monitored near livestock operations were high enough to be harmful to humans, according to a study by the University of Iowa and Iowa State University.

Another study by the University of Iowa concluded that children living on hog farms where antibiotics are added to feed have significantly higher rates of asthma. Similarly, a North Carolina study of more than 58,000 children found a 23 percent higher incidence of asthma symptoms for students attending schools with livestock odors.

Yet another study by the University of Iowa found that residents living within 2 miles of a 4,000-hog confinement farm reported significantly more respiratory problems than other residents.

Ammonia given off by hog waste can drift in the wind and mix with acidic gas to form fine particles that settle to the ground, posing a health risk.

"They cause respiratory distress, they cause reduced lung function," said Joseph Rudek, lead senior scientist for the Environmental Defense Fund.”

A study in Iowa linked factory farms with a number of health problems. Researchers collected mental and physical health information by personal interviews from a random sample of residents living within two miles of a 4,000 sow operation. The information was compared to information from rural residents living in an area with minimal livestock production.

The study showed that "neighbors of the large-scale swine operation reported experiencing significantly higher rates than the controls of four clusters of symptoms that are known to represent toxic or

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inflammatory effects on the respiratory tract. These clusters of symptoms have been well documented among swine confinement workers." Symptoms reported include: cough, shortness of breath, chest tightness, wheezing, nausea, dizziness, headaches, runny nose, burning eyes, musculoskeletal aches, skin rashes and fevers.

The sites driveway is right across our main driveway and our home is located close by. The school bus stops on 631st Ave. where both driveways are located. The noise of the traffic will not be minimal and will create noise during sleeping hours in the early morning.

With the other feedlots around us, we have never been notified before manure agitation and application or educated as such. I would think it would be nuances to call the proposer to plan our kids birthday parties, summer get together with family…ect.

I have too many concerns to list and would like to be more informed in the process of who is going to be held accountable when my children get sick from the odorless gasses and poor air quality, who’s going to test the river and the wet lands in the area and my well. If we sell our home who’s going to responsible for the 30% property value loss of our home due to living next hog barn.

Respectfully

Denise Baer

Gordon Rye

From: Garett Rohlfing [mailto:[email protected]] Sent: Wednesday, June 29, 2016 9:31 AM To: Jensen, Patrice (MPCA) Subject: Strobel EAW

Hi Patrice

I was looking at the EAW for Greg Strobel yesterday afternoon and I noticed that there is a mistake on the cover page. I believe the comment period ended yesterday, but I just got done talking with Desiree and she said that I should probably let you know. I have attached an image that shows the mistake highlight in yellow. The mistake reads Alton Township, section 6, but it should read Alton Township, section 30.

Thanks

Garett Rohlfing

Waseca County Planning and Zoning Technician/Feedlot Officer/Ag Inspector 507-835-0652300 North State StreetWaseca, MN 56093

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APPENDIX B

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Minnesota Pollution Control Agency

Strobel Farms – Alton 30 Site Environmental Assessment Worksheet (“EAW”)

RESPONSES TO COMMENTS ON THE EAW

Overall Project/EAW Procedural Comments

Comment 1: The commenter did not feel there was a 30-day comment period. (1-2) Response: The EAW was put out on public notice on May 30, 2016. The 30-day comment period closed on June 28, 2016. The Minnesota Pollution Control Agency (“MPCA”) provided public notification in accordance with Minn. R. 4410.1500 and 4410.1600.

Comment 2: The commenter is concerned about detrimental impacts to land, water and air from having a large amount of animals confined to a small space. (1-5) Response: The environmental review process is intended to provide comprehensive information about the potential environmental effects of the Project to inform future decisions on permits or approvals needed by the Project, and to identify ways to minimize those impacts to the environment for the purpose of protecting Minnesota’s natural resources. The EAW is a worksheet with a series of questions to guide the MPCA in evaluating the potential direct, indirect, and cumulative impacts by the Project on the surrounding environment. The Project’s potential effects to the environment were assessed based on these questions. After reviewing all of the available information, the Commissioner determines whether the Project has a potential for significant environmental effects following the criteria specified in Minn. R. 4410.1700 subp. 7. In this case, the MPCA does not expect the Project to adversely impact land, water, or air because the barns are constructed as total confinement and the Proposer will inject or incorporate the manure in accordance with the Feedlot Permit and the Manure Management Plan (“MMP”). Comment 3: The commenter feels there is a cumulative impact since this is the third corporate hog farm constructed in the area. (3-2) Response: The EAW process includes an evaluation of cumulative potential effects on the environment that result from the incremental effects of a project in addition to other projects in the environmentally relevant area that might reasonably be expected to affect the same environmental resources. Here, the Proposer completed an air quality modeling analysis to estimate the hydrogen sulfide concentrations, ammonia concentrations, and odor intensities at the feedlot’s property lines and an additional three miles in each direction. The air quality modeling also considered the gaseous emissions from three other hog feedlots and one hog/cattle feedlot within the 3.2 mile area grid surrounding the Project site. The modeling results indicate that the Project will not create exceedances of the acute ammonia inhalation Human Risk Value (iHRV) at the property line. The AERMOD results indicate that the Project will not create exceedances of the chronic ammonia iHRV at the neighboring residences.

Based on the results of the AERMOD modeling study, after construction and operation of the Project, the MPCA expects the Project to comply with Minnesota Ambient Air Quality Standards for hydrogen

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sulfide and not exceed the Minnesota Department of Health’s (“MDH”) iHRVs for ammonium. In addition, other odorous gases predicted to be less than levels usually considered unpleasant. For these reasons, the MPCA does not anticipate cumulative potential air effects from the Project.

The MPCA does not anticipate the Project to adversely contribute to the existing water quality issues. The Project will minimize its potential impact to surface water quality through the manure application activities discussed in Item 5 of the EAW, which include injection of manure and observation of setback distances, as well as the use of an agronomic rate for manure application. These practices are in the Project’s Feedlot Permit, which requires the Proposer 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 on surface-water quality.

The Proposer and CAWT will follow the requirements in Minn. R. ch. 7020 for the construction of the manure storage structures and the manure application. These rules are protecting groundwater from both cumulative and individual feedlot impacts. MPCA staff have reviewed and approved the Project plans and specifications for the manure storage pits, and the MMP for the manure application. The plans and specifications are enforceable conditions of the Project’s Feedlot Permit. The Proposer will also submit an annual report to the MPCA on manure production, application, and any discharges. The Project will not displace or disrupt any wildlife habitat and as a result, will not contribute to an adverse cumulative potential effect related to habitat fragmentation and loss.

Row crop agriculture - The manure application sites will use existing row crop feedstock, rather than to cultivate fallow or marginal land to meet crop use needs. As a result, the MPCA does not expect existing row crop agriculture to create a new impact to environmental quality. Comment 4: The commenter stated that the Minnesota Department of Natural Resources (“MDNR”) appreciated the opportunity to review and comment on the Project. They reviewed the project information and said they have no comments at this time. (7-1) Response: Comment noted.

Missing/Incorrect Information Comment 5: Commenters noted that there were two residences and one vacant building site not included in the air modeling analysis, and that some properties were not included on the maps. (2-1, 3-3, 3-7, 4-1, 6-1, 8-1) Response: One residence was not included in the original air modeling information contained in the EAW when it was placed on public notice. The MPCA has since revised the EAW air modeling analysis to include this residence; the analysis does not take into account vacant building sites. The revised air modeling results show that air quality standards are still met at the Project site property boundary. The maps and descriptions of neighboring residences were revised to include the closest residence. The MPCA completed an errata sheet and appended it to the EAW with the missing information.

Permitting, Compliance and Enforcement Comments

Comment 5: The commenters stated that the EAW does not indicate that the County Feedlot Officer will notify affected residences during manure agitation and application, and that they have never been notified when other feedlots agitate their manure or land apply it. (4-3 and 8-4)

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Response: The Proposer has agreed that it will notify the County Feedlot Officer before operational events such as manure agitation and application. However, the County Feedlot Officer is not required by rule or permit to notify affected residences. The EAW is an informational document to inform the public and government decision makers, but it does not require specific actions. Enforceable requirements must be included in permits or local approvals. (See Findings of Fact - The Extent to Which the Environmental Effects Are Subject to Mitigation by Ongoing Public Regulatory Authority.) Comment 6: The commenter is concerned that the manure application fields will not be checked or tested. (4-4) Response: Minn. R. 7020 and the 2016-2021 General Feedlot National Pollutant Discharge Elimination System (“NPDES”) permit require that a facility keep and maintain records for all land applications of manure, sample their manure on an annual basis, and sample soil from fields receiving manure once every four years. The Proposer must provide this information to the MPCA in an annual report which is required for all permitted facilities and reviewed by MPCA staff on a regular basis. Comment 7: The commenter stated that she contacted the MPCA to inform them that the Proposer had begun construction prior to obtaining their permit. (4-5) Response: MPCA acknowledges this comment and is looking into the situation and will follow up as appropriate.

Economic Impact Comments Comment 8: The commenter feels an economic study should be conducted to determine how the air quality impacts the economies in the area (3-5). The commenter wants to know who will be responsible for the 30% property value loss of her home due to living next to a hog barn. (8-7) Response: The issue and concern regarding potential impacts to economies and property values in the Project area are important to those living in the area as well as the township and county, but these issues are beyond the scope of an EAW. The required content of an EAW is defined in Minn. R. 4410.1200. An analysis of economic effects, such as the effect on neighboring property values, is beyond the scope of information included in an EAW. If a Regulated Governmental Unit determines there is a potential for significant environmental effects, an Environmental Impact Statement (“EIS”) is ordered. An assessment of socio-economic issues is part of the scope of the EIS. See Minn. R. 4410.2300.H.

Land Application of Manure Comments Comment 9: The commenter is concerned that feeding the feedlot animals a greater amount of food to quickly put weight on generates a greater amount of manure. (1-3) Response: The Proposer must follow a MPCA-approved MMP, which is included in its MPCA Feedlot Permit, and is obligated to follow all rules and regulations with regard to feedlot operations. The Proposer also has an appropriate amount of land for manure application of the amount of manure generated. Comment 10: The commenter wanted to know what the Proposer will do to treat the manure prior to land application. (1-4)

4

Response: The Proposer will voluntarily treat the soil with Nitrapyrin (a nitrification inhibitor), although the rule and permit do not require the Proposer to treat the soil.

Water Quality Comments Comment 11: The commenter is concerned about concentrated animal waste being applied where people live and where their wells are located. (1-6) Response: The Proposer will retain ownership of all manure from the Project and apply it at permittee-owned sites. State and local requirements require all applicators of manure, whether transferred or applied at permittee-owned sites, to follow testing, application limits, restrictions, setbacks, keep records, and report spills. Minn. R. 7020 does not have a setback requirement for manure application adjacent to residences; however, the rule does prohibit manure application within 50 feet of a well. The EAW did not disclose any information indicating a concern with public health or water supply when manure is applied in accordance with the requirements in the Feedlot Permit. Comment 12: The commenter had concerns that the Le Sueur River high water comes to within the 300 feet of the proposed site. The commenter indicated that the river has flooded multiple times in the few years he has lived in the area. (2-2) Response: The MPCA reviews a feedlot application to ensure that the Project is not located in a designated floodplain or is located in a shoreland area. The Project meets the requirements of Minn. R. 7020 and is not located in a designated floodplain or shoreland area. The EAW did not disclose any information indicating that the Project site is subject to flooding. Comment 13: The commenter wants to know who will test the river, the wetlands, and her well. (8-6) Response: A number of groups including the MDNR, Ducks Unlimited, the MPCA, the Sentinel Lake Monitoring Project, and the Citizen Lake Monitoring Program have been sampling nearby Buffalo Lake since at least 2004. Some of the sampling parameters include: total suspended solids, pH, dissolved oxygen, inorganic nitrogen, chlorophyll, Kjeldahl nitrogen as N, phosphorus, sulfate, and chloride. The MPCA and local partners (counties) have sampled portions of the Le Sueur River in 2009-2009; it is scheduled for sampling again in 2018-2019. For more details on stream and lake monitoring, please contact Paul Davis, MPCA, at 507-344-5246. The Blue Earth County Environmental Services Department (“BECES”) discontinued private water well testing in 2010. However, Blue Earth County worked out an arrangement with Minnesota Valley Testing Laboratories (“MVTL”) to provide water testing services for certain fees. MVTL water test kits can be picked up at the BECES Office, Monday-Friday, 8:00 a.m. 5:00 p.m. Residents may obtain more information by contacting the BECES at 507-304-4381 or mailto:[email protected]. The Minnesota Department of Agriculture and the MDH monitor groundwater throughout the State and have data available to the public regarding nitrate levels and other readings.

Air Quality Comments Comment 14: The commenter is concerned about how wind can move the effects of manure application across the land beyond where the manure is spread. (1-1)


5

Response: The Proposer will inject the manure into the soil; therefore, the injected manure is not subject to dispersal by the wind. Comment 15: The commenters were concerned about the quality of the air quality modeling, poor air quality and health hazards, and feedlot odors. (3-4, 3-6, 4-2, 8-2, 8-5) Response: The Project is required to meet the hydrogen sulfide standard in Minn. R. 7009.0070 and the MDH risk values for ammonia (Minn. R. 4717-8000 to 4717.8600). As part of the EAW, the Proposer completed an air quality modeling health risk analysis to estimate the hydrogen sulfide concentrations, ammonia concentrations, and odor intensities at the feedlot’s property lines and an additional three miles in each direction. For air dispersion modeling at feedlots, the MPCA has approved the use of AERMOD which is a steady-state dispersion model designed for short-range (up to 50 kilometers) dispersion of air pollutant emissions from stationary industrial sources. AERMOD integrates a meteorological data preprocessor (AERMET) that accepts surface meteorological data, upper air meteorological data to calculate atmospheric parameters needed by the dispersion model. In addition a terrain preprocessor (AERMAP) is integrated into AERMOD to provide a physical relationship between terrain features and the behavior of air pollution plumes. AERMOD makes conservative predictions about potential health risks associated with an air emissions source, meaning that the model over predicts the potential risk. In this case, modeling demonstrated that air emissions from the Project are not predicted to exceed health risk values. The modeling results indicate that the Project will not create exceedances of the acute ammonia inhalation Human Risk Value (iHRV) at the property line. The AERMOD results indicate that the Project will not create exceedances of the chronic ammonia iHRV at the neighboring residences.

Based on the results of the AERMOD modeling study, after construction and operation of the Project, the MPCA expects the Project to comply with Minnesota Ambient Air Quality Standards for hydrogen sulfide and not exceed the MDH’s iHRVs for ammonium. In addition, other odorous gases are predicted to be less than levels usually considered unpleasant. For these reasons, the MPCA does not anticipate cumulative air impacts from the Project.

Several commenters stated that the air dispersion modeling did not predict any odors from the feedlot. In fact, the modeling predicted “faint” odors. The modeling predicts that AERMOD calculated the ground-level odor intensities at the property lines for the proposed Strobel hog feedlot, at the property lines for the two existing Strobel hog feedlots, and at the locations for 57 of the feedlots’ neighboring residences. The maximum hourly odor intensity at the three Strobel feedlots’ property lines is 45 odor units (“OU”), which is below the “faint” odor threshold of 72 OU. No off-site “faint” or stronger odors will be associated with the proposed Strobel hog feedlot, the two existing Strobel hog feedlots, and the two neighboring feedlots. A “faint” odor is defined as an odor that can be detected by an average person if attention is called to the odor.

Traffic and Road Comments Comment 16: The commenter has concerns regarding traffic safety using access from 172nd Lane. (3-1) Response: Travel to the site and access is via County Road 14/West County Line Road, rather than 172nd Lane. County Road 14 is an asphalt-paved all weather-road. Access to County Road 14/West County Line Road is approved by Waseca County.

6

Comment 17: The commenter is concerned about traffic noise during sleeping hours in the early morning. (8-3) Response: In general, the Proposer is required to have construction equipment properly muffled and in proper working order. The County would require the Proposer to comply with applicable local noise restrictions and ordinances to the extent reasonable. Project construction is limited to daytime hours as much as possible. The Proposer will conduct feedlot operations in a manner that no disturbance greater than normal agricultural operations during daylight hours will result.

Historical Comments Comment 18: The commenter concluded that there are no properties listed in the National or State Registers of Historic Places, and no known or suspected archaeological properties in the area that are affected by the Project. (5-1) Response: Comment noted.

Broad Environmental Comments Comment 19: The commenter wanted to know why the MPCA was not using the words “air quality” any more. (1-7)

Response: The MPCA still uses the term air quality when describing effects to air.

Minnesota Pollution Control Agency

Strobel Farms – Alton 30 Site

Environmental Assessment Worksheet (EAW)

ERRATA SHEET

1. One residence was not included in the air modeling analysis. The air modeling analysis was revised to include this residence. The results show that air quality standards are still met at the Project site property boundary. The maps in the analysis were updated and are included in the revised “Air Quality Modeling Report,” Barr Engineering, dated July 2016, which is amended to this sheet.

2. Two residences were not shown on “Attachment D – One Mile Radius Map” of the

EAW. The Proposer revised this map to include these two residences and it is amended to this sheet.

Air Quality Modeling Report Greg Strobel Proposed Hog Feedlot

Waseca County Alton Township SW ¼ Section 30

Prepared by Barr Engineering Company 4700 West 77th Street Minneapolis, MN 55435-4803

July 2016

Table of Contents

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

General Modeling Approach 3 ............................................................................................................Impact Thresholds and Background Values 4 ...............................................................................

Source Characterizations 7 ...........................................................................................................

Neighboring Residences 11 ..........................................................................................................

Site Descriptions 13 ............................................................................................................................Proposed Strobel Hog Feedlot 13 .................................................................................................

Strobel Existing #1 Hog Feedlot 13 ..............................................................................................

Strobel Existing #2 Hog Feedlot 15 ..............................................................................................

Feedlot #3 15 .................................................................................................................................

Feedlot #4 17 .................................................................................................................................

Gas Emission Rates 17 ........................................................................................................................Hog-Finishing Barns 17 ................................................................................................................

Hog Manure Storage Basin 18 ......................................................................................................

Open Cattle Lot 19 ........................................................................................................................

Hydrogen Sulfide at Property Lines and Neighbors 20 ......................................................................

Ammonia at Property Lines and Neighbors 22 ...................................................................................

Odorous Gas Concentrations 24 .........................................................................................................

Odor Intensities at Property Lines and Neighbors 24 .........................................................................

Summary 26 ........................................................................................................................................

Introduction Greg Strobel (Strobel) proposes to construct a

new feedlot consisting of two 2,400-head hog-finishing barns in the SW ¼ of Section 30, Alton Township, Waseca County. Strobel owns and operates two neighboring hog feedlots. One is located in the SE ¼ of Section 23, McPherson Township, Blue Earth County (Strobel Existing #1), and the second is located in the NW ¼ of Section 36, McPherson Township, Blue Earth County (Strobel Existing #2).

Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) on August 13, 2015, air quality modeling calculated the hydrogen sulfide concentrations, ammonia concentrations, and odor intensities at the property lines for the proposed Strobel hog feedlot, the Strobel Existing #1 hog feedlot, and the Strobel Existing #2 hog feedlot, and at the locations for 57 of the Strobel feedlots’ nearest neighbors.

The modeled emission sources for the proposed hog feedlot consisted of two 200-ft by 110-ft mechanically-ventilated hog-finishing barns with concrete manure storage pits located beneath the barns’ slatted floors. For the Strobel Existing #1 feedlot, the modeled emission sources consisted of five 198-ft by 41-ft naturally-ventilated hog-finishing barns and two 255-ft by 150-ft hog manure storage basins. The emission sources for the Strobel Existing #2 feedlot consisted of two 192-ft by 102-ft mechanically-ventilated hog finishing barns. In addition to the three Strobel hog feedlots, the air quality modeling included the gaseous emissions from two neighboring feedlots.The locations of the three Strobel feedlots, the two neighboring feedlots, and the 57 neighboring residences are provided in Figure 1.

The following atmospheric concentrations were calculated:

1. the maximum hourly hydrogen sulfide concentration at the property lines for the proposed Strobel hog feedlot and the two existing Strobel hog feedlots to assess the potential to comply with Minnesota’s ambient air quality standard for hydrogen sulfide of 30 parts per billion by volume (ppb);

2. the maximum monthly hydrogen sulfide concentration at 57 of the proposed and existing Strobel feedlots’ nearest neighbors to assess the potential to exceed Minnesota’s subchronic (13-week) inhalation Health Risk Value (iHRV) for hydrogen sulfide of 10 micrograms per cubic meter (µg/m3);

3. the maximum hourly ammonia concentration at the property lines for the proposed Strobel hog feedlot and the two existing Strobel hog feedlots to assess the potential to exceed Minnesota’s acute iHRV for ammonia of 3,200 µg/m3;

4. the maximum annual ammonia concentration at 57 of the proposed and existing Strobel feedlots’ nearest neighbors to assess the potential to exceed Minnesota’s chronic iHRV for ammonia of 80 µg/m3; and

5. the maximum hourly odor intensities at the property lines for the proposed Strobel hog feedlot, at the property lines for the two existing Strobel hog feedlots, and at 57 of the Strobel feedlots’ nearest neighbors to assess the potential for off-site odor episodes.

The above concentrations were calculated using the AERMOD air quality model, based on 5 years of historical weather data.

# Strobel Hog Feedlot Report1

#

Figure 1. Modeled locations of the proposed Strobel hog feedlot (SW ¼ of Section 30, Alton Township), the Strobel Existing #1 hog feedlot, the Strobel Existing #2 hog feedlot, the two neighboring feedlots, and the 57 neighboring residences (not labeled).


The modeling results suggest that the proposed Strobel hog feedlot and the two existing Strobel hog feedlots will comply with the Minnesota ambient air quality standard for hydrogen sulfide. The standard regards the third exceedance of 30 ppb within any 5-day period as a violation. Modeled compliance is demonstrated when the high-third-high (H3H) concentration (with background) for any 5-day period at each property-line receptor is less than 30 ppb. AERMOD calculated a maximum H3H property-line hydrogen sulfide concentration of 6.23 ppb. When a background concentration of 17 ppb is added to the AERMOD-calculated concentration, the H3H hydrogen sulfide concentration is 23.23 ppb, which is below the ambient standard of 30 ppb. Thus, no violation of the 30-ppb ambient hydrogen sulfide standard was modeled for the proposed and existing Strobel hog feedlots.

The AERMOD results indicate that the three Strobel hog feedlots and the two neighboring feedlots will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the neighboring residences. The calculated maximum monthly hydrogen sulfide concentration for the neighboring residences is 0.45 µg/m3. When a background concentration of 1.00 µg/m3 is added to the AERMOD-calculated concentration, the maximum monthly neighbor hydrogen sulfide concentration is 1.45 µg/m3, which is below the subchronic hydrogen sulfide iHRV of 10 µg/m3.

The modeling results also suggest that the proposed Strobel hog feedlot and the two existing Strobel hog feedlots will not create exceedances of the acute ammonia iHRV. AERMOD calculated a maximum hourly property-line ammonia concentration of 832 µg/m3. When a background concentration of 148 µg/m3 is added to the AERMOD-calculated concentration, the maximum property-line ammonia concentration is 980 µg/m3, which is below the acute ammonia iHRV of 3,200 µg/m3. Thus, no exceedance of the

acute ammonia iHRV was modeled at the property lines for the proposed and existing Strobel hog feedlots.

The AERMOD results indicate that the three Strobel hog feedlots and the two neighboring feedlots will not create exceedances of the chronic ammonia iHRV at the neighboring residences. The calculated maximum one-year time-averaged ammonia concentration for the neighbors is 26.26 µg/m3. When a background ammonia concentration of 5.72 µg/m3 is added to the AERMOD concentration, the maximum annual ammonia concentration for a neighboring residence is 31.98 µg/m3, which is below the chronic ammonia iHRV of 80 µg/m3.

Thus, the modeling results for the proposed Strobel hog feedlot and for the two existing Strobel hog feedlots suggest compliance with the hydrogen sulfide air quality standard, no exceedances of the subchronic hydrogen sulfide iHRV, no exceedances of the acute ammonia iHRV, and no exceedances of chronic ammonia iHRV.

General Modeling Approach The modeling approach assumed that the

proposed Strobel hog feedlot, the two existing Strobel hog feedlots, and the two neighboring feedlots (Feedlot #3 and Feedlot #4) are the only significant and quantifiable emission sources within a 4-mile by 3-mile grid. The air quality impacts associated with the five feedlots were explicitly modeled. The air quality impacts associated with any other sources in the modeled 4-mile by 3-mile grid were considered implicitly as contributors to the background concentrations that are added to the modeling results. Hence, the background concentrations of hydrogen sulfide and ammonia include the impacts associated with sources such as small feedlots, septic tank vents, fertilizer and manure application to cropland, and wetlands.


The AERMOD (version 15181) air quality model , , was used to calculate the property-line 1 2 3

and nearest-neighbor odorous gas concentrations. The calculated concentrations were based on historical wind speeds, wind directions, atmospheric stabilities, and rural mixing heights. The historical weather data consisted of five years (2009-2013) of surface meteorological data for the National Weather Service (NWS) station in Rochester, MN and of upper air weather data for the NWS station in Chanhassen, MN. The Rochester surface weather data represents a location surrounded by flat terrain and row crops. Similar conditions immediately surround the proposed Strobel hog feedlot site. The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file , by the MPCA. 4 5

Maximum one-hour, monthly, and annual average concentrations were calculated. The modeling assumed no decay of any modeled gas due to chemical reactions. A complex terrain was considered. Source and receptor elevations were determined by AERMAP (version 11103) , using 6 7

National Elevation Dataset (NED) files obtained from the Multi-Resolution Land Characteristics

Consortium (MRLC) website. The modeled 8

receptor height was ground level. All modeled property-line and nearest-neighbor receptors were defined as discrete receptors. Property-line receptors were less than or equal to 25 meters apart. An arbitrary Cartesian coordinate system (x, y) was used with the southwest corner of Section 30, Alton Township, Waseca County as the origin (0, 0).

Impact Thresholds and Background Values To assess the potential for environmental

impacts, the concentrations of hydrogen sulfide and ammonia calculated by the air quality modeling were compared to air quality standards and inhalation Health Risk Values (iHRVs). The AERMOD-calculated odor intensities were compared to an odor classification system based on detection-threshold odor numbers.

The direct comparison of model-generated concentrations to these environmental threshold concentrations does not consider the impact of different averaging times. EPA guidelines do not allow concentrations to be time averaged for time

U.S. EPA. 2004. User’s Guide for the AMS/EPA Regulatory Model—AERMOD. U.S. Environmental Protection 1Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-454/B-03-001.

U.S. EPA. 2015. Addendum. User’s Guide for the AMS/EPA Regulatory Model—AERMOD. U.S. Environmental 2

Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-454/B-03-001.

U.S. EPA. 2005. Revision to the Guideline for Air Quality Models. 40 CFR Ch. 1, Part 51, Appendix W 3

(November 9, 2005 Edition).

U.S. EPA. 2004. User’s Guide for the AERMOD Meteorological Preprocessor (AERMET). U.S. Environmental 4

Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC. EPA-454-B-03-002.

U.S. EPA. 2012. Addendum. User’s Guide for the AERMOD Meteorological Preprocessor (AERMET). U.S. 5

Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC. EPA-454-B-03-002.

U.S. EPA. 2004. User’s Guide for the AERMOD Terrain Preprocessor (AERMAP). U.S. Environmental Protection 6

Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-454/B-03-003. U.S. EPA. 2011. Addendum. User’s Guide for the AERMOD Terrain Preprocessor (AERMAP). U.S. 7

Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, March 2011.

http://www.mrlc.gov/viewerjs8


http://www.mrlc.gov/viewerjs

periods less than an hour. This is important 9

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 intensity correlations are often based on instantaneous measurements. For example, an hourly model-generated hydrogen sulfide concentration of 29 ppb 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 AERMOD-calculated concentrations as described in EPA guidelines. The listed 10

background concentrations are 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 when

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 “exceedance 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 exceedance of the iHRV. Also, the 17-ppb hydrogen sulfide background represents the third highest 30-minute concentration that occurred within any 5-day period (i.e., the high-third-high or H3H). This is appropriate, because the ambient hydrogen sulfide standard defines a violation as the third exceedance of 30-ppb within any 5-day period.






Table 1. Background concentrations for rural Minnesota.

Pollutant

Hourly Background

Concentration

13-Week Background

Concentration

Annual Background

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 of hydrogen sulfide and ammonia 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 its 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. 11

The odor threshold concentrations used in this assessment are presented in Table 2.

As a second means of assessing potential odor impacts, the AERMOD-calculated odor intensities (expressed as detection-threshold odor units) were compared to the reference odor intensities provided in Table 3. An odor intensity of 72 detection-threshold odor units (OU) is defined as a faint odor and is the odor intensity that “an average person might detect if attention is called to the odor, but the odor would not otherwise be noticed.” 12

Table 2. Odor threshold concentrations. , 13 14

Odorous Gas

Odor Threshold Concentration

(ppb, v/v)

Hydrogen Sulfide 9.4Ammonia 5,800

Nagy G. Z. 1991. The odor impact model. Journal of Air & Waste Management Association 41(10): 1360-1362.11

Jacobson L. D. and Guo H. 2000. Odor from feedlots setback estimation tool (OFFSET). In: Livestock and 12

Poultry Odor Workshop II, Dept. of Biosystems & Agricultural Engineering, University of Minnesota, St. Paul, MN, 39 pp. AIHA. 1989. Odor Thresholds for Chemicals with Established Occupational Health Standards. American 13

Industrial Hygiene Association, Akron, OH. This reference provided the odor threshold concentrations for hydrogen sulfide.

Devos M., Patte F, Rouault J., Laffort P., and Van Gemert L. J. 1990. Standardized Human Olfactory Thresholds. 14

Oxford University Press, New York, NY. This reference provided the odor threshold concentrations for the ammonia.


Table 3. Odor intensity classification. 15

Source Characterizations The emissions from the mechanically-ventilated

hog barns at the proposed Strobel feedlot and at the Strobel Existing #2 feedlot were characterized as single horizontal point sources to approximate buoyant volume sources. 16

Each modeled horizontal point source was defined in terms of its location, gas emission rate, effective stack diameter, hourly stack velocity, release height, and the temperature of the air exhausted from the barns. The emission rate of 17

each horizontal stack equaled the total emission rate for the modeled barn divided by the horizontal point sources used to characterize the

barn. The effective stack diameter was obtained from the following equation:

# (1)

in which SD is the effective stack diameter (m), Gmax is the maximum hot-weather airflow rate for the entire barn (m3/sec), n is the number of horizontal point sources used to characterize the barn, and us,max is the maximum air velocity leaving the horizontal point source (m/sec). Gmax was calculated by multiplying the number of each type of pig housed in the barn by the respective Midwest Plan Service recommended airflow rate

Odor Intensity Number

Odor Strength

n-Butanol Reference Solution

(ppm)

Detection-Threshold Odor Units (OU, D/T)

0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2,250 2124 strong 6,750 6245 very strong 20,250 1,834

SD = 2Gmaxnπus,max

Jacobson L. D. et al. 2000. Development of an odor rating system to estimate setback distances from animal 15

feedlots: odor for feedlots setback estimation tool (OFFSET). Final Report. Prepared by the Department of Biosystems and Agricultural Engineering, University of Minnesota, St. Paul, MN. 26 pp. Gantzer C. 2014. Characterization of Livestock Barns as Potentially-Buoyant Emission Sources. November 4, 16

2014 Memorandum submitted to the Minnesota Pollution Control Agency. 3 pp.

U.S. EPA. 2014. Addendum. User’s Guide for the AMS/EPA Regulatory Model—AERMOD. U.S. Environmental 17

Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-454/B-03-001.


per pig for hot temperatures. , A maximum 18 19

stack velocity of 7.0 m/sec was assumed. The 20

release height was equal to one-half the height of the barn. The estimated temperature difference between the air inlet and outlet for the barns is provided in Figure 2.

#

Figure 2. Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns. 21

The hourly exhaust velocity (us, m/sec) was calculated from the following re-arrangement of equation (1):

# (2)

in which G is the hourly barn air flow rate (m3/sec). With varying ambient air temperatures, the airflow rates ranged from the minimum cold-weather airflow rate (Gmin) to the maximum hot-weather airflow rate (Gmax). The Gmin and Gmax values for each hog barn were calculated from Midwest Plan Service ventilation factors that are provided in Table 4. Typically, hog barns ventilate at Gmin when ambient air temperatures are less than 5°C (41°F) and ventilate at Gmax when ambient air temperatures are greater than 24 °C (75°F). Between ambient air temperatures of 5°C to 24°C, an approximate linear relationship exists between airflow rate and ambient air temperature. The modeled relationship between 22

ambient air temperature and airflow rate is illustrated in Figure 3.

0

5

10

15

20

25

0 10 20 30 40

Increased)Tempe

rature

of)Exhau

sted

)Air)(°C)

Ambient)Temperature)(°C)

us =G

nπ SD2

⎛⎝⎜

⎞⎠⎟

2

Harmon J. D. 1999. Mechanical Ventilation Design Worksheet for Swine Housing. Iowa State University 18

Extension, PM 1780, 12 pp. Jacobson L. D. 2004. Mechanical Ventilation of Pig Housing. http://www.thepigsite.com/articles/186/mechanical-19

ventilation-for-pig-housing.

BESS. 2014. Agricultural Ventilation Fans. Department of Agricultural and Biological Systems, University of 20

Ilinois at Urbana-Champaign. http://www.bess.illinois.edu The 7.0 m/sec stack velocity is representative of fans with diameters ranging from 36 to 50 inches. MPCA. 2003. Hancock Pro-Pork Hog Feedlot Project. Final Environmental Impact Statement. Minnesota 21

Pollution Control Agency, September 15, 2003.

Hoff, S.J. et al. 2004. Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 22

Emission Rate Estimations. ASAE/CSAE Annual International Meeting, August 1-4, 2004, Paper No. 044178.


http://www.bess.illinois.edu

http://www.thepigsite.com/articles/186/mechanical-ventilation-for-pig-housing

Table 4. Ventilation rate factors. , 23 24

#

Figure 3. Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn, where G is the airflow rate (m3/sec). The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig, respectively. , 25 26

The naturally-ventilated livestock barns at the Strobel Existing #1 feedlot and the two neighboring feedlots were characterized as either line sources or volume sources using the approaches described in EPA air quality modeling documentation. , 27 28

A barn with a length greater than twice its width (aspect ratio greater than 2) was represented as a line source, i.e., a line of separated square volume subsources. Each subsource was defined in terms of its location, size, gas emission rate, initial lateral dimension of the volume source, release height, and the initial vertical dimension of the volume source. The sides of each square volume subsource were equal the width of the modeled barn. The distance between the centers of the neighboring square volume subsources was calculated by the following equation:

# (3)

in which D is the distance between volume subsource centers (m), W is the barn width (m), L is the barn length (m), and n is the number of square volume subsources used to characterize the barn. The emission rate for each square volume subsource equalled the total emission rate for the barn divided by the number of square volume subsources used to represent the barn. The initial lateral dimension was determined by the following equation:

Barn Units Gmin Gmax

Gestation CFM/sow 12 150

Farrowing CFM/sow 20 500

Finishing CFM/pig 10 120

0.0

0.2

0.4

0.6

0.8

1.0

1.2

0 5 10 15 20 25 30

Frac%o

nal)A

irflow

)Rate,)G/G

max

Ambient)Temperature)(°C)

Gmin

Gmax

D =W + L− nWn−1

Harmon J. D. 1999. Mechanical Ventilation Design Worksheet for Swine Housing. Iowa State University 23

Extension, PM 1780, 12 pp.

Jacobson L. D. 2004. Mechanical Ventilation of Pig Housing. http://www.thepigsite.com/articles/186/mechanical-24

ventilation-for-pig-housing. Harmon J. D. 1999. Mechanical Ventilation Design Worksheet for Swine Housing. Iowa State University 25

Extension, PM 1780, 12 pp.

Jacobson L. D. 2004. Mechanical Ventilation of Pig Housing. http://www.thepigsite.com/articles/186/mechanical-26

ventilation-for-pig-housing. U.S. EPA. 1995. User’s Guide for the Industrial Source Complex (ISC3) Dispersion Models. Volume II–27

Description of Model Algorithms. U.S. Environmental Protection Agency, Office of Air Quality, Research Triangle Park, NC, EPA-454/B-95-003b.

U.S. EPA. 2004. User’s Guide for the AMS/EPA Regulatory Model—AERMOD. U.S. Environmental Protection 28

Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-454/B-03-001.




(4)

in which σyo is the initial lateral dimension of the volume subsource (m). The source height of the emitted gas was equal to one-half the height of the barn. The initial vertical dimension was obtained from the following equation:

(5)

in which σzo is the initial vertical dimension of the volume subsource (m) and H is the height of the barn (m).

A barn with an aspect ratio less than or equal to 2 was modeled as a square volume source. The side length was calculated from the following equation:

(6)

in which S is the side length (m). The emission rate for the single square volume source was equal to the total emission rate for the barn. The initial lateral dimension was determined by the following equation:

(7)

in which σyo is the initial lateral dimension of the single volume source (m). The source height of the emitted gas was equal to one-half the barn height. The initial vertical dimension was obtained from equation (5).

The hog manure storage basins at the Strobel Existing #1 feedlot were characterized as non-buoyant area sources. The BASINODOR algorithms calculated hourly emission rates based on the water-phase concentration of the modeled gas, the estimated water temperature, and the recorded wind speed. BASINODOR uses EPA-recommended mass-transfer algorithms to estimate emission rates. The liquid-phase mass transfer coefficient 29

in the BASINODOR algorithms was defined by modified Mackay-Yeun correlations. , , 30 31 32

Hourly water temperatures within the hog manure storage basins were calculated by the heat balance approach described in Thomann and Mueller (1987). The approach assumes that the 33

basin is completely-mixed vertically and that the sky is free of clouds. The EPA’s PCRAMMET algorithms were used to estimate the hourly 34

variation in solar radiation based on day of the year, hour of the day, site latitude, and site

σ yo =D2.15

σ zo =H2.15

S = LW

σ yo =S4.3

U.S. EPA. 1994. Air Emissions Models for Waste and Wastewater. U.S. Environmental Protection Agency, Office 29

of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-453/R-94-080A.

Hedden T. 1982. Volatile Organic Chemical Emissions from Wastewater Impoundments Under No-Wind 30

Conditions. Master’s thesis, University of Arkansas, Fayetteville, AR Lunney P. D. 1983. Characterization of Wind and Depth Effects upon Liquid Phase Mass Transfer Coefficients: 31

Simulation Studies. Master’s thesis, University of Arkansas, Fayetteville, AR.

Blunden J., Anega V. P. and Overton J. H. 2008. Modeling hydrogen sulfide emissions across the gas-liquid 32

interface of an anaerobic swine waste treatment storage system. Atmospheric Environment 42: 5602-5611. Thomann R. V. and Mueller J. A. 1987. Principles of Surface Water Quality Modeling and Control. Harper & 33

Row, Publishers, Inc., New York, NY, 644 pp.

U.S. EPA. 1999. PCRAMMET User’s Guide. U.S. Environmental Protection Agency, Office of Air Quality 34

Planning and Standards, Research Triangle Park, NC. EPA-454-B-96-001 (Revised June 1999).


longitude. Basin depth was assumed constant and equal to maximum design capacity depth. When the water temperature algorithms predicted water temperatures less than or equal to 0°C (32°F), the emission algorithms assumed that the basin was ice covered and that no gas emissions were emitted into the atmosphere.

For the open cattle lot at Feedlot #3, the OPENLOTFLUX algorithms calculated the hourly hydrogen sulfide, ammonia, and odor emission flux rates based on the wind speed, cloud cover, solar radiation, air temperature, and surface soil temperature. OPENLOTFLUX uses mass transfer algorithms obtained from the agricultural and micro-meteorological literature. , 35 36

OPENLOTFLUX uses the average effective hydrogen sulfide and ammonia concentrations at the surface of the manure pack obtained from cattle feedlot monitoring data. , An average 37 38

effective odor surface concentration was obtained from the flux chamber measurements of Duysen et al. (2003) and the ratio of ammonia fluxes 39

measured with flux chambers and micro-meteorological techniques reported by Beak et al. (2006). The impact of manure pack temperature 40

on hydrogen sulfide and ammonia flux rates was calculated using the correlations of Koziel et al. (2005). Manure pack temperatures were 41

calculated from the historical soil temperatures at 4-inch below the surface near Lamberton, MN. 42

Monthly scalars were used to address temperature impacts on odor emission flux rates. 43

Neighboring Residences The air quality modeling calculated the odorous

gas concentrations at the 57 neighboring residences shown in Figure 4.

Sommer S. G. and Olesen J. E. 2000. Modeling ammonia volatilization from animal slurry applied with trail hoses 35

to cereals. Atmospheric Environment 34(15): 2361-2372.

Arya S. P. 2001. Introduction to Micrometeorology. Second Edition. Academic Press, San Diego, CA.36

Todd R. W. et al. 2005. Ammonia and gaseous nitrogen emissions from a commercial cattle feedyard estimated 37

using the flux-gradient method and the N:P ratio analysis. In: State of the Science, Animal Manure and Waste Management, January 4-7, 2005, San Antonio, TX.

Baek B. H. et al. 2006. Ammonia and hydrogen sulfide flux and dry deposition velocity estimates using vertical 38

gradient method at a commercial beef cattle feedlot. International Journal of Global Environmental Issues 6(2-3): 189-203.

Duysen R. D. et al. 2003. Ammonia, hydrogen sulfide and odor emissions from a beef cattle feedlot. ASAE 39

Meeting Paper No. 034109. St. Joseph, MI. Baek B. H. et al. 2006. Ammonia and hydrogen sulfide flux and dry deposition velocity estimates using vertical 40

gradient method at a commercial beef cattle feedlot. International Journal of Global Environmental Issues 6(2-3): 189-203.

Koziel, J. et al. 2005. Ammonia and hydrogen sulfide emissions from beef cattle feedlots. Livestock Emissions 41

Research Symposium, California Air Resources Board, Fresno, CA. www.swroc.coafes.umn.edu/weather/Reports/soil_hist_ave.PDF42


Meeting Paper No. 034109. St. Joseph, MI.


http://www.swroc.coafes.umn.edu/weather/Reports/soil_hist_ave.PDF%06

#

Figure 4. Modeled locations of the proposed Strobel hog feedlot (SW ¼ of Section 30, Alton Township), the Strobel Existing #1 hog feedlot (not labeled), the Strobel Existing #2 hog feedlot (not labeled), the two neighboring feedlots (not labeled), and the 57 neighboring residences.


Site Descriptions

Proposed Strobel Hog Feedlot The proposed Strobel hog feedlot will consist of

two 2,400-head mechanically-ventilated hog-finishing barns. The modeled locations of the two hog barns are provided in Figure 5. The setback distances from the barns to the property lines range from 742 to 1,532 feet.

The physical characteristics of the hog barns are provided in Table 5. Both barns were modeled as buoyant volume sources.

#

Figure 5. Modeled locations of the hog barns and property lines for the proposed Strobel hog feedlot.

Strobel Existing #1 Hog Feedlot The existing Strobel hog feedlot located in the

SE ¼, Section 23, McPherson Township, Blue Earth County consists of five naturally-ventilated hog-finishing barns and two manure storage basins. The modeled locations of the barns and basins are provided in Figure 6.

The physical characteristics of the hog barns are provided in Table 6. The five barns were modeled as line sources.

The two 255-ft by 150-ft manure storage basins were modeled as non-buoyant area sources with emissions that varied hourly.

#

Figure 6. Modeled locations of the hog barns and manure storage basins at the Strobel Existing #1 hog feedlot.

1030'

742'

1270'

1532'

2570'

2640'

(35', 0')

N

E

S

W

Finishing #1

Finishing #2

(-7885', 5280')

900' 1344'

1405'

722'

N

E

S

W

2605'

2640'Finishing #1 through #5

Basin #1 Basin #2


Table 5. Dimensions and capacities of the hog barns at the proposed Strobel feedlot.

Table 6. Dimensions and capacities of the hog barns at the Strobel Existing #1 feedlot.

Table 7. Dimensions and capacities of the hog barns at the Strobel Existing #2 feedlot.

Hog Barn

Barn Length (feet)

Barn Width (feet)

Barn Height (feet)

Number of Housed

Pigs

Finishing #1 200 110 26 2,400Finishing #2 200 110 26 2,400

Hog Barn

Barn Length (feet)

Barn Width (feet)

Barn Height (feet)

Number of Housed

Pigs

Finishing #1 198 41 17 960Finishing #2 198 41 17 960Finishing #3 198 41 17 960Finishing #4 198 41 17 960Finishing #5 198 41 17 960

Hog Barn

Barn Length (feet)

Barn Width (feet)

Barn Height (feet)

Number of Housed

Pigs

Finishing #1 192 102 25 2,400Finishing #2 192 102 25 2,400


Strobel Existing #2 Hog Feedlot The existing Strobel hog feedlot located in the

NW ¼, Section 36, McPherson Township, Blue Earth County consists two 2,400-head mechanically-ventilated hog-finishing barns. The modeled locations of the two hog barns are provided in Figure 7.

The physical characteristics of the hog barns are provided in Table 7. Both barns were modeled as buoyant volume sources.

#

Figure 7. Modeled locations of the hog barns and manure storage basins at the Strobel Existing #2 hog feedlot.

Feedlot #3 Feedlot #3 is a 300-head hog-finishing

operation and a 20-head cattle operation. The hogs are assumed to be housed in one finishing barn. The cattle are assumed to be found in a 177-ft by 40-ft lot. The modeled locations of the barn and lot are provided in Figure 8.

The physical characteristics of the hog barn are provided in Table 8. The barn was modeled as a volume source.

The lot was modeled as a non-buoyant area source with emissions that varied by the hour.

#

Figure 8. Modeled locations of the hog barn and open cattle lot for Feedlot #3.

150'

2153'

1287'

2607'

137'

N

E

S

W

(-5280', -2640')

Finishing #1

Finishing #2958'

(-3638, 1850')

N

E

S

W

50'

50'

250'

50'

370'

Finishing #1

Lot #1

460'

400'


Table 8. Dimensions and capacities of the hog barn at Feedlot #3.

Feedlot #4 Feedlot #4 consists of two naturally-ventilated

hog-finishing barns. The modeled locations of the barns are provided in Figure 9.

The physical characteristics of the hog barns are provided in Table 9. Both barns were modeled as volume sources.

#

Figure 9. Modeled locations of the hog barns at Feedlot #4.

Table 9. Dimensions and capacity of the hog barns at Feedlot #4.

Hog Barn

Barn Length (feet)

Barn Width (feet)

Barn Height (feet)

Number of Housed

Pigs

Finishing #1 60 36 16 300

75'

123'

128'

422'

(4652', -3960')

61'

Finishing #1

Finishing #2

N

ES

W

593'

332'

Hog Barn

Barn Length (feet)

Barn Width (feet)

Barn Height (feet)

Number of Housed

Pigs

Finishing #1 41 23 15 115Finishing #2 52 32 16 200


Gas Emission Rates

Hog-Finishing Barns The mechanically-ventilated hog-finishing

barns at the proposed Strobel hog feedlot and at the Strobel Existing #2 hog feedlot were modeled as sources of hydrogen sulfide, ammonia, and odor. The calculated hydrogen sulfide and ammonia emission rates were based on the following constant emission factors:

• 3.35 µg H2S/(m2•sec)

• 53.3 µg NH3/(m2•sec). 44

Estimated odor emission rates varied hourly based on the following median finishing-pig specific emission factor:

• 6.63 OU•m3/(pig•sec). 45

Odor emissions varied based on exhausted air temperature, barn ventilation rate, and hog diurnal activity cycle. 46

For the naturally-ventilated hog-finishing barns at the Strobel Existing #1 hog feedlot, Feedlot #3, and Feedlot #4, the calculated barn emission rates were based on the following constant emission factors:

• 3.35 µg H2S/(m2•sec)

• 53.3 µg NH3/(m2•sec)

• 6.86 OU•m3/(m2•sec). 47

Hog Manure Storage Basin The hog manure storage basins at the Strobel

Existing #1 hog feedlot were modeled as sources of hydrogen sulfide, ammonia, and odor. The BASINODOR algorithms estimated hourly hydrogen sulfide, and ammonia emissions from the basins based on the manure chemistry provided in Table 10. To illustrate the range and variability in the hourly emissions, the estimated 2009 noon-hour emission flux rates for hydrogen sulfide and ammonia are provided in Figures 10 and 11, respectively.

The odor emission rates for the hog manure storage basins were based on an odor flux of 3.01 OU•m3/(m2•sec). This emission flux rate 48

reflects low air velocities at the liquid surface. To account for the effect of wind velocity on odor emission rates, the emission flux rates were multiplied by the scalars plotted in Figure 12.

Table 10. Chemical characteristics of stored hog manure.

Parameter Units Value

pH -log10[H+] 8.2Sulfide mg S/L 0.6Ammonia mg N/L 784

Gay S. W. et al. 2003. Odor, total reduced sulfur, and ammonia emissions from animal housing facilities and 44

manure storage units in Minnesota. Applied Engineering in Agriculture 19(3): 347-360. Schauberger G. et al. 2013. Empirical model of odor emission from deep-pit swine finishing barns to derive a 45

standardized odor emission factor. Atmospheric Environment 66: 84-90. The median finishing-pig specific odor emission factor assumes a time-averaged pig mass of 69 kg (152 pounds).

Ibid.46

Gay S. W. et al. 2003. Odor, total reduced sulfur, and ammonia emissions from animal housing facilities and 47

manure storage units in Minnesota. Applied Engineering in Agriculture 19(3): 347-360.

Ibid.48


#

Figure 10. Estimated 2009 noon-hour hydrogen sulfide (H2S) flux rates for a hog manure storage basin.

#

Figure 11. Estimated 2009 noon-hour ammonia (NH3) flux rates for a hog manure storage basin.

#

Figure12. Estimated odor emission flux scalars as a function of wind velocity for a crust-free manure storage basin.

Open Cattle Lot The open cattle lot at Feedlot #3 was modeled

as a source of hydrogen sulfide, ammonia, and odor. Emission rates were equal to the surface area times the estimated emission flux rate. The modeled hydrogen sulfide and ammonia emission flux rates from the manure pack of the open lot varied hourly. The OPENLOTFLUX algorithms calculated the emission flux rates, based on the wind speed, manure pack temperature, and effective surface concentrations. Temperature effects on hydrogen sulfide and ammonia flux rates were calculated using the correlations of Koziel et al. (2005). The impact of temperature 49

on odor emission flux rates was addressed by the monthly scalars listed in Table 11.

To illustrate the range and variability in the hourly emissions, the estimated 2009 noon-hour emission flux rates for hydrogen sulfide are provided in Figure 13.

0.00

0.05

0.10

0.15

0.20

0.25

0.30

0.35

0 50 100 150 200 250 300 350

H 2S$Flux$[g

/(m

2 •da

y)]

Julian$Day

0

10

20

30

40

50

60

0 50 100 150 200 250 300 350

NH 3

$Flux$[g/(m

2 •da

y)]

Julian$Day

0

4

8

12

16

20

0 3 6 9 12 15

Odo

r%Flux%Scalar

Wind%Velocity%(meter/sec)

Koziel, J. et al. 2005. Ammonia and hydrogen sulfide emissions from beef cattle feedlots. Livestock Emissions 49

Research Symposium, California Air Resources Board, Fresno, CA.


Table 11. Odor emission scalars for lots. 50

#

Figure 13. Estimated 2009 noon-hour hydrogen sulfide (H2S) emission flux rates for an open cattle lot.

Hydrogen Sulfide at Property Lines and Neighbors

The AERMOD results suggest that the proposed Strobel hog feedlot and the two existing Strobel hog feedlots will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S). The calculated high-third-high (H3H) concentrations at the proposed, Existing #1, and Existing #2 property lines are provided in Tables 12, 13, and 14, respectively. When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations, the maximum H3H hydrogen sulfide concentration is 23.23 ppb, which does not exceed the standard of 30 ppb. Thus, no violations of the hydrogen sulfide standard were modeled for the three Strobel feedlots.

Table 12. High-third-high hourly property-line hydrogen sulfide concentrations for the

proposed Strobel hog feedlot.

Month Odor

Emission Scalar

January 0.38February 0.38March 0.38April 1.00May 1.00June 0.67July 0.67August 0.64September 0.38October 0.38November 0.38December 0.38

0.00

0.04

0.08

0.12

0.16

0.20

0 50 100 150 200 250 300 350

H 2SFlux[g

/(m

2 •da

y)]

JulianDay

Proposed Feedlot

Property Line

High-Third- High H2S

Concentration Without

Background (ppb, v/v)


Concentration With a 17 ppb Background (ppb, v/v)

North 0.93 17.93East 0.51 17.51

South 0.38 17.38West 0.47 17.47


Meeting Paper No. 034109. St. Joseph, MI



Strobel Existing #1 hog feedlot.


Strobel Existing #2 hog feedlot.

The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 14. The plotted 10-ppb concentration isopleth is assumed to represent the the maximum extent of detectable hydrogen sulfide odors. This assumption slightly underestimates the extent of detectable odors, because the reported odor threshold concentration

for hydrogen sulfide is 9.4 ppb (Table 2). The 10-ppb isopleth in Figure 14 suggests that detectable concentrations of hydrogen sulfide can exist beyond the property lines for the Strobel Existing #1 feedlot. No detectable off-site concentrations of hydrogen sulfide are associated with the proposed Strobel hog feedlot and with the Strobel Existing #2 hog feedlot.

#

Figure 14. Maximum AERMOD-calculated hourly hydrogen sulfide concentrations in ppb for the proposed Strobel hog feedlot, the two existing Strobel hog feedlots, and the two neighboring feedlots. The contour lines represent 2, 6, and 10 ppb of hydrogen sulfide. The plotted concentra-tions do not include the 17-ppb background hydrogen sulfide concentration.

The AERMOD results also suggest that the proposed Strobel feedlot, the two existing Strobel feedlots, and the two neighboring feedlots will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the neighboring residences. As provided in Table 15, when a background concentration of 1.00 µg/m3 is added to the AERMOD-calculated concentrations, the maximum monthly hydrogen sulfide concentration for a neighboring residence is 1.45 µg/m3, which is below the subchronic iHRV for hydrogen sulfide of 10 µg/m3.

Existing #1 Feedlot

Property Line






North 3.41 20.41East 3.79 20.79

South 4.32 21.32West 6.23 23.23

Existing #2 Feedlot

Property Line






North 0.52 17.52East 1.54 18.54

South 2.39 19.39West 0.55 17.55

2 2

2

610

2

2

-1

0

1

2

-2 -1 0 1 2

North/Sou

thDistance(m

iles)

East/WestDistance(miles)


Table 15. Maximum monthly H2S concentrations for neighboring residences.

(* = feedlot residence)

Table 15. Maximum monthly H2S concentrations for neighboring residences

(continued). (* = feedlot residence)

Neighbor

H2S Concentration

WithoutBackground

(µg/m3)

H2S Concentration

With a 1 µg/m3 Background

(µg/m3)

A1 0.02 1.02A2 0.02 1.02A3 0.05 1.05A4 0.06 1.06A5 0.13 1.13A6 0.20 1.20B1 0.03 1.03B2 0.02 1.02B3 0.02 1.02B4 0.03 1.03B5 0.02 1.02B6 0.02 1.02B7 0.05 1.05C1 0.02 1.02C2 0.02 1.02C3 0.01 1.01D1 0.01 1.01D2 0.01 1.01D3 0.01 1.01D4 0.01 1.01E1 0.01 1.01E2 0.01 1.01E3 0.01 1.01E4 0.01 1.01F1 0.01 1.01F2 0.01 1.01F3 0.07 1.07G1 0.03 1.03

Neighbor

H2S Concentration

WithoutBackground

(µg/m3)

H2S Concentration With a 1 µg/m3

Background (µg/m3)

G2 0.03 1.03G3 0.03 1.03G4 0.03 1.03G5 0.03 1.03G6 0.03 1.03G7* 0.45 1.45H1 0.02 1.02I1 0.01 1.01I2 0.02 1.02I3 0.02 1.02J1 0.02 1.02

J2* 0.06 1.06J3 0.02 1.02J4 0.03 1.03K1 0.02 1.02K2 0.03 1.03K3 0.03 1.03K4 0.13 1.13K5 0.02 1.02L1 0.03 1.03L2 0.02 1.02L3 0.01 1.01L4 0.01 1.01L5 0.01 1.01L6 0.01 1.01L7 0.01 1.01L8 0.01 1.01L9 0.02 1.02

L10 0.02 1.02


Ammonia at Property Lines and Neighbors

The AERMOD-calculated maximum hourly property-line ammonia (NH3) concentrations at the property lines for the proposed Strobel feedlot, Strobel Existing #1 feedlot, and Strobel Existing #2 feedlot are provided in Tables 16, 17, and 18, respectively. The highest calculated property-line concentration with a background concentration of 148 µg/m3 is 980 µg/m3, which is below the acute iHRV for ammonia of 3,200 µg/m3. Thus, no exceedances of the acute ammonia iHRV were modeled for the three Strobel feedlots.

Table 16. Maximum hourly property-line ammonia concentrations for the proposed

Strobel hog feedlot.

The maximum AERMOD-calculated hourly ammonia concentrations (without background) are plotted in Figure 15. The reported odor threshold concentration for ammonia is 4,125 µg/m3 or 5,800 ppb (Table 2). Because all plotted ammonia concentrations are less than 4,125 µg/m3, Figure 15 suggests that the proposed Strobel hog feedlot, the two existing Strobel hog feedlots, and the two neighboring feedlots will not generate detectable off-site concentrations of ammonia.

Table 17. Maximum hourly property-line ammonia concentrations for the Strobel

Existing #1 hog feedlot.

Table 18. Maximum hourly property-line ammonia concentrations for the Strobel

Existing #2 hog feedlot. Proposed Feedlot

Property Line

NH3Concentration

WithoutBackground

(µg/m3)

NH3Concentration

With a 148 µg/m3

Background (µg/m3)

North 57.50 205.50East 37.31 185.31

South 38.80 186.80West 57.42 205.42

Existing #1 Feedlot

Property Line

NH3Concentration

WithoutBackground

(µg/m3)

NH3Concentration

With a 148 µg/m3

Background (µg/m3)

North 379.09 527.09East 355.94 503.94

South 831.88 979.88West 632.08 780.08

Existing #2 Feedlot

Property Line

NH3Concentration

WithoutBackground

(µg/m3)

NH3Concentration

With a 148 µg/m3

Background (µg/m3)

North 108.57 256.57East 97.88 245.88

South 61.90 209.90West 67.28 215.28


#

Figure 15. Maximum AERMOD-generated hourly ammonia concentration in µg/m3 for the proposed Strobel hog feedlot, the two existing Strobel hog feedlots, and the two neighboring feedlots. The contour lines represent 100 and 500 µg/m3 of ammonia. The plotted concentrations do not include the 148 µg/m3 background ammonia concentration.

The AERMOD results also suggest that the proposed Strobel feedlot, the two existing Strobel feedlots, and the two neighboring feedlots will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors. As provided in Table 19, the highest annual ammonia concentration for a neighbor with a background concentration of 5.72 µg/m3 is 31.98 µg/m3, which is below the chronic ammonia iHRV of 80 µg/m3.

Table 19. Maximum annual NH3 concentrations for neighbors residences.

(* = feedlot residence) 100

100

100

100

500

100

-1

0

1

2

-2 -1 0 1 2

North/Sou

thDistance(m

iles)


Neighbor

NH3Concentration

WithoutBackground

(µg/m3)

NH3Concentration

With a 5.72 µg/m3 Background

(µg/m3)

A1 0.51 6.23A2 0.54 6.26A3 0.88 6.60A4 0.90 6.62A5 2.75 8.47A6 2.49 8.21B1 0.40 6.12B2 0.36 6.08B3 0.22 5.94B4 0.50 6.22B5 0.37 6.09B6 0.37 6.09B7 0.80 6.52C1 0.23 5.95C2 0.19 5.91C3 0.12 5.84D1 0.11 5.83D2 0.09 5.81D3 0.08 5.80D4 0.07 5.79E1 0.09 5.81E2 0.09 5.81E3 0.11 5.83E4 0.16 5.88F1 0.14 5.86F2 0.14 5.86F3 0.49 6.21G1 0.50 6.22


Table 19. Maximum annual NH3 concentrations for neighbors residences. (continued)

(* = feedlot residence)

Odorous Gas Concentrations AERMOD calculated the ground-level

atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed and existing Strobel feedlots, and at the neighboring residences. The calculated maximum property-line concentrations are 1,165 ppb for ammonia (without background) and 9.69 ppb for hydrogen sulfide (without background). The corresponding odor numbers for the maximum property-line concentrations are 1.0 for hydrogen sulfide and 0.2 for ammonia. Population response curves suggest that 52 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 2 percent the ammonia concentration.

The estimated maximum hourly concentrations for the neighboring residences are 1,047 ppb for ammonia (without background), and 7.46 ppb for hydrogen sulfide (without background). The corresponding odor numbers for the maximum neighbor concentrations are 0.8 for hydrogen sulfide and 0.2 for ammonia. Population response curves suggest that 37 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 2 percent the ammonia concentration. The population response curves assume the presence of individual gases.

Neighbor

NH3Concentration

WithoutBackground

(µg/m3)

NH3Concentration

With a 5.72 µg/m3 Background

(µg/m3)

G2 0.44 6.16G3 0.44 6.16G4 0.45 6.17G5 0.43 6.15G6 0.35 6.07

G7* 26.26 31.98H1 0.41 6.13I1 0.17 5.89I2 0.13 5.85I3 0.14 5.86J1 0.24 5.96J2* 0.61 6.33J3 0.28 6.00J4 0.27 5.99K1 0.24 5.96K2 0.28 6.00K3 0.27 5.99K4 1.09 6.81K5 0.18 5.90L1 0.20 5.92L2 0.15 5.87L3 0.11 5.83L4 0.10 5.82L5 0.10 5.82L6 0.10 5.82L7 0.10 5.82L8 0.10 5.82L9 0.11 5.83L10 0.15 5.87


Odor Intensities at Property Lines and Neighbors

AERMOD calculated the ground-level odor intensities at the property lines for the proposed Strobel hog feedlot, at the property lines for the two existing Strobel hog feedlots, and at the locations for 57 of the feedlots’ neighboring residences. As indicated in Tables 20, 21, and 22, the maximum hourly odor intensity at the three Strobel feedlots’ property lines is 45 odor units (OU), which is below the “faint” odor threshold of 72 OU (Table 3).

Figure 16 suggests that no off-site “faint” or stronger odors will be associated with the proposed Strobel hog feedlot, the two existing Strobel hog feedlots, and the two neighboring feedlots.

Table 20. Maximum hourly property-line odor intensities and the frequency at which the

“faint” odor threshold of 72 OU is equaled or exceeded for the proposed Strobel hog

feedlot.


“faint” odor threshold of 72 OU is equaled or exceeded for the Strobel Existing #1 hog

feedlot.


“faint” odor threshold of 72 OU is equaled or exceeded for the Strobel Existing #2 hog

feedlot.

Proposed Feedlot

Property Line

Maximum Hourly Odor

Intensity (OU, d/t)

Frequency at Which the

“Faint” Odor Threshold is

Exceeded (percent)

North 4 0.00East 3 0.00

South 3 0.00West 3 0.00

Existing #1 Feedlot

Property Line

Maximum Hourly Odor

Intensity (OU, d/t)



Exceeded (percent)

North 26 0.00East 25 0.00

South 45 0.00West 31 0.00

Existing #2 Feedlot

Property Line

Maximum Hourly Odor

Intensity (OU, d/t)



Exceeded (percent)

North 5 0.00East 9 0.00

South 11 0.00West 5 0.00


#

Figure 16. Maximum AERMOD-calculated hourly odor intensities for the proposed Strobel feedlot, the two existing Strobel feedlots, and the two neighboring feedlots. The threshold for “very faint” odors is 25 OU and for “faint” odors is 72 OU (Table 3).

The AERMOD-calculated ground-level odor intensities at the 57 neighboring residences are provided in Table 23. The estimated maximum odor intensity for a non-feedlot neighboring residence is 27 OU at Neighbor A6, which is below the 72-OU threshold for “faint” odors.

Table 23. Maximum neighbor odor intensities. (* = feedlot residence)

2572

-1

0

1

2

-2 -1 0 1 2

North/Sou

thDistance(m

iles)


Neighbor

Maximum Hourly Odor

Intensity (OU, d/t)



Exceeded (percent)

A1 10 0.00A2 8 0.00A3 15 0.00A4 15 0.00A5 22 0.00A6 27 0.00B1 10 0.00B2 8 0.00B3 5 0.00B4 10 0.00B5 6 0.00B6 5 0.00B7 9 0.00C1 4 0.00C2 3 0.00C3 2 0.00D1 2 0.00D2 2 0.00D3 2 0.00D4 2 0.00E1 2 0.00E2 2 0.00E3 2 0.00E4 2 0.00F1 3 0.00F2 3 0.00F3 2 0.00G1 7 0.00


Table 23. Maximum neighbor odor intensities. (continued) (* = feedlot residence)

Summary The AERMOD modeling results suggest that

the proposed Strobel hog feedlot , the Strobel Existing #1 hog feedlot, and the Strobel Existing #2 hog feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlot’s property lines. The results also suggest that the three Strobel feedlots will not create exceedances of the acute ammonia iHRV at its property lines.

The modeling results suggest that the proposed Strobel hog feedlot, the two existing Strobel hog feedlots, and the two neighboring feedlots will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences.

The calculated maximum property-line odor intensities for the proposed Strobel hog feedlot , the Strobel Existing #1 hog feedlot, and the Strobel Existing #2 hog feedlot were less the 72-OU threshold for “faint” odors. The modeled odor intensities for the non-feedlot neighboring residences were also below the 72-OU threshold for “faint” odors.

Neighbor

Maximum Hourly Odor

Intensity (OU, d/t)



Exceeded (percent)

G2 5 0.00G3 4 0.00G4 5 0.00G5 3 0.00G6 4 0.00

G7* 76 0.00H1 8 0.00I1 3 0.00I2 2 0.00I3 3 0.00J1 3 0.00J2* 5 0.00J3 3 0.00J4 2 0.00K1 3 0.00K2 2 0.00K3 2 0.00K4 7 0.00K5 2 0.00L1 2 0.00L2 2 0.00L3 1 0.00L4 1 0.00L5 1 0.00L6 1 0.00L7 1 0.00L8 1 0.00L9 1 0.00L10 2 0.00


0 1,300 2,600 3,900 5,200650Feet

Imagery Courtesy of BING.

NOTES:Well locations courtesy of MN County Well Index. Feedlots courtesy of MPCA.

Waseca County, MN Strobel Farms - Alton 30 SiteOne-Mile Radius Map

Greg Strobel Project - EAW

Legend_̂ Site LocationX Wells!( Residence

Distance to ResidenceFeedlots

One Mile RadiusSite MapManure AcresWaterwaySpecial Protection Area

·

Documents

Strobel Farms - Alton 30 site: Signature document (p-ear2-102b)