www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • Use your preferred relay service • Available in alternative formats p-ear2-135a Page 1 of 2 Notice of Availability of an Environmental Assessment Worksheet (EAW) Valley Pork, LLP Site #2 Doc Type: Public Notice Public comment information EAW public comment period begins: November 13, 2017 EAW public comment period ends: 4:30 p.m. on December 13, 2017 Notice published in the EQB Monitor: November 13, 2017 Permit public comment period begins: November 13, 2017 Permit public comment period ends: December 13, 2017 Facility specific information Facility name and location: Facility contact: Valley Pork, LLP Site #2 Traverse County Tintah Township NE1/4, NE1/4, Section 35 Township 129N, Range 45W Scott Strahm Valley Pork, LLP 32686 460 th Avenue Hancock, MN 56244 Office: 320-392-5685 Email: [email protected]MPCA contact information MPCA EAW contact person: MPCA Permit contact person: Steve Sommer Resource Management and Assistance Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 Phone: 651-757-2746 Fax: 651-297-2343 Email: [email protected]Scott Schroeder Watershed Division Minnesota Pollution Control Agency 714 Lake Avenue Detroit Lakes 56501 Phone: 218-846-8134 Fax: 218-846-0719 Email: [email protected]General information The Minnesota Pollution Control Agency (MPCA) is distributing this Environmental Assessment Worksheet (EAW) for a 30-day review and comment period pursuant to the Environmental Quality Board (EQB) rules. The MPCA uses the EAW and any comments received to evaluate the potential for significant environmental effects from the project and decide on the need for an Environmental Impact Statement (EIS). An electronic version of the EAW is available on the MPCA Environmental Review webpage at https://www.pca.state.mn.us/eaw. If you would like a copy of the EAW or NPDES/SDS Permit or have any questions on the EAW or NPDES/SDS Permit, contact the appropriate person(s) listed above. Description of proposed project Valley Pork, LLP proposes to construct and operate a new 3,030 animal unit swine farrowing facility (8,700 head) in Section 35 of Tintah Township in Traverse County (Project). The Project consists of installing one barn, an animal mortality composting structure, a repair shop, an office, three permanent stormwater ponds, three water wells, and employee housing.
Transcript
wwwpcastatemnus bull 651-296-6300 bull 800-657-3864 bull Use your preferred relay service bull Available in alternative formats
p-ear2-135aPage 1 of 2
Notice of Availability of an Environmental Assessment
Worksheet (EAW) Valley Pork LLP Site 2
Doc Type Public Notice
Public comment information EAW public comment period begins November 13 2017
EAW public comment period ends 430 pm on December 13 2017
Notice published in the EQB Monitor November 13 2017
Permit public comment period begins November 13 2017
Permit public comment period ends December 13 2017
Facility specific information Facility name and location Facility contact Valley Pork LLP Site 2 Traverse CountyTintah Township NE14 NE14 Section 35 Township 129N Range 45W
Scott Strahm Valley Pork LLP 32686 460th Avenue Hancock MN 56244 Office 320-392-5685 Email scottstrahmboyssupplycom
MPCA contact information MPCA EAW contact person MPCA Permit contact person Steve Sommer Resource Management and Assistance Division Minnesota Pollution Control Agency 520 Lafayette Road North St Paul MN 55155 Phone 651-757-2746 Fax 651-297-2343 Email stevesommerstatemnus
Scott Schroeder Watershed Division Minnesota Pollution Control Agency 714 Lake Avenue Detroit Lakes 56501 Phone 218-846-8134 Fax 218-846-0719 Email scotttschroederstatemnus
General informationThe Minnesota Pollution Control Agency (MPCA) is distributing this Environmental Assessment Worksheet (EAW) for a 30-day review and comment period pursuant to the Environmental Quality Board (EQB) rules The MPCA uses the EAW and any comments received to evaluate the potential for significant environmental effects from the project and decide on the need for an Environmental Impact Statement (EIS)
An electronic version of the EAW is available on the MPCA Environmental Review webpage at httpswwwpcastatemnuseaw If you would like a copy of the EAW or NPDESSDS Permit or have any questions on the EAW or NPDESSDS Permit contact the appropriate person(s) listed above
Description of proposed project Valley Pork LLP proposes to construct and operate a new 3030 animal unit swine farrowing facility (8700 head) in Section 35 of Tintah Township in Traverse County (Project) The Project consists of installing one barn an animal mortality composting structure a repair shop an office three permanent stormwater ponds three water wells and employee housing
wwwpcastatemnus bull 651-296-6300 bull 800-657-3864 bull Use your preferred relay service bull Available in alternative formats
p-ear2-135aPage 2 of 2
NOTE All comment letters are public documents and will be part of the official public record for this project
Need for an EIS The MPCA Commissioner will make a final decision on the need for an EIS after the end of the comment period
Printed on recycled paper containing 30 fibers from paper recycled by consumers
Alternative EAW Form for Animal Feedlots ENVIRONMENTAL ASSESSMENT WORKSHEET
Note to preparers This form is authorized for use only for the preparation of Environmental Assessment Worksheets (EAWs) for animal feedlots Project proposers should consult the guidance Guidelines for Alternative EAW Form for Animal Feedlots (also available at the Minnesota Environmental Quality Board (EQB) website httpswwweqbstatemnuscontentenvironmental-review-guidance-practitioners-and-proposers or by calling 651-296-6300) regarding how to supply information needed by the Responsible Government Unit to complete the worksheet form Note to reviewers The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects This EAW was prepared by the Minnesota Pollution Control Agency (MPCA) acting as the Responsible Governmental Unit (RGU) to determine whether an Environmental Impact Statement (EIS) should be prepared The project proposer supplied reasonably accessible data for but did not complete the final worksheet Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor Comments on the EAW should address the accuracy and completeness of information potential impacts that are reasonably expected to occur that warrant further investigation and the need for an EIS A copy of the EAW may be obtained from the MPCA by calling 651-757-2100 An electronic version of the completed EAW is available at the MPCA website wwwpcastatemnuseaw 1 Basic Project Information
A Feedlot Name Valley Pork LLP Site 2 B
Feedlot Proposer
Valley Pork LLP
C
RGU
Minnesota Pollution Control Agency
Technical
Contact Person Nick McCabe
Contact Person
Steve Sommer
and Title
Senior Environmental Scientist Information Services Group (ISG)
and Title
Project Manager Address 115 E Hickory St Suite 300 Address 520 Lafayette Road North Mankato MN 56001 St Paul MN 55155-4194 Phone 507-387-6651 Phone 651-757-2746 Fax 507-387-3583 Fax 651-297-2343 E-mail nickmccabeis-grpcom E-mail stevesommerstatemnus
D Reason for EAW Preparation (check one) EIS
Scoping
Mandatory EAW
X
Citizen Petition
RGU Discretion
Proposer Volunteered
If EAW or EIS is mandatory give EQB rule
category subpart number and name Minn R 44104300 subp29A Feedlots ndash For the construction of an animal feedlot with the capacity of 1000 animal units or more
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 2
E Project Location County Traverse CityTwp Tintah Township NE 14 NE 14 Section 35 Township 129N Range 45W Watershed (name and 4-digit code)
Bois de Sioux River Watershed 09020101
F Attach each of the following to the EAW
middot Exhibit A - Site Location Map middot Exhibit B - US Geological Survey Topographic Map middot Exhibit C - Site Layout middot Exhibit D - Soil Survey Map middot Exhibit E - One-Mile Radius Map middot Exhibit F - Minnesota Department of Natural Resources (DNR) Natural Heritage Database
Review middot Exhibit G - State Historical Preservation Office (SHPO) Correspondence middot Exhibit H ndash DNR Preliminary Well Assessment middot Exhibit I - Cumulative Potential Effects Map middot Exhibit J - Air Quality Modeling Report middot Exhibit K - Groundwater Pollution Sensitivity Map
The following documents are on file and available for review by contacting Scott Schroeder of the MPCArsquos Detroit Lakes Office at 218-846-8134 or at scotttschroederstatemnus
middot State of Minnesota General Animal Feedlot National Pollutant Discharge Elimination System (NPDES) Permit (Feedlot Permit) application and associated documents
middot Emergency Response Plan middot Manure Management Plan
G Project summary of 50 words or less to be published in the EQB Monitor
Valley Pork LLP (Proposer) proposes to construct and operate a new 3030 animal unit (AU)1 swine farrowing facility (8700 head) in Section 35 of Tintah Township in Traverse County (Project) The Project consists of installing one barn an animal mortality composting structure a repair shop an office three permanent stormwater ponds three water wells and employee housing
H Please check all boxes that apply and fill in requested data
Animal Type Number Proposed Type of Confinement Swine over 300 pounds 5700 head Total Confinement Swine 55-300 pounds 2400 head Total Confinement Swine under 55 pounds 600 head Total Confinement
Total Swine 8700 head Total Confinement 1 An ldquoanimal unitrdquo or ldquoAUrdquo is a unit of measure developed to compare the differences in the amount of manure produced by livestock species The ldquoAUrdquo is standardized to the amount of manure produced on a regular basis by a slaughter steer or heifer which also correlates to 1000 pounds of body weight The ldquoAUrdquo is used for administrative purposes by various governmental entities for permitting and record keeping
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 3
I Project magnitude data
Total acreage of farm 80 acres Number of animal units proposed in this project 3030 AU Total animal unit capacity at this location after project construction 3030 AU Acreage required for manure application 1150
acresyear J Describe construction methods and timing
The Proposer plans to construct a swine farrowing feedlot in Section 35 Tintah Township Traverse County (Exhibits A B and C) The Project will house up to 8700 swine (3030 AUs) and consists of constructing the following items
middot One 212-foot x 1020-foot total confinement power-ventilated barn with a 10-foot deep 143 million gallon concrete liquid manure storage area (LMSA)
middot One 150-foot x 30-foot animal mortality composting structure middot One 40-foot x 40-foot workshop middot One 35-foot x 100-foot office middot One 60-foot x 100-foot employee housing facility middot Three stormwater ponds (total of 173 acres) middot Three water wells for livestock watering and employee domestic use (total annual pumping
capacity of 69 million gallons per year) middot One onsite septic system for employee use
The Proposer plans to begin construction in the fall of 2017 and complete construction in the fall of 2018 The Proposerrsquos actual construction dates are dependent on completion of the environmental review process issuance of the DNR Water Appropriation Permit and the MPCA Feedlot Permit2
which contains construction stormwater requirements Project construction will begin with the installation of construction-stormwater best management practices (BMPs) The BMPs will include the use of silt fencing around the Project site to limit soil erosion and sedimentation that could occur during site grading excavation and construction Following implementation of the BMPs the Proposer will grade the Project site and then excavate the soil at the LMSA location The Proposer will use excavated soil as backfill for the driveway and stormwater pond berms Following soil excavation the Proposer will begin construction of the LMSA barn composting structure workshop office employee housing and driveway The Proposerrsquos construction will include placement of the concrete for the LMSA floors building and column footings and the compost structure after placement of specified reinforcing steel and concrete forms The Proposer will follow the wall and column construction with placement of precast beams and slats The Proposer will place 4-inch diameter high-density polyethylene drain tile along the perimeter of the barn The drain tile will be below the elevation of the barnrsquos footings The drain tile will relieve any hydrostatic pressure on
2 The Feedlot Permit is required for a Concentrated Animal Feeding Operation capable of holding 1000 or more AUs
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 4
the concrete LMSA walls and dewater the Project excavation area if necessary due to the presence of perched groundwater or following precipitation events The drain tile will include riser pipes to allow the Proposer to be able to inspect the contents of the drain tile The drain tile will discharge to existing field tile Following building construction since more than 1 acre of new impervious surface is being added the Proposer will install three permanent stormwater ponds on the Project site The Proposer will grade the Project site to create swales that would direct any stormwater runoff generated on the Project site to these three ponds The Proposer will seed the swales and ponds after construction to ensure that they are vegetated to limit erosionsedimentation The Proposer will then construct three groundwater extraction wells on the Project site in accordance with applicable codes and regulations In addition the onsite septic system will be installed after construction of the employee housing
K Past and future stages Is this project an expansion or addition to an existing feedlot Yes No Are future expansions of this feedlot planned or likely Yes No If either question is answered yes briefly describe the existing feedlot (species number of
animals and animal units and type of operation) and any past environmental review or the anticipated expansion
2 Land uses and noteworthy resources in proximity to the site
A Adjacent land uses Describe the uses of adjacent lands and give the distances and directions to
nearby residences schools daycare facilities senior citizen housing places of worship and other places accessible to the public (including roads) within 1 mile of the feedlot and within or adjacent to the boundaries of the manure application sites The Project site and all associated manure application sites are all located in Traverse County Minnesota The zoning for the Project and manure sites is ldquoagriculturalrdquo and they are rural in nature Project site The Project is within the Bois de Sioux River Major Watershed (HUC 09020101) There are no waterways within 1 mile of the Project site
The following two residences are within 1 mile of the Project site (Exhibit E)
middot Farm residence located 030 miles (1584 feet) east middot Farm residence located 030 miles (1584 feet) north
The nearest incorporated town to the Project site is Tintah Township Traverse County Minnesota which is approximately 45 miles north of the Project (Exhibit A)
The nearest public roads to the Project site are the following
middot Traverse County Highway 18 ndash ~30 feet north middot Tintah Township 109 ndash ~25 feet east middot Tintah Township 118 ndash ~2660 feet south middot Traverse County Highway 13 ndash ~9125 feet west
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 5
There are no schools daycare facilities senior citizen housing or public places of worship within a 1-mile radius of the Project site (Exhibit E)
Manure application sites As indicated below the Proposer plans to utilize nine separate manure application sites for the Project The manure application sites are all within 5 miles of the Project site (Exhibit B) Eight of the manure application sites are within the Bois de Sioux River Major Watershed (HUC 09020101) and one is in the Mustinka River Major Watershed (HUC 09020102) The manure application sites are all currently being cultivated for crop production and all have been used for manure application Site 1 160 acres in Section 11 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 125 borders the site on the south The nearest residence is approximately 400 feet southeast There is an unnamed ditch directly south across Township Road 125 Site 2 168 acres in Section 14 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 200 borders the site on the south The nearest residence is approximately 500 feet southeast There is an unnamed ditch directly south of Site 2 Site 3 176 acres in Section 25 T129N R45W with a Land Application Agreement County Road 93 borders this site on the west and County Road 18 borders this site on the south The nearest residence is adjacent to the south Site 4 476 acres in Section 28 T129N R45W with a Land Application Agreement County Road 99 borders this site on the north County Highway 13 borders the site on the east and County Highway 18 borders the site on the south The nearest residence is approximately 3000 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 5 156 acres in Section 29 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south The nearest residence is approximately 1200 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 6 316 acres in Section 33 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south and Township Road 119 borders the site on the south The nearest residence is approximately 3000 feet west There is an unnamed stream which flows through the southwest corner of the site Site 7 320 acres in Section 32 T129N R45W with a Land Application Agreement Township Road 119 borders the site on the south The nearest residence is approximately 1800 feet north There is an unnamed stream which flows through the northeast corner of the site
Site 8 176 acres in Section 3 T128N R45W with a Land Application Agreement Township Road 119 borders this site on the north The nearest residence is approximately 6800 feet northeast There is an unnamed ditch directly north across Township Road 119 and an unnamed stream which flows through the southwest corner of the site Site 9 168 acres in Section 7 T128N R45W with a Land Application Agreement Township Road 110 borders this site on the north The nearest residence is adjacent to the southeast There is an unnamed stream which flows through the center of the site
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 6
B Compatibility with plans and land use regulations Is the project subject to any of the following
adopted plans or ordinances Check all that apply
Local comprehensive plan3 Land use plan or ordinance4 Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan
Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked Yes No If yes describe the inconsistency and how it will be resolved
The Project is consistent with the Traverse County Comprehensive Plan and Zoning Ordinance Feedlots are a conditional use in agricultural zoning districts therefore a conditional use permit will be required In addition a variance may be required by the county for construction of the Project within 05 mile of the two nearest residences However these residences are currently owned by the landowner that is selling the land that the Project will be on therefore no conflict is anticipated Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development) Yes No If yes describe the potentially affected use and its location relative to the feedlot its anticipated development schedule and any plans to avoid or minimize potential conflicts with the feedlot
C Nearby resources Are any of the following resources on or in proximity to the feedlot manure storage areas or within or adjacent to the boundaries of the manure application sites
middot Drinking Water Supply Management Areas designated by the Minnesota Department of Health Yes No
middot Public water supply wells (within 2 miles) Yes No middot Archaeological historical or architectural resources Yes No middot Designated public parks recreation areas or trails Yes No middot Lakes or Wildlife Management Areas Yes No middot State-listed (endangered threatened or special concern) species rare plant communities or
other sensitive ecological resources such as native prairie habitat colonial waterbird nesting colonies or regionally rare plant communities Yes No
middot Scenic views and vistas Yes No middot Other unique resources Yes No
If yes describe the resource and identify any project-related impacts on the resource Describe any measures to minimize or avoid adverse impacts
3 Traverse County Comprehensive Plan httpwwwcotraversemnuswp-contentuploads201408Traverse-County-Comprehensive-Planpdf 4 Traverse County Land Use Ordinance httpwwwcotraversemnusdocumentsTRAVERSECOUNTYLANDUSEORDINANCEpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
wwwpcastatemnus bull 651-296-6300 bull 800-657-3864 bull Use your preferred relay service bull Available in alternative formats
p-ear2-135aPage 2 of 2
NOTE All comment letters are public documents and will be part of the official public record for this project
Need for an EIS The MPCA Commissioner will make a final decision on the need for an EIS after the end of the comment period
Printed on recycled paper containing 30 fibers from paper recycled by consumers
Alternative EAW Form for Animal Feedlots ENVIRONMENTAL ASSESSMENT WORKSHEET
Note to preparers This form is authorized for use only for the preparation of Environmental Assessment Worksheets (EAWs) for animal feedlots Project proposers should consult the guidance Guidelines for Alternative EAW Form for Animal Feedlots (also available at the Minnesota Environmental Quality Board (EQB) website httpswwweqbstatemnuscontentenvironmental-review-guidance-practitioners-and-proposers or by calling 651-296-6300) regarding how to supply information needed by the Responsible Government Unit to complete the worksheet form Note to reviewers The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects This EAW was prepared by the Minnesota Pollution Control Agency (MPCA) acting as the Responsible Governmental Unit (RGU) to determine whether an Environmental Impact Statement (EIS) should be prepared The project proposer supplied reasonably accessible data for but did not complete the final worksheet Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor Comments on the EAW should address the accuracy and completeness of information potential impacts that are reasonably expected to occur that warrant further investigation and the need for an EIS A copy of the EAW may be obtained from the MPCA by calling 651-757-2100 An electronic version of the completed EAW is available at the MPCA website wwwpcastatemnuseaw 1 Basic Project Information
A Feedlot Name Valley Pork LLP Site 2 B
Feedlot Proposer
Valley Pork LLP
C
RGU
Minnesota Pollution Control Agency
Technical
Contact Person Nick McCabe
Contact Person
Steve Sommer
and Title
Senior Environmental Scientist Information Services Group (ISG)
and Title
Project Manager Address 115 E Hickory St Suite 300 Address 520 Lafayette Road North Mankato MN 56001 St Paul MN 55155-4194 Phone 507-387-6651 Phone 651-757-2746 Fax 507-387-3583 Fax 651-297-2343 E-mail nickmccabeis-grpcom E-mail stevesommerstatemnus
D Reason for EAW Preparation (check one) EIS
Scoping
Mandatory EAW
X
Citizen Petition
RGU Discretion
Proposer Volunteered
If EAW or EIS is mandatory give EQB rule
category subpart number and name Minn R 44104300 subp29A Feedlots ndash For the construction of an animal feedlot with the capacity of 1000 animal units or more
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 2
E Project Location County Traverse CityTwp Tintah Township NE 14 NE 14 Section 35 Township 129N Range 45W Watershed (name and 4-digit code)
Bois de Sioux River Watershed 09020101
F Attach each of the following to the EAW
middot Exhibit A - Site Location Map middot Exhibit B - US Geological Survey Topographic Map middot Exhibit C - Site Layout middot Exhibit D - Soil Survey Map middot Exhibit E - One-Mile Radius Map middot Exhibit F - Minnesota Department of Natural Resources (DNR) Natural Heritage Database
Review middot Exhibit G - State Historical Preservation Office (SHPO) Correspondence middot Exhibit H ndash DNR Preliminary Well Assessment middot Exhibit I - Cumulative Potential Effects Map middot Exhibit J - Air Quality Modeling Report middot Exhibit K - Groundwater Pollution Sensitivity Map
The following documents are on file and available for review by contacting Scott Schroeder of the MPCArsquos Detroit Lakes Office at 218-846-8134 or at scotttschroederstatemnus
middot State of Minnesota General Animal Feedlot National Pollutant Discharge Elimination System (NPDES) Permit (Feedlot Permit) application and associated documents
middot Emergency Response Plan middot Manure Management Plan
G Project summary of 50 words or less to be published in the EQB Monitor
Valley Pork LLP (Proposer) proposes to construct and operate a new 3030 animal unit (AU)1 swine farrowing facility (8700 head) in Section 35 of Tintah Township in Traverse County (Project) The Project consists of installing one barn an animal mortality composting structure a repair shop an office three permanent stormwater ponds three water wells and employee housing
H Please check all boxes that apply and fill in requested data
Animal Type Number Proposed Type of Confinement Swine over 300 pounds 5700 head Total Confinement Swine 55-300 pounds 2400 head Total Confinement Swine under 55 pounds 600 head Total Confinement
Total Swine 8700 head Total Confinement 1 An ldquoanimal unitrdquo or ldquoAUrdquo is a unit of measure developed to compare the differences in the amount of manure produced by livestock species The ldquoAUrdquo is standardized to the amount of manure produced on a regular basis by a slaughter steer or heifer which also correlates to 1000 pounds of body weight The ldquoAUrdquo is used for administrative purposes by various governmental entities for permitting and record keeping
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 3
I Project magnitude data
Total acreage of farm 80 acres Number of animal units proposed in this project 3030 AU Total animal unit capacity at this location after project construction 3030 AU Acreage required for manure application 1150
acresyear J Describe construction methods and timing
The Proposer plans to construct a swine farrowing feedlot in Section 35 Tintah Township Traverse County (Exhibits A B and C) The Project will house up to 8700 swine (3030 AUs) and consists of constructing the following items
middot One 212-foot x 1020-foot total confinement power-ventilated barn with a 10-foot deep 143 million gallon concrete liquid manure storage area (LMSA)
middot One 150-foot x 30-foot animal mortality composting structure middot One 40-foot x 40-foot workshop middot One 35-foot x 100-foot office middot One 60-foot x 100-foot employee housing facility middot Three stormwater ponds (total of 173 acres) middot Three water wells for livestock watering and employee domestic use (total annual pumping
capacity of 69 million gallons per year) middot One onsite septic system for employee use
The Proposer plans to begin construction in the fall of 2017 and complete construction in the fall of 2018 The Proposerrsquos actual construction dates are dependent on completion of the environmental review process issuance of the DNR Water Appropriation Permit and the MPCA Feedlot Permit2
which contains construction stormwater requirements Project construction will begin with the installation of construction-stormwater best management practices (BMPs) The BMPs will include the use of silt fencing around the Project site to limit soil erosion and sedimentation that could occur during site grading excavation and construction Following implementation of the BMPs the Proposer will grade the Project site and then excavate the soil at the LMSA location The Proposer will use excavated soil as backfill for the driveway and stormwater pond berms Following soil excavation the Proposer will begin construction of the LMSA barn composting structure workshop office employee housing and driveway The Proposerrsquos construction will include placement of the concrete for the LMSA floors building and column footings and the compost structure after placement of specified reinforcing steel and concrete forms The Proposer will follow the wall and column construction with placement of precast beams and slats The Proposer will place 4-inch diameter high-density polyethylene drain tile along the perimeter of the barn The drain tile will be below the elevation of the barnrsquos footings The drain tile will relieve any hydrostatic pressure on
2 The Feedlot Permit is required for a Concentrated Animal Feeding Operation capable of holding 1000 or more AUs
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 4
the concrete LMSA walls and dewater the Project excavation area if necessary due to the presence of perched groundwater or following precipitation events The drain tile will include riser pipes to allow the Proposer to be able to inspect the contents of the drain tile The drain tile will discharge to existing field tile Following building construction since more than 1 acre of new impervious surface is being added the Proposer will install three permanent stormwater ponds on the Project site The Proposer will grade the Project site to create swales that would direct any stormwater runoff generated on the Project site to these three ponds The Proposer will seed the swales and ponds after construction to ensure that they are vegetated to limit erosionsedimentation The Proposer will then construct three groundwater extraction wells on the Project site in accordance with applicable codes and regulations In addition the onsite septic system will be installed after construction of the employee housing
K Past and future stages Is this project an expansion or addition to an existing feedlot Yes No Are future expansions of this feedlot planned or likely Yes No If either question is answered yes briefly describe the existing feedlot (species number of
animals and animal units and type of operation) and any past environmental review or the anticipated expansion
2 Land uses and noteworthy resources in proximity to the site
A Adjacent land uses Describe the uses of adjacent lands and give the distances and directions to
nearby residences schools daycare facilities senior citizen housing places of worship and other places accessible to the public (including roads) within 1 mile of the feedlot and within or adjacent to the boundaries of the manure application sites The Project site and all associated manure application sites are all located in Traverse County Minnesota The zoning for the Project and manure sites is ldquoagriculturalrdquo and they are rural in nature Project site The Project is within the Bois de Sioux River Major Watershed (HUC 09020101) There are no waterways within 1 mile of the Project site
The following two residences are within 1 mile of the Project site (Exhibit E)
middot Farm residence located 030 miles (1584 feet) east middot Farm residence located 030 miles (1584 feet) north
The nearest incorporated town to the Project site is Tintah Township Traverse County Minnesota which is approximately 45 miles north of the Project (Exhibit A)
The nearest public roads to the Project site are the following
middot Traverse County Highway 18 ndash ~30 feet north middot Tintah Township 109 ndash ~25 feet east middot Tintah Township 118 ndash ~2660 feet south middot Traverse County Highway 13 ndash ~9125 feet west
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 5
There are no schools daycare facilities senior citizen housing or public places of worship within a 1-mile radius of the Project site (Exhibit E)
Manure application sites As indicated below the Proposer plans to utilize nine separate manure application sites for the Project The manure application sites are all within 5 miles of the Project site (Exhibit B) Eight of the manure application sites are within the Bois de Sioux River Major Watershed (HUC 09020101) and one is in the Mustinka River Major Watershed (HUC 09020102) The manure application sites are all currently being cultivated for crop production and all have been used for manure application Site 1 160 acres in Section 11 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 125 borders the site on the south The nearest residence is approximately 400 feet southeast There is an unnamed ditch directly south across Township Road 125 Site 2 168 acres in Section 14 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 200 borders the site on the south The nearest residence is approximately 500 feet southeast There is an unnamed ditch directly south of Site 2 Site 3 176 acres in Section 25 T129N R45W with a Land Application Agreement County Road 93 borders this site on the west and County Road 18 borders this site on the south The nearest residence is adjacent to the south Site 4 476 acres in Section 28 T129N R45W with a Land Application Agreement County Road 99 borders this site on the north County Highway 13 borders the site on the east and County Highway 18 borders the site on the south The nearest residence is approximately 3000 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 5 156 acres in Section 29 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south The nearest residence is approximately 1200 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 6 316 acres in Section 33 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south and Township Road 119 borders the site on the south The nearest residence is approximately 3000 feet west There is an unnamed stream which flows through the southwest corner of the site Site 7 320 acres in Section 32 T129N R45W with a Land Application Agreement Township Road 119 borders the site on the south The nearest residence is approximately 1800 feet north There is an unnamed stream which flows through the northeast corner of the site
Site 8 176 acres in Section 3 T128N R45W with a Land Application Agreement Township Road 119 borders this site on the north The nearest residence is approximately 6800 feet northeast There is an unnamed ditch directly north across Township Road 119 and an unnamed stream which flows through the southwest corner of the site Site 9 168 acres in Section 7 T128N R45W with a Land Application Agreement Township Road 110 borders this site on the north The nearest residence is adjacent to the southeast There is an unnamed stream which flows through the center of the site
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 6
B Compatibility with plans and land use regulations Is the project subject to any of the following
adopted plans or ordinances Check all that apply
Local comprehensive plan3 Land use plan or ordinance4 Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan
Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked Yes No If yes describe the inconsistency and how it will be resolved
The Project is consistent with the Traverse County Comprehensive Plan and Zoning Ordinance Feedlots are a conditional use in agricultural zoning districts therefore a conditional use permit will be required In addition a variance may be required by the county for construction of the Project within 05 mile of the two nearest residences However these residences are currently owned by the landowner that is selling the land that the Project will be on therefore no conflict is anticipated Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development) Yes No If yes describe the potentially affected use and its location relative to the feedlot its anticipated development schedule and any plans to avoid or minimize potential conflicts with the feedlot
C Nearby resources Are any of the following resources on or in proximity to the feedlot manure storage areas or within or adjacent to the boundaries of the manure application sites
middot Drinking Water Supply Management Areas designated by the Minnesota Department of Health Yes No
middot Public water supply wells (within 2 miles) Yes No middot Archaeological historical or architectural resources Yes No middot Designated public parks recreation areas or trails Yes No middot Lakes or Wildlife Management Areas Yes No middot State-listed (endangered threatened or special concern) species rare plant communities or
other sensitive ecological resources such as native prairie habitat colonial waterbird nesting colonies or regionally rare plant communities Yes No
middot Scenic views and vistas Yes No middot Other unique resources Yes No
If yes describe the resource and identify any project-related impacts on the resource Describe any measures to minimize or avoid adverse impacts
3 Traverse County Comprehensive Plan httpwwwcotraversemnuswp-contentuploads201408Traverse-County-Comprehensive-Planpdf 4 Traverse County Land Use Ordinance httpwwwcotraversemnusdocumentsTRAVERSECOUNTYLANDUSEORDINANCEpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Printed on recycled paper containing 30 fibers from paper recycled by consumers
Alternative EAW Form for Animal Feedlots ENVIRONMENTAL ASSESSMENT WORKSHEET
Note to preparers This form is authorized for use only for the preparation of Environmental Assessment Worksheets (EAWs) for animal feedlots Project proposers should consult the guidance Guidelines for Alternative EAW Form for Animal Feedlots (also available at the Minnesota Environmental Quality Board (EQB) website httpswwweqbstatemnuscontentenvironmental-review-guidance-practitioners-and-proposers or by calling 651-296-6300) regarding how to supply information needed by the Responsible Government Unit to complete the worksheet form Note to reviewers The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects This EAW was prepared by the Minnesota Pollution Control Agency (MPCA) acting as the Responsible Governmental Unit (RGU) to determine whether an Environmental Impact Statement (EIS) should be prepared The project proposer supplied reasonably accessible data for but did not complete the final worksheet Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor Comments on the EAW should address the accuracy and completeness of information potential impacts that are reasonably expected to occur that warrant further investigation and the need for an EIS A copy of the EAW may be obtained from the MPCA by calling 651-757-2100 An electronic version of the completed EAW is available at the MPCA website wwwpcastatemnuseaw 1 Basic Project Information
A Feedlot Name Valley Pork LLP Site 2 B
Feedlot Proposer
Valley Pork LLP
C
RGU
Minnesota Pollution Control Agency
Technical
Contact Person Nick McCabe
Contact Person
Steve Sommer
and Title
Senior Environmental Scientist Information Services Group (ISG)
and Title
Project Manager Address 115 E Hickory St Suite 300 Address 520 Lafayette Road North Mankato MN 56001 St Paul MN 55155-4194 Phone 507-387-6651 Phone 651-757-2746 Fax 507-387-3583 Fax 651-297-2343 E-mail nickmccabeis-grpcom E-mail stevesommerstatemnus
D Reason for EAW Preparation (check one) EIS
Scoping
Mandatory EAW
X
Citizen Petition
RGU Discretion
Proposer Volunteered
If EAW or EIS is mandatory give EQB rule
category subpart number and name Minn R 44104300 subp29A Feedlots ndash For the construction of an animal feedlot with the capacity of 1000 animal units or more
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 2
E Project Location County Traverse CityTwp Tintah Township NE 14 NE 14 Section 35 Township 129N Range 45W Watershed (name and 4-digit code)
Bois de Sioux River Watershed 09020101
F Attach each of the following to the EAW
middot Exhibit A - Site Location Map middot Exhibit B - US Geological Survey Topographic Map middot Exhibit C - Site Layout middot Exhibit D - Soil Survey Map middot Exhibit E - One-Mile Radius Map middot Exhibit F - Minnesota Department of Natural Resources (DNR) Natural Heritage Database
Review middot Exhibit G - State Historical Preservation Office (SHPO) Correspondence middot Exhibit H ndash DNR Preliminary Well Assessment middot Exhibit I - Cumulative Potential Effects Map middot Exhibit J - Air Quality Modeling Report middot Exhibit K - Groundwater Pollution Sensitivity Map
The following documents are on file and available for review by contacting Scott Schroeder of the MPCArsquos Detroit Lakes Office at 218-846-8134 or at scotttschroederstatemnus
middot State of Minnesota General Animal Feedlot National Pollutant Discharge Elimination System (NPDES) Permit (Feedlot Permit) application and associated documents
middot Emergency Response Plan middot Manure Management Plan
G Project summary of 50 words or less to be published in the EQB Monitor
Valley Pork LLP (Proposer) proposes to construct and operate a new 3030 animal unit (AU)1 swine farrowing facility (8700 head) in Section 35 of Tintah Township in Traverse County (Project) The Project consists of installing one barn an animal mortality composting structure a repair shop an office three permanent stormwater ponds three water wells and employee housing
H Please check all boxes that apply and fill in requested data
Animal Type Number Proposed Type of Confinement Swine over 300 pounds 5700 head Total Confinement Swine 55-300 pounds 2400 head Total Confinement Swine under 55 pounds 600 head Total Confinement
Total Swine 8700 head Total Confinement 1 An ldquoanimal unitrdquo or ldquoAUrdquo is a unit of measure developed to compare the differences in the amount of manure produced by livestock species The ldquoAUrdquo is standardized to the amount of manure produced on a regular basis by a slaughter steer or heifer which also correlates to 1000 pounds of body weight The ldquoAUrdquo is used for administrative purposes by various governmental entities for permitting and record keeping
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 3
I Project magnitude data
Total acreage of farm 80 acres Number of animal units proposed in this project 3030 AU Total animal unit capacity at this location after project construction 3030 AU Acreage required for manure application 1150
acresyear J Describe construction methods and timing
The Proposer plans to construct a swine farrowing feedlot in Section 35 Tintah Township Traverse County (Exhibits A B and C) The Project will house up to 8700 swine (3030 AUs) and consists of constructing the following items
middot One 212-foot x 1020-foot total confinement power-ventilated barn with a 10-foot deep 143 million gallon concrete liquid manure storage area (LMSA)
middot One 150-foot x 30-foot animal mortality composting structure middot One 40-foot x 40-foot workshop middot One 35-foot x 100-foot office middot One 60-foot x 100-foot employee housing facility middot Three stormwater ponds (total of 173 acres) middot Three water wells for livestock watering and employee domestic use (total annual pumping
capacity of 69 million gallons per year) middot One onsite septic system for employee use
The Proposer plans to begin construction in the fall of 2017 and complete construction in the fall of 2018 The Proposerrsquos actual construction dates are dependent on completion of the environmental review process issuance of the DNR Water Appropriation Permit and the MPCA Feedlot Permit2
which contains construction stormwater requirements Project construction will begin with the installation of construction-stormwater best management practices (BMPs) The BMPs will include the use of silt fencing around the Project site to limit soil erosion and sedimentation that could occur during site grading excavation and construction Following implementation of the BMPs the Proposer will grade the Project site and then excavate the soil at the LMSA location The Proposer will use excavated soil as backfill for the driveway and stormwater pond berms Following soil excavation the Proposer will begin construction of the LMSA barn composting structure workshop office employee housing and driveway The Proposerrsquos construction will include placement of the concrete for the LMSA floors building and column footings and the compost structure after placement of specified reinforcing steel and concrete forms The Proposer will follow the wall and column construction with placement of precast beams and slats The Proposer will place 4-inch diameter high-density polyethylene drain tile along the perimeter of the barn The drain tile will be below the elevation of the barnrsquos footings The drain tile will relieve any hydrostatic pressure on
2 The Feedlot Permit is required for a Concentrated Animal Feeding Operation capable of holding 1000 or more AUs
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 4
the concrete LMSA walls and dewater the Project excavation area if necessary due to the presence of perched groundwater or following precipitation events The drain tile will include riser pipes to allow the Proposer to be able to inspect the contents of the drain tile The drain tile will discharge to existing field tile Following building construction since more than 1 acre of new impervious surface is being added the Proposer will install three permanent stormwater ponds on the Project site The Proposer will grade the Project site to create swales that would direct any stormwater runoff generated on the Project site to these three ponds The Proposer will seed the swales and ponds after construction to ensure that they are vegetated to limit erosionsedimentation The Proposer will then construct three groundwater extraction wells on the Project site in accordance with applicable codes and regulations In addition the onsite septic system will be installed after construction of the employee housing
K Past and future stages Is this project an expansion or addition to an existing feedlot Yes No Are future expansions of this feedlot planned or likely Yes No If either question is answered yes briefly describe the existing feedlot (species number of
animals and animal units and type of operation) and any past environmental review or the anticipated expansion
2 Land uses and noteworthy resources in proximity to the site
A Adjacent land uses Describe the uses of adjacent lands and give the distances and directions to
nearby residences schools daycare facilities senior citizen housing places of worship and other places accessible to the public (including roads) within 1 mile of the feedlot and within or adjacent to the boundaries of the manure application sites The Project site and all associated manure application sites are all located in Traverse County Minnesota The zoning for the Project and manure sites is ldquoagriculturalrdquo and they are rural in nature Project site The Project is within the Bois de Sioux River Major Watershed (HUC 09020101) There are no waterways within 1 mile of the Project site
The following two residences are within 1 mile of the Project site (Exhibit E)
middot Farm residence located 030 miles (1584 feet) east middot Farm residence located 030 miles (1584 feet) north
The nearest incorporated town to the Project site is Tintah Township Traverse County Minnesota which is approximately 45 miles north of the Project (Exhibit A)
The nearest public roads to the Project site are the following
middot Traverse County Highway 18 ndash ~30 feet north middot Tintah Township 109 ndash ~25 feet east middot Tintah Township 118 ndash ~2660 feet south middot Traverse County Highway 13 ndash ~9125 feet west
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 5
There are no schools daycare facilities senior citizen housing or public places of worship within a 1-mile radius of the Project site (Exhibit E)
Manure application sites As indicated below the Proposer plans to utilize nine separate manure application sites for the Project The manure application sites are all within 5 miles of the Project site (Exhibit B) Eight of the manure application sites are within the Bois de Sioux River Major Watershed (HUC 09020101) and one is in the Mustinka River Major Watershed (HUC 09020102) The manure application sites are all currently being cultivated for crop production and all have been used for manure application Site 1 160 acres in Section 11 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 125 borders the site on the south The nearest residence is approximately 400 feet southeast There is an unnamed ditch directly south across Township Road 125 Site 2 168 acres in Section 14 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 200 borders the site on the south The nearest residence is approximately 500 feet southeast There is an unnamed ditch directly south of Site 2 Site 3 176 acres in Section 25 T129N R45W with a Land Application Agreement County Road 93 borders this site on the west and County Road 18 borders this site on the south The nearest residence is adjacent to the south Site 4 476 acres in Section 28 T129N R45W with a Land Application Agreement County Road 99 borders this site on the north County Highway 13 borders the site on the east and County Highway 18 borders the site on the south The nearest residence is approximately 3000 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 5 156 acres in Section 29 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south The nearest residence is approximately 1200 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 6 316 acres in Section 33 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south and Township Road 119 borders the site on the south The nearest residence is approximately 3000 feet west There is an unnamed stream which flows through the southwest corner of the site Site 7 320 acres in Section 32 T129N R45W with a Land Application Agreement Township Road 119 borders the site on the south The nearest residence is approximately 1800 feet north There is an unnamed stream which flows through the northeast corner of the site
Site 8 176 acres in Section 3 T128N R45W with a Land Application Agreement Township Road 119 borders this site on the north The nearest residence is approximately 6800 feet northeast There is an unnamed ditch directly north across Township Road 119 and an unnamed stream which flows through the southwest corner of the site Site 9 168 acres in Section 7 T128N R45W with a Land Application Agreement Township Road 110 borders this site on the north The nearest residence is adjacent to the southeast There is an unnamed stream which flows through the center of the site
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 6
B Compatibility with plans and land use regulations Is the project subject to any of the following
adopted plans or ordinances Check all that apply
Local comprehensive plan3 Land use plan or ordinance4 Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan
Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked Yes No If yes describe the inconsistency and how it will be resolved
The Project is consistent with the Traverse County Comprehensive Plan and Zoning Ordinance Feedlots are a conditional use in agricultural zoning districts therefore a conditional use permit will be required In addition a variance may be required by the county for construction of the Project within 05 mile of the two nearest residences However these residences are currently owned by the landowner that is selling the land that the Project will be on therefore no conflict is anticipated Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development) Yes No If yes describe the potentially affected use and its location relative to the feedlot its anticipated development schedule and any plans to avoid or minimize potential conflicts with the feedlot
C Nearby resources Are any of the following resources on or in proximity to the feedlot manure storage areas or within or adjacent to the boundaries of the manure application sites
middot Drinking Water Supply Management Areas designated by the Minnesota Department of Health Yes No
middot Public water supply wells (within 2 miles) Yes No middot Archaeological historical or architectural resources Yes No middot Designated public parks recreation areas or trails Yes No middot Lakes or Wildlife Management Areas Yes No middot State-listed (endangered threatened or special concern) species rare plant communities or
other sensitive ecological resources such as native prairie habitat colonial waterbird nesting colonies or regionally rare plant communities Yes No
middot Scenic views and vistas Yes No middot Other unique resources Yes No
If yes describe the resource and identify any project-related impacts on the resource Describe any measures to minimize or avoid adverse impacts
3 Traverse County Comprehensive Plan httpwwwcotraversemnuswp-contentuploads201408Traverse-County-Comprehensive-Planpdf 4 Traverse County Land Use Ordinance httpwwwcotraversemnusdocumentsTRAVERSECOUNTYLANDUSEORDINANCEpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 2
E Project Location County Traverse CityTwp Tintah Township NE 14 NE 14 Section 35 Township 129N Range 45W Watershed (name and 4-digit code)
Bois de Sioux River Watershed 09020101
F Attach each of the following to the EAW
middot Exhibit A - Site Location Map middot Exhibit B - US Geological Survey Topographic Map middot Exhibit C - Site Layout middot Exhibit D - Soil Survey Map middot Exhibit E - One-Mile Radius Map middot Exhibit F - Minnesota Department of Natural Resources (DNR) Natural Heritage Database
Review middot Exhibit G - State Historical Preservation Office (SHPO) Correspondence middot Exhibit H ndash DNR Preliminary Well Assessment middot Exhibit I - Cumulative Potential Effects Map middot Exhibit J - Air Quality Modeling Report middot Exhibit K - Groundwater Pollution Sensitivity Map
The following documents are on file and available for review by contacting Scott Schroeder of the MPCArsquos Detroit Lakes Office at 218-846-8134 or at scotttschroederstatemnus
middot State of Minnesota General Animal Feedlot National Pollutant Discharge Elimination System (NPDES) Permit (Feedlot Permit) application and associated documents
middot Emergency Response Plan middot Manure Management Plan
G Project summary of 50 words or less to be published in the EQB Monitor
Valley Pork LLP (Proposer) proposes to construct and operate a new 3030 animal unit (AU)1 swine farrowing facility (8700 head) in Section 35 of Tintah Township in Traverse County (Project) The Project consists of installing one barn an animal mortality composting structure a repair shop an office three permanent stormwater ponds three water wells and employee housing
H Please check all boxes that apply and fill in requested data
Animal Type Number Proposed Type of Confinement Swine over 300 pounds 5700 head Total Confinement Swine 55-300 pounds 2400 head Total Confinement Swine under 55 pounds 600 head Total Confinement
Total Swine 8700 head Total Confinement 1 An ldquoanimal unitrdquo or ldquoAUrdquo is a unit of measure developed to compare the differences in the amount of manure produced by livestock species The ldquoAUrdquo is standardized to the amount of manure produced on a regular basis by a slaughter steer or heifer which also correlates to 1000 pounds of body weight The ldquoAUrdquo is used for administrative purposes by various governmental entities for permitting and record keeping
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 3
I Project magnitude data
Total acreage of farm 80 acres Number of animal units proposed in this project 3030 AU Total animal unit capacity at this location after project construction 3030 AU Acreage required for manure application 1150
acresyear J Describe construction methods and timing
The Proposer plans to construct a swine farrowing feedlot in Section 35 Tintah Township Traverse County (Exhibits A B and C) The Project will house up to 8700 swine (3030 AUs) and consists of constructing the following items
middot One 212-foot x 1020-foot total confinement power-ventilated barn with a 10-foot deep 143 million gallon concrete liquid manure storage area (LMSA)
middot One 150-foot x 30-foot animal mortality composting structure middot One 40-foot x 40-foot workshop middot One 35-foot x 100-foot office middot One 60-foot x 100-foot employee housing facility middot Three stormwater ponds (total of 173 acres) middot Three water wells for livestock watering and employee domestic use (total annual pumping
capacity of 69 million gallons per year) middot One onsite septic system for employee use
The Proposer plans to begin construction in the fall of 2017 and complete construction in the fall of 2018 The Proposerrsquos actual construction dates are dependent on completion of the environmental review process issuance of the DNR Water Appropriation Permit and the MPCA Feedlot Permit2
which contains construction stormwater requirements Project construction will begin with the installation of construction-stormwater best management practices (BMPs) The BMPs will include the use of silt fencing around the Project site to limit soil erosion and sedimentation that could occur during site grading excavation and construction Following implementation of the BMPs the Proposer will grade the Project site and then excavate the soil at the LMSA location The Proposer will use excavated soil as backfill for the driveway and stormwater pond berms Following soil excavation the Proposer will begin construction of the LMSA barn composting structure workshop office employee housing and driveway The Proposerrsquos construction will include placement of the concrete for the LMSA floors building and column footings and the compost structure after placement of specified reinforcing steel and concrete forms The Proposer will follow the wall and column construction with placement of precast beams and slats The Proposer will place 4-inch diameter high-density polyethylene drain tile along the perimeter of the barn The drain tile will be below the elevation of the barnrsquos footings The drain tile will relieve any hydrostatic pressure on
2 The Feedlot Permit is required for a Concentrated Animal Feeding Operation capable of holding 1000 or more AUs
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 4
the concrete LMSA walls and dewater the Project excavation area if necessary due to the presence of perched groundwater or following precipitation events The drain tile will include riser pipes to allow the Proposer to be able to inspect the contents of the drain tile The drain tile will discharge to existing field tile Following building construction since more than 1 acre of new impervious surface is being added the Proposer will install three permanent stormwater ponds on the Project site The Proposer will grade the Project site to create swales that would direct any stormwater runoff generated on the Project site to these three ponds The Proposer will seed the swales and ponds after construction to ensure that they are vegetated to limit erosionsedimentation The Proposer will then construct three groundwater extraction wells on the Project site in accordance with applicable codes and regulations In addition the onsite septic system will be installed after construction of the employee housing
K Past and future stages Is this project an expansion or addition to an existing feedlot Yes No Are future expansions of this feedlot planned or likely Yes No If either question is answered yes briefly describe the existing feedlot (species number of
animals and animal units and type of operation) and any past environmental review or the anticipated expansion
2 Land uses and noteworthy resources in proximity to the site
A Adjacent land uses Describe the uses of adjacent lands and give the distances and directions to
nearby residences schools daycare facilities senior citizen housing places of worship and other places accessible to the public (including roads) within 1 mile of the feedlot and within or adjacent to the boundaries of the manure application sites The Project site and all associated manure application sites are all located in Traverse County Minnesota The zoning for the Project and manure sites is ldquoagriculturalrdquo and they are rural in nature Project site The Project is within the Bois de Sioux River Major Watershed (HUC 09020101) There are no waterways within 1 mile of the Project site
The following two residences are within 1 mile of the Project site (Exhibit E)
middot Farm residence located 030 miles (1584 feet) east middot Farm residence located 030 miles (1584 feet) north
The nearest incorporated town to the Project site is Tintah Township Traverse County Minnesota which is approximately 45 miles north of the Project (Exhibit A)
The nearest public roads to the Project site are the following
middot Traverse County Highway 18 ndash ~30 feet north middot Tintah Township 109 ndash ~25 feet east middot Tintah Township 118 ndash ~2660 feet south middot Traverse County Highway 13 ndash ~9125 feet west
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 5
There are no schools daycare facilities senior citizen housing or public places of worship within a 1-mile radius of the Project site (Exhibit E)
Manure application sites As indicated below the Proposer plans to utilize nine separate manure application sites for the Project The manure application sites are all within 5 miles of the Project site (Exhibit B) Eight of the manure application sites are within the Bois de Sioux River Major Watershed (HUC 09020101) and one is in the Mustinka River Major Watershed (HUC 09020102) The manure application sites are all currently being cultivated for crop production and all have been used for manure application Site 1 160 acres in Section 11 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 125 borders the site on the south The nearest residence is approximately 400 feet southeast There is an unnamed ditch directly south across Township Road 125 Site 2 168 acres in Section 14 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 200 borders the site on the south The nearest residence is approximately 500 feet southeast There is an unnamed ditch directly south of Site 2 Site 3 176 acres in Section 25 T129N R45W with a Land Application Agreement County Road 93 borders this site on the west and County Road 18 borders this site on the south The nearest residence is adjacent to the south Site 4 476 acres in Section 28 T129N R45W with a Land Application Agreement County Road 99 borders this site on the north County Highway 13 borders the site on the east and County Highway 18 borders the site on the south The nearest residence is approximately 3000 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 5 156 acres in Section 29 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south The nearest residence is approximately 1200 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 6 316 acres in Section 33 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south and Township Road 119 borders the site on the south The nearest residence is approximately 3000 feet west There is an unnamed stream which flows through the southwest corner of the site Site 7 320 acres in Section 32 T129N R45W with a Land Application Agreement Township Road 119 borders the site on the south The nearest residence is approximately 1800 feet north There is an unnamed stream which flows through the northeast corner of the site
Site 8 176 acres in Section 3 T128N R45W with a Land Application Agreement Township Road 119 borders this site on the north The nearest residence is approximately 6800 feet northeast There is an unnamed ditch directly north across Township Road 119 and an unnamed stream which flows through the southwest corner of the site Site 9 168 acres in Section 7 T128N R45W with a Land Application Agreement Township Road 110 borders this site on the north The nearest residence is adjacent to the southeast There is an unnamed stream which flows through the center of the site
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 6
B Compatibility with plans and land use regulations Is the project subject to any of the following
adopted plans or ordinances Check all that apply
Local comprehensive plan3 Land use plan or ordinance4 Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan
Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked Yes No If yes describe the inconsistency and how it will be resolved
The Project is consistent with the Traverse County Comprehensive Plan and Zoning Ordinance Feedlots are a conditional use in agricultural zoning districts therefore a conditional use permit will be required In addition a variance may be required by the county for construction of the Project within 05 mile of the two nearest residences However these residences are currently owned by the landowner that is selling the land that the Project will be on therefore no conflict is anticipated Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development) Yes No If yes describe the potentially affected use and its location relative to the feedlot its anticipated development schedule and any plans to avoid or minimize potential conflicts with the feedlot
C Nearby resources Are any of the following resources on or in proximity to the feedlot manure storage areas or within or adjacent to the boundaries of the manure application sites
middot Drinking Water Supply Management Areas designated by the Minnesota Department of Health Yes No
middot Public water supply wells (within 2 miles) Yes No middot Archaeological historical or architectural resources Yes No middot Designated public parks recreation areas or trails Yes No middot Lakes or Wildlife Management Areas Yes No middot State-listed (endangered threatened or special concern) species rare plant communities or
other sensitive ecological resources such as native prairie habitat colonial waterbird nesting colonies or regionally rare plant communities Yes No
middot Scenic views and vistas Yes No middot Other unique resources Yes No
If yes describe the resource and identify any project-related impacts on the resource Describe any measures to minimize or avoid adverse impacts
3 Traverse County Comprehensive Plan httpwwwcotraversemnuswp-contentuploads201408Traverse-County-Comprehensive-Planpdf 4 Traverse County Land Use Ordinance httpwwwcotraversemnusdocumentsTRAVERSECOUNTYLANDUSEORDINANCEpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 3
I Project magnitude data
Total acreage of farm 80 acres Number of animal units proposed in this project 3030 AU Total animal unit capacity at this location after project construction 3030 AU Acreage required for manure application 1150
acresyear J Describe construction methods and timing
The Proposer plans to construct a swine farrowing feedlot in Section 35 Tintah Township Traverse County (Exhibits A B and C) The Project will house up to 8700 swine (3030 AUs) and consists of constructing the following items
middot One 212-foot x 1020-foot total confinement power-ventilated barn with a 10-foot deep 143 million gallon concrete liquid manure storage area (LMSA)
middot One 150-foot x 30-foot animal mortality composting structure middot One 40-foot x 40-foot workshop middot One 35-foot x 100-foot office middot One 60-foot x 100-foot employee housing facility middot Three stormwater ponds (total of 173 acres) middot Three water wells for livestock watering and employee domestic use (total annual pumping
capacity of 69 million gallons per year) middot One onsite septic system for employee use
The Proposer plans to begin construction in the fall of 2017 and complete construction in the fall of 2018 The Proposerrsquos actual construction dates are dependent on completion of the environmental review process issuance of the DNR Water Appropriation Permit and the MPCA Feedlot Permit2
which contains construction stormwater requirements Project construction will begin with the installation of construction-stormwater best management practices (BMPs) The BMPs will include the use of silt fencing around the Project site to limit soil erosion and sedimentation that could occur during site grading excavation and construction Following implementation of the BMPs the Proposer will grade the Project site and then excavate the soil at the LMSA location The Proposer will use excavated soil as backfill for the driveway and stormwater pond berms Following soil excavation the Proposer will begin construction of the LMSA barn composting structure workshop office employee housing and driveway The Proposerrsquos construction will include placement of the concrete for the LMSA floors building and column footings and the compost structure after placement of specified reinforcing steel and concrete forms The Proposer will follow the wall and column construction with placement of precast beams and slats The Proposer will place 4-inch diameter high-density polyethylene drain tile along the perimeter of the barn The drain tile will be below the elevation of the barnrsquos footings The drain tile will relieve any hydrostatic pressure on
2 The Feedlot Permit is required for a Concentrated Animal Feeding Operation capable of holding 1000 or more AUs
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 4
the concrete LMSA walls and dewater the Project excavation area if necessary due to the presence of perched groundwater or following precipitation events The drain tile will include riser pipes to allow the Proposer to be able to inspect the contents of the drain tile The drain tile will discharge to existing field tile Following building construction since more than 1 acre of new impervious surface is being added the Proposer will install three permanent stormwater ponds on the Project site The Proposer will grade the Project site to create swales that would direct any stormwater runoff generated on the Project site to these three ponds The Proposer will seed the swales and ponds after construction to ensure that they are vegetated to limit erosionsedimentation The Proposer will then construct three groundwater extraction wells on the Project site in accordance with applicable codes and regulations In addition the onsite septic system will be installed after construction of the employee housing
K Past and future stages Is this project an expansion or addition to an existing feedlot Yes No Are future expansions of this feedlot planned or likely Yes No If either question is answered yes briefly describe the existing feedlot (species number of
animals and animal units and type of operation) and any past environmental review or the anticipated expansion
2 Land uses and noteworthy resources in proximity to the site
A Adjacent land uses Describe the uses of adjacent lands and give the distances and directions to
nearby residences schools daycare facilities senior citizen housing places of worship and other places accessible to the public (including roads) within 1 mile of the feedlot and within or adjacent to the boundaries of the manure application sites The Project site and all associated manure application sites are all located in Traverse County Minnesota The zoning for the Project and manure sites is ldquoagriculturalrdquo and they are rural in nature Project site The Project is within the Bois de Sioux River Major Watershed (HUC 09020101) There are no waterways within 1 mile of the Project site
The following two residences are within 1 mile of the Project site (Exhibit E)
middot Farm residence located 030 miles (1584 feet) east middot Farm residence located 030 miles (1584 feet) north
The nearest incorporated town to the Project site is Tintah Township Traverse County Minnesota which is approximately 45 miles north of the Project (Exhibit A)
The nearest public roads to the Project site are the following
middot Traverse County Highway 18 ndash ~30 feet north middot Tintah Township 109 ndash ~25 feet east middot Tintah Township 118 ndash ~2660 feet south middot Traverse County Highway 13 ndash ~9125 feet west
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 5
There are no schools daycare facilities senior citizen housing or public places of worship within a 1-mile radius of the Project site (Exhibit E)
Manure application sites As indicated below the Proposer plans to utilize nine separate manure application sites for the Project The manure application sites are all within 5 miles of the Project site (Exhibit B) Eight of the manure application sites are within the Bois de Sioux River Major Watershed (HUC 09020101) and one is in the Mustinka River Major Watershed (HUC 09020102) The manure application sites are all currently being cultivated for crop production and all have been used for manure application Site 1 160 acres in Section 11 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 125 borders the site on the south The nearest residence is approximately 400 feet southeast There is an unnamed ditch directly south across Township Road 125 Site 2 168 acres in Section 14 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 200 borders the site on the south The nearest residence is approximately 500 feet southeast There is an unnamed ditch directly south of Site 2 Site 3 176 acres in Section 25 T129N R45W with a Land Application Agreement County Road 93 borders this site on the west and County Road 18 borders this site on the south The nearest residence is adjacent to the south Site 4 476 acres in Section 28 T129N R45W with a Land Application Agreement County Road 99 borders this site on the north County Highway 13 borders the site on the east and County Highway 18 borders the site on the south The nearest residence is approximately 3000 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 5 156 acres in Section 29 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south The nearest residence is approximately 1200 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 6 316 acres in Section 33 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south and Township Road 119 borders the site on the south The nearest residence is approximately 3000 feet west There is an unnamed stream which flows through the southwest corner of the site Site 7 320 acres in Section 32 T129N R45W with a Land Application Agreement Township Road 119 borders the site on the south The nearest residence is approximately 1800 feet north There is an unnamed stream which flows through the northeast corner of the site
Site 8 176 acres in Section 3 T128N R45W with a Land Application Agreement Township Road 119 borders this site on the north The nearest residence is approximately 6800 feet northeast There is an unnamed ditch directly north across Township Road 119 and an unnamed stream which flows through the southwest corner of the site Site 9 168 acres in Section 7 T128N R45W with a Land Application Agreement Township Road 110 borders this site on the north The nearest residence is adjacent to the southeast There is an unnamed stream which flows through the center of the site
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 6
B Compatibility with plans and land use regulations Is the project subject to any of the following
adopted plans or ordinances Check all that apply
Local comprehensive plan3 Land use plan or ordinance4 Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan
Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked Yes No If yes describe the inconsistency and how it will be resolved
The Project is consistent with the Traverse County Comprehensive Plan and Zoning Ordinance Feedlots are a conditional use in agricultural zoning districts therefore a conditional use permit will be required In addition a variance may be required by the county for construction of the Project within 05 mile of the two nearest residences However these residences are currently owned by the landowner that is selling the land that the Project will be on therefore no conflict is anticipated Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development) Yes No If yes describe the potentially affected use and its location relative to the feedlot its anticipated development schedule and any plans to avoid or minimize potential conflicts with the feedlot
C Nearby resources Are any of the following resources on or in proximity to the feedlot manure storage areas or within or adjacent to the boundaries of the manure application sites
middot Drinking Water Supply Management Areas designated by the Minnesota Department of Health Yes No
middot Public water supply wells (within 2 miles) Yes No middot Archaeological historical or architectural resources Yes No middot Designated public parks recreation areas or trails Yes No middot Lakes or Wildlife Management Areas Yes No middot State-listed (endangered threatened or special concern) species rare plant communities or
other sensitive ecological resources such as native prairie habitat colonial waterbird nesting colonies or regionally rare plant communities Yes No
middot Scenic views and vistas Yes No middot Other unique resources Yes No
If yes describe the resource and identify any project-related impacts on the resource Describe any measures to minimize or avoid adverse impacts
3 Traverse County Comprehensive Plan httpwwwcotraversemnuswp-contentuploads201408Traverse-County-Comprehensive-Planpdf 4 Traverse County Land Use Ordinance httpwwwcotraversemnusdocumentsTRAVERSECOUNTYLANDUSEORDINANCEpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 4
the concrete LMSA walls and dewater the Project excavation area if necessary due to the presence of perched groundwater or following precipitation events The drain tile will include riser pipes to allow the Proposer to be able to inspect the contents of the drain tile The drain tile will discharge to existing field tile Following building construction since more than 1 acre of new impervious surface is being added the Proposer will install three permanent stormwater ponds on the Project site The Proposer will grade the Project site to create swales that would direct any stormwater runoff generated on the Project site to these three ponds The Proposer will seed the swales and ponds after construction to ensure that they are vegetated to limit erosionsedimentation The Proposer will then construct three groundwater extraction wells on the Project site in accordance with applicable codes and regulations In addition the onsite septic system will be installed after construction of the employee housing
K Past and future stages Is this project an expansion or addition to an existing feedlot Yes No Are future expansions of this feedlot planned or likely Yes No If either question is answered yes briefly describe the existing feedlot (species number of
animals and animal units and type of operation) and any past environmental review or the anticipated expansion
2 Land uses and noteworthy resources in proximity to the site
A Adjacent land uses Describe the uses of adjacent lands and give the distances and directions to
nearby residences schools daycare facilities senior citizen housing places of worship and other places accessible to the public (including roads) within 1 mile of the feedlot and within or adjacent to the boundaries of the manure application sites The Project site and all associated manure application sites are all located in Traverse County Minnesota The zoning for the Project and manure sites is ldquoagriculturalrdquo and they are rural in nature Project site The Project is within the Bois de Sioux River Major Watershed (HUC 09020101) There are no waterways within 1 mile of the Project site
The following two residences are within 1 mile of the Project site (Exhibit E)
middot Farm residence located 030 miles (1584 feet) east middot Farm residence located 030 miles (1584 feet) north
The nearest incorporated town to the Project site is Tintah Township Traverse County Minnesota which is approximately 45 miles north of the Project (Exhibit A)
The nearest public roads to the Project site are the following
middot Traverse County Highway 18 ndash ~30 feet north middot Tintah Township 109 ndash ~25 feet east middot Tintah Township 118 ndash ~2660 feet south middot Traverse County Highway 13 ndash ~9125 feet west
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 5
There are no schools daycare facilities senior citizen housing or public places of worship within a 1-mile radius of the Project site (Exhibit E)
Manure application sites As indicated below the Proposer plans to utilize nine separate manure application sites for the Project The manure application sites are all within 5 miles of the Project site (Exhibit B) Eight of the manure application sites are within the Bois de Sioux River Major Watershed (HUC 09020101) and one is in the Mustinka River Major Watershed (HUC 09020102) The manure application sites are all currently being cultivated for crop production and all have been used for manure application Site 1 160 acres in Section 11 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 125 borders the site on the south The nearest residence is approximately 400 feet southeast There is an unnamed ditch directly south across Township Road 125 Site 2 168 acres in Section 14 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 200 borders the site on the south The nearest residence is approximately 500 feet southeast There is an unnamed ditch directly south of Site 2 Site 3 176 acres in Section 25 T129N R45W with a Land Application Agreement County Road 93 borders this site on the west and County Road 18 borders this site on the south The nearest residence is adjacent to the south Site 4 476 acres in Section 28 T129N R45W with a Land Application Agreement County Road 99 borders this site on the north County Highway 13 borders the site on the east and County Highway 18 borders the site on the south The nearest residence is approximately 3000 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 5 156 acres in Section 29 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south The nearest residence is approximately 1200 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 6 316 acres in Section 33 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south and Township Road 119 borders the site on the south The nearest residence is approximately 3000 feet west There is an unnamed stream which flows through the southwest corner of the site Site 7 320 acres in Section 32 T129N R45W with a Land Application Agreement Township Road 119 borders the site on the south The nearest residence is approximately 1800 feet north There is an unnamed stream which flows through the northeast corner of the site
Site 8 176 acres in Section 3 T128N R45W with a Land Application Agreement Township Road 119 borders this site on the north The nearest residence is approximately 6800 feet northeast There is an unnamed ditch directly north across Township Road 119 and an unnamed stream which flows through the southwest corner of the site Site 9 168 acres in Section 7 T128N R45W with a Land Application Agreement Township Road 110 borders this site on the north The nearest residence is adjacent to the southeast There is an unnamed stream which flows through the center of the site
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 6
B Compatibility with plans and land use regulations Is the project subject to any of the following
adopted plans or ordinances Check all that apply
Local comprehensive plan3 Land use plan or ordinance4 Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan
Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked Yes No If yes describe the inconsistency and how it will be resolved
The Project is consistent with the Traverse County Comprehensive Plan and Zoning Ordinance Feedlots are a conditional use in agricultural zoning districts therefore a conditional use permit will be required In addition a variance may be required by the county for construction of the Project within 05 mile of the two nearest residences However these residences are currently owned by the landowner that is selling the land that the Project will be on therefore no conflict is anticipated Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development) Yes No If yes describe the potentially affected use and its location relative to the feedlot its anticipated development schedule and any plans to avoid or minimize potential conflicts with the feedlot
C Nearby resources Are any of the following resources on or in proximity to the feedlot manure storage areas or within or adjacent to the boundaries of the manure application sites
middot Drinking Water Supply Management Areas designated by the Minnesota Department of Health Yes No
middot Public water supply wells (within 2 miles) Yes No middot Archaeological historical or architectural resources Yes No middot Designated public parks recreation areas or trails Yes No middot Lakes or Wildlife Management Areas Yes No middot State-listed (endangered threatened or special concern) species rare plant communities or
other sensitive ecological resources such as native prairie habitat colonial waterbird nesting colonies or regionally rare plant communities Yes No
middot Scenic views and vistas Yes No middot Other unique resources Yes No
If yes describe the resource and identify any project-related impacts on the resource Describe any measures to minimize or avoid adverse impacts
3 Traverse County Comprehensive Plan httpwwwcotraversemnuswp-contentuploads201408Traverse-County-Comprehensive-Planpdf 4 Traverse County Land Use Ordinance httpwwwcotraversemnusdocumentsTRAVERSECOUNTYLANDUSEORDINANCEpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 5
There are no schools daycare facilities senior citizen housing or public places of worship within a 1-mile radius of the Project site (Exhibit E)
Manure application sites As indicated below the Proposer plans to utilize nine separate manure application sites for the Project The manure application sites are all within 5 miles of the Project site (Exhibit B) Eight of the manure application sites are within the Bois de Sioux River Major Watershed (HUC 09020101) and one is in the Mustinka River Major Watershed (HUC 09020102) The manure application sites are all currently being cultivated for crop production and all have been used for manure application Site 1 160 acres in Section 11 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 125 borders the site on the south The nearest residence is approximately 400 feet southeast There is an unnamed ditch directly south across Township Road 125 Site 2 168 acres in Section 14 T129N R45W with a Land Application Agreement County Road 93 borders this site on the east and Township Road 200 borders the site on the south The nearest residence is approximately 500 feet southeast There is an unnamed ditch directly south of Site 2 Site 3 176 acres in Section 25 T129N R45W with a Land Application Agreement County Road 93 borders this site on the west and County Road 18 borders this site on the south The nearest residence is adjacent to the south Site 4 476 acres in Section 28 T129N R45W with a Land Application Agreement County Road 99 borders this site on the north County Highway 13 borders the site on the east and County Highway 18 borders the site on the south The nearest residence is approximately 3000 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 5 156 acres in Section 29 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south The nearest residence is approximately 1200 feet southwest There is an unnamed stream which flows through the southwest corner of the site Site 6 316 acres in Section 33 T129N R45W with a Land Application Agreement County Highway 18 borders this site on the south and Township Road 119 borders the site on the south The nearest residence is approximately 3000 feet west There is an unnamed stream which flows through the southwest corner of the site Site 7 320 acres in Section 32 T129N R45W with a Land Application Agreement Township Road 119 borders the site on the south The nearest residence is approximately 1800 feet north There is an unnamed stream which flows through the northeast corner of the site
Site 8 176 acres in Section 3 T128N R45W with a Land Application Agreement Township Road 119 borders this site on the north The nearest residence is approximately 6800 feet northeast There is an unnamed ditch directly north across Township Road 119 and an unnamed stream which flows through the southwest corner of the site Site 9 168 acres in Section 7 T128N R45W with a Land Application Agreement Township Road 110 borders this site on the north The nearest residence is adjacent to the southeast There is an unnamed stream which flows through the center of the site
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 6
B Compatibility with plans and land use regulations Is the project subject to any of the following
adopted plans or ordinances Check all that apply
Local comprehensive plan3 Land use plan or ordinance4 Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan
Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked Yes No If yes describe the inconsistency and how it will be resolved
The Project is consistent with the Traverse County Comprehensive Plan and Zoning Ordinance Feedlots are a conditional use in agricultural zoning districts therefore a conditional use permit will be required In addition a variance may be required by the county for construction of the Project within 05 mile of the two nearest residences However these residences are currently owned by the landowner that is selling the land that the Project will be on therefore no conflict is anticipated Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development) Yes No If yes describe the potentially affected use and its location relative to the feedlot its anticipated development schedule and any plans to avoid or minimize potential conflicts with the feedlot
C Nearby resources Are any of the following resources on or in proximity to the feedlot manure storage areas or within or adjacent to the boundaries of the manure application sites
middot Drinking Water Supply Management Areas designated by the Minnesota Department of Health Yes No
middot Public water supply wells (within 2 miles) Yes No middot Archaeological historical or architectural resources Yes No middot Designated public parks recreation areas or trails Yes No middot Lakes or Wildlife Management Areas Yes No middot State-listed (endangered threatened or special concern) species rare plant communities or
other sensitive ecological resources such as native prairie habitat colonial waterbird nesting colonies or regionally rare plant communities Yes No
middot Scenic views and vistas Yes No middot Other unique resources Yes No
If yes describe the resource and identify any project-related impacts on the resource Describe any measures to minimize or avoid adverse impacts
3 Traverse County Comprehensive Plan httpwwwcotraversemnuswp-contentuploads201408Traverse-County-Comprehensive-Planpdf 4 Traverse County Land Use Ordinance httpwwwcotraversemnusdocumentsTRAVERSECOUNTYLANDUSEORDINANCEpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 6
B Compatibility with plans and land use regulations Is the project subject to any of the following
adopted plans or ordinances Check all that apply
Local comprehensive plan3 Land use plan or ordinance4 Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan
Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked Yes No If yes describe the inconsistency and how it will be resolved
The Project is consistent with the Traverse County Comprehensive Plan and Zoning Ordinance Feedlots are a conditional use in agricultural zoning districts therefore a conditional use permit will be required In addition a variance may be required by the county for construction of the Project within 05 mile of the two nearest residences However these residences are currently owned by the landowner that is selling the land that the Project will be on therefore no conflict is anticipated Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development) Yes No If yes describe the potentially affected use and its location relative to the feedlot its anticipated development schedule and any plans to avoid or minimize potential conflicts with the feedlot
C Nearby resources Are any of the following resources on or in proximity to the feedlot manure storage areas or within or adjacent to the boundaries of the manure application sites
middot Drinking Water Supply Management Areas designated by the Minnesota Department of Health Yes No
middot Public water supply wells (within 2 miles) Yes No middot Archaeological historical or architectural resources Yes No middot Designated public parks recreation areas or trails Yes No middot Lakes or Wildlife Management Areas Yes No middot State-listed (endangered threatened or special concern) species rare plant communities or
other sensitive ecological resources such as native prairie habitat colonial waterbird nesting colonies or regionally rare plant communities Yes No
middot Scenic views and vistas Yes No middot Other unique resources Yes No
If yes describe the resource and identify any project-related impacts on the resource Describe any measures to minimize or avoid adverse impacts
3 Traverse County Comprehensive Plan httpwwwcotraversemnuswp-contentuploads201408Traverse-County-Comprehensive-Planpdf 4 Traverse County Land Use Ordinance httpwwwcotraversemnusdocumentsTRAVERSECOUNTYLANDUSEORDINANCEpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 7
Drinking Water Supply Management Areas amp public water supply wells There are no Drinking Water Supply Management Areas (DWSMA) or public water supply wells within a 2-mile radius of the Project site Manure application sites numbers 1 and 2 are within 2 miles of the town of Tintahrsquo s three public water supply wells (Unique IDs 257201 258202 and 166215) and associated DWSMAs These wells each include an inner wellhead protection zone of 200 feet (Exhibit E) The Proposer will mitigate potential impacts to drinking water by following a MPCA-approved MMP and submitting an annual report to the MPCA on manure production land application and any discharges The approved MMP is an integral and enforceable part of the Feedlot Permit Archaeological historical or architectural resources The SHPO conducted a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Project area and identified no archaeological sites near the Project site (Exhibit G) State-listed species rare plant communities or other sensitive ecological resources The DNR reviewed its Minnesota Natural Heritage database to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate 1-mile radius of the Project or manure application sites Based on the review there are no known occurrences of rare features in the area searched (Exhibit F)
3 Geologic and soil conditions
A Approximate depth (in feet) to Feedlot Manure Application Sites Ground Water (minimum) 15 15 (average) 25 245 Bedrock (minimum) 199 172 (average) 201 206
The Natural Resource Conservation Service (NRCS) Soil Survey define depth of groundwater as ldquoa saturated zone in the soil that occurs during specified months lasting longer than one month at selected sites based on evidence of a saturated zone namely grayish colors redoximorphic features in the soilrdquo Groundwater depth is affected by weather time of year among other factors and is partially subject to interpretation of the investigator The Minnesota Geological Survey provided the bedrock depth information5
5 Lively RS Bauer EJ and Chandler VM January 2006 Maps of Gridded Bedrock in Minnesota (GIS File) Minnesota Geological Survey Open File Report OFR2006_02
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 8
B NRCS Soil Classification Site I397A I243A I379A FeedlotManure Storage Area I397A I170A I379A I674B I802A Manure Application Site 1 I397A I170A Manure Application Site 2 I379A I397A Manure Application Site 3 I5A I377A Manure Application Site 4 I782A I377A Manure Application Site 5 I243A I377A I397A I405A I626A Manure Application Site 6 I507A I377A I397A I405A I626A I718A Manure Application Site 7 I36A I478A I397A I377A I414A I243A Manure Application Site 8 I782A I478A 1397A I643A I405A Manure Application Site 9
See Exhibit D for a soil survey map that covers the area of the feedlot and its manure application sites
C Indicate with a yes or no whether any of the following geologic site hazards to ground water are present at the feedlot manure storage area or manure application sites
Hazard FeedlotManure Storage Area
Manure Application Sites
Karst features (sinkhole cave resurgent spring disappearing spring karst window blind valley or dry valley)
No No
Exposed bedrock No No Soils developed in bedrock (as shown on soils maps) No No
For items answered yes (in C) describe the features show them on a map and discuss proposed design and mitigation measures to avoid or minimize potential impacts
4 Water use tiling and drainage and physical alterations
A Will the project involve installation or abandonment of any water wells appropriation of any ground or surface water (including dewatering) or connection to any public water supply
Yes No If yes as applicable give location and purpose of any new wells the source duration quantity and
purpose of any appropriations or public supply connections and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers if available Identify any existing and new wells on the site map If there are no wells known on-site explain methodology used to determine that none are present There are no wells currently located on the Project site but the Proposer plans to install three wells for livestock watering and human consumption (Exhibit C) The Proposer expects to use approximately 69 million gallons of water annually for a total consumption of 1725 million gallons over 25 years On February 27 2017 the Proposer applied to the DNR for preliminary approval to drill a well approximately 300 feet deep that will pump at 100 gallons per minute The DNR granted preliminary approval to drill the well on April 4 2017 (see Exhibit H) The Proposer may use the DNR preliminary approval to decide whether to proceed in constructing the well The approval to drill a well is not an approval to use or pump the well To use the well the Proposer must obtain a DNR water appropriation permit State law requires the permit for users withdrawing more than 10000 gallons of water daily or 1 million gallons annually
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 9
The DNR water appropriation permit ensures the well user manages water resources so adequate supply is available for long-range seasonal requirements for domestic agriculture fish and wildlife recreation power navigation and water quality State law establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposer must register the well with the MDH before construction
B Will the project involve installation of drain tiling tile inlets or outlets Yes No If yes describe
The Proposer will install a 4-inch diameter high-density polyethylene perimeter drain tile around the base of the LMSA subgrade concrete pit to control hydrostatic pressure on the outside of LMSA walls caused by fluctuations in seasonal saturation Inspection ports connected to the perimeter tiles will allow the Proposer to observe if the tiles are operational and may help to identify seepage from the pits if a leak were to occur The drain tile will connect to existing agricultural drain tile The Proposer will follow the Operation and Maintenance Plan submitted as part of its Feedlot Permit application The Plan is integral to and enforceable through the Feedlot Permit and must meet the requirements of Minn R 70202100 The Plan must include perimeter tile-specific requirements for the Proposer to follow including
middot The Proposer must conduct monthly monitoring of the perimeter drain tile for water flow and signs of discoloration or odor
middot The Proposer must maintain records of all inspections as part of the operation and maintenance for the concrete LMSA
C Will the project involve the physical or hydrologic alteration mdash dredging filling stream diversion
outfall structure diking and impoundment mdash of any surface waters such as a lake pond wetland stream or drainage ditch Yes No
If yes identify water resource affected and give the DNR Protected Waters Inventory number(s) if
the water resources affected are on the PWI Describe proposed mitigation measures to avoid or minimize impacts
5 Manure management
A Check the box or boxes below which best describe the manure management system proposed for this feedlot
Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 10
Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids andor to recover energy Other (please describe)
B Manure collection handling and storage
Quantities of manure generated total 10 million gallons
per year by species 1 Swine
Frequency and duration of manure removal number of days per cycle Twice per year
(~180 days) Total days per year 14-20
days
Give a brief description of how manures will be collected handled (including methods of removal) and stored at this feedlot Swine manure and wastewater generated by the Project will drop through slatted floors in the barn into the LMSA where it will be stored The LMSA will be 10 feet deep with a storage capacity of approximately 143 million gallons which represents manure storage capacity in excess of one year The Proposer will use fans to ventilate the pit
C Manure utilization
Physical state of manure to be applied liquid solid other - describe
D Manure application 1 Describe application technology technique frequency time of year and locations
The Proposer will transfer manure ownership to third parties (ie manure recipients) A licensed commercial animal waste technician (CAWT) will transfer the manure from the Proposerrsquos barn to the manure application sites in the spring andor fall (Exhibit B) The CAWT will then apply the manure to the fields directly into the soil via knife injection The Project will require approximately 1150 acres annually for land application of the manure depending on nutrient needs of the crop All of the manure application sites are currently in row crop production The manure recipients will use manure in place of commercial fertilizer in the existing nutrient management The expected application frequency is approximately once every 2 to 4 years for the designated manure application sites Manure application events will typically last for 14 to 20 days
2 Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus Will there be a nutrient management plan
Yes No The Proposer submitted a MMP with their Feedlot Permit application The MMP becomes an integral and enforceable part of the Feedlot Permit after MPCA review and approval
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 11
The CAWT will apply manure at agronomic rates per the MPCA approved MMP to ensure there is no excess nutrient buildup in the soil based on the type of crop grown the soil type and the soil chemistry The manure application rates cannot exceed the croprsquos nitrogen needs The manure recipient will consider crop phosphorus needs for fields near water features and where soil tests indicate elevated phosphorus levels The agronomic rates are in the Feedlot Permit and the MMP Failure to follow these rules may subject the permit holder to penalties The manure recipient will prioritize manure application sites based on logistics and soil test levels for nitrogen phosphorus andor potassium Fields requiring the most nitrogen phosphorus or potassium receive the manure first Other factors include current field conditions crops grown yield goal organic matter content previous manure credits and other legume credits The manure recipient must ensure nutrient rates for the land application of manure are determined in accordance with the University of Minnesota Extension Service bulletin ldquoFertilizer Recommendations for Agronomic Crops in Minnesotardquo The manure recipient may calculate the rates or hire an agronomist to do this CAWTs then apply the manure at agronomic rates
Note P2O5 removed in grain per crop year P2O5 removed for 2-year rotation ac = acres bu = bushel lbs = pounds N = nitrogen P2O5 = phosphorus
Land Grant University research developed this procedure as the one that best predicts the amount of nutrients in the soil used by plants Using this method a Maximum Return to Nitrogen value determines manure application rates The manure recipients sample the soil every 4 years to monitor crop needs and target acres that will respond positively to manure applications
3 Discuss the capacity of the sites to handle the volume and composition of manure Identify any improvements necessary The Proposer estimates that the Project will generate approximately 10 million gallons of manure and process wastewater per year from the 8700 head of swine The manure storage pit will have a capacity to store 143 million gallons of manure The Proposer will sell and transfer ownership of 100 of the manure generated at the Project site to third parties who have agreements with the Proposer The Proposer will ensure that the manure is first tested using University of Minnesota Extensionrsquos recommended practices for manure sampling prior to land application Accordingly if the manure recipient is using a corn following corn rotation at manure application sites the Proposer estimates that they will need approximately 1150 acres for manure application each year in order to use all of the manure generated from the Project The Proposer has 2100 acres available for manure application through land application agreements There is sufficient land available for manure application to utilize the nutrients generated by this Project
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 12
4 Describe any required setbacks for land application systems The Project is subject to setback requirements contained in the following regulations
middot Minnesota StatutesLaws (ie ldquoMinnesota buffer lawrdquo) o Minn Stat 103F48 Riparian Protection and Water Quality Practices (2016)6 o Minn Session Law ch 85 (SF 2503 ndash April 25 2016)7
middot Minn R 70202225 Land Application of Manure8 middot Traverse County Land Use Ordinance Section 2313 Feedlot Ordinance9
The manure applicator must comply with the most stringent applicable regulation as shown in the following table
Land application setbacks (in feet)
Feature Winter
Non-Winter With Immediate Incorporation (lt24 hours)
Non-Winter Not incorporated within 24 hours
With P Mgmt No P Mgmt With Vegetated
Buffer Inadequate Vegetated Buffer
Lake Stream 300 50 300 100 300 Intermittent Stream DNR protected wetlands Drainage ditch wo quarry
300 50 300 50 300
Open Tile Intake 300 0 0 300 300 Well mine or quarry 50 50 50 50 50
Sinkhole with no diversion Downslope 50 Upslope 300 50 50 Downslope 50
Intermittent streams and ditches pertain to those identified on USGS quadrangle maps excluding drainage ditches with berms that protect from runoff into the ditch and segments of intermittent streams which are grassed waterways Wetland setbacks pertain to all protected wetlands identified on DNR protected waters and wetlands maps (these maps are often located in County Soil and Water Conservation District offices and typically include all wetlands over 10 acres) Riparian Protection and Water Quality Practices Act ndash MN Statute 103F48 Traverse County Feedlot Ordinance ndash The County animal waste utilization and setback distances shown apply for situations where manure is mechanically injected or tilled into the soil during manure application
E Other methods of manure utilization If the project will utilize manure other than by land application please describe the methods
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 13
6 Airodor emissions
A Identify the major sources of air or odor emissions from this feedlot
The buildingrsquos ventilation and the surfaces of the barn that come into contact with animals and manure especially floors are sources of odor The animals themselves are also sources of odor The manure collection and storage facilities the dead animal disposal and storage areas and the manure application fields are also significant sources of odor Dust generated by truck traffic around the Project site can also contribute as a carrier of odor
B Describe any proposed feedlot design features or air or odor emission mitigation measures to be
implemented to avoid or minimize potential adverse impacts and discuss their anticipated effectiveness Feedlot odors will occur at the Project and at manure application sites However the Proposer will implement design and operational measures to reduce odors at the Project site Project design and operation measures to reduce odor include
middot The Proposer will construct a total confinement barn which reduces the surface area of manure exposed to the air
middot The Proposer will maintain clean dry floors eliminate manure buildup and clean up any spilled feed
middot The Proposer will thoroughly wash and disinfect interior surfaces regularly middot The Proposer will give special attention to cleaning the ventilation fans and pit exhaust fans middot The Proposer will only agitate stored manure immediately before the Proposer removes the
manure for land application middot In the event the MPCA County Feedlot Officer or the Proposer receive odor complaints the
Proposer will consult with the MPCACounty Feedlot Officer to identify changes to reduce odors middot The Proposer will plant and maintain a vegetative shelterbelt around the perimeter of the Project middot The Proposer will manage animal mortalities by composting To minimize odors the Proposer
will operate the composting structure as required by the Minnesota Board of Animal Health The Proposer will transfer ownership of all of its manure from the Project to third parties (ie manure recipients) for offsite land application The manure recipients are required to follow the Proposerrsquos MMP which requires manure application by a CAWT The MMP is an enforceable provision of the Feedlot Permit Manure land application measures to reduce odor include
middot The CAWT will land apply all manure by direct injection to prevent contact with the atmosphere
middot The CAWT will observe all required setback requirements from nearby residences for all manure applications
middot The CAWT will evaluate weather conditions primarily wind speeddirection and humidity before manure is land applied to insure minimal impacts on neighbors and the public
middot The CAWT will use BMPs such as properly operating manure equipment to reduceeliminate spillage
middot The CAWT will notify neighbors of manure application periods and avoid holidays
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 14
C Answer this item only if no feedlot design features or mitigations were proposed in item 6B
Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards health risk values or odor threshold concentrations The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts The Proposer conducted air dispersion modeling to predict how the Projectrsquos emissions of hydrogen sulfide ammonia and odors would impact air quality at the Projectrsquos property lines and at the two nearest residences to the Project site The modeling was done using the American Meteorological SocietyEnvironmental Protection Agency Regulatory Model (AERMOD) The modeling results are contained within the report attached as Exhibit J of the EAW The following is a summary of the conclusions of the modeling report Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 parts per billion
(ppb) H2S MAAQS The third exceedance of the MAAQS standard within any 5-day period is a violation Modeled compliance is demonstrated when the high-third-high (H3H) H2S predicted concentration from the Project when added to the existing background ambient air concentration for H2S (at each property-line receptor) is less than 30 ppb AERMOD predicted that the Project emissions alone would result in a maximum H3H property-line H2S concentration of 1170 ppb The ambient air concentration for H2S in the area of the Project site is estimated to be 17 ppb The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2870 ppb at the Projectrsquos property lines
middot Sub-chronic Inhalation Human Risk Value (iHRV) AERMOD predicted that the Project will not result in an exceedance of the 10 micrograms per
cubic meter (microgm3) subchronic (13-week time averaged) H2S iHRV at the two nearest residences to the Project site An iHRV is the concentration of a chemical (or a defined mixture of chemicals) that is likely to pose little or no risk to human health AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 013 micrograms per cubic meter (microgm3) The background ambient air concentration for H2S in the area of the Project site is estimated to be 100 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 113 microgm3 Note that while the iHRV is for a 13-week period AERMOD is not capable of averaging concentrations for this time Instead AERMOD uses a monthly averaging period which produces a more conservative or protective prediction
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
(one-hour time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 556 microgm3 The background ambient air concentration for NH3 in the area of the Project site is estimated to be 148 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 704 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 15
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
(1-year time averaged) NH3 iHRV at the two nearest residences to the Project site AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 070 microgm3 The background ambient air concentration for NH3 in the Project area is estimated to be 572 microgm3 The total (Project emissions plus existing background) maximum NH3 concentration in the air is predicted to be 642 microgm3
Odor
middot At Project Property Line AERMOD predicted that the Project will result in a maximum odor intensity of 76 odor units
per cubic meter (OUm3) at the Project sitersquos south property line This predicted odor intensity is considered to be a ldquofaint odorrdquo
middot At Nearest Residences AERMOD predicted that the Project would result in a maximum odor intensity of 13 OUm3 at
the nearest residences This predicted odor intensity is considered to be ldquono odorrdquo
Property Boundary AERMOD Air Quality Modeling Results Project Property Boundary
1-hour H2S H3H with 17 ppb background (lt30)
1-hour NH3 with 148 microgm3 background (lt3200)
Maximum Hourly Odor Intensity (OUm3)
North 2813 ppb 526 microgm3 63 OUm3 East 2870 ppb 521 microgm3 59 OUm3 South 2650 ppb 704 microgm3 76 OUm3 West 2122 ppb 369 microgm3 30 OUm3
Additional modeling conducted for on-site employee housing In addition to the air dispersion modeling described above the Proposer conducted modeling to predict the concentrations of H2S NH3 and odor at the proposed on-site employee housing The following summarizes the results of that modeling Hydrogen sulfide (H2S)
middot Minnesota Ambient Air Quality Standard (MAAQS) AERMOD predicted that the Project will not result in an exceedance of the 30 ppb H2S MAAQS
AERMOD predicted that the Project emissions alone would result in a maximum H3H H2S concentration of 981 ppb at the proposed on-site employee housing The total (Project emissions plus existing background) H3H H2S concentration in the air is predicted to be 2681 ppb
middot Sub-chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 10 microgm3
subchronic H2S iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum monthly H2S concentration at the neighboring residences of 060 microgm3 The total (Project emissions plus existing background) H2S concentration in the air is predicted to be 160 microgm3
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 16
Ammonia (NH3)
middot Acute iHRV AERMOD predicted that the Project will not result in an exceedance of the 3200 microgm3 acute
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum hourly property-line concentration of NH3 of 311 microgm3 The total (Project emissions plus existing background) NH3 concentration in the air is predicted to be 459 microgm3
middot Chronic iHRV AERMOD predicted that the Project will not result in an exceedance of the 80 microgm3 chronic
NH3 iHRV at the proposed on-site employee housing AERMOD predicted that the Project emissions alone would result in a maximum 1-year time-averaged NH3 concentration of 349 microgm3 The total (Project emissions plus existing background) maximum annual NH3
concentration in the air is predicted to be 921 microgm3 Odor
middot At On-site Employee Housing AERMOD predicted that the Project will result in a maximum odor intensity of 59 OUm3 at
the proposed on-site employee housing This predicted odor intensity is considered to be a ldquovery faint odorrdquo
On-site Employee Housing AERMOD Air Quality Modeling Results
1-hour H2S H3H with 17 ppb background (lt30)
1-month H2S with 10 microgm3 background (lt10)
1-hour NH3 with 148 microgm3 background (lt3000)
Annual NH3 with 572 microgm3 background (lt80)
Maximum Hourly Odor Intensity (OUm3)
2681 ppb 160 microgm3 459 microgm3 921 microgm3 59 OUm3 Thus the air modeling results for the Project and on-site housing suggest compliance with the H2S MAAQS no exceedances of the subchronic H2S iHRV no exceedances of the acute NH3 iHRV and no exceedances of chronic NH3 iHRV
D Describe any plans to notify neighbors of operational events (such as manure storage agitation and
pumpout) that may result in higher-than-usual levels of air or odor emissions The Proposer does not plan to notify neighbors before operational events such as manure storage agitation pump out or application The Proposer will work with county and state officials to find a resolution if there are complaints The Proposer will implement the air emission plan included in the Feedlot Permit application in the event an odor event occurs The air emission plan is an enforceable provision of the Feedlot Permit
E Noise and dust Describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts The Proposerrsquos contractor will do extensive work when constructing the Project generating noise and dust during construction The contractor will remove top soil and haul in gravel to build the Projectrsquos service areas The Proposer or his contractor will use dust abatement such as spraying water to minimize dust if it becomes an issue during Project construction
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 17
After construction noise and dust levels drop Once the Project is operational the Proposer expects noise and dust levels consistent with current operations and general land use in the area The Proposer expects barn exhaust fans will comprise the Projectrsquos largest source of noise Animal feed is a possible source of dust To reduce the amount of dust flex augers will carry feed from the storage bins to the barn and fill feeders through plastic tubing Spills will be cleaned up promptly debris and dust build up will be regularly removed from exhaust fans There is no constant flow of traffic generating dust The only daily traffic at the Project is for employees traveling to and from the Project site Trucks bringing in feed and compost materials and trucks loading and unloading swine visit the Project intermittently throughout the week Nearby roads are unpaved Truck traffic on gravel roads and barn exhaust fans are the major causes of dust The nearest residences are approximately 1700 feet to the north and 1750 feet east of the Project site The distance between the Project and the nearest residences is the biggest factor to mitigate noise and limit dust abatement The Proposer currently has no additional plans in place for noise or dust abatement
7 Dead Animal Disposal
Describe the quantities of dead animals anticipated the method for storing and disposing of carcasses and frequency of disposal
The Proposer plans to use composting as the method of dead animal disposal The Proposer has prepared an Animal Mortality Plan in accordance with State requirements including Minn Stat sect 3582 and Minn R chs 17190100 to 17194600 and 70111215 The Proposer submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA The Animal Mortality Plan is an enforceable condition of the Feedlot Permit The Proposer will construct a 150-foot x 30-foot animal mortality compost structure with impervious concrete flooring and sidewalls and steel siding The Proposer plans to inspect the barn daily for animal mortalities and transfer the dead animals to the compost structure immediately if present The Proposer will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities The Proposer predicts that the annual mortality rate will be approximately 365-730 hogs per year The Proposer will land apply the compost on the fields in the immediate vicinity of the Project site
8 Surface Water Runoff
Compare the quantity and quality of site runoff before and after the project Describe permanent controls to manage or treat runoff
Project Site A Minnesota NPDESState Disposal System (SDS) Construction Stormwater General Permit (CSW Permit) is required when a project disturbs 1 or more acres of soil This Project will disturb approximately 88 acres of soil therefore a CSW Permit is required In this case the CSW Permit is contained within the Feedlot Permit The Proposer will prepare a Stormwater Pollution Prevention Plan that meets the requirements
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 18
for erosion prevention and sediment control during construction BMPs such as silt fence ditch checks temporary soil stabilization etc will be utilized as necessary to prevent erosion and control sediment during construction
The Proposerrsquos construction of a swine barn an animal mortality composting structure a shop an office employee housing as well as associated driving areas will create impervious surfaces at the Project of approximately 88 acres This new impervious surface will cause an increase in surface water runoff The Feedlot Permit requires projects that create 1 acre or more of new impervious surface to retain the water quality volume of one inch of runoff from the new impervious surfaces created by the Project The Proposer must manage this runoff volume on site by infiltration or other volume reduction practices without a discharge to surface waters This stormwater permanent treatment requirement applies to this Project The Proposer will construct three permanent stormwater ponds around the barn to collect stormwater generated at the Project The ponds will allow the collected stormwater to infiltrate into the soils If the basins were to overflow the water will flow to the west and then to the unnamed ditch to the south Once the Proposer has completed construction of the Projectrsquos buildings they will establish perennial vegetation and install a gravel surface driveway at the Project site The Proposer will store manure in a LMSA located entirely below the barn therefore stormwater runoff will not contact livestock or manure The Proposer has drafted and submitted an ERP with the Feedlot Permit application as required The Proposerrsquos ERP includes procedures to address spills should these occur In the event of a spill the Proposerrsquos ERP requires the Proposer to stop the source of the liquid manure leak or spill immediately The ERP also includes using the following measures where appropriate
middot Installation of bale checks middot Blockage of downstream culverts middot Plugging tile intakes middot Tilling ground ahead of the spill middot Use of absorptive materials
Following MPCA approval of the ERP it becomes an enforceable condition of the Feedlot Permit Manure application sites All manure generated by the Project will be land applied at agronomic rates at the manure sites (Exhibit B) by a licensed CAWT The manure recipients determine the agronomic rate based on the type of crop grown the soil type and the soil fertility The CAWT will land apply manure in the spring and fall of the year The CAWT applies the manure directly into the soil via knife injection The CAWT must adhere to applicable manure application setbacks as outlined in Item 5 of the EAW Eight of the Project manure application areas are within three sub-watersheds of the Bois de Sioux River Major Watershed (HUC 09020101) and one is within one sub-watershed of the Mustinka River Major Watershed (HUC 09020102) Previous landowners have farmed land in the watersheds for several decades The Proposer expects the stormwater runoff characteristics from the Project manure application areas to remain the same and under certain circumstances improve because of the land application activities regulated under the Feedlot Permit The improvements occur through developing better soil tilth from organic fertilizer and the uniform practice of incorporating manure over the acres identified in the MMP The Proposer expects no change in stormwater runoff characteristics (physically and chemically) from the Project manure application sites
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 19
9 Traffic and public infrastructure impacts
A Estimate the number of heavy truck trips generated per week and describes their routing over local roads Describe any road improvements to be made The Proposer estimates the Project will generate on average an additional nine truck trips per week See Table 9A1 for current and post-Project traffic counts The Project will generate the following truck traffic increases
middot Seven times per week one feed truck will deliver to the Project site middot Two times per week one truck will take nursery hogs from the barn to market middot Traffic related to manure handling and application is limited to the fall and spring Actual traffic
related to manure handling activities will depend on manure application equipment However it is anticipated to be minimal since drag hoses will be used in lieu of tanker trucks
Vehicle routes will be the discretion of the driver however the Proposer expects that trucks will use Highway 9 to access County Road 18 directly adjacent to the north of the Project site The Proposer does not expect the need for road improvements Drivers will abide by the seasonal road restrictions which may require more frequent trips at lower weights to reduce impacts on the roads Table 9A 1 Table Projected Traffic Counts ndash Post-Project
Road Avg VehicleDay
Avg VehicleWeek
Avg IncreaseWeek
County Road 18 15 105 9 Traffic counts from 2008 Source Minnesota Department of Transportation Office of Transportation Data and Analysis Traffic Volume Program 2008 AADT Product httpwwwdotstatemnustrafficdatatmahtml
B Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No
If yes please describe
10 Permits and approvals required Mark required permits and give status of application
Unit of government Type of Application Status MPCA Feedlot Permit (includes Construction Stormwater and
CountyTwpCity Traverse County Conditional Use Permit (includes permit for onsite septic system)
To be submitted
DNR Water Appropriation Permit To be submitted Other
(List any other approvals required along with the unit of government type of approval needed and status of approval process)
11 Other potential environmental impacts including cumulative impacts If the project may cause any
adverse environmental impacts not addressed by items 1 to 10 identify and discuss them here along with any proposed mitigation This includes any cumulative impacts caused by the project in combination with other existing proposed and reasonably foreseeable future projects that may
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 20
interact with the project described in this EAW in such a way as to cause cumulative impacts Examples of cumulative impacts to consider include air quality stormwater volume or quality and surface water quality (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form)
The MPCA must evaluate whether a project which may not individually have the potential to cause significant environmental effects could have a significant effect when considered along with other projects This type of impact is known as a cumulative potential effect In order to assess the Projectrsquos ldquocumulative potential effects of related or anticipated future projectsrdquo the MPCA conducted an analysis that evaluated other operations and looked for the potential for other projects in the context of potential direct or indirect impacts of the Project that (1) are already in existence or planned for the future (2) are located in the surrounding area and (3) might reasonably be expected to affect the same natural resources The following is a review of the MPCArsquos analysis conducted to determine if the Project would contribute to an adverse cumulative potential effect
The Proposer conducted a public records search and found three feedlots with 15315 AUs within the sub-watersheds containing the Project and its manure application sites (Exhibit I)
Surface water quality The proposed Project site (ie feedlot) is located within the Bois de Sioux River Watershed (Hydrologic Unit 09020101) The Projectrsquos manure application sites numbers 1-8 are located within the Bois de Sioux River Watershed and site number 9 is located within the Mustinka River Watershed (Hydrologic Unit 09020102) Land use within the Project and manure application site areas are predominantly agricultural which can contribute to non-point source pollution of surface waters Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 USC sect 303(d)) (1972) requires that each state develop a plan to identify and restore any waterbody that is deemed impaired by state regulations The US Environmental Protection Agency (EPA) requires a TMDL because of the federal CWA A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the waterbody and still meet water quality standards Mustinka River Twelvemile Creek and Fivemile Creek are the closest listed impaired water bodies to the Project and its manure application sites (Exhibit I)
middot Mustinka River is located within the Mustinka River Major Watershed The Mustinka River is
located approximately 4 miles south of the Project site and approximately 15 miles southeast of the Projectrsquos manure application site number 9 MPCArsquos 2012 impaired waters list identifies the Mustinka River as impaired due to turbidity and dissolved oxygen
middot Twelvemile Creek is located within the Mustinka River Major Watershed Twelvemile Creek is located 5 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Twelvemile Creek as impaired due to fish bioassessments and turbidity
middot Fivemile Creek is located within the Mustinka River Major Watershed Fivemile Creek is located 46 miles southwest of the Project site and approximately 15 miles south of manure application site number 9 MPCArsquos 2012 impaired waters list identifies Fivemile Creek as impaired due to turbidity
The Proposer will implement BMPs through their MPCA-approved MMP an enforceable part of the Feedlot Permit In addition the Proposer will take the following actions to minimize impacts to surface water
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 21
middot Transfer ownership of 100 of the manure to a licensed CAWT for proper land application middot Comply with state and county required manure application setbacks middot If a manure spill occurs comply with the ERP in the Feedlot Permit middot Design and build the Project as a total confinement operation and check drain tile periodically for pit
leaks
Groundwater appropriation There are no water wells currently on the Project site The Proposer will install three new wells which will utilize approximately 69 million gallons of water annually and 1725 million gallons over a 25-year period The Project requires a Water Appropriations Permit from the DNR The Proposer reviewed the Minnesota County Well Index and found that there are two domestic and four test wells within 1 mile of the proposed Project site (Exhibit E) These wells range from a depth of 136 to 290 feet below grade The DNRrsquos Water Appropriation Permit Program regulates groundwater appropriations The program manages water resources so that adequate supply is provided for domestic agricultural fish and wildlife recreational power navigational and quality control The program balances competing management objectives including both development and the protection of water resources Minn Stat sect 103G261 establishes domestic use as the highest priority when water supplies are limited and when well interference occurs the DNR follows a standardized procedure of investigation The Proposers will need to correct any problems a DNR investigation determines they are causing The DNR has preliminarily approved the construction of the Proposerrsquos well (Exhibit H) The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR During its Water Appropriation Permit review process DNR will analyze the results of the Proposerrsquos aquifer pump test to evaluate potential short-term impacts such as well interferences and long-term cumulative effects Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit Program particularly in areas of high groundwater use such as this area
Groundwater quality Feedlot operations and the land application of manure can adversely affect groundwater resources The MPCA has reviewed information complied by the DNR to determine if the Project has the potential to contaminate the underlying aquifer Based on a review of published information related to sensitivity potential the Project and the land application sites are located in areas primarily designated as having a low susceptibility to groundwater pollution (Exhibit K) This means that it could take weeks to months (gt430-1600 hours) for near-surface contamination to reach a depth of 10 feet below land surface10 and application practices reduces the risk to groundwater pollution as discussed in Item 5 of the EAW In light of the required management factors the Project does not pose a significant potential for adverse cumulative effects to groundwater quality in the area
The Proposer will reduce the Projectrsquos potential impacts to groundwater by following the design construction and operation requirements identified in Minn R ch 7020 (Animal Feedlots) These rules protect groundwater from both cumulative and individual feedlot impacts The Proposer has submitted design plans and construction specifications for the manure storage pit and a MMP for the land application of manure Once the MPCA has reviewed and approved the plans they will become enforceable conditions of the Feedlot Permit
10 Adams R Pollution Sensitivity of Near-Surface Materials Minnesota Department of Natural Resources 2016 httpfilesdnrstatemnuswatersgroundwater_sectionmappingmhahg02_reportpdf
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Valley Pork LLP Site 2 Environmental Assessment Tintah Township Traverse County Minnesota Worksheet 22
Air quality The Proposer used the AERMOD dispersion model to predict potential emissions of hydrogen sulfide ammonia and selected odorous gases from the Project The model estimated pollutant concentrations from the Project along with an ambient hydrogen sulfide and ammonia background concentration to account for any nearby air emission sources The air quality modeling evaluation predicted concentrations of the selected gases at the Project property lines and nearest neighbors A background concentration is the amount of pollutants already in the air from other sources and then used in this evaluation to address cumulative air impacts Hydrogen sulfide and ammonia may be present from other feedlot barns the agitation and pump out of a neighboring feedlot or the pumping of a municipal wastewater treatment facility Air emissions from other emission sources may affect the compliance status of the proposed facility or affect downwind human and environmental receptors The Proposer used monitoring data from other Minnesota feedlot facilities to derive a background level for hydrogen sulfide AERMOD adds the monitored background hydrogen sulfide concentration to the predicted modeled emission Based on the results of the modeling the MPCA does not expect significant air quality impacts from the Project including adverse cumulative potential effects (Exhibit J)
Land use The Project and manure application sites are in existing agricultural production areas that have been used for agricultural purposes for decades The Proposer does not expect the Projectrsquos construction to cause the conversion of wildlife habitat fallow or marginal cropland land into row crop production The Project is consistent with nearby land use As a result the MPCA does not expect the Project to contribute to an adverse cumulative potential effect related to land use
Wildlife habitat There is a competing issue in rural landscapes to maintain a balance between agricultural demands and preserving natural resources In this case the Project is in areas already zoned and used for agricultural production for over 20 years The Project will not change the existing land area or use The Proposerrsquos construction of 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 Project and manure land application sites will use existing row crop feedstock rather than cultivate fallow or marginal land to meet crop use needs As a result the Proposer does not expect to create an additional new impact to environmental quality The MPCA and Proposer did not receive information that indicates any other projects in the area will convert fallow or marginal cropland into row crop production within the Project area The proposed Project will not modify land use and will not contribute to an adverse cumulative potential effect related to row crop agriculture
Trafficroad impacts The Proposer evaluated the cumulative potential effects of the direct contribution of new traffic through the development and operation of the Project in context to the existing traffic load The Proposer provided this information in Item 9A This information indicates the Project will result in a slight increase of traffic on Traverse County roads but does not require road improvements In addition the Proposer the Proposerrsquos contractors and other parties must observe Traverse Countyrsquos seasonal in-place weight restriction limits to minimize road impacts The Proposer believes the slight increase in traffic from the Project will not cause an adverse cumulative potential effect
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Site LocationSite Location
T127NR43W
T127NR44W
T128NR43W
T128NR44W
T129NR43W
T129NR44W
T130NR43W
T130NR44W
T131NR44W
T127NR45W
T127NR46W
T128NR45W
T128NR46W
T129NR45W
T129NR46W
T129NR47W
T130NR45W
T130NR46W
T130NR47W
T131NR45W
T131NR46W
T131NR47W
szligszligordfATOSENNIM
55
szligszligordfATOSENNIM
9
TintahTintahTownshipTownship
TintahTintah
poundcurren75
Otter T
ailWil
kin
Otter TailGrant
Wilkin
Grant
Wilkin
Grant
PN 17-20123 Source(s)Municipalities (MN DOT 6242016)Lakes (MN DNR July 2008)Counties (MN DNR July 2013)PLSS (MnGeoUSGS)
SPr
ojects
2000
0 PRO
J201
00-20
1992
0123
Valle
y Pork
Site
2-Tin
tah M
N20
123 G
IS20
123 M
apDo
cs20
123 F
L EAW
Exh
ibit A
- Site
Loca
tion M
apm
xd
1 inch = 12000 feetF
GrantCounty
T129NR44W
T129NR45W
UV101
UV104 UV118UV59
UV116
UV102
UV109
)93
56518
MNTH 9
230th St
340th
Ave
T-102
T-101
T-104
T-59
T-116
CR-9
3
CSAH 18
T-109
T-118
Site LocationSite Location
Sec30
Sec31
Sec 1Sec 2Sec 3Sec 4
Sec 25Sec 26Sec 27
Sec 34 Sec 35 Sec 36
TraverseTraverseCountyCounty
szligszlig
ordfATOSENNIM
9
0 6000 120003000Feet
Tuesday September 05 2017
Exhibit ASite Location Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
6
4
9
3
7
1
22
5
8
9
99
4
5
6
7
USGS Topo (MN Geo)
SP
rojec
ts20
000 P
ROJ2
0100
-2019
9201
23 Va
lley P
ork S
ite 2-
Tintah
MN
2012
3 GIS
2012
3 Map
Docs
2012
3 FL E
AW E
xhibi
t B -
USGS
Topo
Map
mxd
1 inch = 4000 feetF0 2000 40001000
Feet
Wednesday September 27 2017
LegendProject AreaManure Application Fields
Exhibit BUSGS Topographic Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Image courtesy of USGS Earthstar Geographics SIO copy 2017 Microsoft Corporation
20123 C1 SITE LAYOUT
THIS DOCUMENT IS THE PROPERTY OF I amp S GROUP INCAND MAY NOT BE USED COPIED OR DUPLICATEDWITHOUT PRIOR WRITTEN CONSENT
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
BNSF
00174420
00431751
MustinkaRiver
Unname d Stream
O ld Channel
Twelve mileC reek Fivem
ileCr
eek
00163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Unn amed Stream
Un named S tream
Unnamed Strea m
Unnamed Stream
Unnamed Stream
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Minnesota Department of Natural Resources
Division of Ecological amp Water Resources
500 Lafayette Road Box 25
St Paul MN 55155‐4025
April 19 2017
Correspondence ERDB 20170383
Ms Eva Douma
IampS Group
115 E Hickory Street Suite 300
Mankato MN 56001
RE Natural Heritage Review of the proposed Valley Pork Site 2
T129N R45W Seciton 35 Traverse County
Dear Ms Douma
As requested the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any
rare species or other significant natural features are known to occur within an approximate one‐mile radius of the
proposed project Based on this query there are no known occurrences of rare features in the area searched
The Natural Heritage Information System (NHIS) a collection of databases that contains information about
Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department
of Natural Resources The NHIS is continually updated as new information becomes available and is the most
complete source of data on Minnesotas rare or otherwise significant species native plant communities and other
natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state Therefore ecologically significant features for which we have no
records may exist within the project area If additional information becomes available regarding rare features
in the vicinity of the project further review may be necessary
For environmental review purposes the results of this Natural Heritage Review are valid for one year the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form Please contact me if project details change or for an updated review if construction has not
occurred within one year
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these
rare features To determine whether there are other natural resource concerns associated with the proposed
project please contact your DNR Regional Environmental Assessment Ecologist (contact information available at
httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site
assessments or review may be required
nickmcc
Text Box
EXHIBIT F
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Minnesota Department of Natural Resources bull Ecological amp Water Resources 500 Lafayette Road St Paul MN 55155
Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources
Please include a copy of this letter in any state or local license or permit application An invoice will be mailed to
you under separate cover
Sincerely
Samantha Bump
Natural Heritage Review Specialist
SamanthaBumpstatemnus
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
1
Nick McCabe
From Thomas Cinadr ltthomascinadrmnhsorggt
Sent Tuesday February 14 2017 1043 AM
To Eva Douma
Subject Re SHPO Data Review request - Valley Pork LLP
Eva
Thanks for getting back to me I apologize for my error I re-ran the request and found that there are no
archaeological sites or historic properties for you coordinate
Tom
Tom Cinadr
Survey and Information Management Coordinator Minnesota Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd West St Paul MN 55102
651-259-3453
On Tue Feb 14 2017 at 1038 AM Eva Douma ltEvaDoumais-grpcomgt wrote
Hello Tom
Thank you for getting back to me I am wondering if this is not the attachment for the project area I sent you below
though Our project is located in Traverse County in Section 35 T129 R45 and the attachment sent was for Lyon
County Please let me know what you find out Thank you for your time
Eva
Eva Douma
Environmental Scientist
Environmental Group
nickmcc
Text Box
EXHIBIT G
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
2
115 E Hickory Street
Suite 300
Mankato MN 56001
P 5073876651
C 5079951439 evadoumais-grpcom
Architecture
Engineering
Environmental
Planning
From Thomas Cinadr [mailtothomascinadrmnhsorg]
Sent Tuesday February 14 2017 1004 AM
To Eva Douma ltEvaDoumais-grpcomgt
Subject Re SHPO Data Review request - Valley Pork LLP
THIS EMAIL IS NOT A PROJECT CLEARANCE
This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources This message simply reports the results of the cultural resources database seadatabase seadatabase seadatabase search you requested The database search produced rch you requested The database search produced rch you requested The database search produced rch you requested The database search produced results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic results for only previously known archaeological sites and historic properties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyproperties Please read the note below carefullyNo archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for
the search area requested A report containing the historyarchitecture properties identified is attached
The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are
included in the current SHPO databases Because the majority of archaeological sites in the state and many historic architectural
properties have not been recorded important sites or structures may exist within the search area and may be affected by development
projects within that area Additional research including field survey may be necessary to adequately assess the arearsquos potential to
contain historic properties
Properties that are listed in the National Register of Historic Places (NRHP) or have been determined eligible for listing in the
NRHP are indicated on the reports you have received The following codes on the reports you received are
NR ndash National Register listed The properties may be individually listed or may be within the boundaries of a National Register
District
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
3
CEF ndash Certified Eligible to the National Register findings are usually made during the federal review process these properties have
been evaluated as being eligible for listing in the National Register
SEF ndash Staff eligible findings to the National Register are properties that have been determined eligible by SHPO staff
DOE ndash Determination of Eligibility is made by the National Park Service and typically refers to properties deemed eligible but the
owner objects to the listing
CNEF ndash Certified Not Eligible to the National Register SHPO has begun to record properties that have been evaluated as not
eligible for listing in the National Register If the box on the form has a check the property has been determined to be not eligible
Properties without NR CEF SEF DOE or CNEF designations in the reports you received may not have been evaluated and
therefore no assumption to their eligibility can be made
If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites or historic architectural properties
you may need to hire a qualified archaeologist andor historian If you need assistance with a project review please contact Kelly
Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg
The Minnesota SHPO Survey Manuals and Database Metadata can be found at httpwwwmnhsorgshposurveyinventorieshtm
SHPO research hours are 830 AM ndash 400 PM Tuesday-Friday
The Office is closed on Mondays
Tom Cinadr
Survey and Information Management Coordinator
Minnesota Historic Preservation Office
Minnesota Historical Society
345 Kellogg Blvd West
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
4
St Paul MN 55102
651-259-3453
On Thu Feb 9 2017 at 1233 PM Eva Douma ltEvaDoumais-grpcomgt wrote
Mr Cinadr
I am conducting an environmental review for the construction of one hog barn in Traverse County Can you
please provide me information on the archeological and historic sites for this area The specific project
location is located in section 35 T129 R45 (see attached figure) Thank you for your assistance
Regards
Eva Douma
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
1509 1st Ave N
Fergus Falls MN 56537
April 4 2017
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35 NENE
Traverse County
Kristofer Morgan
7734 750th St
Tintah MN 56583
Dear Kristofer Morgan
This is your preliminary approval to construct a well We have reviewed your well drillling proposal and
determined that the proposed rate and volume may interfere with other water users or have negative
impacts on nearby lakes streams or wetlands
Basis for recommendation
State lawsup1 requires that use of water not cause harm to ecosystems degrade water quality or significantly
reduce the public water supply We found that your proposed well has the following potential concerns
bull The field is located in the South Fork of the Rabbit River subwatershed
bull Surface water wetlands within 15 miles may be affected by a high volume well in this location
bull Domestic wells are within 15 miles of the proposed well Minnesota laws state that domestic wells have
highest priority for groundwater use
bull Due to these concerns DNR may require more tests at your expense It will be very important to
perform a specific capacity (pump test) on the new well by testing it at the rate you will be using it I have
attached guidance for performing that test
The attached assessment checklist contains further information about our analysis
If you choose to drill this well
The well contractor or property owner needs to notify the MN Department of Health sup2 before the well is
constructed
ThenThe landowner needs to apply for a DNR water appropriation permit before the well is pumped for
production A permit from the DNR is required for water use above 10000 gallons per day or 1 million
gallons per year The easiest method to apply for a water use permit is through the Minnesota DNR
Permitting and Reporting System (MPARS) at wwwmndnrgovmparssignin Instructions at this website
will assist you step-by-step through the application process
sup1 Minnesota Statute 103G287
sup2 Minnesota Statute 103I
S Yellow Level Well Assessment ID 1052 MPARS revision 03-23-2015 printed 04-04-2017
nickmcc
Text Box
EXHIBIT H
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Page 2Re DNR Well Construction Preliminary Assessment
April 4 2017Kristofer Morgan
To more completely understand the risk to other wells or lakes streams or wetlands you may be asked for
additional information and testing or monitoring at your expense We will use this information to determine
how much water can be appropriated
Please noteThis preliminary approval to construct a well is information you can use to decide whether to proceed in
constructing a well and is based largely on information you provided It is not notification to the MN
Department of Health and is not a DNR water use permit
Thank you for your attention We anticipate this process will save money for landowners with water needs
near sensitive or limited water resources and will help avoid water shortages If you have any questions
please contact me at (218) 739-7576 x253 or janellmierschstatemnus
Sincerely
Janell Miersch
Hydrologist
Enclosures
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Minnesota Department of Natural ResourcesDivision of Ecological and Water Resources
MNDNR PERMITTING AND REPORTING SYSTEM (MPARS)
WELL CONSTRUCTION PRELIMINARY ASSESSMENT CHECKLIST
Re DNR Well Construction Preliminary Assessment Tracking No 2017-0476 T129N-R45W-S35
NENE Traverse County
This well construction preliminary assessment is not an appropriation permit State law requires you
to obtain preliminary approval to drill a well that is required to have a DNR water appropriation permit A
water appropriation permit from the DNR is required for all users withdrawing more than 10000 gallons of
water per day or 1 million gallons per year DNR Staff have evaluated your project to determine whether the
proposed appropriation is likely to meet statutory requirements in Minnesota Statute section 103G287
The factors checked below are those that we believe may be impacted by your proposed water use
Calcareous fens
Designated trout streams
Lakes and rivers wetlandsuumlRare Species (Threatened Endangered Special Concern) Native Plant Communities (S1-3)
Minnesota Biological Survey Sites of Biodiversity Significance (High Outstanding)
Known well interference problems
Existing water appropriation permits with higher priority as defined in Statute 103G261uumlPublicly owned lands such as DNR Wildlife Management Areas
Municipal Wellhead Protection Areas Drinking Water Source Management Areas Source Water
Protection Areas
Known groundwater contamination
Groundwater management areas or areas with declining water levels
MDH Special Well and Boring Construction Areas
If any of the factors above are marked with a checkmark you may be required to install monitoring well(s)
perform aquifer test(s) or provide other information to ascertain anticipated impacts to these features This
information will be used to evaluate and make a decision on your water appropriation request Your water
appropriation request may be modified reduced or denied based upon site specific information
wwwmndnrgovmpars
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
____
2017-0476 Preliminary Well Construction Assessment Traverse County
Uuml0 25 5125 Miles
G Hora 2272017
Legend_ 2017-0476b
_ 2017-0476c
_ 2017-04765 Mile15 MileNational Wetlands Inventory Public Watercourses
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
otilde
otilde
otilde
otilde
otilde
otilde
otildeotilde
otilde
MajorBois de Sioux
River 09020101
MajorMustinka River
09020102
)98
)82
)96
)86
)31
)85
)32
)56
)40
)89
)99
)67
)91
)42
)93
)92
)40)94
)87
)90
)84
56510356520
56512
56522
56511
56514
56520
56518
56519
5658
56516
56513
56516
565156511
56514
56513
6
4
9
3
7
1
22
5
8
999
4
5
6
7
MinorDitch54007
MinorUnknown DNR Minor
Watershed Name 54008
MinorS Fork Rabbit
R 54009
MinorUnknown DNR Minor
Watershed Name 54010
MinorJud Ditch11 54012
MinorUnknown DNR Minor
Watershed Name 54025
MinorDitch54028
MinorDitch 54029
MinorDitch54030
MinorCo Ditch11 54032
MinorMustinka R
55044
MinorMustinkaR 55064
MinorUnknown DNR Minor
Watershed Name 55065
MinorTwelvemile
Cr 55066
MinorOld Channel
55068
County D itch 35
Judic
ial D
itch 2
Judic
ial D
itch 2
Judicial Ditch 2
Judicial Ditch 12
County D itch 35
County D itch 24
Coun
tyD it
ch36
Mustinka River
Fivem ile Cree k
Twelvem ile Creek
Old Channel
0 AU
1470 AU
55 AU
65 AU
747 AU
szligszlig
ordfATOSENNIM
9
szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55szligszlig
ordfATOSENNIM
55
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
szligszlig
ordfATOSENNIM
9
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Vallley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Air Quality Modeling Report Valley Pork LLP Proposed Hog Feedlot
Traverse County Tintah Township NE frac14 Section 35
Prepared by Barr Engineering Company 4300 MarketPointe Drive Suite 200 Minneapolis Minnesota 55435
October 2017
nickmcc
Text Box
EXHIBIT J
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Table of Contents Introduction 1
General Modeling Approach 3 Impact Thresholds and Background Values 4
Source Characterizations 7
Neighboring Residences 8
Site Description 9 Proposed Valley Pork Feedlot 9
Gas Emission Rates 10 Hog Barn 10
Composting Facility 10
Hydrogen Sulfide at Property Lines and Neighbors 11
Ammonia at Property Lines and Neighbors 13
Odorous Gas Concentrations 15
Odor Intensities at Property Lines and Neighbors 15
Summary 17
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Introduction Valley Pork LLP (Valley Pork) proposes
to construct a new feedlot consisting of one multiple-use hog barn in the NE frac14 of Section 35 Tintah Township Traverse County
Based on a protocol approved by the Minnesota Pollution Control Agency (MPCA) air quality modeling calculated the hydrogen sulfide concentrations ammonia concentrations and odor intensities at the property lines for the proposed Valley Pork hog feedlot and at the locations for two of the proposed feedlotrsquos nearest neighbors
The modeled emission sources for the proposed feedlot consisted of one 212-ft by 1000-ft mechanically-ventilated hog barn with a concrete manure storage pit located beneath the barnrsquos slatted floors and one 30-ft by 150-ft composting facility for the processing of mortalities The locations of the proposed Valley Pork feedlot and the two neighboring residences are provided in Figure 1
The following atmospheric concentrations were calculated
1 the maximum hourly hydrogen sulfideconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to comply with Minnesotarsquosambient air quality standard for hydrogensulfide of 30 parts per billion (ppb)
2 the maximum monthly hydrogen sulfideconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos subchronic(13-week) inhalation Health Risk Value(iHRV) for hydrogen sulfide of10 micrograms per cubic meter (microgm3)
3 the maximum hourly ammoniaconcentration at the property lines for theproposed Valley Pork feedlot to assess thepotential to exceed Minnesotarsquos acuteiHRV for ammonia of 3200 microgm3
4 the maximum annual ammoniaconcentration at two of the proposedfeedlotrsquos nearest neighbors to assess thepotential to exceed Minnesotarsquos chroniciHRV for ammonia of 80 microgm3 and
5 the maximum hourly odor intensities at theproperty lines for the proposed Valley Porkfeedlot and at two of the feedlotrsquos nearestneighbors to access the potential for off-siteodor episodes
The above concentrations were calculated using the AERMOD air quality model based on 5 years of historical weather data
The modeling results suggest that the proposed Valley Pork feedlot 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 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 hydrogen sulfide concentration of 1170 ppb at the feedlotrsquos property lines When a background concentration of 17 ppb is added to the AERMOD-calculated concentration the H3H hydrogen sulfide concentration is 2870 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 Valley Pork feedlot
Valley Pork Feedlot Report1
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Figure 1 Modeled locations of the proposed Valley Pork feedlot and the two neighboring residences
ValleyPork
B1 C1
Valley Pork Feedlot Report2
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
The AERMOD results indicate that the proposed Valley Pork feedlot 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 013 microgm3 When a background concentration of 100 microgm3 is added to the AERMOD-calculated concentration the maximum monthly neighbor hydrogen sulfide concentration is 113 microgm3 which is below the subchronic hydrogen sulfide iHRV of 10 microgm3
The modeling results suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV AERMOD calculated a maximum hourly property-line ammonia concentration of 556 microgm3 When a background ammonia concentration of 148 microgm3 is added to the AERMOD-calculated concentration the maximum property-line ammonia concentration is 704 microgm3 which is below the acute ammonia iHRV of 3200 microgm3 Thus no exceedance of the acute ammonia iHRV was modeled at the property lines for the proposed Valley Pork feedlot
The AERMOD results indicate that the proposed Valley Pork feedlot 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 070 microgm3 When a background ammonia concentration of 572 microgm3 is added to the AERMOD concentration the maximum annual ammonia concentration for a neighboring residence is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Thus the AERMOD modeling results for the proposed Valley Pork feedlot 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 Valley Pork feedlot is the only significant and quantifiable emission source within a 3-mile by 3-mile grid Air quality impacts associated with the Valley Pork feedlot were explicitly modeled Air quality impacts associated with any other sources in the modeled 3-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 16216) air quality model was used to calculate the property-line 1 2
and nearest-neighbor odorous gas concentrations The calculations 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 Alexandria MN and of upper air weather data for the NWS station in Chanhassen MN The Alexandria surface weather data represents a location surrounded by flat terrain and row crops Similar conditions surround the proposed Valley Pork feedlot site The surface and upper air weather data files were combined into an AERMET (version 14134) meteorological file by the MPCA
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 1Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 2
(January 17 2017 Edition)
Valley Pork Feedlot Report3
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
using the surface friction velocity adjustment option for low-wind stable conditions 3 4 5 6
Maximum one-hour monthly and annual average concentrations were calculated The modeling assumed no decay of any modeled gas due to chemical reactions The modeled receptor height was 0 meters ie ground level A complex terrain was considered Source and receptor elevations were determined by AERMAP (version 11103) using National Elevation Dataset (NED) 7 8
files obtained from the Multi-Resolution Land Characteristics Consortium (MRLC) website All 9
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 35 Tintah Township Traverse County as the origin (0 0) Positive values of x represent distance east of the origin Positive values of y represent distance north of the origin
Impact Thresholds and Background Values To assess the potential for environmental
impacts the odor intensities and the concentrations of hydrogen sulfide and ammonia
calculated by the air quality modeling were compared to air quality standards inhalation Health Risk Values (iHRVs) and an odor classification system based on detection-threshold odor intensities 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 periods less than an hour This 10
is important because the Minnesota ambient air quality standards for hydrogen sulfide are based on average concentrations over a 30-minute time period and because the published odor 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
US EPA 2004 Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US Environmental 3
Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
US EPA 2014 Addendum Userrsquos Guide for the AERMOD Meteorological Preprocessor (AERMET) US 4
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454-B-03-002
Qian W and Venkatram A 2011 Performance of steady-state dispersion models under low wind-speed conditions 5
Boundary-Layer Meteorology 138(3) 475-491
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 6
(January 17 2017 Edition) US EPA 2004 Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US Environmental Protection 7
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-03-003
US EPA 2011 Addendum Userrsquos Guide for the AERMOD Terrain Preprocessor (AERMAP) US 8
Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park NC March 2011
httpwwwmrlcgovviewerjs9
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 10
(January 17 2017 Edition)
Valley Pork Feedlot Report4
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
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 11
background concentrations are for rural Minnesota The listed 17-ppb background hydrogen sulfide concentration is appropriate when assessing a feedlotrsquos 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 ldquoexceedance or violation conditionrdquo 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 (ie 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
To assess the potential for odor episodes the calculated atmospheric concentrations of hydrogen sulfide and ammonia were compared to each gasrsquos 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 gasrsquos 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 01 suggests that less than 1 percent of the population can detect the
US EPA 2017 Revision to the Guideline for Air Quality Models 40 CFR Ch 1 Part 51 Appendix W 11
(January 17 2017 Edition)
Valley Pork Feedlot Report5
Table 1 Background concentrations for rural Minnesota
Pollutant
Hourly Background
Concentration
13-Week Background
Concentration
Annual Background
Concentration
Hydrogen Sulfide
17 ppb (vv) (243 microgm3)
070 ppb (vv) (100 microgm3)
Not Required
Ammonia 208 ppb (vv) (148 microgm3)
Not Required 807 ppb (vv) (572 microgm3)
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
gas The odor threshold concentrations used in 12
this assessment are presented in Table 2
Table 2 Odor threshold concentrations 13 14
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 ldquoan average person might detect if attention is called to the odor but the odor would not otherwise be noticedrdquo 15
Table 3 Odor intensity classification 16
Odorous Gas
Odor Threshold Concentration
(ppb vv)
Hydrogen Sulfide 94Ammonia 5800
Odor Intensity Number
Odor Strength
n-Butanol Reference Solution
(ppm)
Detection-Threshold Odor Units (OU DT)
0 no odor 0 01 very faint 250 252 faint 750 723 moderate 2250 2124 strong 6750 6245 very strong 20250 1834
Nagy G Z 1991 The odor impact model Journal of Air amp Waste Management Association 41(10) 1360-136212
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 Jacobson L D and Guo H 2000 Odor from feedlots setback estimation tool (OFFSET) In Livestock and 15
Poultry Odor Workshop II Dept of Biosystems amp Agricultural Engineering University of Minnesota St Paul MN 39 pp
Jacobson L D et al 2000 Development of an odor rating system to estimate setback distances from animal 16
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
Valley Pork Feedlot Report6
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Source Characterizations The emissions from the mechanically-ventilated
hog barn at the proposed Valley Pork feedlot will be characterized as 18 horizontal point sources 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 (m3sec) n is the number of horizontal point sources used to characterize the barn and usmax is the maximum air velocity leaving the horizontal point source (msec) 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 per pig for hot temperatures A maximum 18 19
stack velocity of 70 msec was assumed The 20
modeled release height will be 8 ft Near-field impacts of the barn on atmospheric dispersion
were addressed using BPIPPRM (version 04274) The estimated temperature difference 21
between the air inlet and outlet for the modeled barn is provided in Figure 2
Figure 2 Modeled temperature difference between the inlet air and the exhausted air for mechanically-ventilated hog-barns 22
The hourly exhaust velocity (us msec) was calculated from the following re-arrangement of equation (1)
(2)
SD = 2Gmaxnπusmax
0
5
10
15
20
25
0 10 20 30 40
Increased)Tempe
rature
of)Exhau
sted
)Air)(degC)
Ambient)Temperature)(degC)
us =G
nπ SD2
⎛⎝⎜
⎞⎠⎟
2
US EPA 2016 Userrsquos Guide for the AMSEPA Regulatory ModelmdashAERMOD US Environmental Protection 17
Agency Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454B-16-001
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 httpwwwthepigsitecomarticles186mechanical-19
ventilation-for-pig-housing
BESS 2014 Agricultural Ventilation Fans Department of Agricultural and Biological Systems University of 20
Ilinois at Urbana-Champaign httpwwwbessillinoisedu The 70 msec stack velocity is representative of fans with diameters ranging from 36 to 50 inches US EPA 2004 Users Guide to the Building Profile Input Program US Environmental Protection Agency 21
Office of Air Quality Planning and Standards Research Triangle Park NC EPA-454R-93-038 (Revised April 21 2004)
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
in which G is the hourly barn air flow rate (m3sec) 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 5degC (41degF) and ventilate at Gmax when ambient air temperatures are greater than 24 degC (75degF) Between ambient air temperatures of 5degC to 24degC an approximate linear relationship exists between airflow rate and ambient air temperature The modeled relationship between 23
ambient air temperature and airflow rate is illustrated in Figure 3
Table 4 Ventilation rate factors 24 25
Figure 3 Modeled response of airflow rate to ambient air temperature for a mechan-ically-ventilated hog barn where G is the airflow rate (m3sec) The graph assumes Gmin and Gmax values of 10 and 120 cfm per finishing pig respectively 26 27
The composting facility at the proposed Valley Pork feedlot was modeled as a non-buoyant area source
Neighboring Residences The air quality modeling calculated the odorous
gas concentrations at the two neighboring residences shown in Figure 1 Residence B1 is abandoned Residence C1 will house the manager for the proposed Valley Pork feedlot
Barn Units Gmin Gmax
Gestation CFMsow 12 150
Farrowing CFMsow 20 500
Finishing CFMpig 10 120
00
02
04
06
08
10
12
0 5 10 15 20 25 30
Fraco
nal)A
irflow
)Rate)GG
max
Ambient)Temperature)(degC)
Gmin
Gmax
Hoff SJ et al 2004 Real-Time Ventilation Measurements from Mechanically Ventilated Livestock Buildings for 23
Emission Rate Estimations ASAECSAE Annual International Meeting August 1-4 2004 Paper No 044178 Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 24
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-25
ventilation-for-pig-housing Harmon J D 1999 Mechanical Ventilation Design Worksheet for Swine Housing Iowa State University 26
Extension PM 1780 12 pp
Jacobson L D 2004 Mechanical Ventilation of Pig Housing httpwwwthepigsitecomarticles186mechanical-27
ventilation-for-pig-housing
Valley Pork Feedlot Report8
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Site Description
Proposed Valley Pork Feedlot The proposed Valley Pork feedlot will consist of
one mechanically-ventilated barn and one compost facility The modeled locations are provided in Figure 4 The setback distances from the barn to the property lines range from 620 to 1621 feet
The physical characteristics of the hog barn are provided in Table 5
The 30-ft by 150-ft compost facility was modeled as a non-buoyant area source with constant emission rates
Figure 4 Modeled location of the hog barn and compost facility at the proposed Valley Pork feedlot
Table 5 Dimensions and capacity of the hog barn at the proposed Valley Pork feedlot
1370
620
700
1621
N
E
S
W
Mechanically- Ventilated Hog Barn
Compost Facility
836 909
exhaust as horizontal point source
2605
(2640 2640)
Living Quarters
250deg
2605
405
340
Hog Barn
Barn Length (feet)
Barn Width (feet)
Barn Height (feet)
Number of Housed
Pigs
Barn 1 1000 212 253000 gilts
992 farrowing sows 4708 gestating sows
Valley Pork Feedlot Report9
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Gas Emission Rates
Hog Barn The proposed Valley Pork mechanically-
ventilated hog barn was modeled as a source of hydrogen sulfide ammonia and odor The barn emission rates varied hourly based on the diurnal activity of the housed pigs and on the following 28
calculated daily-average emission fluxes 29 30 31
bull 259 microg H2S(m2bullsec)
bull 289 microg NH3(m2bullsec)
bull 664 OUbullm3(m2bullsec)
Composting Facility The composting facility for the processing of
mortalities at the proposed Valley Pork feedlot
was modeled as a source of hydrogen sulfide ammonia and odor The reviewed literature did not provide any emission rates for the composting of hog mortalities The following constant flux rates were used to characterize the emissions from the composting facility
bull 21 microg H2S(m2bullsec) 32
bull 270 microg NH3(m2bullsec) and 33
bull 135 OUbullm3(m2bullsec) 34
The hydrogen sulfide and ammonia flux rates are for a biofilter treating air exhausted from a hog barn The odor flux rate is for a composting facility that processed cattle mortalities
Schauberger G et al 2013 Empirical model of odor emission from deep-pit swine finishing barns to derive a 28
Jacobson L D et al 2005 Aerial pollutants emissions from confined animal buildings dry sow buildings in 29
Minnesota Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005
Jerez S B et al 2005 Aerial pollutant concentration and emission rate measurements from a swine farrowing 30
building in Illinois Air amp Waste Management Association Conference Minneapolis MN June 21-24 2005 Gay S W et al 2003 Odor total reduced sulfur and ammonia emissions from animal housing facilities and 31
manure storage units in Minnesota Applied Engineering in Agriculture 19(3) 347-360
Nicolai R E and Janni K A 1997 Development of a low cost biofilter on swine production facilities ASAE 32
Paper No 984053 ASAE St Joseph MI Ibid33
Hudson N et al 2009 Comparison of odour emission rates measured from various sources using two sampling 34
devices Bioresource Technology 100(1) 118-124
Valley Pork Feedlot Report10
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Hydrogen Sulfide at Property Lines and Neighbors
The AERMOD results suggest that the proposed Valley Pork feedlot will comply with the Minnesota ambient air quality standard for hydrogen sulfide (H2S) The estimated high-third-high (H3H) concentrations at the proposed feedlotrsquos property lines are provided in Table 6 When a background concentration of 17 ppb is added to the AERMOD-calculated concentrations the maximum H3H hydrogen sulfide concentration is 2870 ppb which does not exceed the standard of 30 ppb Thus no violations of the hydrogen sulfide standard were modeled
Table 6 High-third-high hourly property-line hydrogen sulfide concentrations for the
proposed Valley Pork feedlot
The maximum AERMOD-calculated hourly hydrogen sulfide concentrations (without background) are plotted in Figure 5 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 94 ppb (Table 2) The 10-ppb isopleth in Figure 5 suggests that detectable concentrations of hydrogen sulfide will exist beyond the property lines for the proposed Valley Pork feedlot
The AERMOD results also suggest that the proposed Valley Pork will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the two neighboring residences As provided in Table 7 when a background concentration of 100 microgm3 is added to the AERMOD-calculated concentrations the maximum monthly hydrogen sulfide concentration for a neighboring residence is 113 microgm3 which is below the subchronic iHRV for hydrogen sulfide of 10 microgm3
Table 7 Maximum monthly H2S concentrations for neighboring residences
Feedlot Property
Line
High-Third- High H2S
Concentration Without
Background (ppb vv)
High-Third- High H2S
Concentration With a 17 ppb Background (ppb vv)
North 1113 2813East 1170 2870
South 950 2650West 422 2122
Neighbor
H2S Concentration
WithoutBackground
(microgm3)
H2S Concentration
With a 1 microgm3 Background
(microgm3)
B1 012 112C1 013 113
Valley Pork Feedlot Report11
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Figure 5 Maximum AERMOD-generated hourly hydrogen sulfide concentrations in ppb for the proposed Valley Pork feedlot The contour lines represent 5 and 10 ppb of hydrogen sulfide The plotted concentrations do not include the 17-ppb background hydrogen sulfide concentration
5
10
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report12
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Ammonia at Property Lines and Neighbors
The AERMOD-calculated maximum hourly ammonia (NH3) concentrations at the proposed Valley Pork feedlotrsquos property lines are provided in Table 8 The highest calculated property-line concentration with a background concentration of 148 microgm3 is 704 microgm3 which is below the acute iHRV for ammonia of 3200 microgm3 Thus no exceedances of the acute ammonia iHRV were modeled
Table 8 Maximum hourly property-line ammonia concentrations for the proposed
Valley Pork feedlot
The maximum AERMOD-calculated hourly ammonia concentrations (without background)
are plotted in Figure 6 The reported odor threshold concentration for ammonia is 4125 microgm3 or 5800 ppb (Table 2) Because all plotted ammonia concentrations are less than 4125 microgm3 Figure 6 suggests that the proposed Valley Pork feedlot will not generate detectable off-site concentrations of ammonia
The AERMOD results also suggest that the ammonia emissions from the proposed Valley Pork feedlot will not cause exceedances of the chronic ammonia iHRV at the nearest neighbors As provided in Table 9 the highest annual ammonia concentration for a neighbor with a background concentration of 572 microgm3 is 642 microgm3 which is below the chronic ammonia iHRV of 80 microgm3
Table 9 Maximum annual NH3 concentrations for neighbors residences
Feedlot Property
Line
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 148 microgm3
Background (microgm3)
North 378 526East 373 521
South 556 704West 221 369
Neighbor
NH3Concentration
WithoutBackground
(microgm3)
NH3Concentration
With a 572 microgm3 Background
(microgm3)
B1 070 642C1 065 637
Valley Pork Feedlot Report13
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Figure 6 Maximum AERMOD-generated hourly ammonia concentration in microgm3 for the proposed Valley Pork feedlot The contour lines represent 250 and 750 microgm3 of ammonia The plotted concentrations do not include the 148 microgm3 background ammonia concentration
250750
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report14
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Odorous Gas Concentrations AERMOD calculated the ground-level
atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the proposed Valley Pork feedlot and at the two neighboring residences The calculated maximum property-line concentrations are 778 ppb for ammonia (without background) and 1878 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum property-line concentrations are 20 for hydrogen sulfide and 01 for ammonia Population response curves suggest that 84 percent of the population could detect the calculated maximum property-line hydrogen sulfide concentration and 1 percent the ammonia concentration
The calculated maximum hourly concentrations for the neighboring residences are 134 ppb for ammonia (without background) and 342 ppb for hydrogen sulfide (without background) The corresponding odor numbers for the maximum neighbor concentrations are 04 for hydrogen sulfide and 00 for ammonia Population response curves suggest that 8 percent of the population could detect the calculated maximum neighbor hydrogen sulfide concentration and 0 percent the ammonia concentration The population response curves assume the presence of individual gases
Odor Intensities at Property Lines and Neighbors
AERMOD calculated the ground-level odor intensities at the property lines for the proposed Valley Pork feedlot and at two of the feedlotrsquos neighboring residences As indicated in Table 10 the maximum hourly odor intensity at the proposed feedlotrsquos property lines is 76 odor units (OU) which is above the ldquofaintrdquo odor threshold of 72 OU(Table 3)
Table 10 Maximum hourly property-line odor intensities and the frequency at which the
ldquofaintrdquo odor threshold of 72 OU is equaled or exceeded for the proposed Valley Pork feedlot
Figure 7 suggests that any ldquofaintrdquo or stronger odors generated by the proposed Valley Pork feedlot will be largely confined to the feedlot
Feedlot Property
Line
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
North 63 000East 59 000
South 76 000West 30 000
Valley Pork Feedlot Report15
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Figure 7 Maximum AERMOD-generated hourly odor intensities for the proposed Valley Pork feedlot The threshold for ldquovery faintrdquo odors is 25 OU and for ldquofaintrdquo odors is 72 OU (Table 3)
2572
-1
0
1
2
-1 0 1 2
Nor
thS
outh
Dis
tanc
e (m
iles)
EastWest Distance (miles)
Valley Pork Feedlot Report16
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
The AERMOD-calculated ground-level odor intensities at the two neighboring residences are provided in Table 11 The estimated maximum odor intensity for a neighboring residence is 13 OU which is below the 25-OU threshold for ldquovery faintrdquo odors
Table 11 Maximum neighbor odor intensities
Summary The AERMOD modeling results suggest that
the proposed Valley Pork feedlot will comply with the ambient air quality standard for hydrogen sulfide at the feedlotrsquos property lines The results also suggest that the proposed feedlot will not create exceedances of the acute ammonia iHRV at its property lines
The modeling results suggest that the proposed Valley Pork feedlot will not create exceedances of the subchronic iHRV for hydrogen sulfide and of the chronic iHRV for ammonia at the neighboring residences
The calculated nearest-neighbor odor intensities for the proposed Valley Pork feedlot were less than the 25-OU threshold for ldquovery faintrdquo odors
Neighbor
Maximum Hourly Odor
Intensity (OU dt)
Frequency at Which the
ldquoFaintrdquo Odor Threshold is
Exceeded (percent)
B1 13 000C1 12 000
Valley Pork Feedlot Report17
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
Valley Pork LLP Site 2 EAW
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
szligszlig
ordfATOSENNIM
9
szligszligordfATOSENNIM
9
565103
56512
56522
56520
56513
56518
56519
56516
56513
56516
56513
)98
)56
)87
)99
)67
)94
)91
)93
6
4
9
3
7
1
22
5
8
99
45
6
7
00174420
0043175100163067
00129727
00129741
00129702
00118573
00118559
00162390
00213514
00221211
00221212
00221213
00221214
00221216
00221218
00409256
00411956
00411990
00419454
00221217
Source Esri DigitalGlobe GeoEye Earthstar Geographics CNESAirbus DSUSDA USGS AEX Getmapping Aerogrid IGN IGP swisstopo and the GISUser Community
Drinking Water Supply VulnerabilityVery HighHighModerateLowVery Low
Groundwater Contamination Highest Susceptibility High Susceptibility Medium Susceptibility Low Susceptibility Lowest Susceptibility Insufficient Data to Rank
Exhibit KGroundwater Pollution Sensitivity Map
Valley Pork Site 2Tintah Twp Traverse County Minnesota
PN 17-20123 Source(s)
Notice of Availability of an Environmental Assessment Worksheet
